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IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLORADO

Civil Action No. __________

CENTER FOR LEGAL ADVOCACY, d/b/a

THE LEGAL CENTER FOR PEOPLE WITH 

DISABILITIES AND OLDER PEOPLE,

Plaintiff,

v.

REGGIE BICHA, 

in his official capacity as Executive Director 

of the Colorado Department of Human Services, and

TERESA A. BERNAL, 

in her official capacity as Interim Superintendent 

of the Colorado Mental Health Institute at Pueblo,

Defendants.

COMPLAINT

Plaintiff, the Center for Legal Advocacy, d/b/a The Legal Center for People with 

Disabilities and Older People (the “Legal Center”), for its Complaint alleges as follows:

INTRODUCTION

1. Presumptively innocent men and women are languishing in Colorado’s jails

awaiting court-ordered mental health evaluations and restorative treatment. These individuals, 

who have been charged with but not convicted of crimes, have constitutionally protected liberty 

interests in promptly receiving such evaluations and treatment while not being confined any 

longer than necessary. Colorado state officials are failing to timely conduct competency 

evaluations and admit into the state psychiatric hospital individuals found not competent to stand 

trial, creating delays for treatment that last as long as six months. These unjustifiable delays 

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violate the United States Constitution by depriving individuals unable to protect themselves of 

their due process rights, and they strain the resources of local sheriffs unable to treat these 

mentally ill detainees.

PARTIES

2. The Legal Center files this Complaint against Reggie Bicha, in his official 

capacity as Executive Director of the Colorado Department of Human Services (the 

“Department”), and Teresa A. Bernal, in her official capacity as Interim Superintendent of the 

Colorado Mental Health Institute at Pueblo (“CMHIP”).

3. The Legal Center is an independent non-profit corporation headquartered in 

Denver, Colorado. The Legal Center was designated in 1977 by Governor Richard Lamm as 

Colorado’s protection and advocacy system (“P&A System”) to protect and advocate for the 

rights of persons with mental illness and developmental disabilities under the Developmental 

Disabilities Assistance and Bill of Rights Act. 42 U.S.C. §§ 15041-45. Since 1986, the Legal 

Center has received federal grants on an annual basis, and has established and administered a 

P&A System in Colorado for individuals with mental illness pursuant to 42 U.S.C. §§ 10803 and 

10805 of the Protection and Advocacy for Individuals with Mental Illness Act, (“PAIMI Act”). 

Since 1986, the Legal Center has been and is currently the eligible P&A System for individuals 

with mental illness in Colorado as defined at 42 U.S.C. § 10802(2). 

4. The Legal Center has a governing board of directors which is composed of 

members who broadly represent and who are knowledgeable about the needs of individuals with 

mental illness. The Legal Center’s board of directors includes members who have received or 

are receiving mental health services or who have family members who have received or are 

receiving mental health services.

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5. The Legal Center’s constituents include individuals with mental illness. The 

Legal Center has established a PAIMI Advisory Council, over sixty percent (60%) of whose 

members themselves have received or are receiving mental health services or have family who 

have received or are receiving mental health services. The PAIMI Advisory Council advises the 

P&A System on the policies and priorities designed to protect and advocate for the rights of 

individuals with mental illness. The Chair of the Legal Center’s PAIMI Advisory Council, who 

is also a member of the Legal Center’s board of directors, has a family member who has received 

and is receiving mental health services.

6. Together, the Legal Center’s board of directors and PAIMI Advisory Council 

have developed the annual priorities and objectives of the P&A System for individuals with 

mental illness. The Legal Center’s first PAIMI Program Priority states that the Legal Center will 

monitor facilities, including jails, and investigate complaints of abuse, neglect and rights 

violations. When the rights of its constituents—incapacitated individuals with mental illness—

are violated, the Legal Center is authorized by statute to pursue legal remedies on their behalf, 

such as through this lawsuit. 42 U.S.C. § 10805(a)(1)(B) & (C). To the extent the Legal Center 

expends its resources to protect the rights of its constituents in county jails waiting for 

competency evaluations or restorative treatment, its resources are diverted away from other 

priorities of its constituents.

7. The Legal Center has established a grievance procedure for clients or prospective 

clients which allows its constituents with mental illness and family members of such individuals 

to assure them that the Legal Center and the PAIMI Program are operating in compliance with 

the provisions of the PAIMI Act.

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8. The Legal Center’s constituents who are detained and charged with crimes are 

hindered from asserting their own rights. Obstacles they face include the imminent mootness of 

individual claims as individuals are likely to be admitted to CMHIP for restorative treatment 

during the pendency of any case they might bring. In addition, pretrial detainees who suffer 

from mental illness are often impaired and unable to direct or participate in litigation on their 

own behalf.

9. Defendant Reggie Bicha is sued in his official capacity as the Executive Director 

of the Colorado Department of Human Services. The Department is responsible under Colorado 

law for the operation of CMHIP and the provision of mental health evaluations and treatment for 

persons with mental illness found incompetent to proceed to trial. 

10. Defendant Teresa A. Bernal is sued in her official capacity as the Interim 

Superintendent of CMHIP. CMHIP is the only state forensic mental hospital charged with 

providing court-ordered evaluations and accepting custody of pretrial detainees for restorative 

treatment. 

JURISDICTION AND VENUE

11. This Court has jurisdiction over this action pursuant to 28 U.S.C. §§ 1331 and 

1343(a)(3) because it arises under the Fourteenth Amendment to the United States Constitution

and 42 U.S.C. § 1983. This Court also has jurisdiction under the Declaratory Judgment Act, 28 

U.S.C. §§ 2201-02.

12. Venue is appropriate in this Court under 28 U.S.C. § 1391(b)(2) because the 

events giving rise to this Complaint occurred in this district.

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ALLEGATIONS

A. Colorado’s System to Evaluate the Competency of Criminal Defendants

13. Pretrial detainees are presumptively innocent because they have only been 

charged with, but not convicted of, crimes. They are constitutionally entitled to speedy trials, but 

Colorado’s speedy trial statute excludes time spent to evaluate a detainee’s competency and to 

provide restorative treatment from the computation of time within which a detainee must be 

brought to trial under the speedy trial statute. Colo. Rev. Stat. § 18-1-405(6).

14. Under the federal constitution and under Colorado law, the State cannot subject 

incompetent defendants to trial. A defendant is incompetent if, as a result of a mental disability 

or developmental disability, the defendant does not have sufficient present ability to consult with 

the defendant’s lawyer with a reasonable degree of rational understanding in order to assist in the 

defense. Questions of a defendant’s competency can be raised by the trial judge, prosecution, or 

defense. 

15. Once the question of a defendant’s competency to proceed has been raised, “the 

court may make a preliminary finding of competency or incompetency, which shall be a final 

determination unless a party to the case objects within ten days after the court’s preliminary 

finding.” Id. at 16-8.5-103(1). When a party objects to the preliminary finding or “the court 

determines that it has insufficient information to make a preliminary finding, the court shall 

order that the defendant be evaluated for competency by the department and that the department 

prepare a court-ordered report.” Id. at -103(2). The “department” that is required to conduct the 

competency evaluation and prepare the competency report is the Colorado Department of Human 

Services. Id. at -101(8). Then, a party may request a hearing or a second evaluation within ten 

days from when the report is received. Id. at -103(3). “If neither party requests a hearing or a 

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second evaluation within the applicable time frame, the court shall enter a final determination, 

based on the information then available to the court, whether the defendant is or is not competent 

to proceed.” Id. at -103(5).

16. The location of competency evaluations is determined by the trial court. 

Defendants eligible for bond may be released on bond for the evaluation, or the court may 

commit the defendant to the custody of the Department for the evaluation or order that it be 

conducted in the jail where the defendant is being detained. Id. at -105(1)(a). A written report of 

the evaluation must be prepared and delivered to the clerk of the court that ordered it. The report 

must include the name of each physician, psychologist, or other expert who examined the 

defendant; a description of the nature, content, extent, and results of the evaluation and any tests 

conducted; a diagnosis and prognosis of the defendant’s mental disability or developmental 

disability; and an opinion as to whether the defendant is competent to proceed. Id. at -105(5). 

17. When a court orders a defendant committed to the custody of the Department for 

a competency evaluation, that evaluation is conducted by CMHIP at its psychiatric hospital in 

Pueblo. If the court orders the competency evaluation to take place in the jail where the 

defendant is detained, CMHIP hires contract evaluators to complete the evaluation. 

18. After receiving the competency evaluation, the court makes a final determination 

whether the detainee is competent to proceed to trial. Id. at -103(5). If the final determination is 

that the defendant is not competent to proceed, the court may release the defendant on bond on 

the condition that he obtain treatment or habilitation services. Id. at -111(2)(a). If the court 

determines that the defendant is not eligible for release on bond, the court may commit the 

defendant to the custody of the Department for restorative treatment. Id. at -111(2)(b). Once the 

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defendant has been restored to competency, the defendant is returned to the custody of the 

county jail for the resumption of criminal proceedings against the defendant. Id.

19. While a defendant is committed for restorative treatment, the court is required to 

review the defendant’s case at least every three months “with regard to the probability that the 

defendant will eventually be restored to competency and with regard to the justification for 

continued commitment or confinement.” Id. at -116(2). A defendant is entitled to credit for any 

time spent in confinement for restorative treatment against any term of imprisonment imposed 

after restoration to competency, and a defendant may not be confined for restorative treatment 

for a period in excess of the maximum term of confinement that could be imposed for the offense 

with which the defendant is charged. Id. at -116(1). 

B. The Competency Evaluation System Is Plagued by Chronic Delays, Trapping 

Pretrial Detainees Who Are Presumed Innocent in Procedural Limbo

20. Pretrial detainees in many, if not all, of Colorado’s jails are experiencing severe 

delays—some as long as six months—in receiving court-ordered competency evaluations and, 

for those determined not competent to proceed, for admission to CMHIP for restorative 

treatment. In some cases, the delays for evaluation and admission for restorative treatment have 

resulted in confinement of pretrial detainees for periods longer than they otherwise would have 

been confined for the alleged offense.

21. CMHIP currently maintains a wait list of pretrial detainees that have been ordered 

to receive restorative treatment at CMHIP and that it has not admitted. There are more than 50 

people on the wait list, and there are numerous detainees with serious mental illness who are 

waiting four, five, and even six months for admission to CHIP after they have been ordered to 

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receive restorative treatment. See Affidavit of Colorado State Public Defender Douglas K. 

Wilson, attached hereto as Exhibit A.

22. For example, the Colorado Public Defender currently represents Client L.E. L.E. 

was detained in the Boulder County Jail. On December 30, 2010, the Judge D. Archuleta, of the 

Boulder County District Court, ordered that L.E. be evaluated to determine his competency to 

proceed to trial. L.E.’s evaluation occurred on January 28, 2011 at the Boulder County Jail, and 

the written report of L.E.’s evaluation was filed with the court on February 7, 2011. On 

February 14, 2011, the court entered its determination that L.E. was not competent to proceed 

and that L.E. be transported to CMHIP for treatment and restoration. L.E. was not transported to 

CMHIP until July 15, 2011, more than five months after the court ordered that he receive 

restorative treatment. 

23. The Colorado Public Defender represents Client T.M. On or about January 18, 

2011, Judge T. Quammen of the Weld County District Court ordered that T.M. be evaluated to 

determine T.M.’s competency to stand trial. T.M.’s evaluation occurred on February 1, 2011 at

the Weld County Jail and the written report of T.M.’s evaluation was filed with the court on 

February 14, 2011. On February 17, 2011, the court made its determination that T.M., who has a 

history of schizophrenia, is not competent to stand trial and ordered that T.M. be transported to 

CMHIP for treatment and restoration. T.M. was admitted to CMHIP on August 15, 2011, six 

months following the court’s order that he be admitted to CMHIP for restorative treatment. 

24. The Colorado Public Defender represents Client P.E. On January 31, 2011, Judge 

E. Rinaldi, of the Adams County District Court, ordered that P.E. be evaluated to determine 

P.E.’s competency to stand trial. P.E.’s evaluation occurred on March 23, 2011 at the Adams 

County Jail, and the written report of P.E.’s evaluation was filed with the court on April 11, 

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2011. On April 29, 2011, the court made its determination that P.E. is not competent to stand 

trial and ordered that P.E. be transported to CMHIP for treatment and restoration. P.E. had not 

been transported to CMHIP by June 10, 2011, on which date the court held a review hearing and 

entered a second order that P.E. be transferred to CMHIP for treatment and restoration. While 

detained in the Adams County Jail, P.E. has been charged with additional offenses allegedly 

committed while in jail. P.E. was admitted to CMHIP on July 13, 2011, two-and-a-half months 

following the court’s order that he be admitted to CMHIP for restorative treatment. 

25. The Colorado Public Defender represents Client R.J. On March 21, 2011, Judge 

J. Romeo, of the Adams County District Court, ordered that R.J. be evaluated to determine R.J.’s 

competency to stand trial. The Department did not conduct R.J.’s evaluation until June 30, 2011

at the Adams County Jail. The written report of R.J.’s evaluation was filed with the court on July 

5, 2011. On July 26, 2011, the court made its determination that R.J. is not competent to stand 

trial and ordered that R.J. be transported to CMHIP for treatment and restoration. On July 26, 

2011, R.J’s attorney requested that R.J. be released on bond given the wait times for restoration.

The court, however, denied the request. While awaiting transfer to CMHIP, R.J. has been 

charged with an additional offense allegedly committed while in jail. As of the date of this 

Complaint, more than five months following the order to evaluate R.J. for competency, and more 

than a month following the court’s transportation order, R.J. remains in custody at the Adams 

County Jail and has not received any restorative treatment.

26. The Colorado Public Defender represents Client S.R. On April 28, 2011, Judge 

R. Lowrey, of the El Paso County District Court, ordered that S.R. be evaluated to determine 

S.R.’s competency to stand trial. S.R.’s evaluation occurred on June 13, 2011 at the El Paso 

County Jail and the written report of S.R.’s evaluation was filed with the court on July 1, 2011. 

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On July 7, 2011, the court made its determination that S.R. is not competent to stand trial and 

ordered that S.R. be transported to CMHIP for treatment and restoration. On July 28, 2011, Lori 

Carter, Observations/Admissions Administrator for the Institute of Forensic Psychiatry at 

CMHIP notified S.R.’s Deputy Public Defender, that S.R. would not be transported to CMHIP 

for at least seven weeks because there were 55 people ahead of S.R. on CMHIP’s waiting list. 

As of the date of this Complaint, almost two months following the court’s order that he be 

admitted to CMHIP, S.R. remains in custody at the El Paso County Jail and has not received any 

restorative treatment.

27. Numerous other pretrial detainees have experienced or are currently experiencing

similarly severe delays in receiving competency evaluations or in being admitted to CMHIP for 

treatment and restoration. 

28. Data from a county sheriff’s office further demonstrates that delays for evaluation 

and admission for restorative treatment are severe and growing. See Affidavit of Arapahoe 

County Sheriff J. Grayson Robinson, attached hereto as Exhibit B. The Arapahoe County 

Sheriff, who oversees the Arapahoe County Detention Facility, has witnessed the following 

delays in 2010 and 2011. In 2010, an average of 43 days elapsed between a court order for a 

competency evaluation and the provision of the evaluation in jail. In 2011, the average has 

increased to 51.6 days. In one instance in 2011, it took 58 days—more than eight weeks—for a 

detainee to receive a court-ordered competency evaluation.

29. The Arapahoe County Sheriff has also seen increases in delays for admission to 

CMHIP after a finding of incompetency. In 2010, an average of 26.25 days elapsed between a 

court order for commitment of an incompetent detainee to CMHIP and admission to CMHIP. In 

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2011, the average has increased to 32.5 days. In one instance in 2011, it took 48 days—almost 

seven weeks—for a detainee to be admitted into CMHIP.

30. Statistics from the Arapahoe County Sheriff’s Office are set forth in the table 

below.

Arapahoe County Detention Facility Statistics

2010 2011

Average days from courtordered evaluation to conduct 

of evaluation in jail.

43 51.6

Average days from courtordered evaluation to 

evaluation at CMHIP.

31.9 54.5

Average days from courtordered commitment of 

incompetent detainees to 

CMHIP and admission to 

CMHIP.

26.25 32.5

C. The Delays Cause Detainees Severe Harm, Violate Their Constitutional Rights, and 

Impose Significant Burdens on Jails and Sheriff Departments

31. In late 2006, approximately 85 pretrial detainees all over the State of Colorado 

were experiencing significant delays, up to six months, waiting for evaluation and transport to 

CMHIP. In one instance, Judge M. Egelhoff of the Denver District Court, found the Department 

and CMHIP in contempt of his orders for competency evaluations or commitment for restorative 

treatment of three individuals. As a result of the contempt citations, and further proceedings, the 

Department and CMHIP entered into a settlement agreement with Special Counsel, which 

required them to admit pretrial detainees to CMHIP within 24 days of receipt of a court order for 

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evaluation or commitment. This settlement agreement was commonly known as the “Zuniga” 

agreement. The settlement agreement expired in June 2009 when CMHIP’s new 200-bed 

forensic facility was open for admission. Unfortunately, this new facility was not enough to curb 

the dire and growing violation of constitutional rights suffered by those once again waiting for 

months for admission to CMHIP for evaluation and treatment. Beginning in January 2010, 

pretrial detainees were once again waiting for significant periods to obtain evaluations and/or be 

transported to CMHIP for restorative treatment. 

32. Pretrial detainees who wait months for evaluation and/or restorative treatment

suffer serious harm. Jails can provide medication management for people willing to take 

medications, but cannot administer medication involuntarily, except in a life-threatening 

emergency. The psychological condition and behavior of incompetent detainees often 

deteriorates rapidly when they do not receive necessary treatment.

33. None of the jails in Colorado are able to provide treatment designed to restore a 

person found incompetent to proceed. As a result, detainees who suffer from mental illness are 

unpredictable and disruptive, taking up valuable resources needed for the care of other inmates. 

34. The jails’ only system for controlling inmates is through disciplinary control, 

which is behavior driven. Such a system is ineffective and harmful for persons with mental 

illness. Unlike the county jails, CMHIP has the capacity to treat a person’s mental illness. Each 

of the CMHIP units housing persons found incompetent to proceed is staffed by a full-time 

psychiatrist, psychologist, mental health nurses, social workers, mental health technicians, and 

even a recreational counselor.

35. In addition to assessment, medication evaluation and management, and individual 

and group psychotherapy, CMHIP provides legal skills training one to three times per week to 

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assist patients in learning about the law, pleas, and returning to court. This treatment is designed 

to enable a person to regain fitness to participate in criminal proceedings.

36. Pretrial detainees with mental illness are a population that has a high suicide risk, 

and psychosis can be an emergency requiring immediate treatment.

37. Depriving persons with mental illness who are incompetent to proceed with the 

necessary restorative treatment increases the likelihood that their condition will deteriorate and 

they will suffer unduly. The delays also hamper efforts to provide effective representation 

regarding their criminal prosecution.

38. Although the jails have the capacity to transport detainees to CMHIP more 

quickly, detainees cannot be transported until CMHIP agrees to admit them upon arrival. If the 

jails transport detainees before receiving notice from CMHIP that it will admit them, CMHIP 

will refuse their admission. 

39. While pretrial detainees are in jail, they do not receive care giving them a realistic 

opportunity of becoming competent to stand trial. This failure of the Defendants to evaluate and 

admit the pretrial detainees in a timely manner violates their due process rights. 

40. The resources of Sheriffs’ departments around Colorado are strained by the delays 

in evaluating pretrial detainees and admitting those not competent to proceed to CMHIP. For 

example, the average cost per day to house an inmate in the Arapahoe County Detention Facility 

is $68.30. The average cost per day to house a detainee suffering from mental illness can be 

double that amount. Sheriffs’ departments are incurring this increased cost more often than they 

should because of the Defendants’ failure to promptly evaluate and admit detainees.

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CAUSE OF ACTION

(42 U.S.C. § 1983 for violation of the Due Process Clause 

of the Fourteenth Amendment)

41. Plaintiff realleges each allegation above as if fully set forth herein.

42. Defendants, in their official capacities, act under color of Colorado law when they 

provide, or fail to provide, detainees with timely court-ordered competency evaluations and 

timely restorative mental health treatment.

43. Defendants Bicha and Bernal, in their official capacities, have failed to provide 

prompt competency evaluations and prompt admission to CMHIP of detainees determined to be 

incompetent.

44. There is an actual, present, and justiciable controversy between Plaintiff and 

Defendants over the severe delays caused by Defendants in providing court-ordered competency 

evaluations and in admitting pretrial detainees to CMHIP for court-ordered treatment and 

restoration.

45. Due process requires that the nature and duration of confinement bear reasonable 

relation to the purpose for which an individual is confined.

46. Once a defendant is found unable to aid and assist in his own defense, the only 

lawful purpose for confinement is to treat the person in order to return them to competency.

47. Individuals found not competent to aid and assist in their defense have a 

constitutional right to such individualized treatment as will give them a reasonable opportunity to 

be cured or to improve their mental condition.

48. Colorado’s county jails do not have the structure, mission, expertise or resources 

to provide the restorative mental health treatment required by detainees who have been found not 

competent to proceed to trial. There is no legitimate state interest in keeping pretrial detainees

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with mental illness incarcerated in county jails for weeks or months and depriving them of timely 

evaluations and restorative treatment.

49. “The United States Supreme Court has recognized that an individual has a liberty 

interest in being free from incarceration absent a criminal conviction.” Or. Advocacy Ctr. v. 

Mink, 322 F.3d 1101, 1121 (9th Cir. 2003) (quoting Oviatt ex rel. Waugh v. Pearce, 954 F.2d 

1470, 1474 (9th Cir. 1992)). “Because incapacitated criminal defendants have not been 

convicted of any crime, they have an interest in freedom from incarceration. They also have a 

liberty interest in receiving restorative treatment.” Id. 

50. Defendants actions and inactions result in confinement of pretrial detainees with 

mental illness that violates the Due Process Clause of the Fourteenth Amendment to the U.S. 

Constitution.

51. Plaintiff is entitled to a declaratory judgment from this Court under 28 U.S.C. §§ 

2201-02 and Fed. R. Civ. P. 57 that (1) the current delays in Colorado for competency 

evaluations and admission to CMHIP of incompetent detainees violate the Due Process Clause of 

the Fourteenth Amendment, (2) competency evaluations must be completed and submitted to the 

court ordering them no later than 7 days after the court’s order, or within such other time that this

Court determines comports with the Due Process Clause of the Fourteenth Amendment, and (3) 

detainees found not competent to proceed to trial be admitted by CMHIP for restorative

treatment no later than 7 days following the court’s determination of incompetency, or within 

such other time that this Court determines comports with the Due Process Clause of the 

Fourteenth Amendment. See Or. Advocacy Ctr. v. Mink, 322 F.3d 1101, 1121 (9th Cir. 2003) 

(holding that state hospital must admit mentally incapacitated criminal defendants within 7 days 

of judicial finding of incapacitation).

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PRAYER FOR RELIEF

WHEREFORE Plaintiff Legal Center prays for relief as follows:

a. A judgment declaring (1) that the current delays in Colorado for competency 

evaluations and admission to CMHIP for restorative treatment of incompetent detainees violate 

the Due Process Clause of the Fourteenth Amendment; (2) that competency evaluations must be 

completed and submitted to the court ordering them no later than 7 days after the court’s order, 

or within such other time that this Court determines comports with the Due Process Clause of the 

Fourteenth Amendment; and (3) that detainees found not competent to proceed to trial be 

admitted by CMHIP for restorative treatment no later than 7 days following the court’s 

determination of incompetency, or within such other time that this Court determines comports 

with the Due Process Clause of the Fourteenth Amendment;

b. A preliminary and permanent injunction requiring Defendants (1) to complete 

court-ordered competency evaluations within 7 days of the court’s order, or within such other 

time that this Court determines comports with the Due Process Clause of the Fourteenth 

Amendment; and (2) to transport to and accept for restorative treatment at CMHIP detainees 

found not competent to proceed to trial within 7 days of the court’s order, or within such other 

time that the Court determines comports with the Due Process Clause of the Fourteenth 

Amendment; 

c. An award of Plaintiffs’ reasonable attorney fees and costs pursuant to 42 U.S.C. § 

1988; and 

d. Such other and further relief as the Court may deem just and proper.

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DATED: August 31, 2011

Respectfully submitted,

/s/ Jason M. Lynch

Iris Eytan

Jason M. Lynch

Caleb Durling

REILLY POZNER LLP

1900 Sixteenth Street, Suite 1700

Denver, CO 80202

(303) 893-6100

ieytan@rplaw.com

jlynch@rplaw.com

cdurling@rplaw.com

/s/ Marcus Lock

Marcus Lock

BRATTON HILL WILDERSON & LOCK LLC

525 North Main Street

Gunnison, CO 81230

(970) 641-1903

MLock@BrattonHill.com

Chester R. Chapman

Mark J. Ivandick

THE LEGAL CENTER FOR PEOPLE WITH 

DISABILITIES

455 Sherman St., Suite 130

Denver, CO 80203

(303) 722-0300

rchapman@thelegalcenter.org

mivandick@thelegalcenter.org

Attorneys for Plaintiff Legal Center

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EXHIBIT A

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EXHIBIT B

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