DISTRICT COURT, ADAMS COUNTY, STATE OF COLORADO
1100 Judicial Center Drive
Brighton, CO 80601
Phone Number: (303) 659-1161
Plaintiff:
The People of the State of Colorado
? COURT USE ONLY ?
Defendant:
RICK STANLEY
Case Number: 03CR2971
THE REISCH LAW FIRM, LLC 03CR2956
R. Scott Reisch, #26892
Stacey L. Ross, #20823
370 Seventeenth Street, Suite 4970 Div.: Ctrm.:
Denver, CO 80202
Telephone: (303) 291-0555
FAX Number: (720) 904-5797
E-mail: rscottreisch@worldnet.att.net
BULL & DAVIES, P.C.
Brett Davies, #34175
812 Santa Fe Drive
Denver, CO 80204
Telephone: (303) 996-9815
MOTION FOR SUPRESSION OF WIRE COMMUNICATIONS
COMES NOW the defendant, Rick Stanley, by and through his attorneys, and hereby moves
the Court for an Order, suppressing from introduction into evidence at trial any wire
communications which were not available to the general public.
AS GROUNDS THEREFORE, defendant states:
1. The "Affidavit and Application for Arrest Warrant" in each of the above captioned cases
refers to various e-mails which were not posted on defendant's public web site,
www.Stanley2002.org, and which were private communications between the sender and the
recipient.
2. No Court Order authorizing the interception of wire communications has been provided
in the discovery.
3. Defendant asserts that the wire communications were intercepted in violation of rights
under the Fourth, Fifth, and Fourteenth Amendments to the United States Constitution.
WHEREFORE, defendant respectfully requests that the Court issue an Order suppressing from
introduction into evidence any illegally intercepted wire communications and the fruits of
illegally intercepted communications.
Respectfully submitted this ______ day of March, 2004.
__________________________________
R. Scott Reisch
Stacey L. Ross
Brett Davies
CERTIFICATE OF SERVICE
I do hereby certify that on the ____ day of March, 2004, I ? deposited in the U.S. Mail, or ?
sent via facsimile to the following number: ___________ or ? hand delivered the foregoing
Motion for Suppression of Wire Communications to the following:
Mark Warner
Deputy District Attorney
District Attorney's Office
450 S. 4th Ave.
Brighton, CO 80601
