Ms Gutierrez-Reed's lawyers laid the blame at the feet of Mr Baldwin, who they argued violated basic safety.
"The first event that had to happen is the actor Alec Baldwin pointed a gun on that set and he either had his finger on the trigger and the hammer cocked or he pulled the trigger," attorney Jason Bowles said.
Court submissions show assistant director David Halls, who handed the gun to Baldwin, did not know the gun contained live ammunition, and indicated it was unloaded by shouting "cold gun!"
Sante Fe County Sheriff Adan Mendoza said police had recovered 600 pieces of evidence so far - including three firearms and 500 rounds of ammunition.
He (Baldwin) also says he "didn't pull the trigger" of the gun during the incident, and adds: "Someone put a live bullet in a gun. I know it's not me."
The arguments regarding who did what, when, are not relevant to my opinion regarding the lack of basic firearms safety procedures on this film set. It is a fundamental rule that no live ammunition is allowed on any film set where firearms are used unless very specific safety procedures are observed. No ifs or buts. It is the responsibility of the armourer and the producer to make sure procedures are in place to enforce this rule. This has been the case on any film set that I have been on. There are various organisations around the world that promote certain standards in the film and television production industries. I would think that most of them have a clause in their mission statement that promotes or even requires certain standards of health and safety from their members, and I would urge all of them to review their requirements regarding the use of arms and ammunition on film and TV productions. Perhaps the closest to a list of suggested rules is that published by the American Labour Management and Safety Committee.