ata Ser June 11,2010 Frank Zilaitis, Esq. 128 Anona Place Indian Harbour Beach, FL 32937 RE: — Rule 22 Sanctions (Will Pitts, John Stevens, Elizabeth Campbell) Dear Mr, Zilaitis: AL your request, I have reviewed the circumstances surrounding the sanctions imposed on your clients Will Pitts, John Stevens, and Elizabeth Campbell by former Chairman Jim Greer in August 2009. You have asked me to vacate their penalties. Please sce the enclosed memorandum from RPOF counsel. As set forth in the memorandum, I do not have the authority under party rules to take the action you have requested, Should you have any questions or concerns, please feel free to contact RPOF Executive Director Ronnie Whitaker at (850) 222-7920. Tale — Chairman John ThrasherREPUBLICAN PARTY OF FLORIDA MEMORANDUM TO: Chairman John Thrasher FROM: Daniel Nordby Special Counsel, Republican Party of Florida DATE: — June 11,2010 RE: Grievance Committee decisions ~ Will Pitts, John Stevens, Elizabeth Campbell ‘You have been contacted by Frank Zilaitis, an attomey representing Will Pitts, John Stevens, and Elizabeth Campbell, Mr. Zilaitis has asked you to “clear the names” of his clients and remove the penalties imposed on them through the RPOF grievance process. At your request, I have prepared this memorandum outlining the circumstances under which these three individuals were sanetioned by former Chairman Greer, as well as the scope of your authority as, Chairman of the Republican Party of Florida regarding party grievances under RPOF Rule 22. ‘The grievance that led to Ms. Campbell's suspension was filed by Jeff Peacock, Treasurer of the Escambia County Republican Executive Committee. The grievance that led to penalties against Mr. Pitts and Mr. Stevens was filed by William Blythe, a member of the St Johns County Republican Executive Committee. The grievances were thereafter referred to the RPOF Grievance Committee in accordance with Rule 22 of the Rules of the Republican Party of Florida, Rule 22 provides a process for resolving intra-party disputes between members of a county Republican Executive Committee when the dispute cannot be resolved within the local committee. The Grievance Committee convened on July 25, 2009, to take evidence and testimony from Mr. Pitts, Mr. Stevens, Ms. Campbell, Mr. Peacock, and others. At the conclusion of the hearing, the Committee found that Mr. Stevens and Mr. Pitts had engaged in disruptive conduct likely to interfere with the activities of the Republican Party. The Committee voted to recommend that Mr. Stevens be removed from his party position as precinct committeeman and that Mr. Pitts and Mr. Stevens be deemed ineligible to serve as a member of a Republican Exccutive Committee for a period of four years. The Committee found that Ms. Campbell’s actions demonstrated a lack of judgment by someone in a party leadership position and recommended that she be suspended from her position as State Committeewoman for a period of six months.After reviewing the Grievance Committee's findings and recommendations, former Chairman Greer determined that the penalties recommended by the Committee as to Mr. Stevens and Ms, Campbell should be affirmed. As to Mr. Pitts, former Chairman Greer lected to reduce the penalty recommended by the Grievance Committee. Rather than determining Mr. Pitts ineligible to serve for a period of four years, Mr. Pitts was determined ineligible to serve as a member of a Republican Executive Committee until December 31, 2010, and, if thereafter elected, he would be placed on probation until December 31, 2012. Neither the RPOF Constitution nor the Party’s Rules of Procedure provides authority for a subsequent Chairman to unilaterally revisit or reverse sanctions imposed after a party grievance hearing. Instead, it is the Republican State Executive Committee that is vested with final authority in all matters of Republican Party organization and governance. See Article VII, RPOF Constitution, Accordingly, you do not have the authority under party rules to revisit the sanctions imposed on Mr. Pitts, Mr. Stevens, or Ms. Campbell by Chairman Greer in August 2009. Finally, I have been informed me that Mr. Zilaitis may have referred to Section 103.161 of the Florida Statutes as the basis for the penalties imposed on his clients. This statute authorizes a political party chairman to remove or suspend an executive committee member for violation of the member's oath of office, among other reasons. To be clear, the sanctions imposed on Mr. Pitts, Mr. Stevens, and Ms. Campbell by former Chairman Greer were under the authority of RPOF Rule 22, not Section 103.161. The Republican Party of Florida has only removed one executive committee member under the authority of Section 103.161: former Chairman James A. Greer, who you removed in April on the unanimous recommendation of the Executive Board. As always, please do not hesitate to call should you have any questions regarding the information contained in this memorandum,