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Exhibit A to CRP SJ Motion

Exhibit A to CRP SJ Motion

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Exhibit A to CRP SJ Motion (Affidavit of Ryan Call) in Colorado Republican Party v. Gessler, et al., Denver District Court Case No. 2014CV031851
Exhibit A to CRP SJ Motion (Affidavit of Ryan Call) in Colorado Republican Party v. Gessler, et al., Denver District Court Case No. 2014CV031851

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Published by: Colorado Ethics Watch on Aug 22, 2014
Copyright:Traditional Copyright: All rights reserved

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08/22/2014

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DISTRICT COURT, CITY AND COUNTY OF DENVER, COLORADO 1437 Bannock Street, Room 256 Denver, CO 80202
Plaintiffs:
COLORADO REPUBLICAN PARTY
v.
Defendant:
A
COURT
USE
ONLY
Case Number: 2014CV031851
S OTT
GESSLER, in his official capacity as Colorado Div./ Courtroom: 409 Secretary
of
State
Attorneys for Plaintiff Colorado Republican Party
Richard A. Westfall, No. 15295 Allan
L
Hale, No. 14885 Peter
J.
Krumholz, No. 27741 Hale Westfall, LLP 1600 Stout St., Suite 500 Denver, CO 80202 Phone 720-904-60 0 Fax 720-904-6020 rwestfall@hal ewest fall.
com
AFFIDAVIT OF
RYAN
R.
CALL
I,
Ryan
R.
Call.
state
under
oath
as
follows:
1
I
am
the
Chairman
of
the
Colorado Republican Party.
2.
On
May
7,
2014,
I
caused
to
be
filed
with the
Secretary
of State s
office
papers
to
establish
and
register
a
Colorado
Republican Party
Independent
Expenditure
Committee
( IEC ).
3.
On
August
8,
2014,
the
management
committee
of
the
IEC
adopted
a
set
of
Standing
Rules
which
govern
and
restrict
the
activities
of
he
IEC.
4.
Since
its
registration
on
May
7,
2014,
I
am
aware
that
the IEC
has
received
several
contributions totaling approximately
$65,000.
t
has
also
made
certain
expenditures
for
consultant
fees,
including preliminary research,
strategic
planning,
and
fundraising
expenses,
but
EXHI IT
 
it
has not made any
expenditures consisting
o
voter contact designed or intended
to
influence
any
particular race or candidate election.
5
Prior
to
August
8.
2014,
my
interactions
with
the
IEC,
its
executive director.
and
its
management committee, was
fully
consistent with
the
requirements
of
the subsequently adopted Standing Rules.
6.
In
connection with
my
duties
and
responsibilities
as
Chainnan
o
the
Colorado Republican
Party~
I and members
o
the
stan·
o
the
Colorado
Republican Party conduct research concen1ing campaign tinance disclosures
and
related media reports.
In
my
current capacity I
am
also required
to
know and abide
by
state
and federal
campaign finance laws.
7.
Based on
my
research
and
my
familiarity with campaign finance laws and
available public campaign
finance
disclosures, I
have
knowledge
of
the
following concerning the recent recall elections
in
State Senate District 3
in
Pueblo,
and
State Senntc District
in
El
Paso County:
a.
The National Ritlc Association spent more than $360,000
to
support
the
recall
elections.
and labor
unions, including the
SEIU
and
the
AFL-CIO, and other Democrat·aligned individualst groups
and
committees raised and spent
more
than
S3
million to attempt
to
defeat
the
recalls.
b.
New
York
City
Mayor Michael Bloomberg personally contributed
$350,000
and
liberal
philanthropist
Eli
Broad personally contributed
$250.000 to a
committee named
..
Taxpayers
for
Responsible Democracy, which opposed
the
recall elections
and
supported former State Senators John Morse and Angela Giron.
c.
An
individual
who
might
have
wished to directly support the Republican successor candidates
in the
recall elections-Bernie Herpin and George Rhera -would
have
been
allowed
to
contribute
no
more
than $200
to
each candidate's candidate
committee, and
no
more than $2,825
to the
Colorado Republican
Party
to
use
in support
o
those
state
legislative candidates.
8.
According
to
campaign finance disclosures filed with the Colorado Secretary
o
Statt,
in
the 2012 calendar
ye r
alone,
527
political
organizations accepted
14,812~906
in
contributions
and
made $14,350,348
in
expenditures
to
influence
state
nd
local
elections.
Independent
expenditure committees accepted
$6.302,334
in
contributions
nd
m de
$6,304,337
in
expenditures
t
influence the election
o
state and local candidates
in the
same
period.
9.
ln
contrast,
the
two
major
political
p ny
committees
combined
accepted
1.,491,023
in
contributions
and made
$1,492.016
in
expenditures with regulated state
funds in
the
same
calendar
year.
2

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