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Republican Party of Virginia 97" Republican Legislative District Committee First District Republican Committee May 9, 2019 CONTEST AND APPEAL OF SCOTT WYATT INTRODUCTION Petitioner Scott Wyatt makes this contest and appeal and states the following in support thereof: The 97" Legislative District Committee (the “Committee”) of the Republican Party of Virginia (the “RPV") selected a convention (the “Convention” as the method of nomination for the Republican candidate for the 97" House of Delegates District (the “District”), and issued a call for such convention (the “Call”)' to be held on May 4, 2019. In reliance on the Call, the Republican unit committees in the District held mass meetings and selected delegates and alternate delegates for the Convention, and those delegates were certified to the Convention. The Convention was held and Petitioner Scott Wyatt was declared the victor and, therefore, the Republican nominee for the District. " A copy of the Call is attached as Exhibit A. Two members of the Committee have made extraordinary efforts to change the method of nomination afier the mass meetings had been convened and the Convention delegates and alternates selected and certified to the Convention. As will be discussed below, such an effort is at odds with Robert’s Rules of Order, The Plan of Organization of the Republican Party of Virginia (the “Plan”), and Commonwealth law. In furtherance of their effort to change the method of nomination, and thereby nullify the mass meetings, and unseat and disenfranchise the Convention delegates and alternates who had been certified, these two members have purported to pass a motion (the “Rescission Motion”) rescinding the motion originally designating the Convention as the method of nomination and instead designating a party canvass to be held on June 1, 2019 (the “Canvass). In addition, those ‘two members of the Committee have purported to approve a call (the “Canvass Call”) for the Canvass. In order to achieve their goals, these two members have purported to conduct business after meetings of the Committee have been adjourned by the Chairman, and at a ‘meeting’ of the Committee that was the subject of neither a motion to adjourn or a valid call. Petitioner contests all of the purported business of the Committee that was not conducted at a validly calléd meeting. Petitioner further contests the validity of the Rescission Motion because it: (i) was out of, order, since it purports to undo actions that cannot be undone, specifically because it purports to nullify the mass meetings, and unseat and disenfranchise the Convention Delegates who had been certified and (ii) violates the duty of the Committee and its members to remain neutral in contested nomination processes and to act in good faith. Likewise, Petitioner contests the validity of the Canvass Call for the same fundamental reasons; i.e., once the mass meetings had been conducted and the delegates chosen, the Committee lacked the power to unseat such delegates or void such mass meetings by changing the method of nomination, and the attempt to do so is a brazen effort to favor one candidate over another, in violation of the Plan and Robert's Rules of Order. AUTHORITY OF THE COMMITTEES This contest is authorized and brought pursuant to Article X, Section B of the Plan, Petitioner was adversely affected by the Rescission Motion and Canvass Call inasmuch as Petitioner is a declared and qualified candidate for the RPV nomination for the District who has i) campaigned for such office on the basis of the Committee’s selection of the Convention as the nomination process and (ii) participated in the mass meetings, which are a necessary and essential part of such nomination process. Petitioner also was adversely affected by conduct of Committee business outside of valid meetings inasmuch as he is a Republican and a resident of the District with an interest in the integrity and faimess of the meetings of the Committee and its nomination processes. Also, among the co-petitioners who join in this contest are many individuals who had been selected and certified to be delegates to the Convention. This contest can be brought before the Committee, pursuant to Article X, Section B.2 of the Plan, as the Legislative District Committee within which the dispute arose. This matter also * CDC”) pursuant to can be appealed directly to the First District Republican Committee (the “ Article X, Section B.3 of the Plan, since the Committee has already reconsidered and reaffirmed its decision, when it rejected a motion to reconsider the approval of the Canvass Call. Because this matter is time sensitive, Petitioner requests the I" CDC take this matter up immediately, to ensure prompt, fair and impartial adjudication by a body that has not already addressed the