OFFICIAL NOTICE — D. Lee Phelan Sr.
"Action Required: Actionable Fraud Against the CO GOP SCC," June 10, 2026.
Mass notice to Colorado Republican State Central Committee members. (Email headers and
distribution details omitted; the notice is reproduced as written.)

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OFFICIAL NOTICE TO THE COLORADO REPUBLICAN STATE CENTRAL COMMITTEE
Re: Unauthorized Stipulated Settlement Agreement and Consent Order in Leonard v. Colorado
Republican Committee, Case No. 2026CV176

To the Members of the Colorado Republican State Central Committee:

Please accept this as formal notice of a matter requiring immediate attention by the Colorado
Republican State Central Committee.

It has come to my attention that in the matter of Timothy Leonard v. Colorado Republican
Committee, El Paso County District Court Case No. 2026CV176, a Stipulated Settlement Agreement
and Consent Order was entered into on behalf of the Colorado Republican Committee by Eric
Grossman, identified in the document as Acting Chairman, CRC.

The documents appear to commit the Colorado Republican Committee to significant obligations
regarding the party's future participation in Colorado's semi-open primary system, including
notification to the Colorado Secretary of State that the Colorado Republican Party has opted out
for the 2028 election cycle and all subsequent cycles, unless later rescinded.

This is a matter of extraordinary importance to every member of the SCC, every county party, every
candidate, and every Republican voter in Colorado. The decision to bind the Colorado Republican
Committee to future election-cycle obligations, bylaw amendments, court enforcement, and related
legal consequences is not a routine administrative act. It is a major party-governance issue that
should require full disclosure, proper notice, legal review, and action by the governing body of
the Colorado Republican Party.

To my knowledge, the State Central Committee was not called into session to authorize this
settlement. To my knowledge, SCC members were not provided prior notice of the proposed settlement
terms. To my knowledge, there was no recorded SCC vote authorizing any officer, acting officer, or
legal counsel to enter into an agreement of this magnitude on behalf of the Colorado Republican
Committee.

Therefore, I respectfully request that the Chair of the Colorado Republican Party immediately call
a meeting of the State Central Committee for the following purposes:
- Full disclosure of the Stipulated Settlement Agreement and Consent Order in Case No. 2026CV176;
- Full disclosure of who authorized the settlement, who participated in its negotiation, and what
  legal advice was provided;
- Full disclosure of whether the State Executive Committee or State Central Committee ever approved
  or ratified the settlement;
- A full legal explanation of whether an acting officer had authority to bind the Colorado
  Republican Committee to the obligations contained in the settlement;
- A vote of the State Central Committee to reject, rescind, repudiate, invalidate, or otherwise
  refuse ratification of any unauthorized action taken in the name of the Colorado Republican
  Committee;
- A determination of whether corrective action must be taken with the Court, the Colorado Secretary
  of State, or any other entity;
- Consideration of any appropriate disciplinary, removal, or resignation-related action concerning
  any officer who exceeded authority or failed to provide proper notice to the governing body.

This notice is not intended to prejudge the ultimate legal outcome of the opt-out issue. Members
may support or oppose opt-out in good faith. However, regardless of one's position on opt-out, the
process by which the party makes such decisions must be transparent, lawful, and accountable to the
SCC.

The SCC is the governing body of the Colorado Republican Party. No single officer, acting officer,
attorney, litigant, or private settlement should be permitted to bind the party on a matter of this
magnitude without clear authority from the governing body.

Accordingly, I call upon the Chair to convene the SCC without delay and place this matter before the
members for full review and corrective action.

Respectfully,
D. Lee Phelan Sr.
Former Vice Chair, Colorado Republican Party
Former Chair, Las Animas County Republican Party