The respondent, State of Utah, hereby waives the right to file a brief in opposition to the petition for writ of certiorari in the above-referenced case pursuant to rule 50(d), Utah Rules of Appellate Procedure. This waiver does not constitute a stipulation that the petition should be granted, but rather, it is respondent's position that the petition should be denied based upon the legal analysis contained in the State's brief and the lower court's opinion, copies of which are attached to this letter. In the event that the Court deems an additional response by the State necessary to its determination, a brief in opposition will be provided.
Public record document (some rights may be reserved).
Legal Brief, Valasquez v. Utah, No. 910195 (Utah Supreme Court, 1991).