Marriage of Zunker

── Marriage of Zunker ── Court: Colorado Court of Appeals Date: May 14, 2026 Category: General 25CA1989 Marriage of Zunker 05-14-2026 COLORADO COURT OF APPEALS Court of Appeals No. 25CA1989 City and County of Denver District Court No. 11DR4141 Honorable Adam J. Espinosa, Judge In re the Marriage of Derek Zunker, Appellee, and Sabrina Zunker, Appellant. APPEAL DISMISSED IN PART, ORDER AFFIRMED, AND CASE REMANDED WITH DIRECTIONS Division I Opinion by JUDGE FOX J. Jones and Dunn, JJ., concur NOT PUBLISHED PURSUANT TO C.A.R. 35(e) Announced May 14, 2026 Sherr Puttmann Akins Lamb PC, Tanya L. Akins, Denver, Colorado, for Appellee Sabrina Zunker, Pro Se ¶1 In this post-dissolution of marriage proceeding involving Derek Zunker (father) and Sabrina Zunker (mother), mother appeals from the district court’s adoption of the magistrate’s order effectively denying her pro se motion seeking the magistrate’s recusal. We dismiss mother’s appeal in part and otherwise affirm. We also award father his appellate attorney fees under section 13-17-102, C.R.S. 2025, and we accordingly remand the case for the district court to determine the reasonable amount of father’s attorney fees. I. Background ¶2 The parties’ three-year marriage ended in 2012. They are the parents of one child. ¶3 The parties originally shared equal parenting time. In November 2017, a district court magistrate awarded father sole decision-making responsibility and modified parenting time, with father becoming the majority-time parent. In October 2020, mother’s attorneys withdrew from the case. ¶4 Since October 2022, mother has engaged in a persistent campaign of filing largely meritless pro se motions and other requests for relief with the district court. In all, mother filed more 1  than twenty-five motions and other requests for relief between October 2022 and September 2024. ¶5 Given mother’s barrage of pro se pleadings, in January 2024, father moved to enjoin her from filing additional pleadings as a pro se party. After holding a hearing, a district court magistrate granted father’s motion and prohibited mother from filing any further motions or other requests for relief without an attorney. ¶6 The magistrate cited mother’s numerous filings and found that her conduct had been “egregious and harassing” because she had been “us[ing] the judicial process to disrupt [father]’s life” and was causing him to incur significant legal costs. The magistrate also found that most of mother’s pro se filings did “not contain legal authority, misstate[d] facts, and [were] repetitious.” Similarly, the magistrate observed that mother “simply appeals every [m]agistrate [o]rder [to the district court] as a matter of course,” and that the arguments in her multiple petitions for review were “often unclear, overlapping, circular, and recycled.” ¶7 Mother unsuccessfully petitioned for district court review, and another division of this court later affirmed in In re Marriage of Zunker, (Colo. App. No. 25CA0123, Oct. 23, 2025) (not published 2  pursuant to C.A.R. 35(e)). That division agreed that mother’s filings were often meritless, given that they did not contain relevant legal authority, were repetitious and circular, and otherwise contained numerous arguments taken from previously denied motions. Id. at ¶ 19. ¶8 In January 2025, father also obtained an award of approximately $80,000 in attorney fees against mother under section 13-17-102 arising from her numerous frivolous filings. That award of attorney fees has since been affirmed by a different division of this court in In re Marriage of Zunker, (Colo. App. No. 25CA1431, May 14, 2026) (not published pursuant to C.A.R. 35(e)). ¶9 Undeterred by