Beruflich Dokumente
Kultur Dokumente
Synopsis
The principles embedded in our partys platform form the foundation for this
contest.
Honest elections are the foundation of representative government
Every time that a fraudulent vote is cast, it effectively candles out the vote
of a legitimate voter.
We call on every citizen, elected official, and member of the judiciary to
preserve the integrity of the vote.
We recognize that having a physical verification of the vote is the best way
to ensure a fair election. Let ambition counter ambition, as James Madison
said. When all parties have representatives observing the counting of ballots
in a transparent process, integrity is assured.
Indeed, the fundamental purpose of the Convention Rules, rules of order and the
credentialing process is to ensure the integrity of the elections of delegates
permitted to vote at the Convention. Through its pervasive, knowing, and continued
violations of its bylaws, the April 9 Convention standing meeting rules, and state
laws, the Colorado Republican Party conducted an eminently unfair election of
delegates.
The flawed election results are marred by both unintentional material errors,
flagrant violations, and conscious bias on the part of the CRC to benefit the official
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Cruz slate. That 16-member official slate won all 13 delegate seats and the top
three alternate seats, and benefitted from the CRCs favorable treatment and from
the ensuing confusion and chaos.
National media exposed the chaotic and highly irregular balloting practices during
Colorados April 8-9 Congressional District and State Conventions. Exhibit 1.
Hundreds of voting delegates left the conventions disgusted by the practices
employed, knowing that the partys principles of fair elections had been
compromised.
Despite the purported large margins of victory of the official Cruz slate delegates,
the error-riddled election must not be permitted to stand. To fail to decertify the
delegation would make a mockery of the RNCs election standards, and would
reward election manipulation. The Contestants do not claim to be the sole rightful
delegates for the five seats in which they seek to serve. Instead, they are
representatives of the hundreds of candidates who were disenfranchised, or harmed
by the unequal treatment from the party, or who were negatively impacted by
material errors in the balloting process that cause the true will of the state
convention delegates to be unknowable. The rightful owners of any of the delegate
seats is undeterminable because of the flawed processes employed.
Through this Statement of Position the Constants have presented abundant
evidence of election irregularities (Rules and bylaws violations) that calls into
question the results of the Convention election. Important additional information,
needed for a full assessment by this Committee, has been improperly withheld from
the Contestants.
First, the balloting processes violated the most fundamental election bylaw
requirement to print names and affiliation of candidates on the ballot. Once the
State Party decided to circumvent this basic ballot format rule by only printing
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convention fees.
Fifth, the wrongful certification of the at-large delegation was a willful act by State
Party officials, who were engaged in a pattern of deceptive certifications of
Congressional Districts 2,3,4 and 5. The above four issues also plagued the
Congressional District delegate elections of the preceding day, April 8, where fraud
has been credibly demonstrated in one district. Numerous complaints and protests
have been filed with the state party and the Executive Committee, which refused to
investigate or refer the alleged fraud to the Attorney General. False certifications
were made in CDs 2,3,4 and 5 where the conventions delegates were precluded
from objecting to irregularities as no Tellers report was permitted.
Sixth, the rights of the members to object and attempt corrections during the
meeting was obstructed as essential, required parliamentary procedures and
meeting rules were ignored.
Seventh, the cumulative weight of numerous other subsidiary and related violations
of rules and laws combined to exacerbate an unfair and unverifiable election.
The CRCs pervasive violations of state law, rules and bylaws created an
environment in which no fair and proper election result could be achieved. The RNC
must not condone elections where governing rules and fairness are abandoned for
political gains.
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Statement of Position
June 22, 2016
Facts
A. Names and pledged status were not printed on the face of the ballots
The failure to meet the most basic ballot layout requirements and related
rules and bylaws created a fatal flaw from which the election could not recover.
Fundamental election principles and CRC Bylaw Article XIII 5c require that the
ballot include on its face the presidential candidate pledge for each delegate
candidate or indicate that the candidate is unpledged. The April 9, 2016, State
Convention Rules (CO Rules) (Exhibit 2) also require that the ballot shall include
the presidential preference of those so pledging. (CO Rule 7.4(b)) Ballots must
include the name of the candidate to reduce risk of error, voter confusion, and fraud.
CRC officials made the affirmative decision to exclude the candidates required
names and pledged information from the face of the at-large state ballots and CDs
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2, 3, 4, and 5 ballots. The at-large ballot contained only target areas for voting
(ovals) and a series of numbers 1 through 948 (Exhibit 1) assigned to 636
candidates. The resulting confusion, errors, misprinted official candidate lists, and
misprinted campaign materials, and unequal treatment of candidates as described
herein created a materially inaccurate and flawed election.
No supplemental ballot lists can mitigate for excluding the candidates
name on the face of the ballot. The lists can be, and were in this case, incomplete,
misprinted and unavailable to voters. Campaigns can harm targeted delegates
intentionally or unintentionally by misprinting the candidate number on campaign
materials.
In a failed attempt to compensate for the improper and purposeful exclusion
of candidate names from the ballot, the convention program listed the candidates
through number 588. This program was distributed at credentialing. An additional
ballot supplement booklet listing 595 candidate names, pledged information, and
ballot numbers was distributed to all delegates during balloting. A third one-page
ballot supplement addendum with similar information for additional candidates
who were purportedly excluded from the ballot supplement booklet was distributed
separately during ballot issuance. A fourth supplemental list of ballot numbers was
projected on the screen for a brief period, after ballots had been distributed and
voting had begun. A fifth list of 7 selected candidates and ballot numbers left out of
the program was projected on the convention screen. CRCs failure to disclose the
names of 48 candidates until just as voting began gave unfair advantage to the
Respondents.
To date, Contestants have located nine different official ballot lists and
supplements, none of which are have identical candidate information. The voter
confusion created was obvious to all concerned, including CRC officials. (It should be
noted that the candidate information for the 16-member Cruz slate Respondents
was not changed or omitted from the official lists after April 4.)
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Duplicate
Ballot #
15 & 617
326 & 599
411 & 601
440 & 605
532 & 607
LAST
Bamber
Martinez
Piper
Rendleman
Tonkins
FIRST
Robert
Solomon
Barbara
Kay
Vickie
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8 votes separated the 13th delegate from the 2nd alternate. Only 7 votes separate
the 4th alternate from the 5th alternate. These are but a few examples of the close
reported vote tallies as further detailed on the Election Summary (Exhibit 3
[provided by link in the paper copy of this complaint.]) http://cologop.org/wpcontent/uploads/2016/01/2016_ElectionSummaryReport-National-Delegate-by-Votetotals.pdf
Given the pervasive errors and tabulation questions, it is likely that results
are in error, but accurate results are unknowable. It is likely that some
Respondents have been improperly certified as delegates because of the material
errors in the election process. It is impossible accurate measure the quantitative
material impacts on candidates, alternates, and delegates vote counts.
The vote total summary discloses 136 votes were counted for invalid
ballot numbers higher than 636, which were not associated with a candidate. The
ballot contained 948 numbers and oval target areas, 312 of which were ineligible
but permitted recording of votes. These votes were improperly counted although
there was no candidate associated with the ballot number. One-third of the ballot
was invalid, but marks on the invalid area were counted, presumably creating
invalidated over-voted ballots. The delegates and alternates officially elected were
elected with vote tallies between 380 votes and 2,272 votes; therefore, the anomaly
of 136 votes became a material irregularity that likely impacted the close, thinmargin election outcomes. As an example, 41 votes were counted for nonexistent
candidate #948, but those votes were likely intended for eligible candidates. 22
votes were counted for nonexistent candidate #777. These material counts
suggest software or ballot scanning problems.
Tallies for unassigned ballot numbers suggest the lack of names on the
ballots, multiple, confusing ballot supplements, and 312 excess ballot numbers on
the ballot caused voter confusion and mismarked ballots. Given the material
percentage of over-voted ballots (82) and the 136 votes for nonexistent candidate
numbers, questions have been raised as to the accuracy of the ballot scanning and
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9. CRC and EPCO made no attempt to investigate the excess invalid votes
counted for unassigned numbers, to reprint the ballots, reprogram the
software, repair the ballot scanner, print a complete and accurate candidate
list, etc. in order to avoid repetition of the balloting errors the following day
for the at-large election. CRC and EPCO had a full business day after
material flaws were exposed early on April 8 and chose not to address the
similar known errors and predictable failures for the April 9 at-large election.
The decision to repeat and not correct the known April 8th
noncompliant and failed processes indicates that the CRC, House, and EPCO
knowingly permitted the April 9th at-large election to be flawed by the same
violations.
Additional facts. The allegations, details and exhibits in the Notice of
Contest filed June 18, 2016 are incorporated herein and provide some
additional detail on important, yet subsidiary issues. An electronic copy of
the filing can be located at https://www.scribd.com/doc/316124613/Challengeof-Colo-At-Large-Delegates-Amended-6-18-16.
Representatives affidavit (Exhibit 16)
II.
Discussion
This action seeks to set aside the flawed election to find a more equitable
result, and seeks to assure Colorado voters that reckless and materially noncompliant elections will not be tolerated by the party. The election was conducted
with pervasive disregard for the fundamental principles of election fairness and
legal compliance, resulting in an election that is incapable of authentication or
verification. Such elections must not be allowed to stand in seating delegates to the
National Convention, given the critical nature of the decisions to be made there.
Seating delegates chosen by illicit means and willful wrongdoing invites a public
disrespect of the Convention, and its legitimacy, and creates a chilling effect on
candidates and delegates in future delegate elections.
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III.
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CRCs wilful failure to act in good faith and to apply reasonable care and
judgment in planning and conducting the election should subject the party to
sanctions and penalties to be determined by the Committee. Respondents who are
members 16 members of the Cruz official slate should be subject to sanctions for
seeking and accepting CRCs favored treatment, taking advantage of known
violations of the party rules.
Porter, Fore, Alexander, and Gamache should be declared as delegates to the
convention, taking the place of delegates ranked 9, 10, 11, and 12 in revised vote
totals, once the Committee can obtain information to refine vote totals.
We request that one additional delegate (with 13th vote ranking) be
decertified and replaced by one other candidate as a representative of the 610
candidates who were treated less favorably than the Respondents. Such a delegate
could be selected from another slate. We further request such additional relief that
the Committee on Contests deems appropriate to assure a more equitable
representation in Colorados delegation, and appropriate sanctions and penalties to
ensure that CRC is not motivated to repeat the manipulative election practices.
Respectfully submitted,
Marilyn Marks
Non-attorney representative for the Contestants
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Exhibit 1
CONTRIBUTION
Colorados Convention
Craziness Could Cause
Chaos in Cleveland
Apr. 11, 2016 12:24pm
Jennifer Kerns
Jennifer Kerns is a branded contributor to The Blaze and other publications
where she writes about the 2nd Amendment, religious liberty, the future of the
GOP, limited government battles and other political hot topics. She served as
Spokeswoman for the historic Colorado recalls, as Spokeswoman for the
California Republican Party, twice as an Appointee of Governor Arnold
Schwarzenegger, and as Spokeswoman for Prop. 8 which went all the way to the
U.S. Supreme Court.During her career as a GOP strategist, she has been
described as one of the most relevant Press Secretaries in the West -- winning
every major newspaper endorsement for her candidates. Proud of her ability to
win over tough liberal reporters and coalitions, she made her mark by being the
first known Press Secretary in history (Republican or Democrat) to win 52
unanimous endorsements from such liberal publications as the Los Angeles
Times, San Francisco Chronicle and the Spanish-language La Opinion
arguably among the toughest Press Corps, in the most populous State in the
nation.
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Just as in caucus states Iowa and Wyoming before them, Coloradans over
the weekend solidified their delegates who will advance to the Republican
National Convention in Cleveland this summer.
Ted Cruz swept all of the states delegates.
But accusations swirled on Saturday with photo proof by convention
attendees suggesting that Donald Trump delegates were left off of ballots,
Cruz delegates were placed on ballots twice, ballot numbers for some
delegate candidates were wrong, and the Republican Party admitted that at
least one delegates paperwork may have been lost, costing him an
opportunity to become a delegate.
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Patriots against the Iran nuclear deal in front of the Capitol in Washington, DC, on
September 9, 2015. Nicholas Kamm/AFP/Getty Images
To make matters worse in the sharply divided primary season, as the
convention drew to an end the official account of the Colorado GOP
published a tweet that read, We did it. #NeverTrump. It appeared to
suggest the Republican Party was glad that Trump had been shut out.
The tweet was sent out at 8:07 p.m. local time and then deleted within
minutes.
The tweet is problematic primarily because it included the divisive Never
Trump phrase created by a wing of the party who has stated they would
rather vote for Hillary Clinton, a Democrat, over Trump.
It is also problematic because state parties are required to support all GOP
candidates equally during a primary season and to serve as an unbiased
adjudicator at caucuses and state conventions.
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delegation from being seated at the RNC convention. After all, Trump says
if the delegates were won by fraud or administered by a party that was in
the tank for Cruz, the votes should be discounted.
After Cruzs surprise blowout in Wisconsin last week and Cruzs clean
sweep of Colorado, the delegate math now shows that Cruz may be able to
keep Trump from achieving that magic number of 1,237 delegates after all.
With another loss handed to them, on Sunday it appeared that Trumps
campaign began doubling down on convention strategy a sign that Trump
may be giving up on his effort to win any more delegates and instead focus
on wining and dining delegates in the lead-up to the convention.
As if that werent enough, top officials from Colorado over the weekend
began to talk of an open convention.
U.S. Sen. Cory Gardner said that Cruzs success in Colorado continues
the momentum he gained in Wisconsin and leads to an open convention.
A party operative who agrees with that is Andrew Boucher, Gov. John
Kasichs newly-hired convention strategist who was spotted at the
Colorado convention on Saturday. I shadowed Boucher briefly as he made
the rounds briefing reporters on the possibility of an open convention and
even running through various scenarios with them including the fact that
80 percent of delegates become unbound and can suddenly vote for
whomever they want if the RNC nomination process makes it through a
second ballot.
Whatever the outcome at the RNC convention this summer, one thing is
certain: the road to Cleveland just went right through the bumpy roads and
the oh-so-Rocky Mountains of Colorado.
TheBlaze contributor channel supports an open discourse on a range of
views. The opinions expressed in this channel are solely those of each
individual author.
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Breitbart.com
EXCLUSIVE: Colorado County GOP Chair: Errors with Ted Cruzs
Delegate Win, Might Need Do-Over
11543
http://www.breitbart.com/2016-presidential-race/2016/04/25/colorado-3/
33
AP/Brennan Linsley
by PATRICK HOWLEY25 Apr 20165,546
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The Trump supporters think that the Cruz supporters stole the
election. The Cruz supporters were very concerned that they
might not get seated in Cleveland so they have been publicizing
that the Trump campaign does not plan to contest the results,
Cage said. But those delegates could still be un-seated by the
Republican National Committee.
If its that bad, I guess if theres any question that our delegates
wont be seated, then that would be a case where it might make
sense to have a do-over, Cage said. I would say it would. It might
be the better way to go just to make sure that our delegates, they
ought to be able to go forth and get seated.
I think they were mostly, from what I saw, clerical errors. To me,
its inexcusable The ballots themselves had names missing.
People who had signed up.
It seemed to happen in all of the districts. So I guess the state has
something to do it because it was up to the state who received
those forms There were many people at the state convention
itself who they had to say, well this person was this number and it
doesnt appear that way in the book. It just wasnt clean It
wasnt clean because of those clerical mistakes, Cage added.
Cage indicated that she is not a Trump supporter, but rather a
Cruz supporter simply concerned with electoral integrity, saying,
As a county chairman I cant publicly declare. I do have a favorite
Well, I was standing up by the stage when [Cruz] was up there.
Cage sent an email expressing her concerns to fellow party chairs
last Tuesday.
Changing the process by which we get to counting votes wont
change the perception of fraud, Cage wrote. There were
problems with the election in Colorado Springs:
1 Many people who had filed their Intent to Run for National
Delegate forms were not put on a ballot.
2 Clerical errors created the perception of fraud (duplicate and
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Colorado was Cruz Country on April 9th as Senator Ted Cruz completed his
sweep of Colorado delegates. However, the Trump campaign took note of a
multitude of irregularities.
Alan Cobb, a senior advisor to the Trump campaign told Politichicks that they
are not ruling out contesting Colorado delegates. We are gathering all the facts
and documenting everything, Cobb said.
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While the day was a big win for Cruz, the convention itself was riddled with
problemsincluding disenfranchisement of candidates for national delegate.
Some candidates were missing from the ballot. Others were included on the
ballot twice. One U.S. Senate candidate was missing from the ballot.
Numerous irregularities surfaced before the convention from violating party
bylaws to withholding information on convention rules.
Here is a detailed breakdown of some of the issues:
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Five candidates were given two different numbers because they were included
in the original list and on the corrections list.
Two delegates had numbers missing from the ballot itself. Instead, it
contained two numbers with duplications. (378 was listed in place of 379;
523 was listed in place of 513.)
Some candidates who stated they filed their letters of intent were never placed
on the ballot or on the corrections list.
Candidates for national delegate were also disenfranchised at the Congressional
Assemblies and Convention. Attendees across all seven congressional
assemblies and conventions reported that candidates who submitted their
correctly filled paperwork on time were missing from the ballots.
Ten names were missing from the ballot for Congressional District 5 (CD5)
including one member from the officially endorsed Cruz slate. A motion was
approved for all the candidates missing from the ballot to be given ballot
numbers which were then posted on an easel.
In contrast, Congressional District 3 (CD3) did not provide numbers for
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candidates missing from the ballotthough the issue was addressed at the
meeting. When approached after the conclusion of the meeting regarding how
many national delegate candidates from CD3 were missing from the ballot, the
CD3 chair admitted, I have no clue.
The CD lists of candidates are generated by the state party based on letters of
intent submitted by those eligible to run. Some candidates on a previous
version of the list found their names missing from the updated list.
Delegates were shut out from participating in the process at the State
Convention. Process irregularities included an absence of microphones on the
convention room floor, discouraging delegates from calling out points of order
and points of information as per Roberts Rules of Order. Attendees of the
Congressional Assemblies and Conventions report that microphones were
available at their respective meetings.
The State GOP violated party bylaws related to the State Central
Committee (SCC) meeting that covered agenda items related to the State
Convention. The day prior to the State Convention, the State Central
Committee (SCC) convened a meeting to discuss convention issueswith less
than a weeks notice to central committee members in violation of state party
bylaws. The state GOP sent out the notice as an amended call, however there
was no original call to amend. This was confirmed by several SCC members.
At the meeting, SCC members did not receive copies of the Standing Rules
for the State Convention. A delegate who was not a member of the SCC was
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Screen shot of Colorado GOP Web site on day of convention. No link to standing rules for State
Convention.
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nbcnews.com
6/21/16, 1:31 AM
COLORADO SPRINGS, Colorado Sen. Ted Cruz finished Colorado's delegate fight the way he
started it: With overwhelming victory.
Donald Trump finished it the way he started as well: With a disorganized and frustrated campaign
plagued by mistakes.
Cruz took all 13 of the delegates up for grabs on Saturday to complete a clean sweep of the state.
Delegates endorsed by his campaign swept all seven congressional district conventions held over
the last week as well, which added another 21 delegates. Another three slots are reserved for state
party ocials.
"Today was another resounding victory for conservatives, Republicans, and Americans who care
about the future of our country," the Cruz campaign said in a statement Saturday night.
Trump's aides set expectations at rock bottom heading into Saturday's contest, citing the state's
unfavorable demographics and a complicated process that empowers local party activists to vote
on delegates.
Supporters in Colorado nonetheless said they were frustrated with the campaign's chaotic and
uncommunicative campaign, which failed to reach basic levels of competence.
"We could have had some things going, but the campaign decided to not put resources here,"
Becky Mizel, a former Pueblo County GOP chair and Trump delegate candidate, told NBC News.
Related: Trump's Colorado Supporters 'Feeling Demoralized' as He Battles Cruz
On Saturday, Trump backers passed out flyers at the convention site with ocial campaign slate of
13 delegates and 13 alternates accompanied by their three-digit number position on the 600-plus
person ballot. Seven of the names, however, directed people to the wrong number and one
delegate's name was misspelled. Other candidates did not have errors on their slates.
http://www.nbcnews.com/pages/print
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nbcnews.com
6/21/16, 1:31 AM
In one case, an erroneous number corresponded with a Cruz supporter. A second flyer handed out
by the Trump campaign contained four mismatched names and numbers.
Among the names listed incorrectly on both flyers: Becky Mizel.
Related: Bernie Sanders Wins Wyoming Democratic Caucuses
It was the second major error concerning campaign materials this week. On Thursday, a Trump
slate of three names in the 7th Congressional District convention contained two that weren't listed
on the ballot. The campaign's state director, Patrick Davis, said they failed to pay the necessary
fees to qualify.
Trump's campaign wasn't the only one who made mistakes, though. Colorado Republican
chairman Steve House announced several corrections to the ballot from the stage, including
multiple names that were on the ballot twice, none of which aected any candidate's ocial slate.
One Trump alternate, Jerome Parks, was not on the numbers-only ballot at #379 instead the
ballot listed #378 twice.
"They're not in there!" Trump supporter Karen Kasel said to herself in frustration as she tried to
find #379 on her ballot in the hallway.
Related: Cruz Swipes Delegates in Trump-Backed Virginia District
There were also discrepancies between delegate guides posted to the state party's website and
printed materials distributed by the state GOP. Mizel, for example, was listed on a delegate list on
the party website as number #610, but a brochure from the state GOP listing delegates
alphabetically cut o at #588.
Trump campaign aide Alan Cobb accused the Colorado GOP of altering its delegate lists at
dierent points, leaving them in the lurch as it changed, and threatened to dispute the results over
its ballot inconsistencies.
"We'll do whatever it takes to protect the legitimacy of our support in Colorado," Cobb told NBC
News. "Clearly there are some serious issues with the ballot and balloting.
A spokesman for the Colorado GOP said they were looking into the matter.
http://www.nbcnews.com/pages/print
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nbcnews.com
6/21/16, 1:31 AM
In another mix-up, the party's Twitter account appeared to be hacked in the aftermath of the
results, tweeting "We did it. #NeverTrump." A spokesman for the party said that their account had
been taken over and the tweet was not authorized.
Cruz's all-volunteer Colorado campaign distributed accurate slates not only on flyers, but also on
bright orange t-shirts. Groups like Gun Owners of America that endorsed Cruz distributed their
own materials backing the same slate.
Dustin Olson, a delegate whip for Cruz, manned a "persuasion team" in the halls of the arena. The
heavily pro-Cruz crowd needed little convincing, Olson said, but he worked hard to make sure no
one split the vote by supporting Cruz delegates who weren't on the campaign's ocial slate.
Cruz personally addressed the state convention on Saturday while Trump campaign and Ohio
Governor John Kasich supplied campaign surrogates on their behalf.
"It's easy to talk about making America great again, you can even print that on a baseball cap,"
Cruz said. "The real question is do you understand the principles and values that made America
great in the first place?"
Afterwards Cruz told NBC aliate KUSA that Trump's absence "illustrates that when it comes to
the grassroots, Donald has a very hard time competing."
Speaking on behalf of Trump, policy adviser Stephen Miller devoted nearly all his remarks to
recounting Americans who had been killed by undocumented immigrants.
http://www.nbcnews.com/pages/print
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nbcnews.com
6/21/16, 1:31 AM
Unlike Colorado, most of these fights are taking place in states where voters have already weighed
in on how many delegates are bound to each candidate, but where the state party has a separate
process for choosing the actual delegates.
The results are crucial because most
delegates are free to vote for any candidate
they choose in a contested convention that
goes beyond the first ballot.
Several states held delegate selection events
on Saturday, with Cruz's campaign continuing
his string of success in most cases but falling
prey to a surprise alliance between Trump and
Cruz shakes hands with supporters in Colorado on Saturday.
Stacie Scott / AP
Page 4 of 5
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nbcnews.com
6/21/16, 1:31 AM
In Michigan, though, Trump and Kasich supporters appeared to team up to deny Cruz any spots
on the important convention committees that will determine rules and credentials for delegates.
Trump supporters took five of eight slots, while Kasich supporters took the other three.
http://www.nbcnews.com/pages/print
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6/10/16, 11:19 PM
How Colorado
confusion could spell
convention trouble
Story by Maeve Reston; Video by Gabe Ramirez, CNN
Updated 9:51 AM ET, Mon April 11, 2016
Story highlights
Donald Trump's campaign is mad about the
delegate selection process in Colorado
The GOP front-runner says political insiders
are plotting against him
But that is the game that the GOP campaigns will be playing at the convention if no candidate reaches the 1,237
delegates needed to clinch the nomination before Cleveland.
READ: The Colorado delegate process has to be see to be believed
By Sunday, the Trump campaign had voiced a litany of complaints about Colorado's complex process, even
though it was obvious on the ground that they had not done the aggressive leg work to court Colorado delegates
that the Cruz team had done.
"I win a state in votes and then get non-representative delegates because they are oTered all sorts of goodies by
Cruz campaign. Bad system!" Trump tweeted Sunday.
http://www.cnn.com/2016/04/10/politics/donald-trump-ted-cruz-colorado-delegates/
Page 1 of 6
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Donald J. Trump
@realDonaldTrump
6/10/16, 11:19 PM
Follow
26,857
Later in the day, Trump took to Twitter again to protest the fact that Colorado did not hold a primary or a caucus,
due to costs, and inside used arcane party rules for choosing delegates.
"How is it possible that the people of the great State of Colorado never got to vote in the Republican Primary?"
Trump tweeted Sunday evening. "Great anger - totally unfair!"
Donald J. Trump
@realDonaldTrump
Follow
27,916
He also retweeted a link to a Facebook post where one of his supporters burned his Colorado Republican Party
registration over anger at the process at the Colorado state convention.
http://www.cnn.com/2016/04/10/politics/donald-trump-ted-cruz-colorado-delegates/
Page 2 of 6
Page 42
6/10/16, 11:19 PM
Donald J. Trump
Follow
@realDonaldTrump
#MakeAmericaGreatAgain
#Trump2016thegatewaypundit.com/2016/04/despit
3:23 PM - 10 Apr 2016
DESPITE LATEST MEDIA SMEAR=> Trump's Fa
A new Associated Press poll released today found
after months of media and GOP establishment
attacks a majority of Americans ...
thegatewaypundit.com
3,526
8,763
Then he declared: "The people of Colorado had their vote taken away from them by the phony politicians. Biggest
story in politics. This will not be allowed!"
Donald J. Trump
Follow
@realDonaldTrump
The people of Colorado had their vote taken away from them by the
phony politicians. Biggest story in politics. This will not be allowed!
8:50 PM - 10 Apr 2016
11,525
26,881
On NBC's "Meet the Press" Sunday, Trump's new convention manager Paul Manafort accused the Cruz campaign
of using "Gestapo tactics" to wrangle delegates.
Cruz campaign spokeswoman Catherine Frazier said the campaign had won "because we've put in the hard work
to build a superior organization," dismissing the complaints as sour grapes.
But it was the threat of a convention challenge over the ballot
problems in Colorado this weekend that is the kind of legal spat
that could lead to campaign-on-campaign legal warfare at the
convention.
http://www.cnn.com/2016/04/10/politics/donald-trump-ted-cruz-colorado-delegates/
Page 3 of 6
Page 43
TRUMP
presumptive
nominee
563
bound: 512
unbound: 51
CRUZ
KASICH
6/10/16, 11:19 PM
On the rst slate printed by Trump campaign for Saturday's election -- which detailed the names and ballot
numbers of 26 people who were running to be Trump delegates at the convention -- more than a half dozen
names were listed with inaccurate ballot numbers.
http://www.cnn.com/2016/04/10/politics/donald-trump-ted-cruz-colorado-delegates/
Page 4 of 6
Page 44
6/10/16, 11:19 PM
Donald Trump
to be Republican nominee
But the ballot distributed by the state party did include at least
one clerical error: There was no bubble on the ballot for
delegate candidate #379 (who was running as a Trump
delegate, according to the state party list). Instead in the spot
where #379 should have appeared, there was a second bubble
for #378 (who was running as an unpledged delegate).
Another wrinkle: Inside the convention program printed by the
state party, the list of candidates running for the 13 national
delegate slots (and their corresponding ballot numbers) only
went up to #588, even though there were 619 candidates.
The state GOP printed a supplemental ballot and placed the
http://www.cnn.com/2016/04/10/politics/donald-trump-ted-cruz-colorado-delegates/
Page 5 of 6
Page 45
99%
live odds
click to play
Powered by Pivit
6/10/16, 11:19 PM
http://www.cnn.com/2016/04/10/politics/donald-trump-ted-cruz-colorado-delegates/
Page 6 of 6
Page 46
Page 47
Exhibit 2
PROPOSED RULES
COLORADO REPUBLICAN STATE ASSEMBLY AND CONVENTION
April 9, 2016
Colorado Springs, Colorado
These Proposed Rules are submitted by the Committee on Rules appointed
by State Chairman Steve House as provided in Section B1e of Article V of
the Bylaws of the Colorado Republican State Central Committee ("CRC"),
and shall govern the conduct and proceedings of the 2016 Colorado
Republican State Assembly and Convention.
1. Organization
1.1 Delegates. The delegates and alternates to the Colorado Republican State Assembly ("the
Assembly") shall be the delegates and alternates to the Colorado Republican State Convention ("the
Convention"). The Assembly and the Convention hereinafter collectively are referred to as the
"Assembly and Convention."
1.2 Alternate Delegates. Alternate delegates moved into a delegate position due to the absence
of a delegate (see Rule 2.4) are considered delegates under these rules.
1.3
Quorum. A quorum at the State Assembly, and at the Convention, shall consist of those
delegates present. (State Bylaws, Art. XIII, G.)
1.4
Permanent Officers. The permanent officers of the Assembly and Convention shall be the
officers of the Colorado Republican State Central Committee, and the State Chairman may appoint
or designate such other officers, Committee Chairmen, and Committees as the State Chairman may
deem necessary for the operation and conduct of the Assembly and Convention. (State Bylaws, Art.
v, B.)
1.5
Committee Rules. Each Committee of this Assembly and Convention may each establish teller credential
such rules as it deems necessary for the conduct of its meeting(s), including rules relating to
matters to be considered and length of discussion.
1.6 Chairman Pro Tem. The permanent Chairman of the Assembly and Convention may
designate a Chairman Pro Tem to serve for brief periods during the absence of the permanent
Chairman. The term "Chairman" shall refer both to the permanent Chairman and any Chairman Pro
Tem.
1.7 Agenda. The agenda for the Assembly and Convention shall be printed in the Assembly and
Convention program and shall constitute general orders and the order of business for the Assembly
and Convention, except that the Chairman may recognize any person to address the delegates at
any time and for any purpose and may alter the order of business to facilitate the efficient conduct
of the business of the Assembly and Convention.
1.8
Adjournment. The Assembly and Convention may not be adjourned until the order of
business has been completed.
2. Credentials
2.1
Delegate Authentication. Each County Chairman shall provide a written list authenticating
all delegates and alternates elected by the county assembly to the Assembly and Convention,
together with their mailing addresses and zip codes and, where available, e-mail addresses, and
shall provide such list to the State Chairman as soon after the county assembly as practical, and
within (10) days of the county assembly. (State Bylaws, Art. XIII, B3.)
2.2
Contests.
(a) Every person intending to contest the seat of any delegate shall give written notice of such
intention, specifying the grounds of the contest, to the Secretary of the CRC and to the delegate
Page 48
whose seat he intends to contest. He shall give such notice at least seventy-two hours before the
Assembly and Convention convenes. (State Bylaws Art. XV, A4.)
(b) The State Central Committee shall meet at 7:30a.m. on Friday, April 8, 2016, at the Broadmoor
World Arena in Colorado Springs, Colorado, to hear any and all contests of persons claiming seats in
the Assembly and Convention and the recommendations of the Credentials Committee relating
thereto. (State Bylaws Art. XV, A2.)
2.3 Delegate Roll. The names of all delegates elected and uncontested shall be placed on the
temporary roll. All delegates who have been contested and whose names have been placed
upon the temporary roll by a majority of the CRC present and voting shall have the right to vote
on all questions until otherwise determined by the Assembly and Convention, except upon
contests involving their own credentials. (State Bylaws Art. XV, A3.)
2.4 Credentialing Required by 9:30 A.M./Voting by Alternates.
(a) Delegates and Alternates are required to be credentialed by 9:30a.m. on April 9, 2016.
(b) Any delegate who is not credentialed by 9:30a.m. may have his ballot given to the first
alternate of that county and continuing numerically thereafter, except in any county where an
alternate to the Assembly and Convention was elected to represent a designated district or
precinct. In such case, the designated district or precinct alternate shall be entitled to vote in the
absence of the delegate in accordance with the rules of the County Republican Party or the ruling of
the County Chairman.
(c) The decisions and rulings of the County Chairman regarding the promotion of alternates shall
be final.
3. Recognition, Identification and Motions
3.1 Recognition. The Chairman may recognize any person to make either an announcement or
a seconding speech for any candidate, except for candidates for National Delegate. Except as
specified in these rules or as may be necessary for the conduct of business the Assembly and
Convention, only delegates or alternates to the Assembly and Convention may be recognized.
3.2 Identification. With the exception of persons making announcements or a nominating or
seconding speech for any candidate, each person recognized by the Chairman for the purpose of
addressing the Assembly and Convention shall state his name, the name of his delegation, and that
he is a delegate or alternate to the Assembly and Convention, and the purpose for which he wishes
to be recognized. The Chairman may refuse to recognize or may terminate the remarks of any
person who fails to identify himself pursuant to provisions of this rule.
3.3 Written Motions and Amendments. All motions of substance and amendments thereto
shall be in writing, shall be signed by the maker thereof and shall be delivered to the Secretary or
the Chairman of the Assembly and Convention immediately after being made. Unless the Chairman
determines otherwise, no vote shall be taken on any motion or amendment until the written motion
or amendment has been delivered to the Secretary or the Chairman.
3.4 One Amendment at a Time. The Chairman shall permit only one amendment to a motion to
be considered at a time.
4. Debated Issues
4.1 Individual Time Limitation. Except as otherwise provided for in these rules, and except for
officers of the Assembly or Committee Chairmen, no person shall speak more than two minutes on
any debated issue or question, and no person shall speak more than once on each debated issue or
question. The determination as to time spent shall be made by the timekeeper of the Assembly and
Convention, and the determination of the timekeeper shall be conclusive. The timekeeper shall stand
at the end of each period, and the speaker shall end his remarks. In the event the speaker fails to
terminate his remarks, the Chairman may terminate the speaker's access to any microphone.
4.2 Aggregate Time Limitation. The time allotted to debate any issue or question, including all
amendments to motions and substitutions for motions shall not exceed an aggregate of ten
Page 49
minutes. At the end of such period, the Chairman shall call for a vote on such motions or
amendments as may be necessary without further debate or action by the Assembly and
Convention.
4.3 Alternating Comments. To the extent reasonably possible, the Chairman shall recognize in
alternating order persons who wish to speak in favor or in opposition to any debated issue or
question.
5. Demonstrations
5.1 Definition. The term "demonstration" shall be deemed to include all actions, such as
organized verbal or audible disruptions, clapping, waving and parading, which shall disrupt the
business of the Assembly and Convention.
5.2 Prohibition. Except as provided for in 7.2, demonstrations on behalf of, or opposed to, any
candidate or issue are prohibited. The Chairman, in his sole discretion, may charge the time
consumed by any such demonstration to the time otherwise allotted to the candidate or issue being
supported by such demonstration. No personal sound amplification devices or noisemakers shall
be allowed on the floor of the Assembly and Convention, in the facility, or on the premises, that
interfere with or disrupt the business of the Assembly and Convention.
6. Resolutions
6.1 Referral to the Resolutions Committee. Before any resolution shall be considered by the
Assembly and Convention, it shall be referred to the Resolutions Committee. All resolutions
proposed to be considered by the Assembly and Convention shall be submitted to the State
Chairman by March 23, 2016. The State Chairman shall refer all resolutions received by him by
5:00p.m. April 1, 2016 to the Resolutions Committee. (State Bylaws, Art. XIII, E.)
6.2 Consideration by the Resolutions Committee. The Resolutions Committee shall consider
all resolutions properly referred by the State Chairman. The Resolutions Committee shall provide
an opportunity for any person to speak for or against a Resolution at a meeting of the
Resolutions Committee held on March 21, 2016 and March 22, 2016, and at such additional dates
and times and by such means as the Resolutions Committee may provide. The Resolutions
Committee may create, amend, consolidate and/or combine duplicate and similar resolutions into
one Resolution for the efficiency of time and space, and may, but is not required to, consider
additional resolutions as may be submitted or referred by the State Chairman after April 1, 2016.
The Resolutions Committee shall report to the Assembly and Convention all resolutions approved
by a majority of the members of the Resolutions Committee. The Resolutions Committee may
establish such additional rules as it deems necessary for the conduct of its meetings.
6.3 Resolutions for Consideration. Only resolutions submitted in the report of the Resolutions
Committee as provided for in Rule 6.2 shall be considered by the Assembly and Convention.
6.4 No Amendment or Debate. No resolution may be amended or debated at the Assembly and
Convention.
6.5 Two-Thirds Vote to Pass. Resolutions concerning the Republican Party Platform or
concerning the position of the Colorado Republican Party with respect to matters of public policy or
public concern shall be deemed to be adopted only if approved by a two-thirds vote of the delegates
present and voting.
7. Nominations
7.1 Qualifications of Nominators. Only delegates to the Assembly and Convention may make
nominations for any candidate. Seconding and acceptance speeches may be made by any individual
recognized by the Chairman.
Page 50
Florence
Page 51
8. Ballots
Florence, in
normal
meaning this
would
suggest that
subtotals
were to be by
county as
well. ??
Page 52
interesting
Page 53
11.1 Appointment. By the adoption of these rules, the Assembly designates the Executive
Committee of the Colorado Republican State Central Committee as the Assembly Vacancy
Committee, and said Assembly Vacancy Committee is empowered to fill any vacancy that may occur
in designation or nomination for any statewide public office. (State Bylaws, Art. XIV, B1d.)
12. Other Rules
12.1 Reasonable Rules. The permanent Chairman shall make such other reasonable rules as
may be necessary for the operation of the Assembly and Convention and the operation or regularity
of the delegation to the Republican National Convention, provided that such rules shall not conflict
with the Rules of the (national) Republican Party, the rules and bylaws of the Colorado Republican
Party, applicable Colorado statutes and these rules.
12.2 Candidate Literature. Only literature for Republican candidates to be chosen at the
Assembly and Convention or for Republican candidates for President of the United States may be
distributed on the floor of the Assembly and Convention, in the facility, or on the premises. The
State Chairman may bar any literature that does not comply with this rule or fails to identify the
candidate, person, or organization responsible for the literature. No petitions for any candidate or
ballot issue shall be permitted or circulated on the floor, in the facility, or on the premises, except as
the State Chairman may authorize.
12.3 Future Assembly and Convention. These Rules shall serve as the temporary rules of any
succeeding Assembly and Convention of the Colorado Republican Party until such time as
permanent rules are adopted by that Assembly and Convention.
12.4 Suspension. The rules of the Assembly and Convention may be suspended by a two-thirds
vote.
12.5 Deferral to RNC Rules, State Law and CRC Bylaws. Should any rule herein contradict
governing provisions of state or federal law, the Rules of the (national) Republican Party, or the
Bylaws or rules of the Colorado Republican State Central Committee, the Chairman may rule that
such law, rule, or bylaw governs.
13. Parliamentary Authority.
13.1 Robert's Rules of Order, Newly Revised. The eleventh and most recent edition of Robert's
Rules of Order, Newly Revised, shall govern the Assembly and Convention in all cases in which they
are not in conflict with Colorado Revised Statutes, the Bylaws of the Colorado Republican State
Central Committee, the Rules of the National Republican Party, and these rules. The foregoing will be
available for inspection during the Assembly and Convention.
Adopted by the Rules Committee this 7th day of April, 2016.
Page 54
Exhibit 3
Page:
1
of
1
3,825 / 3,897
Undervotes
27,653
Overvotes
2,132
Candidate
98.15%
Total
2,272
3.26%
1,988
2.85%
1,940
2.78%
1,869
2.68%
1,861
2.67%
1,843
2.65%
1,820
2.61%
1,809
2.60%
1,792
2.57%
1,709
2.45%
1,708
2.45%
1,661
2.38%
1,590
2.28%
1,588
2.28%
1,582
2.27%
1,546
2.22%
518
0.74%
493
0.71%
486
0.70%
476
0.68%
475
0.68%
469
0.67%
444
0.64%
410
0.59%
409
0.59%
396
0.57%
380
0.55%
371
0.53%
355
0.51%
Page 55
Page:
1
of
1
471.
Seger,
Wendi
--
[
Donald
Trump
]
1.
Adams,
Ronald
--
[
Ted
Cruz
]
354
0.51%
353
0.51%
350
0.50%
349
0.50%
348
0.50%
344
0.49%
343
0.49%
331
0.48%
326
0.47%
318
0.46%
309
0.44%
308
0.44%
306
0.44%
300
0.43%
297
0.43%
289
0.41%
602
281
0.40%
279
0.40%
275
0.39%
274
0.39%
268
0.38%
266
0.38%
260
0.37%
257
0.37%
252
0.36%
252
0.36%
250
0.36%
241
0.35%
240
0.34%
238
0.34%
238
0.34%
238
0.34%
236
0.34%
233
0.33%
233
0.33%
230
0.33%
227
0.33%
Page 56
Page:
1
of
1
103.
Currey,
Edmund
--
[
John
Kasich
]
305.
Laxar,
Philip
--
[
John
Kasich
]
199.
Grantham,
Caroline
--
[
Ted
Cruz
]
292.
Kueera,
Jay
--
[
Ted
Cruz
]
227
0.33%
224
0.32%
223
0.32%
222
0.32%
217
0.31%
600
215
0.31%
632
210
0.30%
207
0.30%
201
0.29%
631
195
0.28%
190
0.27%
188
0.27%
184
0.26%
181
0.26%
178
0.26%
178
0.26%
170
0.24%
170
0.24%
169
0.24%
167
0.24%
166
0.24%
164
0.24%
164
0.24%
159
0.23%
158
0.23%
155
0.22%
153
0.22%
153
0.22%
153
0.22%
152
0.22%
151
0.22%
150
0.22%
146
0.21%
145
0.21%
145
0.21%
145
0.21%
144
0.21%
141
0.20%
139
0.20%
138
0.20%
Page 57
Page:
1
of
1
132.
Dooley,
John
M
--
[
Donald
Trump
]
14.
Baldwin,
Jacob
--
[
Ted
Cruz
]
136
0.20%
135
0.19%
133
0.19%
131
0.19%
130
0.19%
128
0.18%
127
0.18%
127
0.18%
126
0.18%
126
0.18%
125
0.18%
125
0.18%
123
0.18%
123
0.18%
123
0.18%
122
0.18%
122
0.18%
122
0.18%
122
0.18%
120
0.17%
118
0.17%
117
0.17%
117
0.17%
117
0.17%
116
0.17%
115
0.17%
114
0.16%
113
0.16%
111
0.16%
111
0.16%
111
0.16%
110
0.16%
110
0.16%
110
0.16%
108
0.16%
106
0.15%
104
0.15%
104
0.15%
104
0.15%
Page 58
Page:
1
of
1
90.
Corporon,
Randy
B
--
[
Ted
Cruz
]
103
0.15%
103
0.15%
103
0.15%
103
0.15%
102
0.15%
101
0.14%
99
0.14%
99
0.14%
99
0.14%
99
0.14%
98
0.14%
98
0.14%
98
0.14%
97
0.14%
96
0.14%
96
0.14%
95
0.14%
95
0.14%
95
0.14%
93
0.13%
93
0.13%
91
0.13%
91
0.13%
90
0.13%
90
0.13%
89
0.13%
88
0.13%
87
0.12%
87
0.12%
85
0.12%
596
85
0.12%
84
0.12%
84
0.12%
84
0.12%
82
0.12%
82
0.12%
82
0.12%
81
0.12%
81
0.12%
Page 59
Page:
1
of
1
39.
Bolin,
Drew
--
[
Ted
Cruz
]
80
0.11%
80
0.11%
80
0.11%
79
0.11%
79
0.11%
79
0.11%
79
0.11%
79
0.11%
78
0.11%
609
78
0.11%
77
0.11%
76
0.11%
75
0.11%
75
0.11%
75
0.11%
74
0.11%
73
0.10%
615
72
0.10%
71
0.10%
619
71
0.10%
70
0.10%
68
0.10%
68
0.10%
68
0.10%
66
0.09%
64
0.09%
63
0.09%
63
0.09%
63
0.09%
63
0.09%
63
0.09%
62
0.09%
62
0.09%
61
0.09%
61
0.09%
60
0.09%
59
0.08%
58
0.08%
58
0.08%
58
0.08%
Page 60
Page:
1
of
1
371.
Moss,
Katy
Lynn
--
[
Ted
Cruz
]
57
0.08%
599
57
0.08%
56
0.08%
55
0.08%
52
0.07%
52
0.07%
52
0.07%
51
0.07%
50
0.07%
50
0.07%
50
0.07%
50
0.07%
49
0.07%
47
0.07%
47
0.07%
47
0.07%
46
0.07%
617
46
0.07%
45
0.06%
45
0.06%
45
0.06%
44
0.06%
44
0.06%
44
0.06%
44
0.06%
43
0.06%
43
0.06%
43
0.06%
43
0.06%
43
0.06%
43
0.06%
611
43
0.06%
42
0.06%
42
0.06%
42
0.06%
41
0.06%
41
0.06%
41
0.06%
948
41
0.06%
39
0.06%
39
0.06%
38
0.05%
38
0.05%
Page 61
Page:
1
of
1
418.
Pringnano,
Charles
--
[
Donald
Trump
]
608
38
0.05%
38
0.05%
37
0.05%
37
0.05%
37
0.05%
36
0.05%
36
0.05%
36
0.05%
36
0.05%
36
0.05%
35
0.05%
34
0.05%
32
0.05%
32
0.05%
32
0.05%
32
0.05%
32
0.05%
32
0.05%
31
0.04%
31
0.04%
31
0.04%
31
0.04%
31
0.04%
30
0.04%
30
0.04%
30
0.04%
30
0.04%
30
0.04%
30
0.04%
30
0.04%
30
0.04%
30
0.04%
29
0.04%
29
0.04%
29
0.04%
29
0.04%
29
0.04%
29
0.04%
28
0.04%
28
0.04%
28
0.04%
Page 62
Page:
1
of
1
307.
Lee,
Frank
--
[
Unpledged
]
28
0.04%
28
0.04%
28
0.04%
27
0.04%
27
0.04%
27
0.04%
27
0.04%
26
0.04%
26
0.04%
26
0.04%
26
0.04%
26
0.04%
26
0.04%
25
0.04%
25
0.04%
25
0.04%
25
0.04%
618
25
0.04%
24
0.03%
24
0.03%
24
0.03%
24
0.03%
24
0.03%
24
0.03%
24
0.03%
23
0.03%
23
0.03%
23
0.03%
23
0.03%
624
23
0.03%
22
0.03%
22
0.03%
22
0.03%
22
0.03%
22
0.03%
22
0.03%
22
0.03%
22
0.03%
22
0.03%
21
0.03%
21
0.03%
Page 63
Page:
1
of
1
362.
Mische,
Ted
--
[
Ted
Cruz
]
21
0.03%
21
0.03%
21
0.03%
21
0.03%
20
0.03%
20
0.03%
20
0.03%
20
0.03%
20
0.03%
20
0.03%
20
0.03%
20
0.03%
19
0.03%
19
0.03%
19
0.03%
19
0.03%
18
0.03%
18
0.03%
18
0.03%
18
0.03%
18
0.03%
18
0.03%
18
0.03%
18
0.03%
18
0.03%
18
0.03%
18
0.03%
18
0.03%
18
0.03%
18
0.03%
18
0.03%
17
0.02%
17
0.02%
17
0.02%
17
0.02%
17
0.02%
17
0.02%
17
0.02%
Page 64
Page:
1
of
1
393.
Oram,
Nathan
Paulus
--
[
Ted
Cruz
]
425.
Raleigh,
Helen
Qiang
--
[
Unpledged
]
529.
Tintera,
Elaine
--
[
Ted
Cruz
]
17
0.02%
17
0.02%
17
0.02%
17
0.02%
17
0.02%
634
17
0.02%
16
0.02%
16
0.02%
16
0.02%
16
0.02%
16
0.02%
16
0.02%
16
0.02%
16
0.02%
633
16
0.02%
15
0.02%
15
0.02%
14
0.02%
14
0.02%
14
0.02%
14
0.02%
14
0.02%
14
0.02%
14
0.02%
14
0.02%
14
0.02%
14
0.02%
14
0.02%
14
0.02%
14
0.02%
14
0.02%
14
0.02%
14
0.02%
13
0.02%
13
0.02%
13
0.02%
13
0.02%
13
0.02%
13
0.02%
13
0.02%
Page 65
Page:
1
of
1
485.
Skotty,
Donald
--
[
Ted
Cruz
]
545.
Wagner,
Betty
Lou
--
[
Unpledged
]
559.
Westbrook,
Robert
Lee
--
[
Unpledged
]
607
13
0.02%
13
0.02%
13
0.02%
13
0.02%
12
0.02%
12
0.02%
12
0.02%
12
0.02%
12
0.02%
12
0.02%
12
0.02%
11
0.02%
11
0.02%
11
0.02%
11
0.02%
11
0.02%
11
0.02%
11
0.02%
11
0.02%
11
0.02%
11
0.02%
11
0.02%
11
0.02%
11
0.02%
11
0.02%
11
0.02%
11
0.02%
11
0.02%
10
0.01%
10
0.01%
10
0.01%
10
0.01%
10
0.01%
10
0.01%
10
0.01%
10
0.01%
10
0.01%
10
0.01%
10
0.01%
Page 66
Page:
1
of
1
560.
Westbrook,
Zane
Mark
--
[
Unpledged
]
57.
Brunette,
Alice
T
--
[
Unpledged
]
78.
Chervenak,
Richard
--
[
Unpledged
]
98.
Crumplar,
Marilyn
Gwyn
--
[
Unpledged
]
100.
Cundiff,
Mollie
Jeneane
--
[
Unpledged
]
116.
Davis,
William
Michael
--
[
Unpledged
]
121.
Delohery,
Patrick
--
[
Unpledged
]
210.
Hahn,
Gabriel
--
[
Unpledged
]
215.
Hammett,
Scott
--
[
Unpledged
]
231.
Hecht,
Jeffrey
--
[
Unpledged
]
238.
Hindley,
Forrest
Giles
--
[
Unpledged
]
245.
Hott,
Robert
Troy
--
[
Unpledged
]
314.
Lipetzky,
Tom
--
[
Unpledged
]
317.
Locke,
Peter
Vance
--
[
Ted
Cruz
]
331.
Mayes,
Barbara
--
[
Unpledged
]
365.
Momper,
Arthur
--
[
Unpledged
]
408.
Petton,
Rodney
--
[
Unpledged
]
10
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
Page 67
Page:
1
of
1
187.
Gibson,
Russel
L
--
[
Unpledged
]
229.
Hayward,
Justin
Peter
--
[
Unpledged
]
267.
Jones-Carson,
Jessica
--
[
Unpledged
]
282.
Kinney,
Holly
--
[
Unpledged
]
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
641
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
Page 68
Page:
1
of
1
531.
Tone,
Marian
Adams
--
[
Unpledged
]
546.
Wagner,
Thomas
Melvin
--
[
Unpledged
]
612
159.
Felts,
William
--
[
Unpledged
]
164.
Fitzgerald,
Francis
Patrick
(Patrick)
--
[
Unpledged
]
209.
Hadlock,
LuAnn
L
--
[
Unpledged
]
211.
Hahn,
Sarah
--
[
Unpledged
]
236.
Hewgley,
Richard
Lucian
--
[
Unpledged
]
258.
Janssen,
Mary
--
[
Unpledged
]
332.
Mazzullo-Reuel,
Matteo
--
[
Unpledged
]
361.
Miller,
Robert
Edwin
--
[
Unpledged
]
422.
Rabner
III,
Richard
T
--
[
Unpledged
]
451.
Rosales,
John
--
[
Unpledged
]
459.
Sanders,
Kristine
--
[
Unpledged
]
497.
Spenks,
Gavin
Matthew
--
[
Unpledged
]
504.
Stinnett,
Michelle
--
[
Unpledged
]
538.
Tumlinson,
April
--
[
Unpledged
]
561.
Wheeler,
Jerry
--
[
Unpledged
]
581.
Youngman,
Chase
--
[
Unpledged
]
629
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
Page 69
Page:
1
of
1
407.
Peterson,
Tara
--
[
Unpledged
]
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
0.01%
693
0.01%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
627
0.00%
630
0.00%
654
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
Page 70
Page:
1
of
1
498.
Springer,
Gerald
--
[
Unpledged
]
621
0.00%
0.00%
625
0.00%
652
0.00%
665
0.00%
667
0.00%
677
0.00%
694
0.00%
705
0.00%
713
0.00%
719
0.00%
774
0.00%
800
0.00%
929
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
644
0.00%
646
0.00%
653
0.00%
660
0.00%
666
0.00%
671
0.00%
672
0.00%
680
0.00%
681
0.00%
687
0.00%
690
0.00%
692
0.00%
698
0.00%
700
0.00%
703
0.00%
Page 71
Page:
1
of
1
704
0.00%
714
0.00%
726
0.00%
728
0.00%
739
0.00%
748
0.00%
749
0.00%
770
0.00%
785
0.00%
792
0.00%
795
0.00%
796
0.00%
844
0.00%
868
0.00%
870
0.00%
872
0.00%
888
0.00%
898
0.00%
0.00%
0.00%
0.00%
0.00%
0.00%
637
0.00%
638
0.00%
639
0.00%
640
0.00%
642
0.00%
643
0.00%
645
0.00%
647
0.00%
648
0.00%
649
0.00%
650
0.00%
651
0.00%
655
0.00%
656
0.00%
657
0.00%
658
0.00%
659
0.00%
661
0.00%
662
0.00%
663
0.00%
664
0.00%
668
0.00%
669
0.00%
Page 72
Page:
1
of
1
670
0.00%
673
0.00%
674
0.00%
675
0.00%
678
0.00%
679
0.00%
682
0.00%
683
0.00%
684
0.00%
685
0.00%
686
0.00%
688
0.00%
689
0.00%
691
0.00%
695
0.00%
696
0.00%
697
0.00%
699
0.00%
701
0.00%
702
0.00%
706
0.00%
707
0.00%
708
0.00%
709
0.00%
710
0.00%
711
0.00%
712
0.00%
715
0.00%
716
0.00%
717
0.00%
718
0.00%
720
0.00%
721
0.00%
722
0.00%
723
0.00%
724
0.00%
725
0.00%
727
0.00%
729
0.00%
730
0.00%
731
0.00%
732
0.00%
733
0.00%
734
0.00%
735
0.00%
736
0.00%
737
0.00%
738
0.00%
Page 73
Page:
1
of
1
740
0.00%
741
0.00%
742
0.00%
743
0.00%
744
0.00%
745
0.00%
746
0.00%
747
0.00%
750
0.00%
751
0.00%
752
0.00%
753
0.00%
754
0.00%
755
0.00%
756
0.00%
757
0.00%
758
0.00%
759
0.00%
760
0.00%
761
0.00%
762
0.00%
763
0.00%
764
0.00%
765
0.00%
766
0.00%
767
0.00%
768
0.00%
769
0.00%
771
0.00%
772
0.00%
773
0.00%
775
0.00%
776
0.00%
778
0.00%
779
0.00%
780
0.00%
781
0.00%
782
0.00%
783
0.00%
784
0.00%
786
0.00%
787
0.00%
788
0.00%
789
0.00%
790
0.00%
791
0.00%
793
0.00%
794
0.00%
Page 74
Page:
1
of
1
797
0.00%
798
0.00%
799
0.00%
801
0.00%
802
0.00%
803
0.00%
804
0.00%
805
0.00%
806
0.00%
807
0.00%
808
0.00%
809
0.00%
810
0.00%
811
0.00%
812
0.00%
813
0.00%
814
0.00%
815
0.00%
816
0.00%
817
0.00%
818
0.00%
819
0.00%
820
0.00%
821
0.00%
822
0.00%
823
0.00%
824
0.00%
825
0.00%
826
0.00%
827
0.00%
828
0.00%
829
0.00%
830
0.00%
831
0.00%
832
0.00%
833
0.00%
834
0.00%
835
0.00%
836
0.00%
837
0.00%
838
0.00%
839
0.00%
840
0.00%
841
0.00%
842
0.00%
843
0.00%
845
0.00%
846
0.00%
Page 75
Page:
1
of
1
847
0.00%
848
0.00%
849
0.00%
850
0.00%
851
0.00%
852
0.00%
853
0.00%
854
0.00%
855
0.00%
856
0.00%
857
0.00%
858
0.00%
859
0.00%
860
0.00%
861
0.00%
862
0.00%
863
0.00%
864
0.00%
865
0.00%
866
0.00%
867
0.00%
869
0.00%
871
0.00%
873
0.00%
874
0.00%
875
0.00%
876
0.00%
877
0.00%
878
0.00%
879
0.00%
880
0.00%
881
0.00%
882
0.00%
883
0.00%
884
0.00%
885
0.00%
886
0.00%
887
0.00%
889
0.00%
890
0.00%
891
0.00%
892
0.00%
893
0.00%
894
0.00%
895
0.00%
896
0.00%
897
0.00%
899
0.00%
Page 76
Page:
1
of
1
900
0.00%
901
0.00%
902
0.00%
903
0.00%
904
0.00%
905
0.00%
906
0.00%
907
0.00%
908
0.00%
909
0.00%
910
0.00%
911
0.00%
912
0.00%
913
0.00%
914
0.00%
915
0.00%
916
0.00%
917
0.00%
918
0.00%
919
0.00%
920
0.00%
921
0.00%
922
0.00%
923
0.00%
924
0.00%
925
0.00%
926
0.00%
927
0.00%
928
0.00%
930
0.00%
931
0.00%
932
0.00%
933
0.00%
934
0.00%
935
0.00%
936
0.00%
937
0.00%
938
0.00%
939
0.00%
940
0.00%
941
0.00%
942
0.00%
943
0.00%
944
0.00%
945
0.00%
946
0.00%
0.00%
947
Total
Votes
69,665
Page 77
Page:
1
of
1
Total
Unresolved
Write-In
Page 78
Exhibit 4
Page 79
Exhibit 5
Page 80
Exhibit 6
Obtained by Molly Sullivan, Denver Delegate.
D1
A22
A25
A4
A9
A28
A29
A14
D3
A27
A3
A14
D2
D2
A10
A26
A4
A15
A23
D4
A8
D5
D5
A31
D7
A22
A11
DAL2
A1
A12
A13
A4
A4
D6
D9
D8
A9
D10
A20
A21
D5
A8
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
600836684
778045
2837143
2943422
2544665
2527762
2397370
2648049
2798478
600342063
2879597
2676304
4075726
600754743
2551619
2478404
756631
2416348
601128951
2809446
2640333
2546025
2711324
200304075
600199195
2573937
601096276
2829785
600148748
2533224
601110965
600180422
8009218
600856452
2502875
3967038
2781265
2777325
2484052
601125595
2688172
2427927
RONALD
ADAMS
MARY
ALBI
THOMAS
ALIREZ
GERALD
ASTWOOD
BRUCE
BAIRD
ARDATH
BAKER
HOWARD
BEAMGUARD
KAA
BENTON
DANIEL
BERGMAN
DANIEL
BETTINGER
ANDREW
BICKHARD
JOSEPH
BLOMBERG
T
BOLIN
DOYT
BOLLING
SUSAN
BRANSON
MARY
BURNS
LELIA
CAMERON
ROBERT
CANTER
LAURA
CARR
JANET
CHOYCE
JILENE
COHN
ANNETTE
COLE
THOMAS
COOK
EMILY
CORDES
ERIC
CREWS
CHARLES
CROSSE
EDMUND
CURRY
THEODORE DANN
RANDOLPH DAVILA
WILLIAM
DEERE
CAITLIN
DEMBOWSKI
RICKY
DENNY
ROCKY
DRAUGHON
GRANT
DUPART
PATRICIA
DURBIN
DOUGLAS DYE
CHRISTOPHEREDDY
CYNTHIA
ENGEL
MARGARET FLORENTIN
LAWRENCE FLOWERS
BETH
FOLSOM
JOHN
FRIED
2705N
MACON
ST
Denver
4875S
DTC
BLVD
APT
12-103
Denver
7200E
EVANS
AVE
APT
1Denver
10
1919N
YOSEMITE
ST
Denver
6095W
JEFFERSON
AVE Denver
3521S
HILLCREST
DR
APT
Denver
2
1707S
JASMINE
ST
Denver
5044N
FONTANA
CT
Denver
10700E
DARTMOUTH
AVE
Denver
APT
PP111
2908S
CLERMONT
DR Denver
1313N
WILLIAMS
ST
APT
Denver
402
1552S
SYRACUSE
ST
Denver
252515TH
ST
APT
2H Denver
1174N
GRAPE
ST
Denver
4816W
36TH
AVE
Denver
1972S
GRANT
ST
Denver
4970W
8TH
AVE
Denver
4877N
KNOX
CT
Denver
10050E
HARVARD
AVE
ADenver
PT
A701
4591N
ORLEANS
ST
Denver
2750S
JAY
ST
Denver
15090
ROBINS
DR
Denver
1523N
QUITMAN
ST
APT
Denver
701
3144S
AKRON
ST
Denver
3066S
TRENTON
ST
Denver
220N
JACKSON
ST
Denver
3602N
DECATUR
ST
Denver
3923S
NEWPORT
WAY Denver
4151N
KALAMATH
ST Denver
13004E
ELGIN
DR
Denver
6343E
GIRARD
PL
APT
378
Denver
5173W
COLUMBIA
PL Denver
3357N
NAVAJO
ST
Denver
2146GLENARM
PL
Denver
8101E
DARTMOUTH
AVE
Denver
APT
6
5511N
TUCSON
ST
Denver
2733N
JAVA
CT
Denver
6700E
MANSFIELD
AVE Denver
3903S
CHASE
WAY
Denver
10050E
HARVARD
AVE
ADenver
PT
A701
4567E
ILIFF
AVE
Denver
3271S
GLENCOE
ST
Denver
Page 81
A15
A11
D13
A28
D10
D7
D11
A17
D14
A25
D12
A22
A11
A10
A12
A21
A25
A32
A3
A12
A7
A14
A3
A28
A33
D11
A18
A2
A13
A13
A24
A26
A1
A16
A5
D18
A15
D11
A4
D19
A5
D16
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
Denver
2534112
5920213
200005185
2839226
2707827
600929355
200259312
200259363
5793243
2424343
827713
2916624
5946858
5776028
2774330
2456906
200316966
601167566
4030618
2774009
2401982
234833
601117939
2913343
2913956
2886066
2421648
2448034
2476161
2476161
2767133
2773740
600342088
4076134
200089822
136408
2757697
600906022
2479492
600330257
2454990
200006159
ALISA
GARNER
LISA
GEISLER
BEATRICE
GREEN
LAWRENCE GREEN
JEFFREY
GUARD
BRENT
GUGLIELMINO
GABRIEL
HAHN
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2964591 WILLIAM
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Exhibit 7
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Exhibit 8
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Exhibit 9
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Exhibit 10
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7. My name was published in voting material that the 4th Congressional District Convention
received, thus making it clear that the Colorado Republican Party had received my
correct form to run for National Delegate and setting up my assurance that I would be on
the ballot at the Colorado Republican State Convention election on April 9, the day
following the 4th Congressional District Convention.
8. About two hours into the Colorado Republican State Convention, I had a friendly
conversation with former State Chairman Ryan Call and asked if he was running for
National Delegate. Call replied that he had planned to run as a candidate but that the
State Party had failed to give him a number.
9. The ballots for National Delegate at the Colorado Republican State Convention did not
have names on them, only numbers with ovals beside them. This methodology clearly
violated both reasonable judgment and the bylaws for conducting an election.
Separately, a booklet was provided to the State Delegates when they entered the
convention area. The booklet contained a list of the individuals running for National
Delegate and their assigned numbers. Near the end of the convention, I received a
second booklet, followed by an addendum sheet containing the National Delegate
candidates names, their ballot numbers, and their pledging status. I had to crossreference the multiple published lists of numbers and National Delegate candidates
names with my ballot to determine how to vote.
10. Following the conversation with former Chairman Call, I suspected that I might not have
been assigned a number.
11. Upon review of the booklet I was given when I arrived at the convention, I found my
name was not published anywhere as a candidate running for National Delegate. I set
out to find out how to remedy this situation by approaching various volunteers and
inquiring as to where the Teller Committee room was located or where the Credentials
room and or any room in which Republican Party officials who could help me with my
ballot number was located.
12. After some time, I finally encountered a volunteer who connected me with someone who
listened to my situation and told me to wait where I was (in the hallway) and she would
return with information. After about 20 minutes, a State Party staff person returned and
told me my assigned number was 632. I repeated that number and wrote it on my
program. The volunteer repeated the number as well to confirm it was in fact 632.
13. The remaining details of my situation are shown by my Protest email (Exhibit 1) that I
sent first to Colorado Republican Party Executive Director Shana Kohn, who never
acknowledged receipt, and then to Colorado Republican Party State Chairman Steve
House.
14. In emails (Exhibit 2) between House and me, I inquired as to the status of my Protest,
and House repeatedly responded that the attorney was reviewing my situation. House
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never gave me a definite Yes or No to my Protest even after the deadline to file this
Contest and after he had certified the official Colorado National Delegate and Alternate
list to the Republican National Convention. House kept telling me it was at the attorneys
and House was waiting on the attorney.
15. Getting no resolution from Chairman House and feeling that I certainly had had every
expectation of being elected as an at-large delegate to the Republican National
Convention, I saw no other avenue of resolution than to join in this Contest.
16. As stated in my Protest email (Exhibit 1), my name was not published in the booklet
provided to state convention voting delegates when they arrived at the convention. My
name was not published in the official booklet that was handed out to the Douglas
County state convention voting delegates some 30 minutes before the ballots were
handed out. My name was not published in any addendum sheets that were passed out
to the Douglas County state convention voting delegates some 15 minutes before the
ballots were handed out. In fact, my name and number for a National Delegate ballot
position were not provided to any voting delegate at the state convention in print form at
all.
17. Late in the day, it was announced that the candidates for National Delegates should start
lining up to give their ten-second speeches. I was paying close attention and was near
the beginning of this line. At this time, I and the other Douglas County state convention
delegates had already received our ballots, and many were casting their voted ballots
before my name had even been published as a candidate. I observed other state
delegates putting their ballots in the ballot boxes before I proceeded to the line to give
my National Delegate speech.
18. While I was waiting in line for the start of the ten-second National Delegate speeches
and after people were putting their ballots into the ballot boxes, an overhead projection
image (Exhibit 3) was displayed that showed errors and omissions in the booklet of
National Delegate candidates. From my memory, this list contained misspellings and
incorrect first names or last names and corrections such as that. Then a document was
projected with additions with numbers higher than those on the addendum sheet that
had been handed out just prior to ballots. The 632 number I had campaigned with most
of the day was listed as someone elses number! My name was the very last one
displayed and with number 636.
19. My chances of obtaining votes for the correct number of 636 were very limited. The
chances of people not having already voted, or having already selected their 26 people
to vote for, were immense. The convention at this time was unruly, disorderly, and
chaotic with delegates moving about placing their ballots in the ballot boxes and leaving
the arena to go home. No one can know how many delegates were actually paying
attention and would even notice my now new number as different from the 632 I had
campaigned with, or even that I was on this list at all.
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20. In the end, my vote count was impressive, considering all the factors involved. Adding
the votes cast for number 632 (no name in vote tally results, 210 votes), number 636 (no
name in vote tally results, 153 votes), and number 2 (Jimmy Clayton Alexander in vote
tally results, 18 votes) that is discussed in my Protest email (Exhibit 1), I did receive 381
votes. I feel confident if I had not been treated so wrongly by my number not being
published anywhere, including on the face of the ballot as required, I would certainly
have gotten the votes to be a National Delegate. In my Protest email to Chairman House
(Exhibit 1), I pointed out to him that I would not have thought about including Number 2's
votes for me, but during the State Convention while I was telling my story to Brandi Meek
(State Party Secretary) at Chairman House's request, a voting delegate named Betty
Benson from Leadville, Colorado, interrupted our conversation and very enthusiastically
told us she had voted for me and she so hoped I would get elected as a National
Delegate. I thanked her and asked her how she had voted for me. She explained she
hoped I was running, searched the entire booklet, and only found one last name
Alexander so she figured they just messed up the first name. She told Brandi and me
she voted for me as number 2. It could be surmised that others may have voted for other
people with the first name Alexander as there were at least four of those in the booklet of
candidates running for National Delegate. I am not including those here. Looking now at
the total votes above, this is more votes than some of the alternates who were certified
by the Colorado State Republican Party got, showing that even with all the
disadvantages raised in this Contest, I got enough votes to be at least an Alternate
delegate. Without the disadvantages, I would certainly have gotten enough votes to be a
delegateby looking any of the published material, no one could even see that I was
running. PLEASE NOTE these vote numbers are different than in Exhibit 1.
21. As a voting delegate I was also disadvantaged by being unable to vote for eligible
candidates whose names were not published along with other candidates. For example,
my friend Lemoine Dowds number was not published until the final image was projected
(Exhibit 3), which was too late for me vote for her.
22. Another friend, Marty Neilson, was assigned number 378, which appeared twice on the
ballot, once where 379 should have been printed. It was unclear how to vote for Neilson
with this ballot layout error and with no name beside her number. After speaking with
Neilson yesterday, I believe she thought she withdrew from running as an at-large
National Delegate altogether. It is therefore unclear why she was assigned a ballot
number at all.
23. By this reference, I hereby incorporate into this affidavit all other irregularities for election
of National Delegate at the Colorado Republican State Convention presented in this
Contest even though I might not have personally been aware of them. The irregularities
caused me to not be properly credited with votes that I would have gotten had the
irregularities not occurred.
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Exhibit 1
From: "Kelsey M. Alexander"
Date: April 14, 2016 at 11:23:43 AM MDT
To: seh@gmail.com, steve@cologop.org
Subject: Fwd: Protest of Colorado National Delegate/Alternate list and votes
Hi Steve,
Tyler Hart told me to send this protest to Shana at the email I sent it to on Monday. Tyler told this to me
when I came into the State GOP office Monday afternoon.
I have received nothing from Shana....not even an acknowledgement that is requested.
Would you please see that this protest is taken seriously and in a timely manner?
And I repeat from within the protest, would you please confirm this protest is received?
I would like a list of all those who ran for national delegate and the vote counts for each. I hope we believe in
transparency.
You and I discussed this Saturday at the assembly.
Thanks,
Kelsey Alexander
, Ron Remy
Abraham Laydon
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see if adding the votes for my numbers would be significant -- and if it was he would figure out how to make it
right. Today (Monday) Tyler Hart told me the vote counts for the numbers that might have been votes for me and I
think I should be seated as an alternate or as a delegate. I understand the list has not yet been published. I want to
be on it.
The long story -Today after calling State Party numerous times -- getting busy signals and full mailboxes, I drove to State Party HQ
and spoke with Tyler Hart at the front desk. I told her my story which is this -- I turned in my form to run for
delegate to the National Assembly through my county chair with my intention to run for National delegate at both
CD4 and State. I know you all got my form because I was correctly on the ballot for CD 4. But I was not on the
ballot at the State Assembly.
A couple of hours into the assembly I happened to see Ryan Call and asked him if he was running for National
delegate. He told me he had been left off the ballot. I was surprised. After thinking about Ryan's situation for some
time, I wondered if I had been left out too. Not having a ballot -- I found a list someone had printed -- and I was not
on that. It was in alphabetical order and the last name Alexander only showed up once -- with Jimmy Carlson (?) as
the first name. So....I went in search of how to resolve this and run anyway.
I finally connected with some State Party people and my first question was -- could they check to see if there were
two delegates with the last name Alexander -- if not, I should be number 2 and they just got the first name wrong.
The request was flatly denied -- we can't verify that for you. Then I asked if they could tell me if Jimmy Carlson (?)
was a delegate or alternate -- it seemed like that was an entire name for someone rather than a first name as the
printed list showed. No, they would not verify that either. So, I had to ask for a new number. After and standing
and waiting for quite some time a State Party person told me my number was 632. I wrote it down on my hand. I
admit I was pretty amazed because the last number in the list I had seen was in the 580's. How could it be that
there were fifty people not listed on the ballot and 580 on the ballot? That means that more than ten percent of
the candidates for national delegate were missing from the published list!!!! If this is true, I find it totally
unacceptable!!!!!
So, my first protest is to say this cannot be a fair election with fifty some people missing off the ballot. Through the
day I found at least twenty more people who told me their name was left off the ballot too!
But I went back into the arena and ran into several of my friends whom I told my situation. One of them wrote the
number 632 on my forehead in ink and I proceeded to use a good deal of my remaining time campaigning to get
votes by showing the number 632 and asking for votes.. A lot of people wrote down my number and said they
would vote for me. I worked hard for several hours -- I really want to be a delegate or an alternate to the national
assembly!
After the ballots were distributed to the County Chairmen, an official booklet of people running for national
delegate and their assigned numbers came through our county chair and our district captains. I looked at that
booklet -- I was not in it either -- the highest number was in the 580's like the previous list I had seen. Very soon
after that a blue addendum sheet came out through the same channels. I was hoping I would be printed on that,
but no! It only went to 619. That means that my name and my assigned number were still not printed anywhere to
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facilitate my supporters being able to vote for me. If I had not directly interfaced with a voting member of the
assembly there was no way they could know I was running nor what number to mark in their ballot to vote for me.
And people were marking their ballots as soon as they got them.
Candidates for offices had just finished speaking. People started lining up to speak for national delegate -- I was
paying attention - I was about 15th in line to speak. Chairman Steve House made the announcement that there
were some corrections and additions -- he put up that list on the monitor. I was dismayed to find my number 632
was indicated to belong to Rebecca Wang (not sure I have the last name right)! And I was the last one listed with
636! I had done all that campaigning for a number different than what was displayed on the monitor!
When Steve House came down from the stage I went over and explained this situation to him. He told me to find
out the numbers after the vote and see if I got enough votes when adding those of the various numbers were close
to being what was needed to be a delegate or alternate. I did that today and they exceed the number of the lowest
seated alternate. Tyler Hart told me the lowest seated alternate was a Cruz supporter with 396 votes..
I want to be placed as an alternate or as a delegate to the National Assembly!
Even though I was not published as a candidate I can take credit for the following votes -Number 2 (only place last name Alexander was printed) 18 votes
Alexander Pinto (don't know number, but my name) 238 votes
Alexander DeValle (don't know number, but my name) 99 votes
Alexander Crane (don't know number, but my name) 13 votes
Alexander Williamson (don't know number, but my name) 4 votes
Number 632 (I campaigned for votes on this number -- even had it written on my face! ) 210 votes
Number 636 - only shown on monitor and after many had turned in their ballots but had my correct name - 153
votes.
Total votes 735
I got these numbers from Tyler Hart this afternoon -- I was denied a request for a printed copy of all the candidates
and votes. I was denied a request to actually look at this list -- I do not know why there is no transparency in our
vote counts. Very disturbing!
Tyler told me the last alternate had gotten 396 votes. I clearly had more -- even if you take out the votes for first
name Alexander I am short only 15 votes. Considering I was not printed anywhere when many people marked their
ballots this is certainly clear a lot of people want me to be a delegate! or at least an alternate! I did not have time
to connect with many people beyond the Douglas County section, the people on the aisles, and people I just
happen to see that I knew. I did not have anywhere near the entire day to campaign because I was (it seems) the
very last person to get a number.
Tyler told me the list of alternates was not yet published. I asked her to delay publishing it until my protest was
considered and played out. I told her I would be submitting it this evening. I am asking to be seated. I believe the
intention of the voters at the assembly clearly shows I should be a delegate or maybe an alternate. I do not know
where the number of votes between alternate and delegate is. But I exceed the number of votes the lowest
alternate got.
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I have been a County Chair, a Judicial Chair, President of a large Republican Women's Club for several terms, and
on the CFRW state board. I am on the LPR ,and Steamboat Institute Advisory boards. I belong to and attend
regularly CRBC, Lincoln Club, Arapahoe Republican Men's Club, and attend Center Right Coalition. I know a lot of
Republicans who were voting delegates at this assembly! I have worked hard for Ted Cruz - made phone calls into
NH, WI, MS, NV, FL, and other states. I know a lot of Republicans around the state who could not have voted for
me because I was not published on the ballot list!!!! I am positive I would have gotten more than fifteen more
votes had you all not made the mistake and not put my name on the list with a number that people could find and
thus vote for me!!!! Look how many votes I got in the short time I campaigned for them! Especially that last
number which was only up on the monitor part of the time at the end when many had already voted!!!!
I am sincerely asking you to seat me as a delegate or as an alternate depending on where my vote count falls.
I am further requesting a complete printout of all the people running for national delegate at the state assembly
and the number of votes received by each person.
I look forward to hearing from you as soon as possible on this. I am sending it to you, Shana, because Tyler Hart
told me you were the one to send it to. Please acknowledge you got this as soon as you read it so I will know that.
And please let me know what the process will be for considering my protest. I am available by phone with my
numbers below, or I can come down to State Party HQ if you would like. I worked very hard to campaign for this
position. I have worked hard through the years and hoped I had enough respect from a lot of people around the
state to get elected. And then you left me off the ballot. I did everything I could to recover only to find my number
was wrong. A double - bad whammy! Please attempt to make this right and see that I am seated correctly.
I also request you bring this to the attention of Chairman Steve House as I spoke with him about it at the assembly
as mentioned above. He should have an opportunity to correct this unfortunate error.
I look forward to hearing from you at your soonest convenience.
Sincerely,
Kelsey M. Alexander
cc: Tanne Blackburn, Chairman, Douglas Co. GOP
Ron Remey, District 2 Captain, Douglas Co. GOP
Abe Laydon, Treasurer, Douglas Co. GOP
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Exhibit 2
From: Chairman House <steve@cologop.org>
Date: Thu, Jun 16, 2016 at 2:02 PM
Subject: Re: Protest status
To: Kelsey Alexander
Kelsey,
I was waiting on our attorney to look at officially. My original view of it was that we cannot add all the
votes by people named Alexander. There are legitimately people named Alexander who were in those
name slots and legitimate delegate candidates who earned votes and I don't see how confusion could
have occurred in those cases. To get on the delegation as an alternate you had to have more than 396
votes overall to get into the last alternate slot. To be a delegate you had to get over 1500 votes and
there is nothing that shows me that if we added anything up we get to that level.
The guest pass is an offer and it is not conditional on anything. You have earned that and I am not trying
to pacify you on this issue. Chris is out of trial finally and he should weigh in also.
Thanks
Steve
Sent from my iPad
On Jun 16, 2016, at 12:41 PM, Kelsey Alexander
Hi Steve,
wrote:
What I really want is a positive resolution to my protest which it seems you have still not answered.
A guest pass? Well, I can't say no, but I need to look in to what it would cost to get there, where I would
stay, etc. Would I be able to get into housing with our delegation at all? What does a "guest" get to
attend? I appreciate the offer and would like more information on it.
And I am not sure you are actually offering me a guest pass -- you did say it conditionally. A bit strange.
But I really want you to address my protest which was submitted in a timely and serious manner. I have
followed up with you several times including in person at Center Right last month.
If you will add up the votes for the one published person with my last name Alexander, the number 632
that I was given during the assembly and that was later put up on the monitor after many had turned in
their ballots and credited to someone named Rebecca Wang (sp?) and number 636 that was also put up
on the monitor after many had voted but had my name by it -- I think those add tmo a total of votes that
exceeds what Tyler Hart told me when I went in on Monday afternoon after our Saturday State
Assembly/Convention. The information Tyler gave me now seems to have been incorrect. That sum puts
me well INTO the pack of alternates. It does not put me 15 votes out of being an alternate as Tyler told
me -- and as my Protest stated. I definitely believe I should be seated as a delegate because the number
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of votes I most certainly would have gotten had you published my name on the ballot or even in the
booklet, or even on the add-on sheet would have bumped me into the delegate vote count.
I still await you answer on the Protest and info on the guest pass info.
Thanks,
Kelsey
On Thu, Jun 16, 2016 at 11:28 AM, Chairman House <steve@cologop.org> wrote:
Kelsey,
I have no doubt that what we are going to find is that we cannot add all the potential votes you
suggested which means we wouldn't get to a point of having you on the delegation. Personally I think
you are an important activist so would you go to Cleveland if I gave you a guest pass?
Thanks
Steve
Sent from my iPad
On Jun 16, 2016, at 11:21 AM, Kelsey Alexander
> wrote:
Hi Steve,
It has now been two more days and I still do not have an answer from you. Your response was to ask
your attorney for an answer.
I am asking you as State Chair for an answer.
Please get back to me with substantive information. I am certainly trying to resolve this with you in good
faith.
Kelsey Alexander
On Tue, Jun 14, 2016 at 2:37 PM, Chairman House <steve@cologop.org> wrote:
I agree Kelsey it has been long enough.
Chris Murray I sent this over to you in April can you please give us your opinion on Kelsey's protest.
Sent from my iPad
> On Jun 14, 2016, at 1:44 PM, Kelsey M. Alexander <
wrote:
>
> Hi Steve,
> Please send me the results of the protest I filed regarding my running for national delegate. Your
attorneys have had enough time to give an opinion.
> Thanks,
> Kelsey Alexander
>
> Kelsey M. Alexander
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Exhibit 3
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Exhibit 11
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Exhibit 12
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Exhibit 13
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Exhibit 14
Friday,
May
20,
2016
at
11:53:18
AM
Eastern
Daylight
Time
Becky, I mean.
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from Pueblo
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He is not in CD3.
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Who is conducting
investigation?
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Exhibit 15
Requested Documentation from Colorado Republican Party
The following information is needed promptly to provide appropriate documentation
for claims in this contest. The majority of this information has been requested by
potential contestants and denied by CRC. (See Exhibit 4).
1) Provide national delegate candidate names corresponding to all ballot counts
showing ballot numbers with no names on the published Election Summary for
National Delegates.
http://cologop.org/wp-content/uploads/2016/01/2016_ElectionSummaryReportNational-Delegate-by-Vote-totals.pdf
2) Provide high quality electronic scans of all ballots, which are automatically
generated by the Dominion voting equipment used.
3) Provide Intent to Run forms of all Respondents. Provide documentation of the
date the form was received in CRC office.
4) Provide the recording of the YouTube live-stream of the assembly/convention.
https://www.youtube.com/watch?v=V2k8PB0gIxw
5) Provide all slides shown on the projection screen at the assembly/convention
relating to national delegate balloting.
6) Provide copies of all ballot supplements whether paper or electronically projected
at the convention.
7) Provide the written scope of services excerpted from the agreements with
Dominion (voting system vendor), and the El Paso County Clerks office.
8) Provide each iteration of national delegate candidate list posted to the CRC
website from inception through April 9, 2016.
9) Provide Intent to Run forms from all candidates who were allowed to file Intent
to Run forms after the deadline of March 28, 2016.
10) Provide a copy of the amended Rule 16(f) filing.
We respectfully request that the Committee on Contest order the CRC to give
Contestants and Respondents equal access to documents.
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Exhibit 16
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