ALICÉ LEUCHTE

Secretary May 23, 2013 Re: Complaint and process against the Chairman, Debra Holle Brown Dear Members,

ALASKA REPUBLICAN PARTY
1001 West Fireweed Lane, Anchorage, Alaska 99503 Direct: (910) 742-0467 • Fax: (907) 331-4202

The elected officers of the Alaska Republican Party are tasked to serve the interests of Alaska Republicans. Contrary to popular opinion, the office of Secretary should not serve the whims of a Chairman, but the welfare of the organization. Therefore, as Secretary, I have a responsibility to voice concern when a matter jeopardizes the integrity of the Party. Over the course of my time in office, and after obtaining what records I could that pertained to my responsibilities, I raised concerns when and as appropriate to the Chairman (Ruedrich & Brown), the Executive Committee (SEC) and Central Committee (SCC). One such matter included the election of the Regional Representatives, who hold 7 of the 17 authorized voting positions on the SEC. The information gathered January 2013 on these positions indicates that the majority of the offices were not filled through a proper election process, but through inconsistent and informal methods. Members of the SCC that were eligible to run for these positions were not informed of the opportunity. In some cases, District Chairmen (who cast a vote to determine the Regional Representatives) were not included in the process. Also, the confusion with the regions in May 2012, and the interim rule change on their composition in December 2012, contributed to my concerns. After reviewing the rules and gathering supporting data, I explained my concerns to Chairman Brown. It was her intent, as later stated in a letter dated April 3, to hold proper elections for these positions in April. She also added the regional issue to the SEC agenda for March 11, 2013; however, business was stalled with discussion over all the 2012 SEC minutes tabled under Chairman Ruedrich. The following day Goldberg contacted Chairman Brown, stating she would be removed by the SEC if she didn’t resign. On April 9, 2013, I released a letter summarizing my records pertaining to the office of State Chairman. determination. In this presentation, I support my objections to the process Bruce Schulte’ s complaint followed. I stand by that

It is important to note that the actions and efforts of those involved – including those of Vice Chairman Goldberg and National Committeeman Seekins (also the proxy of National Committeewoman Joslin) in Los Angeles – has not only caused further chaos to the Party business, it also deprived Alaska full representation at the 2013 Spring RNC meeting. We have the opportunity to restore the representative process within our organization during 2013, which will heal and fortify against the struggles we will find in 2014. In order to do this, we must have leadership that is not only willing to work on rehabilitating our infrastructure, but is willing to do so within the rules. On a related note, it seems unethical for SEC members to vote on the decisions they have made. Therefore, I challenge the voting members of the SEC (past and present) to refrain from voting on these appeals. You, your credibility and office are just as much on trial as that of Russ Millette, Debbie Brown, and whoever else is kept from serving their elected office before May 25. For those voting on these appeals, put aside your personal loyalties, and clear your mind of the rumors and sensationalism that has clouded the matters at hand. Base your decisions on facts and principles. Our Party and our future depend on it. Thank you,

Alicé Leuchte Secretary, Alaska Republican Party

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Complaint and Process against the Chairman, Debra Holle Brown
This file contains an assessment of my records, as they pertain to the process for the complaint brought against Chairman Debbie Brown by Bruce Schulte of District 21. The documents linked in blue and bold are contained within this file. Click the link to jump to the document, or navigate using the bookmarks available within this file. The following is the body of my April 9 letter, regarding the positions of Chairman, Vice Chairman and Executive Director:
As the elected State Secretary of the Alaska Republican Party, I affirm my records reflect: Debra Holle Brown is the current State Chairman. Chairman Brown was elected to the Vice Chairman position at the last State Convention on April 28, 2012. She was found ‘not guilty’ of a complaint brought against her in January 2013, and assumed the office of State Chairman February 1, 2013 after the removal of the Chairman Elect, Russ Millette. A second attempt to remove Chairman Brown from leadership took place April 8, 2013; however, according to my records, this meeting was not an official ARP meeting, as: ⋆ ⋆ ⋆ ⋆ The outcome was predetermined (March 12) before charges were even filed (March 14); 25% of the voting membership did not call the meeting (March 24-26); The complaint did not go through the proper process before the call of the meeting; and The complaint was reviewed by the new Rules Committee and was determined to be unfounded (April 6).

Therefore, Debra Holle Brown still remains the Chairman of the Alaska Republican Party. Peter Goldberg is the current State Vice Chairman. Peter was elected to serve as Vice Chairman by the State Central Committee at the February 9, 2013 meeting in Juneau, Alaska. Randy Ruedrich is the Past Chairman. He is incorrectly listed on GOP.com (http://www.gop.com/members/alaska/) as the Executive Director. The Alaska Republican Party does not currently have an Executive Director.

The following pages of exposition and materials provide the support for the bulleted items.

⋆ The outcome was predetermined (March 12) before charges were even filed (March 14)
The outcome to the latest hearing to remove Chairman Debbie Brown from office was predetermined, as admitted by Vice Chairman Peter Goldberg in a phone conversation with Brown, and in a follow up email sent to the Chairman March 12, 2013:
From: Peter Goldberg <padipete@gmail.com> Date: March 12, 2013 10:14:39 PM AKDT To: DEBBIE BROWN <db@gci.net> Subject: Final Thought When We Lost Connection Debbie, Should you decide to resign rather than go through a hearing, a hearing that will inevitably have the same result, i.e. removing you as chair, I would suggest that you do it before you go to the RNC meetings. This way, you will not have wasted your money on the cost of the trip. There woud be no hotel bill at $189 per night and you could cancel your airline reservation and get credit for the airfare (minus the airline change fee). This will save you in excess of $1000. [continued…]

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While I know it is hard for you to accept, I need to tell you again that everyone that I am aware of in this process believes you to be of strong moral fiber, of good character, and dedicated to the Party. While all believe this to be true, it does not change the opinion of all of these same people that you have neither adequately performed your duties thus far as relates to finances nor do these people believe that you would be successful at it in the future. I'm sorry for the pain that this causes you. I wish I did not have to be the one to bring it to you. -Peter S. Goldberg Vice Chairman, Alaska Republican Party Colonel, US Army Retired

Not only does this email show a predetermined outcome, but also misrepresents the opinions of select voting members of the SEC (e.g. Secretary Alicé Leuchte). Other aspects to this email, specifically the “advice” about not attending the RNC meeting, gives evidence that what transpired in Los Angeles at the spring RNC meeting was premeditated and carried out with the cooperation of Ralph Seekins and Debbie Joslin, our National Committeeman and Committeewoman:
“I would suggest that you do it before you go to the RNC meetings. This way, you will not have wasted your money …”

Essentially, Vice Chairman Goldberg issued Chairman Brown an ultimatum - resign or charges will be manufactured, and “we” will remove you. Chairman Brown refused to be blackmailed, and did not resign the Chairmanship. According to Vice Chairman Goldberg, charges were filed March 14, 2013, and he immediately (and improperly) attempted to call an “Emergency” meeting for March 30, 2013 in order hear the se unevaluated charges:
From: Peter Goldberg <padipete@gmail.com> Sent: Thursday, March 14, 2013 8:24 PM To: Alicé Leuchte; Beka Zerbst; Bruce Schulte; Charlie Huggins; Debbie Joslin; Frank McQueary; Glenn Clary; Julie Gillette; Mike Chenault; Mike Tauriainen; Paulette Simpson 32; Ralph Seekins; Randy Reudrich; Rex Shattuck; Rhonda Boyles 2; Steve Strait; kpjlaw@yahoo.com Subject: Emergency Meeting of the SEC, March 30, 2013, 9 a.m., ARP Headquarters Flag Status: Flagged All SEC Members, I have received a written complaint alleging that Debbie Brown had failed to carry out or perform the duties to which she was elected. As Vice Chairman, it is my duty to hold a hearing where the charge will be heard and Chairwoman Brown will be given an opportunity to defend against that charge. It will then be your duty to determine if the charge is valid. If determined to be valid, it will be your duty to determine how to proceed, up to and including removal from office. Therefore, an Emergency Meeting of the SEC will be held on March 30, 2013, 9 a.m. at the ARP Headquarters at 1001 West Fireweed Lane, Anchorage, AK 99503. I know that most of you are familiar with the situation. Please do not share the reasons for this meeting with anyone. From my conversations with you, I am under the impression that all of you agree with me that nothing has happened to suggest any kind of malicious, destructive, disloyal, or criminal behavior. I believe that Debbie's heart is in the right place, that she is a strong believer in Republican principles, and she wants the best for the Party. We should do all in our power to minimize the possibility that her reputation will be maligned by any actions that we feel compelled to take. For these reasons, we are not inviting the media to this hearing. Peter S. Goldberg Vice Chairman, Alaska Republican Party Colonel, US Army Retired Page 3 of 10

Please note that all SEC members were not included as addressed - Debbie Brown was not included, while Randy Ruedrich, a nonSEC member, was included instead. Also, the name of the Complainant was not given, the charges were not distributed, and no investigative committee had reviewed the charges prior to this attempted call for a hearing, as prescribed by Robert’s Rules of Order (see Chapter XX beginning on page 643, particularly §63, Investigation and Trial). Multiple objections were voiced via email, including by ARP Legal Ken Jacobus, who had not been notified or consulted regarding this complaint. Not consulting Legal Counsel on such a matter opens up the ARP - and very specifically, members of the SEC - to serious legal liabilities, and indicates a clear disregard for the welfare of all involved. In his email dated March 16 (1:15PM), Jacobus references Goldberg’s email on March 12:
In that email, you specifically stated, and I quote this: "Should you decide to resign rather than go through a hearing, a hearing that will inevitably have the same result, i.e. removing you as chair....(emphasis added)" In doing so, in effect you have told Ms. Brown that the matter has already been decided, and that she would not get a fair hearing as guaranteed to her by Party Rule, Article X, Section 3(c).

⋆ 25% of the voting membership did not call the meeting (March 24-26)
The first attempt to call an “Emergency” meeting for March 30 was also addressed by ARP Legal, Ken Jacobus in his March 16 email:
This hearing was called as an "emergency" meeting of the SEC. However, under Party Rule Article VI, Section 5, special meetings may be called upon petition of 25% of the SEC membership, and emergency meetings may be called by the State Chairman and no one else. Accordingly, the Party will be faced with the argument that this was not a validly called emergency meeting.

On March 22, Goldberg sent an email stating the meeting was to be moved to April 8:
Ken Jacobus, ARP counsel has indicated that it would be better to handle the complaint at the next regularly scheduled SECmeeting. At least two other members of the SEC concur. As I recall, that would be on April 8th. I would hope that we can deal with this with maximum fairness so I have no problem moving the date of the hearing. Unless there is substantial objection, I will consider it moved.

While April 8, 2013 was one of several potential dates considered for the next regular SEC meeting (scheduling was intentionally left flexible due concerns for the availability of a Parliamentarian), no regular meeting of the SEC had been called yet for April. It isn’t until March 22 that I began to receive formal requests for a meeting to hear these charges, to be held April 8, 2013. For general reference, the requests stated something similar to the following:
I request an emergency meeting of the Alaska Republican Party State Executive Committee on April 8 at 5:30 at the office of the ARP on Fireweed Lane. The purpose of the meeting is to hear the March 14, 2013 charges against Debbie H. Brown.

I received requests between March 23 and 26 (please note these dates are a correction to my initial bullet item) from Steve Strait, Paulette Simpson, Rhonda Boyles, Rex Shattuck and Glenn Clary. Peter Goldberg cited the requestors as “Bruce Schulte, Paulette Simpson, Rex Shattuck, Rhonda Boyles, Glenn Clary and Steve Strait” in an email dated March 26. As of March 26, the 25% of the membership required had requested the meeting. Five (5) was needed with all voting positions filled on the SEC (with the exception of the State Finance Chairman); however, the number of voting members changed April 3, 2013. The Treasurer, Glenn Clary (along with the Assistant Treasurer, Frank McQueary) had been terminated, and an unconfirmed Treasurer appointed (Treasurer Julie Hamm, with Assistant Treasurer Liz Vazquez).

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The previously confirmed Regional Finance Chairmen (Regions II-VII) had been terminated, leaving one Regional Representative ineligible to serve as Regional Representative (Region VII, Paulette Simpson). The Past Chairman had failed to confirm another Regional Finance Chairman (Region I, Beka Zerbst), which also jeopardized the eligibility to serve despite proper election otherwise. While emails had been submitted January 17, 2013 asserting the proper measures were taken in filling these offices, no minutes had been submitted for the elections of these Regional Representatives – again, with the exception of Region I. After further research, I found reasonable evidence that proper elections were needed for these positions, and submitted the findings to Chairman Brown. These findings included cases where all the District Chairmen in a region had not voted, and other cases where they were unaware they were participating an election. For example, in a later email chain from April 9, Chris McMullins, Chairman of District 10, wrote:
From: Chris McMullins Subject: Re: reply to Aaron Downing To, Cc: [Multiple Recipients] Date: Tuesday, April 9, 2013, 10:18 PM Rex, You and I both know there were no minutes. There was no meeting. There was no election. The process was EXTREMELY informal. I question whether or not some folks actually realized they were "voting" for you. Frankly I felt manipulated and I don't know how many others did too. I would testify to that. Chris McMullins Dist 10 Chair

Also, SCC members that were eligible to run for the Regional Representative positions had not been informed there was an election for these seats, much less informed of their eligibility to be candidates (ARP Rules, Article VI, Section 17). And all of these concerns even outweigh the controversy surrounding the composition and interim confirmation of the “new” regions which took place December 2012. Chairman Brown decided to add this topic to the agenda for the March 11, 2013 SEC meeting and arrange for new elections; however, the meeting ran long due to housekeeping items (all of the 2012 SEC minutes Randy Ruedrich, the Past Chairman, failed to address) and the issue was not addressed with the SEC. Note that it was the day after this meeting, where the Regional concerns were to be addressed, that Vice Chairman Goldberg contacted Chairman Brown to inform her that the members of the SEC would produce charges and seek her removal if she didn’t resign. The Regional Representatives held 7 of the 16 voting positions at the time. Upon the ruling of ARP Legal on March 25 concerning the Chairman’s ability to remove and replace appointed members (and that the submittal of a complaint against the Chairman does not effect a removal from office), Chairman Brown terminated the Regional Finance Chairmen on April 2, and then notified the Regional Representatives (for regions II-VII) that proper elections would be held during April. For general reference, here is the body of one such letter:
Your participation and countless hours of volunteer service to the Alaska Republican Party are greatly appreciated. Given your work towards promoting republican values, I am certain you understand the importance of public trust when it comes to the success of our Party – now and in 2014. [continued…]

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To this end, we must restore trust in the Party leadership by evaluating how we conduct our business. Unfortunately, Party records show a lack of documentation verifying your election to the position of Region VI Representative. Therefore, your service as the Region VI Representative is terminated, effective immediately. A regional meeting will be called this month so that elections may take place for this vacant position. All Republicans eligible will be notified and encouraged to run. Not only do I encourage you to run, but I look forward to your help in this effort to restore confidence in the SEC and the Party at large. More election information will be available soon. Also, I am seeking letters of application for appointed positions from members who are genuinely committed to our platform, dedicated to integrity and determined to grow the participation within our Party. Please consider submitting a letter of application for the position or standing committee you feel most qualified. I would also welcome any suggestions you may have for achieving mutual respect and unity within our party.

As of April 3, 2013, all seven of the Regional Representatives were no longer voting members of the SEC. In recalculating the required number for quorum (to include only filled voting positions), three (3) calls from voting members would be needed to have the April 8, 2013 “Emergency” SEC meeting. After this date, only one of the submittals was from a voting member - even if you prefer the six (6) requests cited by Goldberg:
Glenn Clary Rex Shattuck Steve Strait Bruce Schulte Paulette Simpson Rhonda Boyles Treasurer Region II Representative Region IV Representative Region V Representative Region VII Representative AFRW Replaced Pending Reelection Pending Reelection Pending Reelection Ineligible Voting Member

⋆ The complaint did not go through the proper process before the call of the meeting
Since the ARP Rules do not encompass a complete complaint process (RNC Rules do not either), then per Article I, Section 1, the th latest edition of Robert’s Rules of Order (11 Edition, unabridged) is to guide our disciplinary procedures. Robert’s Rules of Order defines the ‘steps in a fair disciplinary process’ (page 656):
1. 2. 3. 4. 5. Confidential investigation by a committee; Report of the committee, and referral of charges if warranted; Formal notification of the accused; Trial; and The assembly’s review of a trial committee’s findings (if the trial has been held in a committee instead of the assembly…).

While the investigative committee does not have to be the ARP Rules committee (actually, many recommend a special committee be formed to review complaints), the precedence has been set thus far that the Rules Committee also serve this function. As with prior complaints, the ARP Rules Committee has served as the investigative committee within the disciplinary process; however, the Rules Committee - as it was composed until March 22, 2013 - had not reviewed Bruce Schulte’s complaint that was submitted to the Vice Chairman. Only after Chairman Brown replaced the members did the Rules Committee finally meet and review the charges. The following email illustrates this fact:
From: Frank McQueary <fmcqueary@gci.net> Date: Fri, Mar 22, 2013 at 10:11 PM Subject: Current Events To: Terri Mooradian <aklawgal@yahoo.com>, Kirk Wickersham <kirkwickersham@gmail.com>, northpoledentist@gci.net, "Brown, Ben" <benjamino1789@hotmail.com>, robinphillipsak@gmail.com, Eileen Becker <ELBecker@reagan.com>, pruitt_maryann@yahoo.com Cc: "Goldberg, Peter" <padipete@gmail.com>, "Steven R. Strait" <Steve@alaskabroadcastmedia.com>, Ralph Seekins <ralph@seekins.com>, Debbie Joslin <joslin@wildak.net>, "Clary, Glenn" <dclary@gci.net>, Bruce Schulte <bruce.schulte@gmail.com>,

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aliceleuchte@gmail.com, "Gillette, Julie" <arpasstsecgillette@yahoo.com>, "Zerbst, Beka" <armorwife@gmail.com>, "Shattuck, Rex" <2akb4udie@gmail.com>, miket@gci.net, Paulette Simpson <paulettem@gci.net> All: Given what is now transpiring I have postponed the Rules Committee hearing until sometime next week. As I’m sure that you are aware by now charges have been filed against Debbie Brown and the SEC has been asked to remove her from office. Debbie has countered by attempting to continue acting as Chair and has stated that she is dismissing the Rules Committee. It is my understanding of the rules that she does not have this power while charges are pending and that she only has it in the normal course of events with the advice and consent of the SCC. Since I and you were all appropriately appointed to two year terms after the last convention we would expect to serve until the next convention unless replaced with the approval of the SCC. I will verify my interpretation with Thomas Balch and if I am correct we will schedule a meeting next week. I know that the turmoil has taken its toll on our morale, however, we must remember that the rules were written the way they were to enable our organization to protect itself from the kind of external attacks which we are currently experiencing. The SEC and SCC will act in the best interests of the party vis a vis Debbie. We all saw in the hearing on Russ Millette’s removal that he admitted that every charge he had brought against the ARP before , during and after his election were admitted by him to have been false. Even though he admitted bearing false witness against the Party and its officers in front of television cameras, that has not kept him from continuing with his attacks from outside the party. While we can only speculate as to the motives of the various groups involved (Ron Paul, Occupy Wall Street and Joe Miller) there is some speculation that the intent was to take over the Party, suspend the rules and convert to a caucus based selection process for our statewide candidates. It is pretty obvious who would benefit from this change. Debbie will also have a fair hearing and an opportunity to convince the governing board of the party that she has been acting in the best interests of the party. If she fails in that she will be replaced. Cordially, Frank McQueary, Chair ARP Rules Committee

Upon receiving this email, I engaged McQueary about the process which complaints should follow, and clearly stated my objections. I also cleared up the fact that the Rules Committee, under McQueary, had not been confirmed by the SCC after the State Convention (April 28, 2012) – in fact, I had just learned who the members of the Rules Committee were that week. Also, as Chairman of the Rules Committee, he had failed in providing the State Secretary of any minutes as required by the ARP Rules (Article VI, Section 7(f)). In a later response to Goldberg, I expressed:
From: Alicé Leuchte [mailto:secretary@arp.aliceleuchte.com] Sent: Tuesday, March 26, 2013 12:31 PM To: 'alaskadebbiebrown@gmail.com'; 'padipete@gmail.com'; 'kpjlaw@yahoo.com'; 'akannw@gmail.com' Cc: 'ralph@seekins.com'; 'joslinak@gmail.com'; 'arpasstsecgillette@yahoo.com'; 'gclary@ancbt.org'; 'fmcqueary@myeterra.com'; 'armorwife@gmail.com'; '2akb4udie@gmail.com'; 'stevestrait@gci.net'; 'bruce.schulte@gmail.com'; 'miket@gci.net'; 'paulettem@gci.net'; 'craigj73@hotmail.com'; 'kmeyer@gci.net'; 'boyles@gci.net'; db@gci.net Subject: Point of Order! Point of Order: I am extremely concerned about the lack of process being used with this newest complaint. Before I personally commit to attending yet another hearing, I want to know what process this complaint has gone through. I do not think it is appropriate to schedule a meeting for a hearing where the charges have been simply distributed by the Complainant. If we establish the precedent that no review process is required for a complaint, this would mean that any complaint ARP receives would be automatically valid and must be heard. Just imagine the level of havoc the Democrats could wreak on the party under this scenario. They would be able to shut us down any time they pleased and for as long as they pleased. Not acceptable. So: “Point of order!” Page 7 of 10

The communications I have received since have been predominately false accusations and threats of removal if I do not comply with their approach. This includes a “verbal reprimand” for my April 9 letter, which came in the form of a proposed resolution brought to the floor by Steve Strait and Bruce Schulte on April 29. This “reprimand” included the threat of a written censure, followed by removal. While the motion ultimately failed (and was expunged from the minutes), the inappropriateness of the motion stands.

⋆ The complaint was reviewed by the new Rules Committee and was determined to be unfounded (April 6)
The new Rules Committee, as appointed by Chairman Brown, met to review the complaint submitted by Bruce Schulte on April 6, 2013. The Rules Committee made the following ruling:
Charge: Since being elected as Vice‐Chair in 2012 and subsequently taking office as Chair on February 1 – Debbie Brown has raised no funds for the ARP, nor has she shown any aptitude or ability to do so. Possible Grounds: Art X Section 1(b) Failure to carry out or perform the duties of the office to which he was elected. Facts: Debbie Brown was elected as Vice Chairman‐Elect at the State Convention 2012 by the majority of the convention body. This means that on February 1st, 2013, she would have become Vice Chairman of the party, and during the interim between the 2012 State Convention and that date, she was in the appointed position of Vice‐Chair of the State Finance Committee (Article VI, Section 19(b)). This charge was filed March 14th, approximately 6 weeks after she became Chair. Ruling: Since her term as Vice‐Chair of the State Finance Committee was already over, it is too late to file charges based on her performance on that job. Also, those charges would have to be filed with the chair of her committee. There were no charges filed with that committee before February 1st, and due to SCC action at the February 9th SCC meeting there is currently no chair (or vice‐chair) of the State Finance Committee. In regards to her current position of Chairman (starting February 1st), the rules don’t give an amount of time that is to be used to evaluate performance, but it is incredulous that anyone would think that her job performance could be evaluated after six weeks. The final phrase in that sentence “nor has she shown any aptitude or ability to do so.” is subjective, and has no relation to the possible grounds, since “Failure to carry out or perform” has nothing to do with aptitude or ability, but with whether actions are actually carried out or not. Charge: In addition, historically reliable donors have indicated that they have no confidence in Debbie as Chair and will contribute no money to the ARP while she remains in office. Thus, in addition to being ineffective in raising funds, she has regrettably, become a significant impediment to the efforts of others trying to raise funds for the ARP. Possible Grounds: There are no grounds in Article X Section 1 that this charge can be based on. The body of the convention expressed confidence in her by their act of electing her as Vice Chairman, and the will of that body is the ultimate authority for the Alaska Republican Party. Conclusion: These charges do not meet any of the grounds for removal that are given in Article X Section 1.

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Additional Information
Continued Election Concerns Upon Peter Goldberg assuming the position of Vice Chairman on February 9, this left the Region III Representative seat open for election. Instead of holding a proper election, the same informal approach was applied:
From: Jason Rampton [mailto:ramptonhome@gmail.com] Sent: Sunday, March 31, 2013 7:07 PM To: secretary@aliceleuchte.com Subject: ellection to Region III Alice, I have been told that I need to pass this info on to you. I have been elected to serve as the region III representative. I received vote from Robert Timmins, Mike Paulson, and Jeremiah Stevens. The final vote was cast by Mr. Stevens on 27 Mar 2013. Thanks for all you do. Jason Rampton District 26

Region III includes districts 12, 13, 14, 25 and 26. David Eastman and Kyle Easterly, Chairmen in Districts 12 and 13 respectively, were not included in this process. Also, no consideration was given to any other SCC members who wished to run for the seat. Quorum Given the recent, targeted quorum determination solicited from Thomas Balch (by McQueary, Raygor & Goldberg), I would like to add that if this opinion were applied to the April 8, 2013 meeting led by Vice Chairman Goldberg, then it would also be without quorum. All voting positions would have to be considered, properly filled or not. There are 17 authorized voting positions on the SEC, which requires 9 positions to be represented in order to have a quorum. If you look beyond the issue of how the meeting was called, and assume the meeting could take place (those requesting the meeting were voting members at the time they submitted their requests), only 7 of the authorized positions were properly represented on April 8.
POSITION
Filled by

POSITION STATS
Voting Position Elected/ Confirmed Validly Filled

APRIL 8 STATS
Vote Used Vote Used By

NOTE

Chairman Election Yes Yes Yes No N/A Absent Vice Chairman Election Yes Yes Yes Yes Goldberg Present/Phone Natl. Com. Man Election Yes Yes Yes Yes Seekins Present Natl. Com. Woman Election Yes Yes Yes Yes Hove Proxy – Brian Hove Secretary Election Yes Yes Yes Yes Gillette Automatic Proxy – Assistant Secretary Asst. Secretary Election No Yes N/A N/A N/A Non-Voting Member Treasurer Appointment Yes No No Yes McQueary Appointed but not confirmed by SCC Asst. Treasurer Appointment No No N/A N/A N/A Appointed but not confirmed by SCC Finance Chairman Appointment Yes No No No N/A Vacant – Appointment rejected Feb 9 SCC Region I Rep. Election Yes No No Yes Zerbst* Pending SCC Confirmation as Finance Chair* Region II Rep. Election Yes No No Yes Shattuck Election Pending Region III Rep. Election Yes No No Yes Rampton Election Pending Region IV Rep. Election Yes No No Yes Strait Election Pending Region V Rep. Election Yes No No Yes Schulte Election Pending Region VI Rep. Election Yes No No Yes Tauriainen Election Pending Region VII Rep. Election Yes No No Yes Simpson Election Pending House Rep. I Affiliate Yes Yes Yes Yes Higgins Selected by House Majority Senator I Affiliate Yes Yes Yes Yes Stedman Selected by Senate Majority AFRW Affiliate Yes Yes Yes Yes Johnson Proxy – Ginger Johnson Parliamentarian Appointment No Yes N/A N/A Raygor Non-Voting Member Legal Counsel Appointment No Yes N/A N/A Jacobus Non-Voting Member *There are minutes showing election; however, it was later found Zerbst was never confirmed by the SCC as Finance Chairman, therefore ineligible for election. Also, given the change in regions which took place December 2012 via interim rule, holding a new election would be recommended to ensure full representation.

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Altered Complaint It is also worth noting that on April 8, Bruce Schulte submitted an altered complaint containing a new charge at Brown’s hearing. The charges read at that meeting are documented in the minutes (available upon request) from that meeting, and are as follows:
Charge 1a: Failure to perform as Vice-Chair of the State Finance Committee – Failure to raise funds. Specification: At the 2012 State Convention, Mrs. Brown was elected as Vice-Chair Elect. Under ARP Rules (Article VI, Section 22,) this automatically made her State Finance Committee Vice-Chair. During the period between the April 2012 Convention and February 1, 2013, no funds were raised that could be directly or indirectly attributable to Mrs. Brown’s activities in that office. Charge 1b: Failure to perform as State Chair -Failure to raise funds. Specification: Since taking office as State Chair on February 1, 2013, Mrs. Brown has raised no funds that could be directly attributable to her efforts, and the ARP has received a scant few hundred dollars that might be indirectly attributable. As State Chair, one of Mrs. Brown ’s responsibilities is to raise funds to finance ARP activity (Article VI, Section 9; Functions and Duties of the State Chairman.) Charge 2: Failure to perform as State Chair – Failure to faithfully represent the ARP. Specification: Because of her actions – including attempts to dismantle the ARP (SEC and SCC,) historically reliable donors have indicated that they too have no confidence in Debbie as Chair and will contribute no money to the ARP while she remains in office. Thus, in addition to being ineffective at raising funds, she has regrettably, become a significant impediment to the efforts of others trying to raise funds for the ARP. Without the ability to raise funds, the mission of the ARP is impossible to fulfill.

The original charges distributed March 20 are as follows:
Since being elected as Vice-Chair in 2012 and subsequently taking office as Chair on February 1 – Debbie Brown has raised no funds for the ARP, nor has she shown any aptitude or ability to do so. As a nonprofit organization, the ARP cannot function without the contributions from donors which are our only source of income. In addition, historically reliable donors have indicated that they have no confidence in Debbie as Chair and will contribute no money to the ARP while she remains in office. Thus, in addition to being ineffective in raising funds, she has regrettably, become a significant impediment to the efforts of others trying to raise funds for the ARP. Without the ability to raise funds, the mission of the ARP is impossible to fulfill. Applicable Rules: ARP Rules (Article VI, Section 22: Functions of the State Vice-Chair Elect) [The] State Vice Chair-Elect shall serve as State Finance Committee Vice Chair until February 1 after the state convention. The State Vice Chair Elect becomes State Vice Chair on February 1 and serves for two years. ARP Rules (Article VI, Section 9: Functions and Duties of the State Chairman) The State Chairman shall supervise the ARP organization and affairs; chair State Conventions and ARP meetings; and perform other duties incident to his office, subject in all cases to SCC direction, ARP rules and RNC rules. ARP Rules (Article X, Section 1: Grounds for removal) Any person holding elected ARP office may be removed from office for any of the following reasons: b) Failure to carry out or perform the duties of the office to which he was elected. Page 10 of 10

BEGIN EXHIBITS
Complaint against ARP Chair – Debbie Brown
The following complaint is brought against Debbie Brown, ARP Chair for failure to perform her role as ARP Chair. Since being elected as Vice-Chair in 2012 and subsequently taking office as Chair on February 1 – Debbie Brown has raised no funds for the ARP, nor has she shown any aptitude or ability to do so. As a nonprofit organization, the ARP cannot function without the contributions from donors which are our only source of income. In addition, historically reliable donors have indicated that they have no confidence in Debbie as Chair and will contribute no money to the ARP while she remains in office. Thus, in addition to being ineffective in raising funds, she has regrettably, become a significant impediment to the efforts of others trying to raise funds for the ARP. Without the ability to raise funds, the mission of the ARP is impossible to fulfill.

Applicable Rules: ARP Rules (Article VI, Section 22: Functions of the State Vice-Chair Elect) [The] State Vice Chair-Elect shall serve as State Finance Committee Vice Chair until February 1 after the state convention. The State Vice Chair Elect becomes State Vice Chair on February 1 and serves for two years. ARP Rules (Article VI, Section 9: Functions and Duties of the State Chairman) The State Chairman shall supervise the ARP organization and affairs; chair State Conventions and ARP meetings; and perform other duties incident to his office, subject in all cases to SCC direction, ARP rules and RNC rules. ARP Rules (Article X, Section 1: Grounds for removal) Any person holding elected ARP office may be removed from office for any of the following reasons: b) Failure to carry out or perform the duties of the office to which he was elected.

Submitted by:

Bruce Schulte District 21 Chairman

Alicé Leuchte
From: Sent: To: Kenneth Jacobus <kpjlaw@yahoo.com> Saturday, March 16, 2013 1:15 PM Peter Goldberg; Alicé Leuchte; Beka Zerbst; Bruce Schulte; Charlie Huggins; Debbie Joslin; Frank McQueary; Glenn Clary; Julie Gillette; Mike Chenault; Mike Tauriainen; Paulette Simpson 32; Ralph Seekins; Randy Reudrich; Rex Shattuck; Rhonda Boyles 2; Steve Strait Emergency Meeting of the SEC, March 30, 2013, 9 a.m., ARP Headquarters Flagged

Subject: Flag Status:

Dear Mr. Goldberg,

I have been in California and just read this email today, Saturday, March 16, at about noon. Ms. Brown called me today. She informed me that she was aware of the fact that a complaint was allegedly filed against her, but has not been provided a copy of the complaint. I have not seen one either, nor do I know who filed it. Please provide me with a copy by return email. As a matter of procedural due process, Ms. Brown is entitled to a copy of the complaint so that she can defend against it. As of this point, she does not even know who made the complaint. One should be provided to her as soon as possible. I have told Ms. Brown, who presently is party chairman, that my role in this matter is to represent the Republican Party of Alaska, and not any individuals. My responsibilities are set forth in Party Rule, Article VI, Section 14. I must advise and assist the Party as necessary, generally, to keep the Party out of trouble. Until very recently, I did not know that a complaint had been filed or that an "emergency" meeting of the SEC had been called to conduct a hearing. I cannot keep the Party out of trouble if I am not consulted with before the Party does something which is likely to get it into trouble. Had I been asked, I would have recommended that this hearing be conducted at the next regular meeting of the SEC, and that Ms. Brown be immediately provided with a copy of the complaint. At the very least, she should have immediately been told who filed it. At this point, I anticipate that the Party is going to be faced with the following problems: 1. This hearing was called as an "emergency" meeting of the SEC. However, under Party Rule Article VI, Section 5, special meetings may be called upon petition of 25% of the SEC membership, and emergency meetings may be called by the State Chairman and no one else. Accordingly, the Party will be faced with the argument that this was not a validly called emergency meeting.
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2. It is now March 16, which is only 14 days before the scheduled meeting. The argument will be that this is not sufficient time for Ms. Brown to prepare for the hearing. 3. The meeting has been set for the Saturday between Good Friday and Easter. I do not believe that this is a good time for most people involved. 4. The worst thing about this situation, however, is the email that you sent to Ms. Brown on March 12, suggesting that she should resign before the RNC meeting so that she would save an amount in excess of $1000 to travel there. In that email, you specifically stated, and I quote this: "Should you decide to resign rather than go through a hearing, a hearing that will inevitably have the same result, i.e. removing you as chair....(emphasis added)" In doing so, in effect you have told Ms. Brown that the matter has already been decided, and that she would not get a fair hearing as guaranteed to her by Party Rule, Article X, Section 3(c). Remember the two kangaroos that someone brought and set up in front of the Party headquarters on the day of the Millette hearing? You have just proved that the person who brought the kangaroos was correct. How can I defend this from the inevitable court challenge which will follow from the second removal from office of a party officer elected at the Convention?? My recommendation is that this "emergency" meeting be canceled and that everyone work together for the benefit of the Alaska Republican Party. If the complaint goes forward, it should be considered at the next regular SEC meeting. What is going on is only helping the Democrats and other Socialists. We and others in the United States are living in an out of control left-wing nightmare right now, and self-destruction of the Alaska Republican Party is not at all appropriate. Thank you. Ken Jacobus
Kenneth P. Jacobus 310 K Street, Suite 200 Anchorage AK 99501-2064 Phone 907-277-3333 Fax 907-264-6666 kpjlaw@yahoo.com

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Alicé Leuchte
From: Sent: To: Peter Goldberg <padipete@gmail.com> Friday, March 22, 2013 12:52 PM Alicé Leuchte; Bruce Schulte; Debbie Joslin; Glenn & Debbie Clary; Frank McQueary; Frank McQueary; Mike Tauriainen; Mike Chenault; Randy Reudrich; Paulette Simpson 32; Rhonda Boyles 2; Ralph Seekins; Charlie Huggins; Julie Gillette; Rex Shattuck; stevestrait@gci.net; DEBBIE BROWN SEC Meeting Date Flagged

Subject: Flag Status:

Ken Jacobus, ARP counsel has indicated that it would be better to handle the complaint at the next regularly scheduled SECmeeting. At least two other members of the SEC concur. As I recall, that would be on April 8th. I would hope that we can deal with this with maximum fairness so I have no problem moving the date of the hearing. Unless there is substantial objection, I will consider it moved. I am still out of the country. The earliest I might be back in Alaska would be on a red eye flight arriving Tuesday morning. If any of you have tried to call me, I'm sorry, but I haven't had phone reception. Internet access has also been sporadic. Peter

-Peter S. Goldberg Vice Chairman, Alaska Republican Party Colonel, US Army Retired 907-726-1265 (home) 907-250-8822 (cell)

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Alicé Leuchte
From: Sent: To: Subject: Glenn Clary <gclary@ancbt.org> Tuesday, March 26, 2013 10:38 AM 'secretary@aliceleuchte.com'; 'kpjlaw@yahoo.com' SEC Meeting

Request for Emergency ARP SEC Meeting   
I request an emergency ARP SEC meeting to hear the March 14, 2013 charges  against Debbie H Brown on April 8 at 5:30 pm at the ARP office, 1001 W Fireweed  Lane, Anchorage.    This matter needs to be settled and a fair hearing conducted.  The ARP needs  strong leadership to move forward.  Our ship has been battered by the tumultuous  storms of mistrust, deception, and character assassination.  The sails of united  purpose and transparent communication have been torn and lowered.  This has  caused the power to propel us to the port of significance and influence to be  gravely diminished.  We must repair our sails and chart another course that will  moor us to the dock of victory.  This new course will ensure an ARP US Senator,  Governor and additional State Legislators.  But this course can only be achieved  when all Republican shipmates lay aside personal ambitions.  Each of us must  honestly evaluate our personal abilities and skills to determine the assignment we  can successfully complete on this great political warship.  Only then will the knives  and swords we point at one another be sheathed, causing us to focus our efforts  on our individual tasks at hand.  Having this kind of crew will ensure victory and  success.  It will not matter if our task is to swab the deck, hoist the sail, control the  anchor, prepare the meals, guard the gold, or captain the ship.  We will be united  as the victorious crew of the USS ARP, working together for a common goal, which  is getting Republicans elected.  So put away selfish ambitions and conceits, look  not on to your own desires but to the desires and goals of an entire united crew.  If  your malice is munity and destruction stay on shore.  For the rest, WELCOME  ABOARD!  I am a voting member of the SEC serving as Treasurer. Glenn Clary
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Request for an Emergency Meeting of the Alaskan Republican Party State Executive Committee
Madam Secretary] I Rex Shattuck] Region III Representative] serve notice to the State Secretary and purported Legal Council that we meet in an emergency meeting of the SEC to hear the March 14] 2013 charges against Debbie H Brown. I request this meeting be conducted on April 8 at 5:30 pm in the ARP office at 1001 W Fireweed Lane] Anchorage] and by teleconference for members of the SEC who are unable able to make it to Anchorage. So requested as a voting member of the SEC serving as Region III Representative

Rex Shattuck Region III Representative Alaska Republican Party

Date 1..5 fYlOJl 20/3

Alicé Leuchte
From: Sent: To: Subject: Rhonda Boyles <boyles@gci.net> Sunday, March 24, 2013 4:01 PM kpjlaw@yahoo.com; secretary@aliceleuchte.com SEC meeting request

MR. Jacobus and Ms Leuchte:     I request an emergency meeting of the Alaska Republican Party State Executive Committee on April 8 at 5:30 at the  office of the ARP on Fireweed Lane.    The charges filed against Debbie H. Brown on March 14, 2013 would be the purpose of the meeting.    I am the president and  voting member of the Alaska Federation of Republican Women on the SEC.      Thank you.    Rhonda Boyles at 907‐388‐2606   March 24, Sunday, 2013     

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Alicé Leuchte
From: Sent: To: Subject: Paulette Simpson <paulettem@gci.net> Sunday, March 24, 2013 12:09 PM Kpjlaw@yahoo.com; secretary@aliceleuchte.com emergency meeting

 

March 24, 2013  Dear Mr. Jacobus and Ms. Leuchte:  I hereby request an emergency meeting of the Alaska Republican Party State Executive Committee (SEC) on April 8 at 5:30 pm at the ARP office, 1001 W Fireweed Lane, Anchorage. The purpose of the meeting is to hear the March 14, 2013 charges against Debbie H. Brown. I am a voting member of the SEC, serving as Region VII (Southeast) chair.  Paulette Simpson  907­321­0056 

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Alicé Leuchte
From: Sent: To: Peter Goldberg <padipete@gmail.com> Tuesday, March 26, 2013 12:32 PM Alicé Leuchte; Beka Zerbst; Bruce Schulte; Charlie Huggins; Debbie Joslin; Glenn Clary; Julie Gillette; Mike Chenault; Mike Tauriainen; Ralph Seekins; Randy Reudrich; Rex Shattuck; Rhonda Boyles 2; Steve Strait; DEBBIE BROWN; Kenneth Jacobus Emergency Meeting of the SEC, April 8, 2013, 5:30 p.m., ARP Headquarters PROXYFORMSEC.doc

Subject: Attachments:

All SEC Members: In accordance with Article VI - State Central Committee, Section 6: State Executive Committee, paragraph (c), voting members of the State Executive Committee in excess of 25% of the voting members, have requested an emergency meeting of the State Executive Committee to be held at the Alaska Republican Party Headquarters, 1001 West Fireweed Lane in Anchorage at 5:30 p.m. The requestors are: Bruce Schulte, Paulette Simpson, Rex Shattuck, Rhonda Boyles, Glenn Clary and Steve Strait. The emergency meeting will be held at the time and place requested. The purpose of the meeting is to hold a hearing regarding the charges filed against Chairman Debbie Brown on March 14, 2013 by Bruce Schulte. If you cannot attend, you have the option of sending a proxy in your place. That form is attached. If you do send a proxy, in addition to sending or faxing that form to the ARP Headquarters, I suggest that you have your proxy carry the oriiginal copy.to the meeting. Given the nature of the meeting, please try to attend in person if you are reasonably able to do so. Information for joining the meeting via teleconference will be provided separately. -Peter S. Goldberg Vice Chairman, Alaska Republican Party Colonel, US Army Retired 907-726-1265 (home) 907-250-8822 (cell)

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DEBRA HOLLE BROWN
Chairman April 3, 2013

ALASKA REPUBLICAN PARTY
1001 West Fireweed Lane, Anchorage, Alaska 99503 Phone: (907) 276-4467 • Fax: (907) 276-0425 Visit us online at alaskarepublicans.com

NOTICE

The duties of Chairman include making appointments to offices and committees which serve at the pleasure of the Chairman. With this notice, I am appointing the following Alaska Republicans to serve as State Treasurer and Assistant State Treasurer, effective immediately:

Julie Hamm Liz Vazquez

District 8 District 20

State Treasurer Assistant State Treasurer

Confirmation of these appointed members will be placed on the agenda for the Saturday, 25 May State Central Committee Meeting, to be held in Homer, Alaska.

Sincerely,

Debra Holle Brown Chairman, Alaska Republican Party

Paid for by the Alaska Republican Party • 1001 W. Fireweed Lane, Anchorage, AK 99503. Not authorized or approved by any candidate or candidate committee.

ALASKAREPUBLICANS.COM

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Regional Representative Documentation Regions
From: Randy Ruedrich <raraep@gci.net> Sent: Thursday, January 17, 2013 9:06 AM To: 'Alicé Leuchte' Subject: RE: Do you have access to a fax machine for materials for tomorrow's meeting? The adopted interim rule conforms precisely to the district combinations use before the May elections of Regional Representatives. One change is Gloria Shriver resigned as District Chair which eliminates her as Region IV Representative. District 19 Chair Steve Strait has been elected as the Region IV Representative. From: Alicé Leuchte [mailto:secretary@aliceleuchte.com] Sent: Thursday, January 17, 2013 8:49 AM To: 'Randy Ruedrich' Subject: RE: Do you have access to a fax machine for materials for tomorrow's meeting? Oh, hey… I am getting together the roll for this evening and realized that since the regions changed in December, that there should be new elections for the Regional Reps. Do you have the minutes/election results for the new reps? Alicé Leuchte Secretary, Alaska Republican Party secretary@aliceleuchte.com

Region I
Minutes documenting the proper election process of Beka Zerbst were submitted from the Golden Heart GOP (available upon request). District 38 was not present (unknown reason). District 39 (Nome) was included in Region I in the December 2012 SCC interim rule change; therefore, this district was not represented. Also, Zerbst was never presented to the SCC for confirmation for the appointed position of Region I Finance Chairman, making her ineligible to serve in this office (according to ARP Rules). Please note that once it was realized (April 2013) that District 39 had been left out, Beka Zerbst reached out to the Chairman of District 39, Don Handeland, and has included this district in recent regional activities.

Region II
From: Rex Shattuck [mailto:2akb4udie@gmail.com] Sent: Thursday, January 17, 2013 4:52 PM To: Randy Ruedrich Subject: Historical Report Dear Alaska Republican Party, I was recently asked about historical information related to events in our region. Here is a brief note on several points of interest. In early April 2012 our Region’s Chairmen voted for me to be their representative to State Executive Committee (SEC). Initially Jim Norcross, Lisa Santerre, and Brandon Wahl supported me for the position on the SEC. After further discussion with Chris Mullin and Edna DeVries and answering their questions, they also supported me for the position. I believe these individual voted to support me in this position due to past experience with party process and my commitment to work with them on issues. Over the summer we worked together on a Valley Republican picnic, local political races, and a number of events leading up to the Presidential election. We are presently planning a future meeting and ways to continue our success in the Mat‐Su Valley. Rex Shattuck

Region III
From: Peter Goldberg [mailto:padipete@gmail.com] Sent: Thursday, January 17, 2013 4:04 PM To: Randy Ruedrich Subject: Re: I need a note on your election prior to May 5, 2012 SEC meeting Mr. Ruedrich, I received either verbal concurrence or email concurrence for each of the District Chairman for Region 3 agreeing that I would be the Regional Chairman. All of these concurrences occurred between approximately May 1st and May 4th. There were no abstentions and no votes in the negative. Furthermore, none of the other District Chairs of my Region expressed any interest in being the Regional Representative. I might add that at the last SCC meeting where I was asked to give a Region 3 report, there were no objections from the floor challenging my representation of Region 3 as the Representative. Peter S. Goldberg District 26 Chair Region 3 Representative

Region IV
From: S [mailto:steve@straitmedia.us] Sent: Thursday, January 17, 2013 10:14 AM To: 'Randy Ruedrich' Subject: RE: I need a note on your election prior to May 5, 2012 SEC meeting Randy, Here's a listing of the votes I received to become Dist. 4 Regional Rep. Do you need more details ? Steve Strait District 15 District 16 District 17 District 18 David Morgan 2170 Stanford Dr Anchorage 99508 563‐4812 Spoke with David M. 1/16/03 ‐‐phone call . David agreed to support my position of Region Rep. Kirk Wickersham 280 W 34th Ave Anchorage 99503 561‐3726, 351‐3726 Spoke with Kirk Wickersham 1/15/03 ‐‐phone call . Kirk agreed to support my being the Region Rep. Randy Stevens 830‐4246 Spoke with Randy Stevens by phone Dec 31. He supports my representing Region 4 Ric Davidge 1515 W ThirteenthAve. Anchorage 99501 Ric Davidge, at Dec 30 Dist 18 mtg gave his support for my representing Dist. 18. This was the mtg Gloria resigned Dist Steve Strait Anchorage 99502 248‐1028 I support my representing Region 4 William Spearman 2920 Rita Cir Anchorage 99502 248‐0792; 786‐3910 Spoke with Bill Spearman via phone Dec. 31st. He agreed to support me as Region 4 Rep.

District 19 District 20

Region V
From: Bruce Schulte [mailto:bruce.schulte@gmail.com] Sent: Thursday, January 17, 2013 3:07 PM To: Randy Ruedrich Subject: Fwd: Region 5 Rep selection Randy, On May 7 and in response to the e-mail below, I received the support of all of the District Chairs in my Region to serve as our Regional Rep on the SEC. Cheers, Bruce Schulte

---------- Forwarded message ---------From: Bruce Schulte <bruce.schulte@gmail.com> Date: Sun, May 6, 2012 at 9:27 PM Subject: Region 5 Rep selection To: Andy Clary <abclary@gmail.com>, Joe Riggs <northpeak@hotmail.com>, Richard Giessel <rich@giessel.org>, Jason Pretzel <jpretzel@hotmail.com> Cc: ErikinAK@gci.net, Alex Gimarc <agimarc@ak.net> Gentlemen, We have some unfinished business to complete: Accoring to the ARP rules, we (Region 5 Chairs) are to select our Regional Representative from amongst the various SCC members within our Region (District Chairs and Bonus Votes). As some of you know, I have served as our Regional Rep. since 2010 and I would be honored to continue in that capacity - pending your approval. What say you? Regards, Bruce Schulte District 21 Chair

Region VI
From: Randy Ruedrich <raraep@gci.net> Sent: Thursday, January 17, 2013 4:45 PM To: 'Alicé Leuchte' Subject: Region Rep VI Chris Byrnes confirmed his approval of a Kenai Regional Rep to me at the State Convention From: Mike Tauriainen [mailto:miket@gci.net] Sent: Thursday, January 17, 2013 2:22 PM To: Ruedrich, Jr, Randy Cc: DuPerron, Neal; 'Dick Hawkins' Subject: Region Rep Randy On or about May 4, 2012 I called Neal DuPerron (D29) and Dick Hawkins (D30) to discuss Region Rep for our region. I expressed my willingness to serve in that capacity and they each consented that I be our region’s rep. No meeting was held – just phone calls. I did not call the Kodiak D35 Chair because I did not have any contact information. I did not contact D36 or D 37 chairs because I was not aware they were in our region. Let me know if you need additional information. Mike From: Randy Ruedrich <raraep@gci.net> Sent: Tuesday, January 29, 2013 2:29 PM To: Alice Leuchte (secretary) Subject: Mike Tauriainan update ----- Forwarded message ----From: "Mike Tauriainen" <miket@gci.net> Date: Mon, Jan 28, 2013 6:17 pm Randy I have contacted all Region VII district chairs. Brandt, Sherman and Byrnes concur with previous decision by DuPerron, Hawkins and Tauriainen that Tauriainen be Region VII Rep on SEC. Mike

Region VII
From: Paulette Simpson [mailto:paulettem@gci.net] Sent: Thursday, January 17, 2013 12:18 PM To: randy ruedrich Subject: Region 7 Chair Randy, At the state convention, (Southeast) Region 7 district chairs and district officers did not have time to formally meet so agreed to connect via telephone to formalize regional representation. Ben Brown had previously served as our SEC representative for 4 years. The first week of May, after discussing the issue in person with Connie McKenzie and outgoing chair Ben Brown, I phoned Kathy Hosford in Skagway, Bill Privett in Wrangell and Robert Venables in Haines. All agreed that I should serve as Region 7 representative for purposes of serving on the State Executive Committee. Mr. Privett recalls that I phoned him around Wednesday, May 2. District 31 ‐ Connie McKenzie, Juneau District 32 ‐ Kathy Hosford, Skagway District 33 ‐ Bill Privett, Wrangell District 34 ‐ Robert Venables, Haines Paulette Simpson

KEN JACOBUS
Legal Counsel March 25, 2013 For Your Information:

ALASKA REPUBLICAN PARTY
1001 West Fireweed Lane, Anchorage, Alaska 99503 Phone: (907) 276-4467 • Fax: (907) 276-0425 Visit us online at alaskarepublicans.com

The extent of the power of the Chairman is a substantive legal question and is not a question of parliamentary procedure as McQueary would have you believe. It is very clear that the chairmen of the standing committees serve at the pleasure of the chairman. ARP Rules Article VI, Section 7(c). Mr. McQueary has now been validly removed from his position as chairman of the Rules Committee. It is also very clear that until a person is removed from office, that they continue to act in the office. It is only during the period of appeal that they cannot perform the duties of the office. ARP Rules Article X, Section 5(b). Accordingly, Ms. Brown continues to act in her office as Party Chairman until she is "removed." The filing of a complaint does not effect a removal from office. If that were so, then that complaint against Mr. Ruedrich, which the Executive Committee allegedly ignored for over a year, would have removed him from office immediately, and the position would have to have been filled by the vice-chairman. This never took place. Sincerely, Ken Jacobus Legal Counsel, Alaska Republican Party Kenneth P. Jacobus, PC • 310 K Street, Suite 200, Anchorage AK 99501-2064 Phone (907) 277-3333 • Fax (907) 264-6666 • Email kpjlaw@yahoo.com

Paid for by the Alaska Republican Party • 1001 W. Fireweed Lane, Anchorage, AK 99503. Not authorized or approved by any candidate or candidate committee.

ALASKAREPUBLICANS.COM

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Alicé Leuchte
From: Sent: To: Cc: db@gci.net Friday, March 22, 2013 2:48 PM Jacobus Ken Frank 20/AT McQueary; aklawgal@yahoo.com; Kirk Wickersham; northpoledentist@gci.net; benjamino1789@hotmail.com; robinphillipsak@gmail.com; Becker Eileen; pruitt_maryann@yahoo.com Regarding: ARP Rules Committee

Subject:

22 March 2013 Dear Rules Committee member, This email is to inform you that your appointment to the ARP Rules Committee is hereby terminated effective immediately. Pursuant to the ARP Rules, the chairman and members of each standing and special committee serve at the pleasure of the ARP State Chairman. Many thanks for your past efforts, volunteer service, and contributions to the Rules Committee and the Alaska Republican Party. Sincerely, Debra Holle Brown, Chairman Alaska Republican Party

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Alicé Leuchte
Subject: FW: Current Events

MESSAGES IN REVERSE ORDER READ LAST MESSAGE FIRST

From: Alicé Leuchte [mailto:secretary@arp.aliceleuchte.com] Sent: Sunday, March 24, 2013 4:10 PM To: 'Frank McQueary' Cc: 'Terri Mooradian'; 'Kirk Wickersham'; 'northpoledentist@gci.net'; 'benjamino1789@hotmail.com'; 'robinphillipsak@gmail.com'; 'Eileen Becker'; 'pruitt_maryann@yahoo.com'; 'padipete@gmail.com'; 'Steven R. Strait'; 'Ralph Seekins'; 'Debbie Joslin'; 'dclary@gci.net'; 'Bruce Schulte'; 'Julie Gillette'; 'armorwife@gmail.com'; '2akB4udie@gmail.com'; 'miket@gci.net'; 'Paulette Simpson'; kpjlaw@yahoo.com Subject: RE: Current Events

Hey, Frank!  I spent quite a bit of time reviewing the relevant sections of Robert’s Rules (11th edition, unabridged) and the ARP rules  last night, and found nothing supporting your assertion.  In fact, what is going on in this situation *does not* appear to  be in keeping with the process described for complaints and removal.  Given the liabilities, having ARP Legal involved is very relevant and very important, I have copied Ken Jacobus on this  email (who was appointed and confirmed by the SCC).  In the meantime (and as I did in similar circumstances while Randy was in office), I plan to continue with the business of  the party under the Chairman.  Thank you,  Alicé Leuchte  Secretary, Alaska Republican Party  secretary@arp.aliceleuchte.com   
From: Alicé Leuchte [mailto:secretary@arp.aliceleuchte.com] Sent: Saturday, March 23, 2013 9:11 PM To: 'Frank McQueary' Cc: 'Terri Mooradian'; 'Kirk Wickersham'; 'northpoledentist@gci.net'; 'benjamino1789@hotmail.com'; 'robinphillipsak@gmail.com'; 'Eileen Becker'; 'pruitt_maryann@yahoo.com'; 'padipete@gmail.com'; 'Steven R. Strait'; 'Ralph Seekins'; 'Debbie Joslin'; 'dclary@gci.net'; 'Bruce Schulte'; 'Julie Gillette'; 'armorwife@gmail.com'; '2akB4udie@gmail.com'; 'miket@gci.net'; 'Paulette Simpson' Subject: RE: Current Events

Hey, Frank!  I appreciate your response to my question.  I will check out RoR tonight.  Thanks!  Alicé Leuchte  Secretary, Alaska Republican Party  secretary@arp.aliceleuchte.com   
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From: Frank McQueary [mailto:fmcqueary@gci.net] Sent: Saturday, March 23, 2013 8:53 PM To: secretary@arp.aliceleuchte.com Cc: 'Terri Mooradian'; 'Kirk Wickersham'; northpoledentist@gci.net; benjamino1789@hotmail.com; robinphillipsak@gmail.com; 'Eileen Becker'; pruitt_maryann@yahoo.com; padipete@gmail.com; 'Steven R. Strait'; 'Ralph Seekins'; 'Debbie Joslin'; dclary@gci.net; 'Bruce Schulte'; 'Julie Gillette'; armorwife@gmail.com; 2akB4udie@gmail.com; miket@gci.net; 'Paulette Simpson' Subject: RE: Current Events Importance: High

Alice:  These questions all default to Roberts Rules where it is quite clear that once charges are leveled the charged  officer loses the power to act in any official capacity.  This is not a legal question, it is one of parliamentary  procedure.  So whatever the other issues that you bring up, until the SEC and SCC rule on the charges against Ms. Brown  she can no longer act in any official capacity for the party nor can she instruct you or any other official in any manner.  Cordially,  Frank McQueary 
From: Alicé Leuchte [mailto:secretary@arp.aliceleuchte.com] Sent: Saturday, March 23, 2013 6:26 PM To: Frank McQueary Cc: 'Terri Mooradian'; 'Kirk Wickersham'; northpoledentist@gci.net; benjamino1789@hotmail.com; robinphillipsak@gmail.com; 'Eileen Becker'; pruitt_maryann@yahoo.com; padipete@gmail.com; 'Steven R. Strait'; 'Ralph Seekins'; 'Debbie Joslin'; dclary@gci.net; 'Bruce Schulte'; Julie Gillette; armorwife@gmail.com; 2akB4udie@gmail.com; miket@gci.net; 'Paulette Simpson' Subject: RE: Current Events

Hey, Frank!  I have a question, and a few points of clarification:  "It is my understanding of the rules that she does not have this power while charges are pending and that she only has it  in the normal course of events with the advice and consent of the SCC."  Could you please direct me to the article(s) & section(s) of the rules which apply, specifically to your first point?  I believe  the second aspect has already been addressed by ARP Legal.  "Since I and you were all appropriately appointed to two year terms after the last convention we would expect to serve  until the next convention unless replaced with the approval of the SCC."  The Rules Committee appointments were not presented, declared or approved at the SCC Meeting following the  convention (April 28, 2012 SCC Minutes attached).  In fact, I didn't even known who the members of the Rules  Committee were until this week, and I am now halfway through my term.  What makes this really surprising is that, according to the rules (VI.7f), the Chairman of each Standing Committee is to  submit minutes of each meeting of their committee to the State Secretary.  This includes the Rules Committee, yet I  have received none.  “While we can only speculate as to the motives of the various groups involved (Ron Paul, Occupy Wall Street and Joe  Miller) there is some speculation that the intent was to take over the Party, suspend the rules and convert to a caucus  based selection process for our statewide candidates.” 
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Every time you speculate about the motives of “those people,” it is something different.  Last spring it was about  stealing the elections or stealing all of the National Delegates – and now you say it was about changing to a caucus  system?!  It is almost like you aren’t actually speculating at all, but instead just fanning the flames of the division in the party to  motivate people your way.  “I know that the turmoil has taken its toll on our morale, however, we must remember that the rules were written the  way they were to enable our organization to protect itself from the kind of external  attacks which we are currently  experiencing.  The SEC and SCC will act in the best interests of the party vis a vis Debbie.”  I really like you, Frank, and I sincerely respect the work you have done for the party; however, I have to call you out at  this point.  I am sick of hearing about “these people” and “those people” in reference to *Republicans.*  Debbie Brown is not some external force attacking the party.  She is the Chairman, and she was unequivocally *elected*  at the State Convention to serve the party.  Sincerely,  Alicé Leuchte  Secretary, Alaska Republican Party  secretary@arp.aliceleuchte.com   

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Alicé Leuchte
Subject: FW: Your Point of Order

MESSAGES IN REVERSE ORDER READ LAST MESSAGE FIRST

From: Alicé Leuchte [mailto:secretary@arp.aliceleuchte.com] Sent: Tuesday, March 26, 2013 1:39 PM To: padipete@gmail.com Cc: kpjlaw@yahoo.com; Julie Gillette Subject: FW: Your Point of Order

Peter,  I am standing up for what I believe by asking about the process being followed in this situation.   Let me make this clear: My demanding to know what process this complaint has followed has nothing to do with whom  the charges are against.  I would be concerned for the same reasons if it were anyone else, including you.  And I fully think your letter is sincere.  I also think there is a disturbing similarity between this letter and the one  floating around that you sent Debbie March 12 that states she would face more charges, a hearing, and unequivocally be  removed from office if she didn’t take your suggestion to resign.  And you wrote this email before any charges had been  submitted!  That doesn’t look good at all, Peter.  I hope you aren’t making this a pattern.  Alicé Leuchte  Secretary, Alaska Republican Party  secretary@arp.aliceleuchte.com   
From: Peter Goldberg [mailto:padipete@gmail.com] Sent: Tuesday, March 26, 2013 12:57 PM To: Alicé Leuchte Subject: Your Point of Order

Alice, This is just to you. I told you that I hope you will stay on as secretary of the ARP regardless of what happens in the next few weeks. We both know that there are some personality conflicts going on and I hope to broker some peace between conflicting parties. (That comment has nothing to do with the charges against Mrs. Brown.) I'd be happy to discuss them more specifically at a later date. This note is to specifically ask you to participate in the hearing. If you stay away out of protest, you set yourself up for possible later charges since we are obligated to attend meetings (or send a proxy). I would not like to see charges brought against you. I think you are a valuable asset and want you to be part of the ARP hierarchy. Another reason that I want you to be part of the meeting is because I have the distinct impression that you believe that Debbie is getting a raw deal. She deserves a fair hearing. She deserves to have folks on her side that believe in her. If you do support her, then the April 8th meeting will be the place to go on record as having done so. I thing most folks would respect you more for standing up for your beliefs than for boycotting the meeting. I pray that you will receive these comments as sincere. Peter S. Goldberg Vice Chairman, Alaska Republican Party Colonel, US Army Retired

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CENSURE OF THE ARP SECRETARY (AS TRANSCRIBED)
April 29, 2013 Submitted by Steve Strait Seconded by Bruce Schulte

Steve Strait: “This is a motion to censure the Secretary of the ARP.” The purpose of this censure is “to reprimand the member with the hopes of reforming him or her so that the behavior won’t occur again…. The result of a censure, if it were to pass, would be that the member is put on notice, that if he or she repeats the offense, he or she could be suspended or removed from membership or office.” The censure reads:

WHEREAS, the Secretary violated her duties by not forwarding timely information to the membership regarding SEC actions taken place April 8 to remove the current Chair and appoint Peter Goldberg as the new Chair; and WHEREAS, the following removal of Chair Brown on April 8, the Secretary issued a factually incorrect press release the next day on RPA letterhead, stating that Debbie Holle Brown remains the current ARP Chairman; WHEREAS, the Secretary falsely stated in her April 9 press release on ARP letterhead that 25% of the voting membership did not call the SEC meeting; WHEREAS, the Secretary incorrectly announced in her April 9 press release “The complaint did not go through the proper process before the call of the meeting” referring to Brown’s hearing; WHEREAS, the Secretary worked against the Republican Party of Alaska showing disloyalty, spreading confusion to party members during a critical time of leadership change; and WHEREAS, such conduct was detrimental to the organization; NOW THEREFORE BE IT RESOLVED, that the ARP Secretary be censured.

This motion did not pass as a written censure. Instead, it was decided to let the reading of this resolution serve as a “verbal reprimand,” to be followed by a written complaint and/or removal. Also, this item of business was expunged from the minutes at the request of the body.

This resolution was transcribed from the audio of the April 29, 2013 meeting held by Vice Chairman Peter Goldberg. Transcribed by Alicé Leuchte (the ARP Secretary).

From: Alicé Leuchte [mailto:secretary@arp.aliceleuchte.com] Sent: Friday, May 17, 2013 5:32 PM To: 'Peter Goldberg' Cc: 'Frank Jeanne McQueary'; 'bruce.schulte@gmail.com'; 'Pam Raygor'; 'Ralph Seekins'; 'paulettem@gci.net'; 'arpasstsecgillette@yahoo.com'; 'Christy Strutz - RPA'; kpjlaw@yahoo.com; 'S' Subject: RE: Revised Agenda Item Special Rules of Order Peter – I know precisely what was addressed at your meeting April 29, as I listened to the recordings. This “committee” was to address a very specific subject. From the attached: “Pam Raygor stated that RoR gives the society the right to protect itself. The society can stop its meeting and have a person removed that is doing something against the will of the body. The person can also be accused of trespassing if he refuses to leave after a vote of removal by the body. A committee of the following people will meet and determine a course of action: Frank McQueary, Pam Raygor, Ken Jacobus, and St eve Strait.” My job does not include agreeing with or voting with another officer, misleading members about independent proposals or playing mail server for unofficial business. Nor does it include supporting unethical behavior. Sorry. I am the Secretary, and Julie is the Assistant Secretary. Together, we two determine how our responsibilities will be carried out and divided. Thank you, Alicé Leuchte Secretary, Alaska Republican Party secretary@arp.aliceleuchte.com From: Peter Goldberg [mailto:padipete@gmail.com] Sent: Friday, May 17, 2013 5:01 PM To: secretary@arp.aliceleuchte.com Subject: Re: Revised Agenda Item Special Rules of Order

MESSAGES IN REVERSE ORDER READ LAST MESSAGE FIRST

If you had bothered to do your job and be part of the last SEC meeting you would understand what this special committee was doing. They came up with a recommendation for conducting business at the SCC meeting in Homer. It still requires SCC approval. The secretary is recording, I.e. Julie since you won't be there. Julie will be assisted in vote counts by two folks to be appointed. For the appeals, the respondent will pick one and the complainant the other to assist Julie. If you want to stay on as Secretary, stop refusing to do your job. Peter On Friday, May 17, 2013, Alicé Leuchte wrote: Discipline Committee?! Are you guys now creating new committees in secret, and making decisions about how business will be conducted without consulting with those who will be affected? Three clarifications: 1. The Secretary reserves the right to record. 2. Votes from those on the phone need to be copied to the Secretary. 3. This is not a communication or proposal from an official body within the Party; therefore, I will not be sending this out. Thanks, Alicé Leuchte Secretary, Alaska Republican Party secretary@arp.aliceleuchte.com From: S [mailto:steve@straitmedia.us] Sent: Friday, May 17, 2013 1:53 PM To: Peter Goldberg; secretary@arp.aliceleuchte.com Cc: Frank Jeanne McQueary; bruce.schulte@gmail.com; Pam Raygor; Ralph Seekins; paulettem@gci.net; arpasstsecgillette@yahoo.com; Christy Strutz - RPA Subject: Revised Agenda Item Special Rules of Order

Peter Goldberg, Our discipline committee met again this morning via phone calls and agreed to revise agenda item “Special Rules of Order for the May 25 Homer meeting. We trimmed our Motion by eliminating Items already covered by RPA and R.R.s. This tidy's up the motion significantly and we wish to thank those who made these suggestions. Please accept this as an agenda item Motion "Special Rules of Order" immediately following Introductions on the agenda. I am copying our Secretary so this can be placed on the agenda and distributed to SCC members in advance of our May 25 Meeting. Sincerely, Steve Strait Chair Discipline Committee Reg. 4 Rep Chair Dist. 19

ARP State Central Committee May 25, 2013 Special Rules of Order The following Special Rules of Order are presented for adoption with the intention using them to conduct SCC business. These Special Rules of Order are subordinate to the Alaska Republican Party Rules, and National Republican Party Rules. Voting Body SCC members and those carrying Proxy voting authorizations will be issued name tags which must be worn at all time during the meeting. Floor Tellers Floor Tellers shall be appointed to count, tabulate and report to the Chair standing votes. A record of the tabulated vote shall be entered in the minutes. All doors are to be secured during a counted vote, only floor tellers shall be permitted to move about. Phone Tellers Phone Tellers shall be appointed to monitor teleconference calls to ensure members are afforded the ability to participate and to count, tabulate and report voice votes to the Secretary. Voting Members in attendance must remain in their seats at the time the vote is taken. Members participating telephonically may vote by conveying their vote to the Phone Tellers by email or text; using pre-determined or recognizable contact information that has been previously provided to the ARP. Conduct of Members and Guests Attendees shall not record audio or video, videotape, broadcast, transmit, photograph, without prior permission of the Chair. Press/Media shall be accredited by the Chair and shall be identified with Name Badge and Organization. Please turn off or mute cell phones, etc.

From: Alicé Leuchte [mailto:secretary@arp.aliceleuchte.com] Sent: Friday, May 17, 2013 9:23 PM To: 'S'; 'Pamela Ann Raygor' Cc: 'Peter Goldberg'; 'Frank Jeanne McQueary'; 'bruce.schulte@gmail.com'; 'Ralph Seekins'; 'paulettem@gci.net'; 'Julie Gillette'; 'Christy Strutz - RPA'; 'kpjlaw@yahoo.com' Subject: RE: Publish the Agenda for May 25 Steve – Pursuant to ARP Rules Article VI, Section 15(a) - stating “The State Secretary and the Assistant State Secretary shall divide and perform such duties as are mutually agreeable between them to carry out the duties of the ARP Secretary” - you are in no position to dictate how or when these duties are carried out. Thank you, Alicé Leuchte Secretary, Alaska Republican Party secretary@arp.aliceleuchte.com

MESSAGES IN REVERSE ORDER READ LAST MESSAGE FIRST

From: S [mailto:steve@straitmedia.us] Sent: Friday, May 17, 2013 9:16 PM To: secretary@arp.aliceleuchte.com; 'Pamela Ann Raygor' Cc: 'Peter Goldberg'; 'Frank Jeanne McQueary'; bruce.schulte@gmail.com; 'Ralph Seekins'; paulettem@gci.net; 'Julie Gillette'; 'Christy Strutz - RPA'; kpjlaw@yahoo.com Subject: Publish the Agenda for May 25 Madame Secretary, Please be cognizant of your duties under RPA rules , see RPA highlights below. The Chair has directed you to publish the agenda as submitted. Please do so this evening. Steve Strait Reg. 4 Rep From: Peter Goldberg [mailto:padipete@gmail.com] Sent: Friday, May 17, 2013 5:01 PM To: secretary@arp.aliceleuchte.com Subject: Re: Revised Agenda Item Special Rules of Order If you had bothered to do your job an d be part of the last SEC meeting you would understand what this special committee was doing. They came up with a recommendation for conducting business at the SCC meeting in Homer. It still requires SCC approval. The secretary is recording, I.e. Julie since you won't be there. Julie will be assisted in vote counts by two folks to be appointed. For the appeals, the respondent will pick one and the complainant the other to assist Julie. If you want to stay on as Secretary, stop refusing to do your job. Peter

Article VI, Section 11 : Functions and Duties of the State Secretary. The State Secretary shall be responsible for keeping the minutes of all SCC meetings and for maintaining the current RPA records and files. He shall be responsible for the giving and serving of all SCC notices and shall perform such other duties as shall be required by the SCC or the State Chairman. The State Secretary shall transmit SCC and State Executive Committee minutes to all members within a period of not more than thirty (30) calendar days.

DEBRA HOLLE BROWN
Chairman March 26, 2013

ALASKA REPUBLICAN PARTY
1001 West Fireweed Lane, Anchorage, Alaska 99503 Phone: (907) 276-4467 • Fax: (907) 276-0425 Visit us online at alaskarepublicans.com

NOTICE

The duties of Chairman include making appointments to offices and committees which serve at the pleasure of the Chairman. With this notice, I am appointing the following Alaska Republicans to serve as members of the Rules Committee, effective immediately:

Lance Roberts Chris McMullins Ron Johnson Randy Stevens Rich Giessel Neal DuPerron Alice Leuchte

District 5 District 10 District 11 District 17 District 27 District 29 District 32

Committee Chairman

Confirmation of these appointed members will be placed on the agenda for the Saturday, 25 May State Central Committee Meeting, to be held in Homer, Alaska.

Sincerely,

Debra Holle Brown Chairman, Alaska Republican Party

Paid for by the Alaska Republican Party • 1001 W. Fireweed Lane, Anchorage, AK 99503. Not authorized or approved by any candidate or candidate committee.

ALASKAREPUBLICANS.COM

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