"Granting such requests would jeopardize Mr. Holmes' constitutional rights to due process, a fair trial, to be presumed innocent, and to a fair and impartial jury," the document says.
Judge William Sylvester apparently disagreed, deciding to allow 2 cameras during Holmes' arraignment. One will be allowed to record video and another will be allowed to take still photos. No audio can be recorded.
Holmes is charged with multiple counts of murder and attempted murder in the July 20 shootings at a suburban Denver movie theater. Twelve people were killed and 70 were injured.
Holmes is scheduled to enter a plea during an arraignment hearing on March 12. Arraignments and initial appearances are the only pretrial hearings in which cameras are allowed in courtrooms under Colorado law.
Cameras were allowed in court during his July 23 initial appearance.