SD-27 Preliminary Findings

Below is a summary of findings regarding the conduct of officers of the Colorado 27th Senate District Republican Central Committee. This is based on documented communications, candidate testimony, a review of the Bylaws of the Colorado Republican State Central Committee (Corrected August 2024), the Model District Central Committee Bylaws incorporated therein, applicable Colorado Revised Statutes, public records, and documentary evidence referenced in the Exhibits section.

1. Applicable Bylaws Provisions

A. COGOP Bylaws, Article III, Section C — "Republican Candidate Endorsement"

Source: Bylaws of the Colorado Republican State Central Committee, Corrected August 2024, pp. 1–2.

"No candidate for any designation or nomination for partisan public office shall be endorsed, supported, or opposed by the CRC, acting as an entity, or by its state officers or committees, before the Primary Election, unless such candidate is unopposed in the Primary Election, or the candidate has gained access to the primary election ballot but has not participated in the applicable authorized Republican Assembly/Convention."

"Additionally, the CRC, and the various Republican county and district central committees, have no obligation to support, and may oppose, any candidate who has gained access to the primary election ballot outside of the Assembly/Convention process."

"Personal contributions of time or money to candidates by CRC officers or CRC committee members shall not be considered to be 'endorsements' or 'support' or 'opposition' in violation of this section unless the officer or committee member uses their official position to encourage other people to support or oppose a pre-primary candidate going through the Convention/Assembly process."

Application: This provision extends explicitly to "the various Republican county and district central committees." The safe harbor protects personal contributions of time or money. It does not protect use of official position — defined as using the office to encourage others to support or oppose a pre-primary candidate. The distinction between personal activity and official action is the controlling test.

B. Model District Bylaws, Article III, Section 2A — Duties of the Chairman

Source: Model Bylaws of the Republican Central Committee for Senate/Representative District, incorporated in COGOP Bylaws, Corrected August 2024, pp. 55–56.

"The Chairman shall perform such duties and have powers as are incident to the offices of Chairman. In addition, the Chairman shall:

1. Preside at all meetings of the District Central Committee and any of its committees and shall serve as Chair of the District Assembly and as the Chair of each Vacancy Committee.
2. Serve as ex-officio voting member of all committees of the District Central Committee.
3. Issue the Call and Notice of all meetings of the District Central Committee and for all meetings of any Vacancy Committee.
4. Perform such other duties as the District Central Committee or Vacancy Committee may assign or as may be required by law."

Application: The Chair controls the Call and Notice (duty 3), presides over the Assembly (duty 1), and serves on all committees (duty 2). These are official powers. Actions taken through these powers — including when and to whom the Call is issued, what information is shared with candidates, and how the assembly is administered — constitute use of official position.

C. Model District Assembly Bylaws, Article V, Section 2 — Qualifications of Delegates

Source: Model District Assembly Bylaws, incorporated in COGOP Bylaws, Corrected August 2024, p. 62.

"The delegates and alternates to the District Assembly shall be those delegates and alternates to the County Assembly that reside within the territory included in the limits of the District."

Application: SD-27 Assembly delegates are defined as County Assembly delegates residing in SD-27. The delegate list is derivable from the County Assembly delegate list. A claim that no delegate list exists is inconsistent with this provision.

D. Model District Bylaws, Article III, Section 2B — Duties of the Vice-Chairman

Source: Model District Bylaws, pp. 56–57.

"The Vice-Chairman shall assist the Chairman in the execution of his or her duties. In addition, the Vice-Chairman shall:
1. Exercise the powers and assume the duties of the Chairman in the absence, or in the inability to perform, of the Chairman, except that the Vice-Chairman shall not have the power to make any appointments.
2. Perform such other duties as the District Central Committee or the Chairman may assign."

E. Model District Bylaws, Article III, Section 2C — Duties of the Secretary

Source: Model District Bylaws, p. 57.

"The Secretary shall perform such duties and have such powers as are incident to the office of Secretary, including the duty and power to give written notice of all District Central Committee, District Assembly, Vacancy and Special Committee meetings, to attend all such meetings and keep a written record of the proceedings, and to be custodian of the records of the District Central Committee, District Assembly and Vacancy Committee."

Application: The Secretary (Gormley) is custodian of records and co-responsible for written notice. Records requests regarding candidate notice filings and assembly communications may be directed to the Secretary.

2. Applicable Colorado Revised Statutes

Application: The SD-27 Assembly is April 4, 2026. Thirty days prior is March 5, 2026. Any candidate seeking designation must have provided written notice to the SD-27 district chair (Baker) by that date. If Gibbs did not file timely notice, and party rules do not waive this requirement, he is not eligible for designation. Baker — who recruited Gibbs — is the same person who receives and would verify his notice. This dual role is relevant to the question of official position.

Application: Both candidates could be designated if both receive 30% or more. The assembly is not winner-take-all. Two ballots maximum. The presiding officer (Baker) and secretary (Gormley) certify the results.

Application: Defines delegate qualifications. Any delegate meeting these requirements cannot be excluded from the assembly. Relevant to credentialing at the April 4 assembly.

Application: Provides an alternative path to the June 30 primary ballot independent of the assembly process.

Application: Criminalizes dishonest or fraudulent performance of duties by "any person in authority" at an assembly. The SD-27 Chair is a person in authority. Acts that constitute dishonest performance of duties devolving on the Chair — such as selectively withholding notice, manipulating credentialing, or administering the assembly to benefit a favored candidate — fall within the scope of this statute. Not alleged at this time; included as reference for the statutory framework.

3. Documented Conduct

A. Withholding Delegate Information

The SD-27 Chair claimed that the delegate list "doesn't exist for delegates." (Exhibit C: Candidate testimony, March 23, 2026.)

The Arapahoe County Secretary produced the SD-27 contact list the same day it was requested directly. (Exhibit B: Baugh email with SD27 List.xlsx, March 19, 2026.)

Under the COGOP Bylaws (District Assembly Bylaws, Art V, Sec 2), SD-27 Assembly delegates are defined as County Assembly delegates residing in the district. The list exists by definition. (See Section 1.C above.)

B. Delayed Assembly Call

The SD-27 Assembly Official Call was sent at 7:09 PM on March 21 — the evening of the County Assembly. (Exhibit A: Assembly Official Call document and Baker email, March 21, 2026.)

Baker acknowledged the delay: "My apologies for the tardiness of the official call as we have been waiting for the delegate names." (Exhibit A.)

Issuing the Call and Notice is the Chair's duty under the bylaws (Art III, Sec 2A-3). The Call was not sent to the candidate; it was forwarded by a third party. (Exhibit A: McCartin forward.)

C. Recruiting a Primary Opponent

As reported at the Arapahoe County Executive Committee meeting on March 18 and documented in writing on March 19: (Exhibit D: Email to Chair Temple, March 19, 2026.)

"I was informed — unexpectedly — that my district chair has been actively recruiting and supporting a primary opponent, while also withholding information that would typically be shared with a candidate."

The recruited opponent is Darryl Gibbs, who ran for HD-40 in 2024. Baker — who filed for HD-40 in 2026 — would have known Gibbs from his prior campaign in her capacity as a district officer. (See Section 6: Gibbs public record.)

D. Assembly Logistics Failures

Delegates were unable to find the assembly location, were in the hallway asking for directions, and were removed from the room. The Chair presides over the District Assembly (Art III, Sec 2A-1). (Exhibit C: Candidate testimony.)

4. Compliance Matrix — Rules vs. Conduct

Reading the matrix: Items 1–4 are documented conduct based on evidence in hand. Item 5 is an open factual question that could be dispositive. Items 6–7 are prospective (April 4 assembly). Item 8 is the criminal statutory framework.

5. What Is Not Clearly a Violation

• Chair filing to run for HD-40 while serving as SD-27 Chair. The bylaws do not explicitly prohibit simultaneous candidacy and district chair service. It creates an apparent conflict of interest but is not a named violation.
• Vice Chair cooperating with Chair. The Vice Chair's duty is to "assist the Chairman" (Art III, Sec 2B). Absent independent use of her own official position to recruit or oppose candidates, the conduct follows from the Chair's direction.

6. Public Record Findings

Darryl Gibbs — Recruited Opponent

Source: Colorado Secretary of State TRACER database; Ballotpedia; Denver Post candidate questionnaire (Oct 11, 2024).

Three races in four years with minimal fundraising. USAF veteran (C-130 crew chief). Owner/operator truck driver. Gibbs does not appear on the SD-27 delegate list — he is not a PCP, District Captain, or County Assembly delegate. He has no party infrastructure role in SD-27.

Susan Baker — SD-27 Chair

Mila Shusterman — SD-27 Vice Chair

Shusterman previously started a public petition titled "Stand for Transparency in Arapahoe GOP!" on Change.org, demanding open Executive Committee meetings, citing Arapahoe County GOP Bylaws, Article VIII, Section 8.01. She invoked bylaws to demand transparency when she felt excluded — while now cooperating with a Chair who is withholding information from a candidate. This also confirms that Arapahoe County GOP bylaws exist as a separate document with their own article and section structure.

Source: Change.org petition, publicly accessible.

SD-27 Delegate List

Source: Exhibit B — SD27 List.xlsx provided by Arapahoe County Secretary, March 19, 2026.

Arapahoe County GOP Leadership

O'Meara provided the Candidate Go Bag and DC/PL contact list on January 21, 2026. Baugh provided the SD-27 delegate list on March 19, 2026. Both county officers acted appropriately in providing candidate resources.

7. Assembly Details

Note on timing: Baker's email was sent at 7:09 PM on March 21. The assembly is April 4 — 14 days notice, but only because a third party forwarded it. Baker sent the call to herself (BCC to her own list) and did not include the candidate. Without the forward, the candidate would have had no notice.

Source: Exhibit A.

8. Exhibits

9. Outstanding Items

1. Arapahoe County GOP bylaws. Confirmed to exist (Shusterman's petition cites Art VIII Sec 8.01). Not yet obtained.
2. SD-27 committee bylaws if they exist separately from the COGOP model.
3. Written evidence of Chair recruiting Gibbs. Emails, texts, witness statements. Highest-priority evidentiary item.
4. Communications sent to Gibbs but not to the candidate. The assembly call BCC list would demonstrate selective use of official communications.
5. Gibbs's 30-day notice under CRS 1-4-601. Did Gibbs file written notice to Baker by March 5? The Secretary (Gormley) is custodian of records (Art III, Sec 2C). If notice was untimely and Baker accepted it, Gibbs may not be eligible for designation.

10. Summary of Key Facts

Preliminary Findings — March 23, 2026