Colorado

Civil Procedure

Rule 251.15 – Answer-Filing, Failure to Answer, Default

(a) Answer. Within 21 days after service of the citation and complaint, or within such greater period of time as may be approved by the Presiding Disciplinary Judge, the respondent shall file an original and three copies of an answer to the complaint with the Presiding Disciplinary Judge and one copy with the Regulation Counsel. In the answer the respondent shall either admit or deny every material allegation contained in the complaint, or request that the allegation be set forth with greater particularity. In addition, the respondent shall set forth in the answer any affirmative defenses. Any objection to the complaint which a respondent may assert, including a challenge to the complaint for failure to charge misconduct constituting grounds for discipline, must also be set forth in the answer.
(b) Failure to Answer, and Default. If the respondent fails to file an answer within the period provided by subsection (a) of this Rule, the Regulation Counsel shall file a motion for default with the Presiding Disciplinary Judge. Thereafter, the Presiding Disciplinary Judge shall enter a default and the complaint shall be deemed admitted; provided, however, that a respondent who fails to file a timely answer may, upon a showing that the failure to answer was the result of mistake, inadvertence, surprise, or excusable neglect, obtain leave of the Presiding Disciplinary Judge to file an answer.

Notwithstanding the entry of a default, the Regulation Counsel shall give the respondent notice of the final hearing, at which the respondent may appear and present arguments to the Hearing Board regarding the form of discipline to be imposed.

Thereafter, the Hearing Board shall review all pleadings, arguments, and the report of investigation and shall prepare a report setting forth its findings of fact and its decision as provided in C.R.C.P. 251.19.

If, however, after the entry of default neither the respondent nor Regulation Counsel timely requests a hearing before the Hearing Board, then the sanctions hearing shall be held solely before the Presiding Disciplinary Judge.

C.R.C.P. 251.15

Source: Amended and adopted June 25, 1998, effective January 1, 1999; b amended and adopted September 30, 2004, effective January 1, 2005; a amended and adopted December 14, 2011, effective January 1, 2012, for all cases pending on or filed on or after January 1, 2012, pursuant to C.R.C.P. 1 b.

This rule was previously numbered as 241.13.

Annotation Annotator’s note. The following annotations include cases decided under former C.R.C.P. 241.13, which was similar to this rule. Both the charges and the well-pleaded facts are deemed admitted by the entry of a default judgment. People v. Richards, 748 P.2d 341 (Colo. 1987); People v. Young, 201 P.3d 1273 (Colo. O.P.D.J. 2008 ). The allegations of fact were deemed admitted where attorney did not answer the complaint filed in the case and the hearing board entered a default against him. People v. Davies, 926 P.2d 572 (Colo. 1996); In re Demaray, 8 P.3d 427 (Colo. 1999). A motion to set aside a default because the respondent failed to file a timely answer under this rule can be analogized to a motion under C.R.C.P. 60(b)(1). The decision to grant relief is entrusted to the sound discretion of the trial court and will not be disturbed on appeal unless there is an abuse of discretion. In re Weisbard, 25 P.3d 24 (Colo. 2001). In a motion to set aside a default judgment, the movant bears the burden of proving the grounds for relief by clear, strong, and satisfactory proof. In re Weisbard, 25 P.3d 24 (Colo. 2001). Because an attorney has a duty to cooperate with disciplinary proceedings, default judgments are not subject to being set aside easily. In re Weisbard, 25 P.3d 24 (Colo. 2001). In setting aside a default judgment on the grounds of excusable neglect, the court must determine: Whether the neglect causing the default was excusable; whether the movant has alleged a meritorious defense; and whether relief from the order would be equitable. In re Weisbard, 25 P.3d 24 (Colo. 2001). Failure to act because of carelessness and negligence is not excusable neglect. In re Weisbard, 25 P.3d 24 (Colo. 2001). Applied in People v. Moore, 681 P.2d 480 (Colo. 1984); People v. Stauffer, 745 P.2d 240 (Colo. 1987); People v. Jacobson, 747 P.2d 654 (Colo. 1987); People v. Dohe, 800 P.2d 71 (Colo. 1990); People v. Ashley, 817 P.2d 965 (Colo. 1991); People v. Rouse, 817 P.2d 967 (Colo. 1991); People v. Barr, 855 P.2d 1386 (Colo. 1993); In the Matter of Scott, 979 P.2d 572 (Colo. 1999).