Complaint No. 1763580048 - 1500641492

Andrew Mark Staples
6450 South Revere Parkway
Centennial, Colorado 80111

Reporting Authority

This complaint has been forwarded to the Colorado Bar Association

Statement

The complainant respectfully submits this statement to report attorney misconduct arising from the attorney’s violation of constitutional and statutory disclosure duties. The attorney engaged in the destruction of material evidence that was reasonably foreseeable to be relevant to the defense, thereby impairing the ability to obtain a fair adjudication. Further, the attorney failed to disclose exculpatory and impeachment material, and its progeny, despite possessing information that directly undermined the credibility of key allegations and supported alternative factual conclusions favorable to the accused. During judicial proceedings, the attorney presented representations to the court that omitted critical facts and thereby misled the presiding judge concerning the existence, condition, and nature of the suppressed evidence. Such conduct constituted an obstruction of justice by impeding lawful fact-finding, frustrating the court’s supervisory role, and interfering with the respondent's constitutional rights to due process and meaningful confrontation. The suppressed and destroyed evidence - had it been disclosed - would have materially affected investigative decisions, strategic preparation, and the ability to test the veracity of the State's theory.