May 30, 2018

Via Hand Delivery and Email to bill@montgomerycountygop.com

Bill Donnelly, Chairman MCRC

Re: Montgomery County Republican Committee Meeting, May 31, 2018

Dear Mr. Donnelly:

I represent Madame Justice Sandra Schultz Newman. This morning, you
conducted a conference call. I participated, along with Anthony Spangler on behalf
of Liz Havey and Jim Saring as Executive Director of the Montgomery County
Republican Committee (MCRC). I participated on behalf of Justice Newman. The
purpose of the call was to answer questions with regard to the MCRC scheduled for
May 31, 2018.

The MCRC by-laws call for the election for Chairman by the elected
committee people. I expressed concern that the Montgomery County Board of
Elections will not certify the results from the Spring 2018 until Monday, June 5,
2018. You stated that you attended the count of the vote last week and compiled a
list of those whom you believe were elected as committee persons. You
acknowledged that the Board of Elections has not and cannot notify those who won
the election until next week when the election is certified. Nonetheless, you, as
Chairman of MCRC caused a letter to go out by regular mail, notifying those who
you believed to be elected committeeperson that they won and also that an election
for Chairman would be held on May 31, 2018. With regard to the divisions wherein
there is a tie, you are allowing all of those individuals to vote provisionally. After
the Board of Elections determines the winners of the tie votes on June 1, 2018, if
the vote for Chairman is close enough, you will count those votes. You
acknowledged, then, that some people participating in the election will later be
deemed to be ineligible once the Board of Elections certifies the vote. You also
mentioned that those ineligible voters are not enough to "matter." Accordingly, you
decided that the MCRC Chairman will be elected by those whom you believe won
Law Offices of Linda A. Kerns, LLC Page 2

the committee people elections and not the official winners as certified by the Board
of Elections.

My client believes that holding the MCRC election prior to the official
certification by the Board of Elections violates the Pennsylvania Election
Code. More importantly, your actions violate the rights of all Montgomery County
voters who participated in the Spring 2018 election and voted for committee
people. Those voters had no notice that you would be deciding the winners of the
committee people election based on your observation of the vote count, rather than
relying on the Official Certification of the Board of Elections. Your belief as to who
was elected as committee person based on your witnessing of the count and your
personal compilation of a list of names is irrelevant. The Pennsylvania Election
Code is clear on this issue. I also note that I have personally spoken to people who
believe that they may have been elected in Spring 2018 that did not receive your
letter. Accordingly, your notification process is obviously fatally flawed.

My client formally requests that you postpone the May 31, 2018 meeting
until after the Board of Elections has certified the Spring 2018 election results on
June 5, 2018 and those elected have been duly notified by the county. I ask that
you provide me with your decision no later than close of business today. Please
email me at linda@lindakernslaw.com and call me at 215-731-1400.

I trust you will make the right decision. Election integrity is a hallmark of
Republican values. The party of Lincoln should strive to make sure every election is
free, fair and lawful. Montgomery County should not be an exception.

Very truly yours,

Linda A. Kerns
LINDA A. KERNS

Cc: Madame Justice Sandra Schultz Newman

Jim Saring, Executive Director, MCRC
Dr. Robert Griffith
France Krazalkovich