60 UPTON LANE

LONDON E7 9LN
TEL: 020 3500 0185
FAX: 020 7018 9478

24 June 2022
Direct Phone: 020 3500 1447
Direct Email: khaled@exons.legal
Mr Matt Gaffar
National Organiser, SERA
200A Pentonville Road
London N1 9JP

By email also: organiser@sera.org.uk and enquiries@sera.org.uk

Dear Mr Gaffar

Our client: Mr Harry Stratton

We act for Mr Harry Stratton, a member of the Socialist Environment and Resources Association
(“SERA”), of which you are the National Organiser. We refer to the letter dated 23 June 2022
which you sent us on behalf of SERA’s directors, Jake Sumner and Melanie Smallman. You
indicated that you also agreed with the content of that letter.

By our letter of 17 June 2022, we had asked you a number of specific questions about the conduct
of the ballots, and specifically requested the appointment of independent tellers. If, as you say, the
election is being conducted fairly and transparently, you should have no problem with answering
these questions. If you cannot, or will not, the only reasonable inference is that the election is not
in fact being conducted fairly.

You say that the same electorate received ballots on 4 June 2022 and 7 June 2022. How many
ballots were issued on each occasion, and can you provide the Election Runner receipts or any
other evidence from Election Runner showing this number? Our client is aware that a number of
additional ballots were issued on 7 June 2022 to people who were previously not considered
eligible voters, and that more eligible voters were being added to the rolls as late as Wednesday
22 June (nearly three weeks after the rolls had closed), for the specific purpose of influencing the
result of a “challenging” election. Part of that evidence is appended to this letter at Appendix A.
You say that there was no result from the original ballot. The Election Runner platform produces
a tally of votes even for an election that had been terminated early. What was that tally? Please

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provide original Election Runner receipts showing the numbers. Who did you consult in making
the decision to cancel the election? Did those people include Gurinder Singh Josan? Please
provide the original correspondence.

Our nominees for independent tellers of the election result are Andy de Emmony
(andydedirect@mac.com) and Pat Quigley (langleylane@hotmail.co.uk). Please allow them
access to the Election Runner platform at their email addresses. We would be grateful if they
could be allowed direct access to both ballots to verify that the receipts are accurate. They are
both prepared to sign a declaration of their compliance with data protection legislation.

If the election is being conducted fairly, it should be straightforward enough for you to answer
these questions and permit the appointment of independent tellers and you should have no
problem with doing so. If you cannot do this, it is difficult to avoid the inference that the election
is not being conducted fairly, and our client would have little choice but to commence
proceedings seeking a declaration, inter alia, that the election result would be null and void.
Furthermore, if, despite your assurances to the contrary, voters had been added to the rolls after 4
June 2022, declaring a result on this basis would amount to fraud and our client would seek
findings of personal dishonesty against those involved.

We would be grateful for a response urgently and at the latest by 12pm on Monday 27 June
2022. We note that your last response was sent to us two days after the deadline. Our client
suspects that you may be deliberately delaying things. The information we are seeking in this
letter is readily available to you and therefore it should not take you long to comply with our
client’s requirements.

Yours sincerely

Enc.

2
Appendix A