Eugene Delgaudio - Sterling District
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March 8, 2020

This week Larry O'Connor condemned corruption and other problems apparent in the Republican Party of Virginia and promised to keep focused on it in the comming months including a visit to the Republican Party state convention in Richmond May 1 and May 2 at the Richmond Convention center. (contact: @LarryOConnor on twitter)

Later in the week, as if on cue, the Rob Jones for Congress campaign, in Virginia's tenth district, sent a letter to cease and desist administrative efforts to verify submitted registration forms under the normal rules of the Republican Party to a May 30th nominating convention, in a possible effort to browbeat volunteers and candidates in the Tenth Congressional District Republican units and committees, according to several sources.

Reagan George a member of the Republican State central committee posted on facebook social media the following statement:

"I received an email the other day informing me that the Rob Jones 10th District Congressional Campaign had sent a formal Cease and Desist Demand Letter to the 10th District Chair, as-well-as, all of the Unit Chairs in the 10th District. The letter calls into question the legitimacy of allowing each Unit committee to form their own Credentials Committee to process, vet, and follow-up on the hundreds of Delegate Filing forms and checks for filing fees for the Unit, District, and State Conventions. The letter also does not want the Unit level Credentials Committees to question the source of funds being paid by their delegates. It seems to me that the campaign doth protest too much, unless of course they have something to hide.
This is nothing more than a ploy by Team Whitbeck and Stratpoli to play legal games with the 10th District Convention leadership. This will cause them to spend money they don't have and expend volunteer time, which is always a valuable resource. We should be focused on beating Congresswoman Wexton in the General Election.
Remember John Whitbeck was Chairman of RPV for almost 4 years. If he recognized a discrepancy between the Party Plan and the accepted practice of allowing the formation and function of Unit Level Credentials Committees. Why didn't he fix it? Maybe he subscribes to the Democrat method of never letting a crisis, or in this case, a piece of legal B.S. to go to waste.
For me, this action certainly calls into question the judgement and common sense of the candidate and the team that surrounds him."


"Many of the deadlines have passed for Virginia's 10th district Republicans to apply to be delegates to their quadrennial convention on May 30th. The delegates will choose their 10th district chairman, their candidate for Congress as well as representatives to the State Central Committee and other offices. The full list of offices and candidates is here.

In the past local units have looked over the submitted delegate forms to make sure the applicant was a registered voter at the address listed, to verify payment, signatures, and other things on the form. If an applicant made an error, such as forgetting to sign the document or the amount of their check was incorrect, they would be contacted to correct the error.

The Rob Jones campaign for the congressional nomination in the 10th district has objected to this procedure and hired a law firm to send a "Cease and Desist" request to the 10th district chairman, Matt Leeds, and all of the local unit chairs. The letter is signed by Cherylyn Harley LeBon of the law firm Dunlap Bennett & Ludwig PLLC. The letter reads:"

"Dear Chairmen,
Our firm represents Rob Jones for Congress in all matters pertaining to the 10th Congressional District Republican Convention. Please direct all future communications to my attention. At this time, I have no knowledge that any of you are represented by counsel. If this is incorrect, please forward this letter to your respective attorneys.

We want to thank you for your hard work and dedication to this process. We are aware you are volunteers and our client believes you are doing a great service to the Republican Party of Virginia ("RPV"), and to the many delegates who will be attending our conventions this year.

Please do not mistake the concerns raised in this letter as personal attacks directed at you or the committees you serve.

RPV conventions are governed by Article VIII of the RPV Party Plan as amended through December 6, 2019 ("the Party Plan"). Pursuant to the Party Plan, delegates to the 10th District Convention are elected at the mass meetings/canvasses of each jurisdiction in the 10th District. If they are not elected at a mass meeting/canvass, they may still be seated by a majority vote of the credentials committee at the convention itself, or by the full body of the convention.

Please note that there are no credentials committees/nominations committees in existence prior to the convention. Indeed, there are no committees that are authorized to exist until the convention is convened. Therefore, the 10th District and/or local units' committees do not have the authority to determine who is eligible to be a delegate to any convention. Delegate eligibility must be decided at a mass meetingg/canvass or at the convention.

In light of the aforesaid, the following activities have come to our attention, all constituting the potential to suppress delegate turnout to the 10th District Convention:
1. One or more units are contacting potential delegates and advising that they may be ineligible to vote in the convention. They are then requesting they appear before a committee to explain why they should be permitted to vote in the convention. This is improper and inconsistent with the Party Plan for two reasons. First, there is no such thing as a committee that determines eligibility of delegates at this stage in the process. Only the body of the mass meeting, canvass and/or convention can perform this function. Second, there is no authority for volunteers of an unauthorized committee to call delegates and tell them that they are potentially or actually ineligible to attend a convention. This has the effect of suppressing delegate turnout at the convention since delegates may choose not to be involved rather than jump through invalid procedural hurdles.

2. One or more units are contacting delegates and advising them they may be ineligible to vote in the convention because of mistakes or irregularities with the pre-filing forms. Regardless of whether there may be issues with forms, that is for the mass meeting, canvass, and/or convention to decide, not for unauthorized committees or volunteers
reviewing forms.

3. A chair of an official committee has suggested that potential delegates be investigated regarding the source of funds for specific filings. Apparently, the concern is checks paid by third parties. This is problematic for three reasons. First, there is nothing illegal or in the Party Plan that precludes third parties from paying delegate filing fees. Second, there is nothing in the Party Plan, the 10th District Call or the official filing form that states a third party check is not acceptable. Third, initiating improper investigations of delegates and their funding sources can have a negative impact on the turnout of delegates to the convention. Potential delegates may feel intimidated if they believe they are part of an investigation by a chair of an official committee.

The purpose of this letter is to identify and resolve these concerns. Please understand this is a convention to nominate a candidate for the United States Congress. Our client is prepared to use
any means necessary to ensure a fair process is conducted and to protect voters from delegate suppression, intimidation and misapplication of Party rules. Accordingly, we request the following to occur immediately:
1. All committees not officially recognized by the Party Plan should cease and desist

2. All direct contact to delegates cease and that eligibility to vote be decided at the 10th
District Convention (or mass meetings/canvasses) as required by the Party Plan. We recognize that eligibility may be reviewed before the convention to save time, but no delegate should be told they are ineligible at this point in the process.

3. All investigations into the source of funds for checks paid for delegate fees terminate immediately. My understanding is that the required campaign finance information will be provided to the appropriate unit. The chair of the official committee is not required to take any additional action.

If all of the aforesaid occur, there will be no further need for contact from our firm or our client's campaign on these issues. I sincerely hope this is the last time we need to communicate with you on these issues.

Cherylyn Harley LeBon Dunlap Bennett & Ludwig PLLC T: (703) 442-3890"

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