Appeal
Defendants’ Notice of Appeal (1/23/12)
Briefs
Defendants-Appellants’ Opening Brief (7/18/12)
Plaintiffs-Appellee’s Response Brief (9/26/12)
Plaintiff-Intervenors-Appellee’s Response Brief (9/26/12)
Defendants-Appellants’ Reply Brief (11/2/12)
Amici Curiae Briefs in Support of Defendants-Appellants
Amici Curiae Brief of the Colorado League of Charter Schools and National Alliance for Public Charter Schools (7/18/12)
Amici Curiae Brief of Colorado Concern, et al. (7/18/12)
Amicus Curiae Brief of the Regents of the University of Colorado (7/18/12)
Amici Curiae Brief of the Colorado Behavioral Healthcare Council and Alliance (7/18/12)
Amici Curiae Brief of Former Colorado Governors Bill Ritter, Bill Owens, Roy Romer, and Richard Lamm (7/18/12)
Amici Curiae Briefs in Support of Plaintiffs-Appellees
Amicus Curiae Brief of Colorado Education Association (9/26/12)
Amici Curiae Brief of Colorado Cross-Disability Coalition, The Legal Center for People with Disabilities and Older People, and The ARC of Colorado (9/26/12)
Amicus Curiae Brief of Education Law Center (9/26/12)
Amici Curiae Brief of Brennan Center for Justice and Professors of Constitutional Law and Civil Procedure (9/26/12)
Amici Curiae Brief of Colorado Women’s Bar Association, Colorado Hispanic Bar Association, Colorado Lawyers Committee, and Colorado Gay Lesbian Bisexual Transgender Bar Association (9/26/12)
Amici Curiae Brief of Colorado Boards of Cooperative Educational Services Association, Colorado Rural Schools Caucus, and Rural School and Community Trust (9/26/12)
Amici Curiae Brief of Colorado Association of School Boards and Colorado Association of School Executives (9/26/12)
Amici Curiae Brief of the Bell Policy Center and American Civil Liberties Union of Colorado (9/26/12)
Amici Curiae Brief of Kim Reorganized School District 88, Lake County School District R-1, and Limon Public Schools District Re-4J (9/26/12)
Amici Curiae Brief of the Campaign for Educational Equity, Teachers College, Columbia University and the National Education Access Network (9/26/12)
Amici Curiae Brief of Padres Unidos and Colorado Association for Bilingual Education (9/26/12)
Amici Curiae Brief for Great Education Colorado, Colorado Parent-Teachers Association, and Colorado Association for Gifted and Talented (9/26/12)
Amicus Curiae Brief of Colorado Center on Law and Policy (9/28/12)
Complaint/Answer
Complaint
Complaint in Intervention
Amended Complaint
Answer to Amended Complaint
Answer to Complaint in Intervention
Second Amended Complaint
Answer to Second Amended Complaint
Amended Complaint in Intervention
Answer to Amended Complaint in Intervention
Third Amended Complaint (3/25/11)
Answer to Third Amended Complaint (4/8/11)
Court Orders
Case Management Order
Court Order Granting Plaintiffs’ Motion in limine to Exclude Evidence of Non-Education Appropriations and TABOR provisions (7/11/11)
Court Order Granting in Part and Denying in Part Plaintiffs’ Motion to Compel Discovery (7/11/11)
Court Order Denying Defendants’ Motion for Determination of Questions of Law (7/14/11)
Court Order Granting Plaintiffs’ and Plaintiff-Intervenors’ Motions to Strike Affirmative Defenses (7/21/11)
Trial Court Findings of Fact and Conclusions of Law (12/9/11)
Discovery
Initial Disclosures
Plaintiffs’ Rule 26(a)(1) Initial Disclosures
Plaintiff-Intervenors’ Rule 26(a)(1) Initial Disclosures
Defendants’ Rule 26(a)(1) Initial Disclosures
Defendants’ First Supplemental Disclosures
Plaintiffs’ First Supplemental Disclosures
Defendants’ Second Supplemental Disclosures
Defendants’ Third Supplemental Disclosures (2/9/11)
Defendants’ Fourth Supplemental Disclosures (3/15/11)
Plaintiffs’ Second Supplemental Disclosures (5/4/11)
Defendants’ Fifth Supplemental Disclosures (5/23/11)
Discovery Requests
Plaintiffs’ First Set of Discovery Requests to Defendants
Plaintiff-Intervenors First Set of Discovery Requests to Defendants
Defendants’ First Request for Production of Documents to School District Plaintiffs
Defendants’ First Set of Interrogatories to School District Plaintiffs
Defendants’ First Request for Production of Documents to Individual Plaintiffs
Defendants’ First Set of Interrogatories to Individual Plaintiffs
Defendants’ First Request for Production of Documents to Plaintiff-Intervenors
Defendants’ First Set of Interrogatories to Plaintiff-Intervenors
Defendants’ Second Request for Production of Documents to School District Plaintiffs (2/10/11)
Defendants’ Second Request for Production of Documents to Individual Plaintiffs (2/10/11)
Plaintiffs’ Second Set of Discovery Requests to Defendants (3/28/11)
Defendants’ Third Request for Production of Documents to School District Plaintiffs (4/1/11)
Plaintiffs’ Third Set of Discovery Requests to Defendants (4/14/11)
Plaintiff-Intervenors’ Third Set of Interrogatories, Second Request for Production, and Second Request for Admissions to Defendants (4/15/11)
Defendants’ Second Set of Interrogatories to School District Plaintiffs (4/20/11)
Defendants’ Request for Production of Expert Witness Documents to Plaintiffs (5/13/11)
Defendants’ Request for Production of Expert Witness Documents to Plaintiff-Intervenors (5/13/11)
Plaintiffs’ Third Set of Discovery Requests to Defendants (5/25/11)
Defendants’ Discovery Responses
Defendants’ Responses to Plaintiffs’ First Set of Discovery Requests
Defendants’ Responses to Plaintiff-Intervenors’ First Set of Discovery Requests (11/10/10)
Defendants’ Second Supplemental Responses to Plaintiffs’ First Set of Discovery Requests (2/10/11)
Defendants’ First Supplemental Responses to Plaintiff-Intervenors’ First Set of Discovery Requests (2/10/11)
Defendants’ Third Supplemental Responses to Plaintiffs’ First Set of Discovery Requests (3/15/11)
Defendants’ Responses to Plaintiff-Intervenors’ Second Set of Interrogatories (3/15/11)
Defendants’ Amended Responses to Plaintiff-Intervenors’ Third Set of Interrogatories, Second Requests for Production and Second Requests for Admissions (5/19/11)
Defendants’ Responses to Plaintiffs’ Second Set of Discovery Requests (5/19/11)
Defendants’ Responses to Plaintiffs’ Third Set of Discovery Requests (5/19/11)
Defendants’ Amended Fourth Supplemental Responses to Plaintiffs’ First Set of Discovery Requests (5/24/11)
Plaintiff School Districts’ Discovery Responses
Alamosa’s Combined Response to Defendants’ First Discovery Requests
Montezuma-Cortez’s Combined Response to Defendants’ First Discovery Requests
Pueblo 60′s Combined Response to Defendants’ First Discovery Requests
Centennial’s Combined Response to Defendants’ First Discovery Requests
North Conejos’s Combined Response to Defendants’ First Discovery Requests
South Conejos’s Combined Response to Defendants’ First Discovery Requests
Sanford’s Combined Response to Defendants’ First Discovery Requests
Mountain Valley’s Combined Response to Defendants’ First Discovery Requests Moffat’s Combined Response to Defendants’ First Discovery Requests
Moffat’s First Supplemental Response to Defendants’ First Discovery Requests (2/16/11)
Creede’s Combined Response to Defendants’ First Discovery Requests
Creede’s First Supplemental Response to Defendants’ First Discovery Requests (2/16/11)
Del Norte’s Combined Response to Defendants’ First Discovery Requests
Del Norte’s First Supplemental Response to Defendants’ First Discovery Requests (2/16/11)
Colorado Springs D11′s Combined Response to Defendants’ First Discovery Requests
Colorado Springs D11′s First Supplemental Response to Defendants’ First Discovery Requests (4/18/11)
Colorado Springs D11′s Second Supplemental Response to Defendants’ First Discovery Requests (3/8/11)
JeffCo’s Combined Response to Defendants’ First Discovery Requests
JeffCo’s Response to Defendants’ Second Set of Interrogatories to School District Plaintiffs (5/23/11)
JeffCo’s Response to Defendants’ Third Request for Production to School District Plaintiffs (5/23/11)
Monte Vista’s Combined Response to Defendants’ First Discovery Requests
Monte Vista’s First Supplemental Response to Defendants’ First Discovery Requests (4/15/11)
Aurora’s Combined Response to Defendants’ First Discovery Requests
Aurora’s First Supplemental Response to Defendants’ First Discovery Requests (3/1/11)
Bethune’s Combined Response to Defendants’ First Discovery Requests
Center’s Combined Response to Defendants’ First Discovery Requests
MCSD’s Combined Response to Defendants’ First Discovery Requests
Sangre de Cristo’s Combined Response to Defendants’ First Discovery Requests
Sargent’s Combined Response to Defendants’ First Discovery Requests
Sierra Grande’s Combined Response to Defendants’ First Discovery Requests
Plaintiffs Combined Responses to Defendants’ Second Request for Production of Documents to School District and Individual Plaintiffs (3/18/11)
Plaintiffs’ Response to Defendants’ Third Request for Production of Documents to School District Plaintiffs (5/20/11)
Plaintiff-Intervenors’ Discovery Responses
Plaintiff Intervenors’ Supplemental Responses to Defendants’ First Request for Production (5/20/11)
Expert Reports
Initial Expert Disclosures (list potential experts and subject matter of testimony)
Plaintiffs’ Initial Expert Disclosures (2/2/11)
Plaintiff-Intervenors’ Initial Expert Disclosures (2/2/11)
Defendants’ Initial Expert Disclosures (3/4/11)
Defendants’ Amended Expert Disclosures (5/11/11)
Plaintiffs’ Expert Reports
Plaintiffs’ Expert Disclosures (3/21/11)
Expert Statements of Carol Hedges, Dr. Monte C. Moses, Glenn E. Gustafson, Lucinda Hundley, Randy K. Boyer, Dr. Dan Maas, George Welsh, Michael Poore, Dr. Susan Scheibel, Dr. John Hefty, Sue Windels, Jack Pommer, and Andrew Romanoff
Exhibits A-M to Plaintiffs’ Expert Disclosures (3/21/11)
Ex. A: Costing Out the Resources Needed to Meet Colorado Education Standards and Requirements — Augenblick, Palaich and Associates, Inc.
Ex. B: Colorado School Finance — Expert Report of Dr. Bruce Baker, Rutgers University
Ex. C: Education and Colorado’s Constitution — Expert Report of Dr. Tom Romero, University of Denver Sturm College of Law
Ex. D: Colorado Student Assessment Program and National Assessment of Educational Progress — Expert Report of Dr. Robert L. Linn, University of Colorado at Boulder
Ex. E: CV of Dr. Monte C. Moses
Ex. F: CV of Glenn E. Gustafson
Ex. G: CV of Lucinda Hundley
Ex. H: CV of Randy K. Boyer
Ex. I: CV of Dr. Daniel R. Maas
Ex. J: CV of George S. Welsh
Ex. K: CV of Michael Alan Poore
Ex. L: CV of Dr. Susan Riley Scheibel
Ex. M: CV of Dr. John C. Hefty
Plaintiffs’ First Supplemental Expert Disclosures (3/31/11)
Expert Statement of Cary Kennedy
Plaintiffs’ Second Supplemental Expert Disclosures (4/11/11)
Expert Statement of Dr. Lisa Escarcega
Exhibits N-P to Plaintiffs’ Expert Disclosures (4/11/11)
Ex. N: Preschool Education and Colorado — Expert Report of Dr. W. Steven Barnett, National Institute for Early Education Research
Ex. O: Expert Report of Dr. Margaret McLaughlin, University of Maryland
Ex. P: CV of Dr. Lisa A Escarcega
Plaintiffs’ Third Supplemental Expert Disclosures (5/13/11)
Ex. Q: The Fiscal and Social Burden of Inadequate Education in Colorado — Expert Report of Dr. Clive R. Belfield, City University of New York, and Dr. Henry M. Levin, Columbia University (5/12/11)
Plaintiffs’ Fourth Supplemental Expert Disclosures (5/17/11)
Ex. R: Expert Report of Dr. Linda Darling-Hammond, Stanford University (5/17/11)
Plaintiffs’ Rebuttal Expert Disclosure (6/7/11)
Rebuttal Expert Statements of Dr. Margaret McLaughlin and Lucinda Hundley
Defendants’ Expert Reports
Defendants’ Expert Disclosures (4/18/11)
Expert Statements of Ted Hughes and Dr. Rob Stein
Defendants’ First Supplemental Expert Disclosures (4/20/11)
Expert Statement of Jo O’Brien
Defendants’ Second Supplemental Expert Disclosures (5/2/11)
Expert Statements of Dr. William Moloney, Dr. John Covington, Mark Hyatt, and Dr. Kristen Waters
Defendants’ Third Supplemental Expert Disclosures (5/9/11)
Expert Statements of Lori Bowers, Lt. Governor Joseph Garcia, and Dr. Ed Steinberg
Defendants’ Fourth Supplemental Expert Disclosures (5/16/11)
Expert Statement of Vody Herrmann
Defendants’ Fifth Supplemental Expert Disclosures (5/23/11)
Expert Statement of Henry Sobanet
Defendants’ Sixth Supplemental Expert Disclosures (6/13/11)
Expert Statement of Dr. Trish Boland
Ex. A: Expert Report of Dr. Eric A. Hanushek, Hoover Institution (6/13/11)
Defendants’ Seventh Supplemental Expert Disclosures (6/15/11)
Expert Statement of Dr. Barbara Medina
Plaintiff-Intervenors’ Expert Reports
Plaintiff-Intervenors’ Expert Disclosures (3/21/11)
Expert Statements of Michael Clough, Charlotte Ciancio, Dr. Ranelle Lang, Nancy Aschermann
The Implications of Inadequate Levels of Education for the Socioeconomic Future of Colorado — Expert Report of Dr. Steve H. Murdock (3/30/11)
Expert Report of Dr. Kathy Escamilla, University of Colorado at Boulder (4/15/11)
Motion to Dismiss
District Court Ruling (3/2/06)
Appellate Court Ruling (1/24/08)
Supreme Court Appellants/Plaintiffs’ Opening Brief
Supreme Court Appellees/Defendants’ Answer Brief
Supreme Court Appellants/Plaintiffs’ Reply Brief
Supreme Court Brief of Amicus Curiae Great Education Colorado
Supreme Court Brief of Amici Curiae Colorado Association of School Boards and Colorado Association of School Executives
Supreme Court Brief of Amicus Curiae Colorado Education Association
Supreme Court Brief of Amici Curiae Colorado Lawyers Committee and Colorado Center on Law and Policy
Supreme Court Brief of Amicus Curiae Colorado League of Charter Schools
Supreme Court Brief of Amici Curiae Padres Unidos and META
Colorado Supreme Court Ruling (10/19/09)
Other Motions
Motion to Strike Affirmative Defenses
Plaintiffs’ Motion to Strike Defendants’ Second, Third, and Fourth Affirmative Defenses
Plaintiff-Intervenors’ Motion to Strike Defendants’ Second, Third, Fourth, and Fifth Affirmative Defenses
Defendants’ Combined Response to Plaintiffs and Plaintiff-Intervenors’ Motion to Strike Affirmative Defenses
Plaintiffs’ Reply in Support of Their Motion to Strike Defendants’ Second, Third, and Fourth Affirmative Defenses
Plaintiff-Intervenors’ Reply in Support of Their Motion to Strike Defendants’ Second, Third, Fourth and Fifth Affirmative Defenses
Motion for Determination of Questions of Law
Defendants’ Motion for Determination of Questions of Law (2/25/11)
Plaintiffs’ Response to Defendants’ Rule 56(h) Motion (5/16/11)
Plaintiff-Intervenors’ Opposition to Defendants’ Rule 56(h) Motion (5/16/11)
Defendants’ Combined Reply to Plaintiffs’ Response and Plaintiff Intervenors’ Opposition to Defendants’ Rule 56(h) Motion (6/27/11)
Motion In Limine
Plaintiffs’ Motion in Limine to Exclude Evidence of Non-Education Appropriations and Tabor Provisions (6/27/11)
Defendants’ Opposition to Plaintiffs’ Motion in Limine to Exclude Evidence of Non-Education Appropriations and Tabor Provisions (7/1/11)
Plaintiffs’ Reply in Support of Their Motion in Limine to Exclude Evidence of Non-Education Appropriations and Tabor Provisions (7/6/11)
Trial
Trial Court Decision (12/9/11)
Proposed Findings of Fact and Conclusions of Law
Plaintiffs’ Proposed Findings of Fact and Conclusions of Law (10/31/11)
Plaintiff-Intervenors’ Proposed Findings of Fact and Conclusions of Law (10/28/11)
Defendants’ Proposed Findings of Fact and Conclusions of Law (10/28/11)
Trial Briefs
Plaintiffs’ Trial Brief (7/25/11)
Plaintiff-Intervenors’ Trial Brief (7/25/11)
Defendants’ Trial Brief (7/25/11)
Offer of Proof re Former State Senator Norma Anderson
Defendants’ Offer of Proof re Testimony of Former State Senator Norma Anderson (8/25/11)
Plaintiffs’ Response in Opposition to Defendants’ Offer of Proof (8/29/11)
Plaintiff-Intervenors’ Joinder with Plaintiffs’ Response to Defendants’ Offer of Proof (8/29/11)
Plaintiffs’ Closing Argument (9/2/11)
Trial Transcripts
Trial Transcript Day 1 (8/1/11)
Opening Statements
George Welsh, Superintendent Center School District
John Hefty, Former CASE Executive Director
Trial Transcript Day 2 (8/2/11)
John Hefty cont’d, Former CASE Executive Director
Scott Murphy, Superintendent Littleton Public Schools
Glenn Gustafson, CFO Colorado Springs School District 11
Tom Romero II, Professor, Sturm College of Law, University of Denver
Trial Transcript Day 3 (8/3/11)
Ed Steinbrecher, Former Superintendent
Monte Moses, Former Superintendent, Cherry Creek Schools
Elliot Asp, Assistant Superintendent, Cherry Creek Schools
Taylor Lobato, Individual Plaintiff, Center School District
Miguel Cendejas, Individual Plaintiff, Center School District
Kevin Edgar, Superintendent, Sanford School District
Trial Transcript Day 4 (8/4/11)
Mike Poore, Former Superintendent of Instruction, Colorado Springs School District 11
Cynthia Stevenson, Superintendent, Jeffco Public Schools
Carol Eaton, Executive Director of Assessment and Research, Jeffco Public Schools
Traci Weisensee, Individual Plaintiff, Woodlin School District
Trial Transcript Day 5 (8/5/11)
Carol Eaton cont’d, Executive Director of Assessment and Research, Jeffco Public Schools
Dan Maas, Chief Information Officer, Littleton Public Schools
Bruce Baker, Professor, Graduate School of Education, Rutgers University
Trial Transcript Day 6 (8/8/11)
Justin Silverstein, Vice President, Augenblick, Palaich, and Associates
Shila Adolf, Superintendent, Bethune School District
Gerald Keefe, Superintendent, Kit Carson School District
Trial Transcript Day 7 (8/9/11)
John Barry, Superintendent, Aurora Public Schools
Lisa Escarcega, Director of Assessment and Research, Aurora Public Schools
Lucinda Hundley, Former Assistent Supt of Special Services, Littleton Public Schools
Margaret McLaughlin, Professor, University of Maryland
Trial Transcript Day 8 (8/10/11)
Margaret McLaughlin cont’d, Professor, University of Maryland
Jessica Spangler, Individual Plaintiff, Denver Public Schools
Ty Ryland, School Board President, Sierra Grande School District
Buck Stroh, Superintendent, Creede School District
Matt Keefauver, Teacher, Montezuma-Cortez School District
Justine Bayles, Teacher, Montezuma-Cortez School District
Trial Transcript Day 9 (8/11/11)
Anastasia Campbell, Teacher, Colorado Springs School District 11
Brenda Krage, Chief Academic Officer, Pueblo 60 School District
Teresa Wrangham, Individual Plaintiff, Boulder Valley School District
Dan Stensrud, Principal, Fairview High School, Boulder Valley School District
Trial Transcript Day 10 (8/12/11)
Holly Hultgren, Former Principal and Administrator, Boulder Valley School District
Ellen Miller-Brown, Chief Academic Officer, Boulder Valley School District
Herbert Conboy, Individual Plaintiff, Pueblo 70 School District
Cary Kennedy, Former Colorado State Treasurer
Trial Transcript Day 11 (8/15/11)
Susan Chandler, Superintendent, Adams 14 School District
Lillian Leroux, Individual Plaintiff, Adams 14 School District
Rollie Heath, Colorado State Senator
David Hart, Chief Financial Officer, Denver Public Schools
Trial Transcript Day 12 (8/16/11)
Steven Barnett, Professor, Rutgers University
Stefan Welsh, Graduate, Center High School
Trial Transcript Day 13 (8/17/11)
Henry Levin, Professor, Teacher’s College, Columbia University
Sue Windels, Former Colorado State Senator
Jack Pommer, Former Colorado State Senator
Trial Transcript Day 14 (8/18/11)
Michael Clough, Superintendent, Sheridan School District
Maribel Payan, Plaintiff-Intervenor, Sheridan School District
Kathy Escamilla, Professor, University of Colorado at Boulder
Trial Transcript Day 15 (8/19/11)
Kathy Escamilla cont’d, Professor, University of Colorado at Boulder
Armandina Ortega, Plaintiff-Intervenor, Rocky Ford School District
Robert Pizano, Plaintiff-Intervenor, Rocky Ford School District
Linda Darling-Hammond, Professor, Stanford University
Trial Transcript Day 16 (8/22/11)
Wayne Eads, Budget Director, Greeley-Evans School District
Dana Selzer, Former Assistant Superintendent, Greeley-Evans School District
Abigail Diaz, Plaintiff-Intervenor, Greeley-Evans School District
Steve Murdock, Office of the State Demographer, Texas
Trial Transcript Day 17 (8/23/11)
Celia Levya, Plaintiff-Intervenor, Mapleton School District
Mary Wickersham, Colorado Children’s Campaign
Charlotte Ciancio, Superintendent, Mapleton School District
Trial Transcript Day 18 (8/24/11)
Liutenant Governor Joe Garcia
Rich Wenning, Former Associate Commissioner, CDE
Jo O’Brien, Assistant Commissioner of Standards and Assessment, CDE
Trial Transcript Day 19 (8/25/11)
Kristin Waters, Principal, South High School, Denver Public Schools
Erik Hanushek, Senior Fellow, Hoover Institution, Stanford University
Trial Transcript Day 20 (8/26/11)
Angelika Schroeder, Colorado State Board of Education
Nina Lopez, Vice President of Strategy and Partnerships, Legacy Foundation
William Moloney, Former Colorado Commissioner of Education
Trial Transcript Day 21 (8/29/11)
Marcia Neal, Colorado State Board of Education
Vody Herrmann, Former Assistant Commissioner for School Finance, CDE
Ted Hughes, Director Public School Capital Construction, CDE
Elaine Gantz Berman, Colorado State Board of Education
Linda Darling-Hammond, Professor, Stanford University
Trial Transcript Day 22 (8/30/11)
Mike Miles, Superintendent, Harrison School District
Bob Schaffer, Colorado State Board of Education
Barbara Medina, State Director Language, Culture, and Equity, CDE
Trial Transcript Day 23 (8/31/11)
Trish Boland, Federal Program Administration, CDE
Ed Steinberg, Assistant Commissioner Special Education, CDE
Jacqueline Medina, Gifted and Talented Director, CDE
Ben Alexander, Former State Senator
Trial Transcript Day 24 (9/1/11)
Senator Andrews, Former State Senator
Matt Gianneschi, Deputy Executive Director, Colorado Department of Higher Education
Lisa Escarcega, Director of Assessment and Research, Aurora Public Schools
Commissioner Robert Hammond
Lori Bowers, Supervisor, Colorado Preschool Program, Colorado Department of Education
Trial Transcript Day 25 (9/2/11)
George Welsh, Superintendent, Center School District
Keith King, State Senator
David Hart, Chief Financial Officer, Denver Public Schools
Carol Eaton, Executive Director Assessment and Research, Jeffco Public Schools
Andrew Romanoff, Former Colorado Speaker of the House
Scott Murphy, Superintendent Littleton Public Schools
Brenda Krage, Chief Academic Officer, Pueblo 60 School District