In support of these charges we accuse William Redpath of the following acts, which, among others that he has committed, warrant his suspension from the Libertarian National Committee:

1) Use of Party resources in the form of a gift in kind to support a Presidential candidate of another party.
2) Use of Party resources in the form of a gift in kind to support a Presidential candidate of our party.
3) Failure to ensure that the aforementioned gifts in kind were properly disclosed on LNC FEC filings.
4) Misappropriation of Party funds in violation of the Statement of Principles, namely use of Party funds to attempt an act of theft and fraud.
5) Silent participation in acts of fraud against the Libertarian Party National Convention.

Evidence in support of these charges:

1) At the December 2007 LNC Meeting, Redpath as Chair failed on his own volition to rule out of order as a violation of the Party Bylaws a resolution authorizing the staff to permit Ron Paul supporters to make use of the Ballot Base software. Instead, this motion was passed without objection. Staff, who report to Redpath as CEO, allowed Paul supporters to attempt to use the software.

It is unmistakably the case that Paul was a candidate for the Republican Party Presidential nomination. In contrast, Libertarian Party Bylaws clearly and unmistakably state that our purpose is to function as a political party separate and distinct from all others. The Libertarian Party has raised extensive funds from libertarian donors who believed that they were donating to support our party's objectives. Use of Libertarian Party funds to advance the political campaign of a Republican was a gross breach of fiduciary responsibility on the part of Chairman Redpath.

Furthermore, the Libertarian National Committee with Redpath as Chair chose to use party resources, such as the party web page displaying their minutes, to publicly invite a particular person to become a candidate for President with our party. Similar access to party resources was not given to other candidates. It has been the policy of the Libertarian National Committee since it was observed that Honey Lanham had used party resources in support of the Russell Means Presidential Campaign that the Libertarian National Committee is expected to remain above the fray and not use party resources to support that candidate. Failure to adhere to this policy in 1996 and 2000, as described in George Phillies' book Funding Liberty, caused great damage to our party. In contravention of this policy of several decades, under Redpath as Chair the National Committee used its resources to advocate for Paul as our presidential candidate.

Furthermore, at this meeting, four members of the LNC, namely Pat Dixon, Hardy Macia, Julie Fox, and Rebecca Sink-Burris, admitted in their statements of conflict of interest that they had contributed financially to the nominating campaign of a Republican Presidential candidate. The rule for closure of conflict of interests exists so that appropriate corrective measures can then be taken. It was clearly the duty of the Chair to instruct the LNC members who had disclosed that they had supported a Republican that Roberts indicates [RONR (10th ed.), p. 394, l. 15-25] that if a member has a direct personal or pecuniary (monetary) interest in a motion under consideration not common to other members, the member should not vote on such a motion. Redpath failed to make such instruction.

2) Under the leadership of Chairman Redpath, the Libertarian National Committee has used party resources to support the campaigns of particular candidates for our party's presidential nomination. In particular: The party newspaper LP News for most of the presidential nominating campaign took a position of the nominal objectivity, primarily by ignoring the nominating campaigns of our presidential candidates. However, the April, 2008 issue of the newspaper featured a front page article describing in glowing terms the nominating campaigns of precisely two of our multiple candidates. One of the two was Bob Barr, whom Redpath publicly claimed he had recruited as our candidate.

Other candidates who wished positive articles or statements about them to appear in LP News had to buy the space as an advertisement, at a price far higher than that charged in years previous. Furthermore that space was clearly purchased advertising rather than earned media and was thus far less invaluable.

Under party bylaws and LNC rules, Redpath is personally responsible for this event. National committee resolutions as gathered in the Policy Manual establish that sole responsibility for articles in LP news replies in the hands of the chairman. While the Chairman may delegate this authority, at such time as the authority is abused, as happened here, it was the duty of the chairman to make appropriate compensation to our other candidates. Redpath failed to do so. His failure constitutes misappropriation of party funds in support of his personal candidate for the nomination of our party.

3) The actions described in points one and two were gifts in kind by the Libertarian National Committee to the presidential campaigns of Ron Paul, Bob Barr, and Mike Gravel. Perusal of the LNC FEC reports for this period shows that these gifts in kind, while extremely valuable, were not disclosed. Failure to disclose spending in an accurate and timely manner leaves the LNC open to potential civil or criminal action by the Federal Election Commission.

4) Redpath as party Chief Executive Officer is personally responsible for the decision to file the so called "LNC" suit against New Hampshire Secretary of state William Gardiner. The core claims of that suit are clearly and unmistakably fraudulent. Furthermore, the suit represents a conspiracy to deny New Hampshire Libertarians, namely the New Hampshire Libertarian Party State Convention, their right of freedom of association and petition, namely their right to choose a candidate for President and petition to have him placed on the ballot. Use of LNC funds in support of this lawsuit constitutes an act of fraud and theft in gross violation of the statement of principles.

5) Redpath as Chief Executive Officer is responsible for the conduct of his employees. As chair of the national convention he is also responsible for seeing that actions that he reasonably should have known were based on fraud were prevented from taking place. In the matter of the alleged "District of Columbia" delegation to our national convention, Redpath failed to discharge his duties in an effective and appropriate manner

Our Party Bylaws require that the recognized affiliate must appoint the delegation to the National Convention. However, the DC affiliate is noted for its total silence. As the convention approached, MPP chair Rob Kampia claimed to be the 'delegation chair' and demanded recognition of his delegation. There is no basis for this claim under party bylaws. Instead, Redpath's Executive Director, whom Bob Barr brought to the stage after the nomination and thanked for unspecified services, had sent a memo

From: Shane Cory <shane.cory@lp.org>
To: "salvette@umich.edu" <salvette@umich.edu>
Emily,
What's the latest that delegate names can be submitted to you? Also, Rob Kampia in D.C. has stepped up to the plate to be delegation chair. I spoke with Bob Sullentrup about this. Since there is no D.C. party, he said someone can step up to be the delegation chair (not party chair) to fill in vacancies.
Rob will be submitting names to you after a D.C. Meetup.
Thanks for everything!
Best,
Shane

to create a fraudulent claim that a DC delegation existed. Members will recall that the DC delegation chair, Rob Kampia, participated in this fraud in order to be Bob Barr's nominator from the stage at the national convention.

Redpath as National Chair must have been aware that there was no active DC party, and failed to take adequate steps to ensure if that the fraudulent DC delegation was not seated.