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DISTRICT COURT, CITY AND COUNTY OF

DENVER, COLORADO
1437 Bannock Street, Room 256
Denver, CO 80202
Plaintiffs:
COLORADO REPUBLICAN PARTY
v.
Defendant:
.A COURT USE ONLY A
Case Number: 2014CV031851
SCOTT GESSLER, in his official capacity as Colorado Div./ Courtroom: 409
Secretary of State
Attorneys for Plaintiff Colorado Republican Party:
Richard A. Westfall, No. 15295
Allan L. Hale, No. 14885
Peter J. Krumholz, No. 27741
Hale Westfall, LLP
1600 Stout St., Suite 500
Denver, CO 80202
Phone 720-904-60 I 0
Fax 720-904-6020
rwestfall@hal ewest fall. com
AFFIDAVIT OF RYAN R. CALL
I, Ryan R. Call. state under oath as follows:
1. I am the Chairman of the Colorado Republican Party.
2. On May 7, 2014, I caused to be filed with the Secretary of State's office papers to
establish and register a Colorado Republican Party Independent Expenditure Committee ("IEC").
3. On August 8, 2014, the management committee of the IEC adopted a set of
Standing Rules which govern and restrict the activities of the IEC.
4. Since its registration on May 7, 2014, I am aware that the IEC has received
several contributions totaling approximately $65,000. It has also made certain expenditures for
consultant fees, including preliminary research, strategic planning, and fundraising expenses, but
EXHIBIT
A
it has not made any expenditures consisting of voter contact designed or intended to influence
any particular race or candidate election.
5. Prior to August 8. 2014, my interactions with the IEC, its executive director. and
its management committee, was fully consistent with the requirements of the subsequently
adopted Standing Rules.
6. In connection with my duties and responsibilities as Chainnan of the Colorado
Republican I and members of the stan of the Colorado Republican Party conduct research
concen1ing campaign tinance disclosures and related media reports. In my current capacity I am
also required to know and abide by state and federal campaign finance laws.
7. Based on my research and my familiarity with campaign finance laws and
available public campaign finance disclosures, I have knowledge of the following concerning the
recent recall elections in State Senate District 3 in Pueblo, and State Senntc District 11 in El Paso
County:
a. The National Ritlc Association spent more than $360,000 to support the
recall elections. and labor unions, including the SEIU and the AFL-CIO, and other
Democrataligned individualst groups and committees raised and spent more than S3
million to attempt to defeat the recalls.
b. New York City Mayor Michael Bloomberg personally contributed
$350,000 and liberal philanthropist Eli Broad personally contributed $250.000 to a
committee named .. Taxpayers for Responsible Democracy," which opposed the recall
elections and supported former State Senators John Morse and Angela Giron.
c. An individual who might have wished to directly support the Republican
successor candidates in the recall elections- Bernie Herpin and George Rhera -would
have been allowed to contribute no more than $200 to each candidate's candidate
committee, and no more than $2,825 to the Colorado Republican Party to use in support
of those state legislative candidates.
8. According to campaign finance disclosures filed with the Colorado Secretary of
Statt, in the 2012 calendar year alone, 527 political organizations accepted in
contributions and made $14,350,348 in expenditures to influence state and local elections.
Independent expenditure committees accepted $6.302,334 in contributions and made $6,304,337
in expenditures to influence the election of state and local candidates in the same period.
9. ln contrast, the two major political pany committees combined accepted
$1.,491,023 in contributions and made $1,492.016 in expenditures with regulated state funds in
the same calendar year.
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Further, Affiant sayeth not.
By:
1JJ,r c9 'S
STATE OF et)t{)R},DO )
CoD fc )ss.
COUNTY OF 9:ENVER )
Subscribed and sworn to before me this 8th day of August, 2014, by Ryan R. Call.
WITNESS my hand and official seal.
My Commission Expires: ~
~ jt116/ P.t' ~
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