I

Brownstein Hyatt 

FarberSchreck 

Christopher 0. Murray 

April 28, 2018 Attorney at Law 

303.223.1183 tel 

303.223.8003 fax 

cmurray@bhf8.coni 

Via E-mail ^to Audlt(P.fec.qov) 

Federal Election Commission 

Audit Division 

Ms. Zuzana Pacious 

ggg E. street N.W. 

Washington, D.C. 20463 

RE: Response of the Colorado Republican Committee to IAR dated February 25,2016 

Dear Ms. Pacious: 

This firm represents the Colorado Republican Committee (the 'Conrfrrilttee'). This letter will serve as the 

Committee's response to the Commission's Interim Audit Report (^ted- February 25,2016. I address the 

Committee's response to each of the Audit Division's interim Findings and recommendations in turn. 

Finding 1 - "Misstatement of Financial ActivitV 

The Committee agrees with the Audit Division's recommendations regarding Finding 1(A) and Finding 1(B). 

The misstatements were inadvertent. The Committee will file amendments to the relevant reports on or 

before May 6,2016 consistent with the Audit Division's recommendations. 

As to Finding 1(C), the Committee disagrees with the Audit Division's recommendations. The Committee 

has prevloosily provided doeumeritptionr-as noted.in.the Interim Audit Report—demonstrating that the 

account in question (the "Colorado. RNG-Host aceounr) Is not tdntrolied by tile Committee and Is-ther^rg 

not a.n uhrepdiied fede^l abcognt. The Gonhmittee's position i's'that it has by itis prior correspendenee arid 

cooperation with GomrhlsPioh staff PuffiCiOhtly derrioristrated thatjtjdoes not cpntrol thp Colorado RN& 

Host accoupt. A copy of the': prior eorrespofndience Is- enclosed with this letter. 

Finding 2 -.'Reotirtind of ApparOht Independent Exoenditures-:' 

The Committee disagrees with the Audit Division's recommendations as to Finding 2. The Committee 

has-iae noted in the Interim Audit Report—consistently asserted that the communications at issue are not 

reportable as. independent expenditures because they are. subject to the volunteer material .exemption, 

The Committee has provided documentation .substantiating volunteer irivolvement including the volunteer 

names, the location the work was done and the date of the volunteer involvement. The Committee 

appreciates the Audit Division's desire for additiorial Information regarding the voiuatper work on these 

communications, but the Committee has provided all the documentation In its possession. The Committee 

has never before been requested to provide volunteer timesheets and photographs arid cannot do so here 

because it did not collect timesheets or photographs from the volunteers at Issue. The Committee believes 

it has provided enough information to substantiate application of the voiuriteermaterial exemptiph: As a 

result, the Committee will not make any amendments to disclose these dlstiursshierits as Independent 

410 SeMntoenth Street, Suite 1200 

Denver, CO 80202-4432 

main 303.223.1100 

blifii.cDm Brownstein Hyatt Farber Schreck, LLP 
Zuzana Pacious 

April 28,2016 

Page 2 

expenditures, and continues to believe that no 24/48 hour report was necessary for any of these 

disbursements. 

•Finding 3 - "RecordkeeoinQ tor Communicatjons" 

The Conrimittae disagrees with the Audit Diyisidh's recorhmendatjons ap to Findirig 3. After AUdit.staff . 

pYovitleid ttfe-Qommilteie with a schedule of disbursements fbrwhieh It required further dbdumdntatlpn, the 

Gommittee; provided altdocumentatibn In Its pt^ssesslpn In a a^eries..of Idttere,. UGB:thumbrdrive&airid;oii!ine 

Tile site links between Janua'7.31,2614 and August 11,.2QT4. TheCpmmifte'e iS pre^rpd .tQ.pipylde.thls 

informatijon again if thp Audit Division requireis a'ltiother-Qppy.. The bommlttee Is wofklhg to assoeiafe. ^e 

already, provided invoices arid. Communications with eaeti ofher and Will provide the -Audlt Qlyisiqn with .a 

final record associating, all communications .w|th .lnuoice.s as sobii .as that record. Is Complete. 

Finding 4 - "Fallgre to Itemize Debts and Obilgatipns!' 

The Corhmittee agrees.vyKh .the Audit Division's recdmrheridatiens as t0 Finding 4. .Given the 

Cbrhmissidh's determination that the amouh^ owed to the Committee's, termer legal Ceunsel Were not 

privileged from disclosure, the Cgmrhittee Will amend,ils repods ter-the applicable period td^reflect thjeSe. 

amounts as debt, these amendments will becompieted-by May 9. .12016. The Committee will ript amend 

its reports to cover the amounts allegedly owed to Its-termer get-^.Ut-the-vote C'GOTV''^ vendor, as. that 

contract-was terminated. The Audif-.Oivision requested that the Committee provide de'eumentatlon of this 

termination - such documentation was provided to Audit'Staff on December 9,2014. Anotheroppy pffhiS 

communication is enclosed with this letter. 

Thank you for your attention to this response; please do not hesitate to contact me should you have any 

questions regarding it. 

Regards, 

Christopher O. Murray 

cc. Mary Moss, Federal Election Commission 

Steve Hbuse, Colprado Republican Committee 

Enclosures