Start Here · Sixty-Second Screen

The cert‑pool memo — one page, the format appellate reviewers actually screen on.

Five questions, three operative facts, four panel errors, two statewide stakes, the ask. Built to be printed, attached to outreach email, and read in under a minute — before any decision to engage further.

Read the Memo → Download the PDF

Pick the path that fits your firm or organization

Three pathways to amicus support.

All three are equally welcome. The right choice depends on how much editorial control your office requires, and how much the existing draft already says what you would say.

1

Sign as drafted.

The unsigned amicus brief is fully briefed under C.A.R. 29 and 53: 20 pages, 3,122 words. It addresses the four legal procedural questions presented (Issues I–IV) plus the access‑to‑justice consequences; the Petition's Issue V (factual conclusions) is intentionally left to the Petition itself, where the record citations sit. The draft is built around the Amada‑conflicting forfeiture rule as Issue I, with federal‑authority surveys from the Tenth, Ninth, Eleventh, and Second Circuits. Add your name (or your organization's), execute the signature page, and you are filed.

Lowest‑burden pathway — the brief is ready for execution.
Ideal for organizations where the procedural‑fairness framing already aligns with institutional positions.
Minor edits to Interest of Amici Curiae are typical and welcome.

Open the Draft (PDF)

2

Modify and sign.

Strengthen the arguments your organization is positioned to advance. Recast the Interest section. Add a section that draws on your institutional research, an empirical study, or a parallel federal authority. Reorganize, replace, refine.

Editable .odt source provided — opens cleanly in Word, LibreOffice, and Google Docs.
The cite‑checked draft serves as your scaffold; you adjust the framing.
Best for organizations whose distinct expertise (civil rights, civil procedure, access to justice empirical work) materially extends the petition.

Edit the Source (ODT)

3

Replace with your own.

If your office's voice, methodology, or institutional priorities call for an entirely independent brief, all of the underlying record materials are publicly available here—including the full Petition, Court of Appeals Opinion, both lower‑court records, and the consolidated MSJ briefing—to support a brief written from scratch in your firm or organization's own format.

Best for organizations with established amicus practices and independent house style.
Master Case File (2,114 pp.) and consolidated briefing compendiums available for citation parity.
Petitioner's only request: a courtesy heads‑up and a copy of the final filing.

Browse the Record

The Scope of Your Commitment

What signing does not commit your organization to.

Amicus support at the cert stage is a narrower commitment than amicus practice on the merits, and narrower still than party representation. For the avoidance of any doubt:

Signing is not an endorsement of the Petitioner's underlying conduct or character. The brief addresses the four procedural questions presented — forfeiture, the Amada conflict, and access‑to‑justice consequences — and takes no position on the merits of the underlying detention claim or on Mr. Montgomery personally.
No further obligation beyond the cert stage. If certiorari is granted, the Petitioner will remain pro se on the merits and will not seek amicus counsel for merits briefing. Your filing concludes when the Court rules on the petition.
Your Interest of Amici Curiae section is yours alone. It is the only section your office must author, and it is the section in which your institutional voice, mission, and reasons for filing are stated in your own words.
Minor edits to the brief, or replacement with your own, are equally welcome. The three pathways above are not a hierarchy — an organization that signs as drafted, an organization that recasts entire sections, and an organization that files independently are each making the same contribution to the Court.

Before You Sign

A senior attorney's natural next question.

The Court of Appeals' opinion devotes its first two pages to a footnote cataloging Mr. Montgomery's prior litigation. A careful reviewer will encounter that footnote before reading anything else. The Record is the deep‑dive page documenting why the prior Walmart litigation has nothing to do with this Best Buy case — including the diametric‑distinctions table, a chronology of all four prior proceedings, and primary‑source PDFs. The cert questions are independent of any of this; the page exists so amici reviewing the file can confirm that for themselves.

It also gathers, with deep links into the live consolidated briefing PDFs, every passage in which Plaintiff has himself directly refuted the “lawsuit scammer” framing on the record — from the Response to Defendant's MSJ, through the centerpiece MFR § II (six pages devoted entirely to the question), the Attorney Fees Response § II, and the Court of Appeals Opening Brief § III. Across roughly eighteen months and five separate filings, none of these passages has been engaged in any opinion in this case.

Read the Record → Skip to "From the Record Itself" → About the Petitioner

Filing Logistics

What the rules require, in plain English.

Below is a working checklist drawn from C.A.R. 29, 32, and 53. This is not legal advice; your office should independently confirm compliance. The unsigned draft already meets each requirement—but if you modify or replace it, you'll need to re‑verify.

Timing & Deadline

Filing mechanism: Per C.A.R. 53(g), file by motion for leave (with the proposed amicus brief attached).
Petition will be filed: On May 28, 2026.
Amicus brief deadline: June 4, 2026 (one week after the petition). Earlier is better, but not before May 28, 2026.
The court grants leave (or not) at its discretion; promptness signals that your brief will be useful at the cert stage.

Required Contents (C.A.R. 29)

Cover page with case caption and party identification.
Interest of Amici Curiae—the only section your organization must rewrite.
Argument section (already drafted).
Certificate of Compliance and Certificate of Service.

Length & Format

Word limit: 3,150 words at the cert stage (per C.A.R. 53(g)). The unsigned draft uses 3,122 words.
Format: All C.A.R. 32(a) requirements (page size, margins, font, line spacing) apply.
Certificate of Compliance: Required under C.A.R. 32(h).
Unsigned draft already complies with all of the above.

Where & How to File

Filing system: Colorado Courts E‑Filing (CCEF).
Caption: "Brief of Amici Curiae in Support of Granting Plaintiff's Petition for Writ of Certiorari."
Service: All parties (Petitioner pro se & Defendant's counsel—addresses below).
Leave of court required: Per C.A.R. 29(a), an amicus may file a brief only by leave of court or at the court's request — party consent alone is no longer sufficient.
Motion contents: Per C.A.R. 29(b), the motion for leave must (1) identify the movant's interest and (2) state why an amicus brief would be helpful to the court. The proposed brief must be conditionally filed with the motion, unless the court grants leave to file the motion without the brief.

Service Information

For your Certificate of Service.

Petitioner

William Montgomery, Pro Se

2443 S University Blvd # 129
Denver, CO 80210

(970) 412‑5463

william@bestbuyamicus.com

Defendant‑Appellee's Counsel

Lori K. Bell · Sarah K. Vogel

Montgomery | Amatuzio
720 S Colorado Blvd, Suite 1200‑N
Denver, CO 80246

T: (303) 592‑6600
F: (303) 592‑6666

lbell@mac-legal.com
svogel@mac-legal.com

Reach Out Before You File

A short heads‑up is all the Petitioner asks.

If you are considering filing in any of the three pathways above, a brief email lets the Petitioner coordinate, share any updates, and avoid duplicative arguments across multiple amici. It is not required, but it is appreciated.

Email the Petitioner

william@bestbuyamicus.com · (970) 412‑5463

Not Filing Yourself?

Know a Colorado civ‑pro professor or appellate practitioner who should see this?

One click opens your email client with a short, pre‑written message. Just add their address and send.

Forward to a Colleague

Become an amicus curiae.