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THOMAS COMBS SPANN, PLLC

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TELEPHONE: (304)414?1800 CHARLESTON, WEST VIRGINIA 25301 DEEM

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July 18, 2019

VIA ELECTRONIC MAIL, HAND
DELIVERY, AND CERTIFIED
MUL RETURN RECEIPT
REQUESTED

Honorable Mac Warner, West Virginia Secretary of State
ATTENTION: Elections Division

1900 Kanawha Boulevard East, Floor

Charleston, WV 25305

RE: Notice of Pending Claim for Relief Under W. Va. Code 55-17-3

Dear Mr. Secretary of State:

I write to satisfy the thirty-day notice of pending claim against the State of West Virginia as
described in West Virginia Code 55-17?3 by the following individuals: Thomas Collins,
Cross Lanes, Rich Greathouse, Clendenin, Barbara Hackworth, Cedar Grove,
Candace Joseph, Charleston, Frank Larese, Belle, Bree Lemmon, Cross
Lanes, and Nancy McClanahan, Charleston, WV.

The claims against the Secretary of State, acting in his capacity as Chief Elections Officer, are
related to recent events in Kanawha County which have culminated in the removal of duly
elected and appointed members of the Kanawha County Republican Executive Committee
through inaccurate bases and by improper means. In so doing, the Kanawha County
Republican Executive Committee through Chairwoman, Tresa Howell, has violated sections
of Chapter 3 of the West Virginia Code, West Virginia Code 6?6?7, and the published by-
laws of the Kanawha County Republican Executive Committee.

The aforementioned seek relief, including but not limited to, a writ of prohibition against the
WVSOS to preclude the publishing or honoring of the roster submitted by the Kanawha
County Republican Executive Committee on July 9, 2019. And the aforementioned,
generally, reserve the right to seek any further relief appropriate for themselves, for the other
wrongfully removed members, and for those whose voting rights have been infringed by the

THOMAS COMBS SPANN, PLLC

Honorable Mac Warner, West Virginia Secretary of State
July 18, 2019
Page 2

actions of Chairwoman Tresa Howell and the Kanawha County Republican Executive
Committee.

Pursuant to the aforementioned reserve the right to seek injunctive relief as
may be necessary prior to the thirty?day threshold if it is determined that irreparable harm
would occur due to the otherwise mandatory delay of the institution of the corresponding
action.

Sin erely, 

[10/ Mm we,

Salshiey N. Dee (yr/?V813 13192)


THOMAS COMBS SPANN, PLLC

300 Summers Street, Suite 1380
Charleston, WV 25338?3824

Direct: (304) 414?1838

Cell: (304) 389?7187

COUNSEL FOR THE
AFOREMENTIONED

 

cc: Attorney General Patrick Morrisey