Executive Summary ‘Tim Griffin - Outline of Key Dates December 17, 2017 by Tim Griffin (“TG”) as the date he began residing 2 This is an Airbnb in Forest. Based on Court testimony, itis believed that the date of “2017” is a typo and that the actual date he began residing in Forest was in 2019. ‘Source: Interrogatory Answers, signed under Oath on November 20, 2620. December 17, 2019 ‘This appears to be the actual date that TG ‘began living at the Airbnb in Forest ‘Source: Court testimony on November 3, 2021, audio tape transcript ‘March 7, 2020 ‘TG begins serving as the Chairman of the Bedford GOP July 5, 2020 TG is charged with a violation of Maryland. Jaw ...” Feed, Touch, Tease, Frighten, Intentionally disturb wildlife.” The address for TG on the Cour citation pLynchburg, VA (this was ‘the former ‘of his mother in Lynchivurg) ~ far beyond the 30 Days allowable by State Law to change one’s driver’s license, ‘Court Hearing set for 10-2-20 RECEIVED APR 06 2023July 31, 2020 October 2, 2020 ‘November 3, 2020 November 20, 2020 June 2021 ‘November 2, 2021, ‘This is the date that TG provided the Court as the date that at w resided ati According to Court testimony, TG lived at the Forest address for about 8 months in 2020, after which he never returned (not even for one night), The Court testimony from the owner of the Airbnb is that there ‘was no rental agreement or any other kind of written agreement with TG. TG used the address of the Airbnb ‘as his “personal for the next year and a half. ‘Source: Court testimony from the owner of the Airbnb on November 3, 202) and Interrogatory Answers from TG, signed under oath on November 20, 2020. TG did not appear for Court on 10-2-20, an Axrest Warrant was issued on 10-30-20, ‘TG votes in General Election (AB 10-6-20) ‘TG files Interrogatory Answers — signed under Oath and states: “The address where I resided from Nover ic until J ‘ince that time, ] have ‘been working on the campaign out of state (primarily in Michigan) and I have not had a local residence.” (Emphasis added) Source: Court documents ‘1G votes in Republican Primary Election (AB 52-21) 7G votes in General Election (AB 9-30-21)‘November 3, 2021 ‘November 22, 2021 Lynchburg Circuit Court enters Final Order in domestic matter with TG's former wife. The issue of TG’s residency and/or permanent residence was addressed extensively. Judge states that TG was “essentially homeless.” ‘The owner of the testified that TG lived at residence for about 8 months, but left over a year and a halfago. He fold the Court that TG had not retumed since that time, not even for one night. He told the Court that he and TG had not had any written rental agreement, or any written agreement of any kind. He told the Court that be did not have an issue with TG using that location as his “address” to receive mail. He was represented to the Court as an acquittance of TG. ‘The Circuit Court Judge stated that am Airbnb is not a residenee or permanent address (emphasis added). Neither TG nor his attorney provided the Court with an actual address to place in the Order for TG, after the Court took a brief recess to allow TG and his attorney to discuss the “addross” matter. After the brief recess, TG’s attorney told the Court“... basically does not have a permanent address.” ‘The Judge stated that he would was not going to put the Airbnb address in the Order as Mr. Griffin's address because an Airbub is not a permanent address. ‘The Judge stated that TG did not have a permanent address. Source; Audio transcript from Court proceeding ‘TG appeals Circuit Court Order to the Virginia Court of Appeals,‘March 2022, October 14, 2022 October 18, 2022 ‘November 8, 2022 December 22, 2022 ‘TG represents himself, TG uses the address of as his address on the Court pleadings ‘Source: Court of Appeals documents TG re-elected as Chairman of Bedford GOP ‘TG pulled over for speeding in Maryland and arrested for outstanding warrant on Failure to Appear from two years earlier. Elkridge Drive address handwritten in on court documents. Virginia Court of Appeals hands down decision and rules against TG on all 3 points taken up on appeal, Case is remanded to the Lynchburg Circuit Court to determine the amount of attorney fees to be awarded to his former wife ‘Source: Court of Appeals documents ‘TG votes in General Election (AB 10-6-22) Maryland case resolved — TG pays a fine is and is placed on unsupervised probation for ‘one year (beginning on 12-22-22). The ‘Maryland Court file shows that there were ‘numerous unsuccessful attempts 10 contact TG at the 16 uso he In all communication with the Maryland Court Source: Maryland Court documentsJanuary 20, 2023 March 2, 2023 ‘March 20, 2023 Hearing in Lynchburg Circuit Court to determine amount of the award of attormey fees to former wife. TG tells ie aurent residence ‘TG refers to this as a “garage,” ‘Source: Audio transcript from Court ‘TG changes his voter registration in Bedford at the Be ‘Registrar's Obnce. TG files paperwork to run as a candidate for the Virginia HDS3 Legislative seat ~ 8 jination — using the! address ‘TG posted (in pertinent part) the following. ‘statement on Facebook: “Let me be clear, I live in Forest, Virginia, The residence where ‘lay my head down at night is the same address where J am registered to vote at, ‘This is in Forest, Bedford County, and within the House of Delegates District 53. 1 was at this address before I filed to run in this race. My voter registration status is clear, and there is nothing that would prevent me from running for House of Delegates.” “As I traveled out of state, I retained my home address where still received mail, ‘even wien I was physically present in other states. There is no requirement under ‘Virginia law that someone who travels for work, change their physical voting location from state to state as they fight for clean clections. A voter may set his ONE domicile or residence and register to vote there. My home has always been, and always will be central Virginia. (Emphasis in original) .,.1 have always maintained one voting residence.”Issues Presented: Virginia Law (Section 24.2-101, Code of Virginia), requires a registered voter to be a “Resident” of the Commonwealth and of the precinct in which he offers to vote, “Resident” (as defined by the 24,2-101) “for all purposes of qualification to register and vote, means and requires both domicile and a place of abode. To establish domicile, a person must live in a particular locality with the intent ta remain. A place of abode is the physical lace where a person dwells.” (Emphasis added) ‘A “short-term rental” ~ such a5 the AirBnB that he rented by definition cannot be a location that one lives “with intent to remain,” Additionally, per ‘T's own submitted Interrogatory Answers as well asthe sworn testimony of the property owner Charles Gibson, TG did not spend a single night there after July of 2020. ‘The AirBnB owner, Charles Gibson, additionally testified that there was no rental agreement in place to supercede the AirBnB arrangement, This fails both the “domicile” and “place of abode” requirements. Interrogatory Answers submitted on November 20, 2020 and Court Testimony on November 3, 2021 reveal that TG left the idress on July 31, 2020, and never retumed. Neither TG nor his attomey provided any physical location at which ‘TG had resided in the Commonwealth of Virginia since July 31, 2020. The Judge at the Circuit Court hearing held on November 3, 2021 stated that TG had not had a permanent address (i.e, place of abode) for the last year and a half and was “essentially homeless.” Virginia Law (Section 24.2-401, Code of Virginia), allows a registered voter to vote in one additional federal election after they leave their residence — in this case the 2020 federal election. “A person who is qualified to vote except for having moved his residence from one precinct to another within the Commonwealth may vote in the precinct from ‘which he has moved in the following November general election and any intervening election unless his registration has been transferred or cancelled as provided in this chapter. Virginia Law (Section 24,2-417.1, Code of Virginia), allows three specific exemptions where requirements for domicile & abode are partially waived. These exemptions are the American Conservation & Youth Service Corps, the military, and the merchant marine, and also apply to a spouse or dependent of a military or merchant marine member. “In determining the residence as defined in § 24.2-101 and the domicile and place of abode of a participant in the American Conservation and Youth Service Corps provided for by federal law (42 U.S.C. § 12685 et seq.), there shall be aresumption that a participant in the Corps who was domiciled and had a place of abode in Virginia at the time of entering the Corps continues to be domicited and retains the same place of abode unless the participant expressly states otherwise, In determining the residence as defined in § 24.2-101 and domicile and place of abode of a military or merchant marine spouse or dependent, there shail be a ‘Presumption that a military or merchant marine spouse or dependent who has established physical presence and a place of abode in the Commonwealth shall also have established domicile in the Commonwealth unless the spouse or dependent expressly states otherwise. Once residence is changed, the military or merchant marine spouse or dependent may not revert to any previous residence without re-establishing new physical presence and intent to remain or return.” TG fails these exemptions because he is not a member of the American Conservation & Youth Service Corps, the military, or the merchant marine ~ but even if he were eligible for these exemptions he would stil fal this exemption because he “expressly stato(®) otherwise” in the Interrogatory Answers he swore and submitted under penalty of perjury on November 20, 2020 where he renounced his residency and stated that he no longer lived at hc AIRING rnd had not since July 31, 2020. Following the November 2020 federal election, TG failed to further update his address to a now residency after previously renouncing the Elkridge address, ‘Virginia Law (Section 24.2-500, Code of Virginia) states: “Tn order to qualify as a candidate for any office of the Commonwealth, or of its governmental units, a person must be qualified fo vote for and hold that office. In order to hold any office of the Commonwealth or its governmental untts, elective by the people, the candidate must have been a resident of the Commonwealth for ‘one year next preceding his election and be qualified to vote for that office.” At what location did TG re-establish residency so as to meet the qualification of residency within the Commonwealth for the “one year next preceding his election”? Administrative Code Section 1VAC 20-40-20.B speaks to the required intent for voter registration. “B. Pursuant to the requirements of § 24.2-404 D of the Code of Virginia, the following shall apply only in determining a person's residence under Article It, ‘Sec. I of the Constitution of Virginia and Tltle 24.2 of the Code of Virginia, 1.A person who intends to remain in a location for an unlimited time has established the intent required to establish domicile, 2. A person who intends to remain in his current location for an unlimited me has established the intent required to establish domicile even if he mayJeave upon the happening of a future contingency. Examples of such furure contingencies include, but are not limited to, a change in job status or location, graduation from school, military transfer deployments or other relocations, and medical emergencies. 3. A person who presently intends to leave his current location at a fixed and Certain date may not have established the intent required to establish domicile depending on the facts and circumstances of each case, as determined by the registrar, with all due consideration given to persons in the circumstances contained in 1VAC20-40-30 B, 4. A person who applies to register to vote in a precinct for the primary purpose of registering to vote or voting in that precinct has not established ‘the intent to establish domicile there,” “TG has attempted to establish residence in a detached garage owned by a friend for the purposes of establishing a voter registration residence on the same day that he filed to run for office with the Republican Party in the 53% House of Delegates District, Per zoning office records this garage appears to both lack a full bathroom, and a certificate of ‘occupancy, as well as the property itself appearing to lack the proper zoning ordinance to have a detached apartment from the regular living quarters of the house. No reasonable person can reach the conclusion that TG intends to “remain in the location (garage) for an, unlimited time” (VAC 20-40-20.B1). As such, he fails the requirement of intent for establishing domicile, It also appears that TG has failed the requirement for 1VAC 20-40-20;B.4, TG changed his voter registration address on March 2, 2023 to TT 2 same day he filed to run for the Republican nomination for the House of inthe 53% District. This plainly fails the requirement that “a person who applies to Tegister to vote in a precinct for the primary purpose of registering to vote or voting in that precinct has not established the intent to establish domicile there.” ‘Case law is clear on this matter in the matter of Ubrin v, Nygaard, 101 Va. Cir, 252, 2019 Ya. Cir, LEXIS 54 (Virginia Beach Mar, 5, 2019). “The candidate did not have the intent to establish residency at an apartment in the district, but only intended to acquire an address in order to ran for city council as a representative of the district.” It is not a difficult nexus to connect the voter registration address change to the candidate filing within the same few hours of proximity as a case of TG registering to vote in a precinct for the primary purpose of voting in that precinet as a requirement to run for office, and thus not establishing the intent to establish domicile there. Conversely, in the same set of circuit court opinions regarding a candidate establishing new residency & domicile, the candidate (Dixon) was able to establish a legitimate residence at a new address by demonstrating that “the candidate had not spent a night at the old residence after moving.” We know via the testimony of the homeowner at theElkridge Dr address that TG has not spent a single night there since July 2020, Further solidifying, in conjunetion with TG's own cout filing, that this residence has been renounced and that no residency was re-established prior to the one-year residency requirement window preceding the date of the election for which TG seeks to be a candidate, On all of these items, TG fails the requirements for establishing residency and domicile, ‘and is neither a qualified voter, nor an eligible candidate to run for office in 2023 in the Commonwealth of Virginia, For these reasons, we as qualified voters of Bedford County believe Timothy Paul Griffin is improperly registered and hereby challenge his voter eligibility according to VA Code 24.2-429 and ask that he be removed from the voter rolls. Pr sigy