SULTON LAW OFFICES Anne T, Sulton, Ph.D., J.D. Post Office Box 371335, Milwaukee, WI 53237 Telephone (360) 870-6000; E-mail annesulton@gmail.com Licensed in Wisconsin and Colorado April 2, 2018 Via Email: Kirsten Crawford@denvergov.org> Ms. Kirsten J. Crawford, Esq. Legislative Counsel Department of Law 1437 Bannock Street, Room 353 Denver, Colorado 80202 Re: Demand for Litigation Hold Dear Attorney Crawford: Lam asking the Colorado Supreme Court's Office of Attorney Regulation Counsel to review the conduct of all attorneys involved in the payment of $75,000 to Leslie Branch Wise on or about June 28, 2013. A copy of a document relating to this payment is attached hereto, If any other payments or benefits (including but not limited to requested work assignments or extra/special paid leave) were made to or conferred upon Ms. Wise relating to Wayne McDonald and/or Mayor Michael Hancock, then this demand for litigation hold also applies to these additional payments and/or benefits. To facilitate my request for a review, I hereby formally demand that your office identify all persons, communications and documents, and place a litigation hold on any and all documents, relating to this $75,000 payment and any and all other payments and/or benefits made to or conferred upon Ms. Wise relating to Wayne McDonald and/or Mayor el Hancock. Definitions are provided below to minimize any potential confusion you ht have concerning the persons, communications and documents covered by this demand for litigation hold. Page 1of3IDENTIFY: “Identify” or “identification” has the following meanings: 1, When used in reference to an individual person, it means to state a. The person’s full name b. The person’s business address and telephone number on June 28, 2013 c. The person's last known employer, business address, and business telephone number 2. When used in reference to any entity other than an indi state idual person, it means to a, The entity’s full name and its nature (e.g,,a corporation) b. The entity's last known address has its principal place of business In the case of a corporation, the state of incorporation, or in the case of a limited liability company, the state of organization e. _ Inthe case of a partnership, the name and address of each general partner, or in the case of a limited liability partnership, the state of organization and each managing partner £ Inthe case of any business entity other than a corporation, partnership, or limited liability company, the name and address of each owner 3. Whenused in reference to a communication that is not a document, it means to state a. The date of the communication b. The place where the communication occurred c. The type of communication (e.g, telephone conversation, meeting) The content of the communication e f ‘The name and address of the parties to the communication The name and address of all others who participated in or witnessed the communication. 4, When used in reference to a document, it means to state a. The date and description of the document b. The document's present location and the name and address of its custodian . The name and address of the person who drafted, prepared, and signed the document; and the name and address of his or her current employer d. Any other descriptive information necessary to adequately describe the document DOCUMENT: The term “document’ is used in the broadest possible sense and refers to any form of communication or data storage, as well as any and all drafts and copies, whether written, recorded or other graphic matter, electronic or not, however produced or reproduced. It includes any and all matter that relates or refers in whole or in part to the payment of $75,000 to Leslie Branch Wise and any and all other payments and/or benefits made to or conferred upon Ms. Wise relating to Wayne McDonald and/or Mayor Michael Page 2 of 3Hancock. “Document” includes, but is not limited to: any paper, writing, chart, memorandum, note, letter, interoffice memo, intra-office memo, E-mail, text message, working paper, report, study, statement, map, log entry, drawing, photograph, sketch, picture, agreement, advertisement, book, calculation, chart, computer printout, computer stored or generated data, contract, attorney's fee request, attorney billing statements, copy of check or other bank draft, data compilations from which information can be obtained, data sheet, data processing card, envelope, electronic information, form, graph, handwritten note, index, invoice, letter, notebook, pamphlet, periodical, proposal, receipt, record, study, summary, survey, tape, telegram, telephone record or message, videotape, audio tape, CD- ROM, DVD, cassette tape, WAV file, tape recording, or any other written, recorded, verbal or pictorial representation of any event or idea that has transpired, whether meant for communication to others or for personal need. If a document has been prepared in several copies, or if additional copies have been made, and the copies are not identical, or have undergone alteration, each non-identical copy is a separate “document.” Any “document” that contains any comment, notation, addition, signature, insertion, or marking of any Kind, so that it is different from the original, is a separate “document”, RELATING TO: The term “relating to” means pertinent, relevant or material to, evidencing, having a bearing on, or concerning, affecting, discussing, dealing with, considering or otherwise relating to in any manner whatsoever, the subject matter of inquiry. Please immediately assemble and hold all documents. On or before April 16, 2018, please produce the requested identification of persons, communications and documents. A copy of this letter and your response will be provided to the Colorado Supreme Court's Office of Attorney Regulation Counsel. Thank you for your kind attention to this matter and cooperation in this regard. Sincerely, s/Anne T. Sulton Anne T. Sulton, Ph.D., J.D. Colorado Bar # 023464 Mr. Wayne MeDonald Attorney William F. Sulton “Justice League” and "GTO" c/o Attorney Craig Silverman Tal Page 3 of 3