July 3, 2012 Page 1
July 3, 2012
Mr. Allen Alley Chairman Oregon Republican Party 311 B Ave, Suite N (2nd Floor) Lake Oswego, OR 97034 Re:Ultra Vires Action by Oregon GOP Executive Committee
Dear Chairman Alley:
Our firm represents the Ron Paul 2012 Presidential Campaign Committee, Inc. (the “Paul Campaign”). It has come to our attention that the Executive Committee of the Oregon Republican Party (“Oregon GOP”) convened an improper meeting on June 30, 2012 to allegedly address “business” resulting from the district conventions held the previous weekend. It appears that this meeting was convened for the specific purpose of improperly appointing a new slate of Alternate Delegates for four of the five congressional districts. The “business” of this improper meeting was to change the results of elections at the congressional district conventions that the Executive Committee did not like.
The Executive Committee’s ultra vires actions are a blatant violation of the rights of party members who were selected as Alternate Delegates at the district conventions through the democratic and proper parliamentary process.
We are aware that certain members of the party leadership in four of the five congressional districts attempted to railroad the process by running out the clock when it became clear that their “approved” delegates had not been elected to serve. In spite of this egregious behavior by certain party leaders, consistent with proper parliamentary procedure, a duly recognized majority of delegates to these district conventions continued the process and elected slates of Alternate Delegates. These proceedings were recorded by both audio and video and there are scores of witnesses.
As I am sure you are aware, by operation of well established law, a political party must act in accordance with its own rules and may not act in an arbitrary manner.
July 3, 2012 Page 2
Nowhere in the Oregon GOP Bylaws is there authority for the actions taken by the Executive Committee. Nor can such authority be found in the Rules of the Republican Party.
The Paul Campaign has already filed an official challenge to the seating of these bogus Alternate Delegates. The Paul Campaign will take every procedural action available to it to ensure that the properly elected Alternate Delegates are seated at the National Convention in Tampa.
We urge the Oregon Republican Party to accept the slates of Alternate Delegates elected at the congressional district conventions through the democratic and proper parliamentary process. Indeed, any other outcome is unjust. These voters have spent money, resources, and time to participate in this process—to rob them of the fruits of their labors is not only inconsistent with the principles of the Republican Party, but a violation of their rights. In addition to the methods of redress available to it through party rules and procedures, the Paul Campaign will, if necessary, also pursue all of the legal remedies available to ensure that the rights of these voters are protected.
Should you or your counsel wish to discuss this matter, feel free to contact me at your earliest convenience.
David A. Warrington
cc: John Tate, RP2012 Campaign Manager Jeff Larson, RNC Chief of Staff
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