OFFICE OF ADMINISTRATIVE COURTS,

STATE OF COLORADO
1525 Sherman Street, 4th Floor
Denver CO 80203
________________________________________________________________________________________________________

Complainant:
CAMPAIGN INTEGRITY WATCHDOG (CIW)
v.
Respondent:
DENVER COUNTY REPUBLICAN CENTRAL COURT USE ONLY
COMMITTEE (DCRCC)
Attorney or Party Without Attorney (Name and Address):
Matthew Arnold, Pro Se for Campaign Integrity Watchdog Case No.: OS 2017-0006
P.O. Box 372464, Denver CO 80237
(303) 995-5533
Email: campaignintegritywatchdog@gmail.com
STIPULATION AND JOINT MOTION FOR ENTRY OF STIPULATED JUDGMENT

Pursuant to Office of Administrative Courts Procedural Rule 15, and Colorado Rule of
Procedure 54, Complainant Campaign Integrity Watchdog (CIW) and Respondent Denver
County Republican Central Committee (DCRCC) jointly move for entry of a Stipulated
Judgment in the form attached hereto.
The parties hereby stipulate as follows:

(Failure to Accurately and Properly Report Individual Contributions)

1. DCRCC failed to timely, accurately and properly report twenty-eight (28) individual
contributions, as required by law, until filing the 8 December 2016 Report of Contributions and
Expenditures (RCE) as listed in paragraphs 11 (a-bb) and 14-19 of the Complaint, as follows:
a. $100 contribution from A. Barry Brandt reported received on 4/6/2015
b. $50 contribution from Judith Case reported received on 6/12/2016
c. $25 contribution from Fletcher Cole reported received on 10/7/2016
d. $50 contribution from Frank DeFilippo reported received on 12/29/2015
e. $50 contribution from Oborne Jefferson Dykes reported received on 4/6/2015
f. $75 contribution from Oborne Jefferson Dykes reported received on 6/15/2015
g. $25 contribution from Celeste Gamache reported received on 6/8/2016
h. $205 contribution from George Gramer reported received on 10/7/2016
i. $25 contribution from Brenda Harms reported received on 6/16/2016
j. $50 contribution from Sara Holmes reported received on 6/12/2016
k. $25 contribution from John Kidd reported received on 11/16/2015
l. $25 contribution from John Kidd reported received on 12/16/2015
m. $25 contribution from John Kidd reported received on 1/19/2016
n. $25 contribution from John Kidd reported received on 2/16/2016
o. $25 contribution from John Kidd reported received on 3/16/2016

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 p. $25 contribution from John Kidd reported received on 4/20/2016
q. $25 contribution from John Kidd reported received on 5/16/2016
r. $100 contribution from Marilyn Marks reported received on 12/4/2015
s. $25 contribution from Susan Moore reported received on 6/13/2016
t. $100 contribution from Flo Nath reported received on 4/6/2015
u. $100 contribution from Janet OCallaghan reported received on 10/7/2016
v. $50 contribution from Joan Poston reported received on 6/6/2016
w. $35 contribution from Jennifer Qualtieri reported received on 10/7/2016
x. $500 contribution from Daniel Ritchie reported received on 2/3/2016
y. $50 contribution from Robert Seklemian reported received on 4/6/2015
z. $100 contribution from Paul Steinhauer reported received on 4/6/2015
aa. $20 contribution from Jacob Viano reported received on 10/7/2016
bb. $500 contribution from Fred Wulff reported received on 4/6/2015
2. DCRCC agrees that, per statute, the applicable penalties would equal $50 per day per
violation for each of the violations set forth in paragraph 1 (a through bb). Given that many of
the contributions were unreported for over a year, applicable statutory penalties could potentially
thus total many thousands of dollars.
3. Both parties agree that imposition of the full amount of penalties specified per statute, in
light of Respondent DCRCCs acceptance of responsibility and agreement to amend their past
reports to rectify the multiple compliance failures, would be excessive.
4. DCRCC agrees to remit to the Colorado Secretary of State a civil penalty in the amount
of fifty dollars ($50), representing a civil penalty of fifty (50) dollars total in connection with the
contributions not timely and accurately disclosed until DCRCCs 8 December 2016 Report of
Contributions and Expenditures (RCE).
5. DCRCC further agrees to correct and amend the committees previous Reports of
Contributions and Expenditures (RCE) for each of the above contributions within 30 days or pay
a suspended penalty of $500 within 30 business days of the Effective Date of this Agreement.
(Failure to Accurately and Properly Report Committee Disbursements)
6. DCRCC failed to timely, accurately and properly report twenty-two (22) committee
disbursements, as required by law, as set forth in paras. 12 (a through v) and 20-23 of the
Complaint, as follows:
a. $593.75 paid to 1660 S. Albion LLC reported expended on 5/27/2016
b. $483.84 paid to All My Sons Moving reported expended on 5/19/2015
c. $860.00 paid to Colorado Chinese News reported expended on 10/17/2016
d. $900.00 paid to Colorado Dragon Boat Festival reported expended on 6/8/2016
e. $21.58 paid to Colorado Liquor Mart reported expended on 10/5/2016
f. $191.00 paid to Cube Smart reported expended on 2/19/2015
g. $285.00 paid to Denver GOP Municipal Account reported expended on 5/27/2016
h. $26.16 paid to King Soopers reported expended on 5/1/2015
i. $89.94 paid to Meetup.Com reported expended on 10/11/2016
j. $275.00 paid to Mile High Catering reported expended on 5/2/2015
k. $37.43 paid to Office Depot reported expended on 10/17/2016
l. $43.05 paid to Office Depot reported expended on 10/26/2016

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 m. $86.61 paid to Party City reported expended on 4/29/2015
n. $45.16 paid to Party City reported expended on 5/1/2015
o. $146.85 paid to Staples reported expended on 5/1/2015
p. $70.00 paid to Tavern Hospitality Group reported expended on 10/3/2016
q. $140.39 paid to Tavern Hospitality Group reported expended on 10/5/2016
r. $210.39 paid to Tavern Hospitality Group reported expended on 10/11/2016
s. $80.00 paid to Tavern Hospitality Group reported expended on 10/18/2016
t. $188.54 paid to Tavern Hospitality Group reported expended on 10/20/2016
u. $593.75 paid to Tower 1660 reported expended on 10/3/2016
v. $450.00 paid to Weekly Focus reported expended on 10/17/2016
7. DCRCC agrees that, per statute, the applicable penalties would equal $50 per day for
each of the violations set forth in paragraph 6 (a through v, inclusive). Given that many of the
contributions were unreported for over a year, applicable statutory penalties could potentially
thus total many thousands of dollars.
8. Both parties agree that imposition of the full amount of penalties specified per statute, in
light of Respondent DCRCCs acceptance of responsibility and agreement to amend their past
reports to rectify the multiple compliance failures, would be excessive.
9. DCRCC agrees to remit to the Colorado Secretary of State a civil penalty in the amount
of fifty dollars ($50), representing a civil penalty of fifty (50) dollars total in connection with the
twenty-two (22) disbursements not accurately disclosed until DCRCCs 8 December 2016 RCE.
10. DCRCC further agrees to correct and amend the committees previous Reports of
Contributions and Expenditures (RCE) for each of the above disbursements or pay a suspended
penalty of $500 within 30 business days of the Effective Date of this Agreement.

(Amendment of Report of Contributions and Expenditures)

11. Respondent agrees to file Amended Reports of Contributions and Expenditures for each
of the reports containing violations (unreported contributions and/or disbursements) within 30
business days of the Courts entry of a Stipulated Judgment in this matter, correcting the
reporting errors and violations for each of the matters listed above.
12. Parties agree that failure to file Amended Reports of Contributions and Expenditures for
each of the violations listed above within 30 business days of the Courts entry of a Stipulated
Judgment in this matter which correct the reporting errors and violations for each of the matters
listed above shall trigger the imposition of the suspended penalty of $500 for each claim for
relief not corrected and amended, as described above in paragraphs 5 and 9, respectively.

CONCLUSION
The Parties Stipulation is subject to approval by the Administrative Law Judge, and shall
become binding upon the parties hereto (without any right to appeal or review) upon such
approval. In the event the Administrative Law Judge does not approve this Stipulation, the
parties are not bound by the terms of this Stipulation and shall retain all rights, claims, and
defenses available to them in this action.

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 In support of this Motion, and pursuant to Office of Administrative Courts Procedural
Rule 19, the parties hereby notify the Administrative Law Judge that they have reached an
agreement to settle this action subject to, and in accordance with, the terms set forth above and in
the proposed Stipulated Judgment.

Dated this 14th day of June, 2017.

CAMPAIGN INTEGRITY WATCHDOG

By: __/signed/ Matt Arnold_______________

Matthew Arnold
PRO SE FOR COMPLAINANT

DENVER COUNTY REPUBLICAN CENTRAL COMMITTEE

By: __/signed/ ________________________

Jake Viano, DCRCC Chairman

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 CERTIFICATE OF SERVICE

The undersigned hereby certifies service of the foregoing JOINT MOTION TO

VACATE HEARING by electronic filing or E-mail, as indicated, on this 14th day of June 2017,
addressed to the following:

Office of Administrative Courts (Electronically filed via CaseConnect)

1525 Sherman Street 4th Floor
Denver, CO 80202

Jake Viano (E-Mail)

Denver County Republican Chairman
1660 S. Albion Street, Suite 708
Denver, CO 80222
(720) 364-5532
chairman@denvergop.org

Matthew Arnold
Campaign Integrity Watchdog
P.O. Box 372464
Denver, Colorado 80237

Campaign Integrity Watchdog

___/signed/ Matt
Arnold ________________
MATTHEW ARNOLD, pro se for
Campaign Integrity Watchdog
P.O. Box 372464
Denver, Colorado 80237

DENVER COUNTY REPUBLICAN CENTRAL COMMITTEE

By: __/signed/ ________________________

Jake Viano, DCRCC Chairman

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