Whereas, the Montana Republican State Central Committee (“MTGOP”) is the governing
body for the statewide Republican Party;
Whereas, the Montana Republican State Central Committee (“MTGOP”) is a political
party committee organized pursuant to Mont. Code Ann. § 13-38-101 et seq.;
Whereas, Montana’s statutory framework governing political parties recognizes their right
of association and the strength it affords political parties, protecting them from takeover
or destabilization by rogue individuals or factions;
Whereas, Montana law provides that each political party may:

• make its own rules;
• provide for and select its own offices;
• call conventions and provide for the number and qualification of delegates;
• adopt platforms;
• provide for selection of delegates to national conventions;
• provide for the nomination of presidential electors;
• provide for the selection of national committee representatives;
• make nominations to fill vacancies occurring among its candidates nominated for
  offices to be filled by the state at large or by any district consisting of more than
  one county where the vacancies are caused by death, resignation, or removal from
  the electoral district;
• perform all other functions inherent in a party organization.
  Mont. Code Ann. § 13-38-101;
  Whereas, to protect the inherent functions of political parties, Montana law requires that
  the state central committee of each political party file a current copy of its governing rules
  with the Secretary of State. Mont. Code Ann. § 13-18-104;
  Whereas, MTGOP has enacted its own rules and has filed a current copy with the
  Montana Secretary of State;
  Whereas, city and county central committees of each political party must file a copy of
  their governing rules with the election administrator and are only effective when filed.
  Mont. Code Ann. § 13-38-105;
  Whereas, city and county central committee rules must not conflict with any of the
  provisions of state election laws or the rules of the state political party. Mont. Code Ann.
  § 13-38-203(1)(a);

Whereas, state law protections are further understood via their parameters for legal
recognition of an assumed business name and trademarks. Only a city, county, or state
central committee of a political party may register an assumed business name, trademark,
or service mark for the central committee. Mont. Code Ann. § 13-38-107;
Whereas, only a city, county, or state central committee of a political party may register
an assumed business name on behalf of the central committee. Mont. Code Ann. § 30-
13-219;
Whereas, the Secretary of State may not accept an application for an assumed business
name of a city, county, or state central committee of a political party unless it is
accompanied by a resolution of the relevant central committee attesting that it is the entity
applying for an assumed business name. Id.;
Whereas, only a city, county, or state central committee of a political party may register
a mark on behalf of the central committee. Mont. Code Ann. § 30-13-342;
Whereas, like Montana law, the United States Supreme Court has also long recognized
official political parties’ rights of association. “Representative democracy in any populous
unit of governance is unimaginable without the ability of citizens to band together in
promoting among the electorate candidates who espouse their political views.” Cal.
Democratic Party v. Jones, 530 U.S. 567, 574 (2000). “The formation of national political
parties was almost concurrent with the formation of the Republic itself.” Id. “Consistent
with this tradition, the Court has recognized that the First Amendment protects ‘the
freedom to join together in furtherance of common political beliefs,’ which ‘necessarily
presupposes the freedom to identify the people who constitute the association, and to
limit the association to those people only.’” Id. In other words, “a corollary of the right to
associate is the right not to associate.” Id. “Freedom of association would prove an empty
guarantee if associations could not limit control over their decisions to those who share
the interests and persuasions that underlie the association’s being.” Id.
Whereas, “It is well settled that partisan political organizations enjoy freedom of
association protected by the First and Fourteenth Amendments.” Eu v. San Francisco
Democratic Central Committee, 480 U.S. 214, 283 (1989). “Freedom of association
means not only that an individual voter has the right to associate with the political party
of her choice, but also that a political party has a right to ‘identify the people who constitute
the association,’ and to select a ‘standard bearer who best represents the party’s
ideologies and preferences.’” Id.
Whereas, MTGOP’s own Rules provide in relevant part:

• These rules are created for the governance of the Montana Republican Party. They
  shall govern when not in conflict with the Rules of the Republican National
  Committee. These rules shall govern the organization, the conduct of meetings
  and the business of the Montana Republican State Central Committee, its officers, executive board and committees, all Republican State Conventions, and all Republican County Central Committees, to the extent applicable thereto. Rule A.I.
• The State Central Committee shall be composed of the County Chairman, State
  Committeeman, State Committeewoman, and Finance Chairman for each county,
  who have been elected or appointed in the manner provided by these rules. Rule
  C.I.A.
• The State Central Committee is the governing body of the Montana State
  Republican Party, responsible for establishing all State rules, policies, and
  programs for the Executive Board in accordance with these Rules. Rule C.I.B.
• In each county of the state there shall be a Republican Central Committee which
  shall consist of the duly elected or appointed Precinct Committeemen and
  Committeewomen of each precinct within the county. Rule C.III.A.
• The County Central Committee may adopt rules for the government of the Party in
  its county, including rules governing the approval of campaign literature to be used
  for public distribution, which rules may not be inconsistent with any of the provision
  of the election laws of this state or with these rules. County Committee Rules or
  Bylaws will be effective only if adopted by a two thirds majority vote of all elected
  and appointed precinct committeemen and committeewomen present and voting
  at a properly noticed meeting of the Committee and then filed of record with the
  Executive Office of the Montana Republican Party within two weeks of adoption.
  Failure to properly file County Rules or Bylaws with the State Party shall render
  them null and void. Rule C.III.J.

Whereas, federal law, Montana law, and MTGOP’s own rules make clear that only official
political parties can carry out the functions and powers of political parties;
Whereas, rogue individuals or factions may not register assumed business names,
register trademarks, undertake fundraising activities, create party platforms, organize
central committees, elect officers, or conduct any other activity that is within the province
of the official party under the auspices of the official party;
Whereas, in the fall of 2023, Lisa Bennett repeatedly falsely presented herself as an
official, representative, or employee of the MTGOP to the general public, as well as to the
Montana Commissioner of Political Practices (“COPP”);
Whereas, Lisa Bennett had multiple phone calls and email correspondence with COPP
employees in which she led COPP to believe she was representing MTGOP as a
“compliance” officer. Lisa Bennett corresponded with an email address of
“compliance@gopmontana.com” in an apparent effort to mislead COPP and others into
thinking she was affiliated with MTGOP;

Whereas, Lisa Bennett also used the MTGOP’s name, images, logos, and marks to
mislead the general public;
Whereas, the email address “compliance@gopmontana.com” and the website address
“gopmontana.com” are clearly meant to give the false impression that she is
communicating on behalf of MTGOP;
Whereas, Lisa Bennett’s actions caused confusion to third parties. For instance, the
COPP—believing the false information Lisa Bennett presented—stopped sending official
correspondence concerning MTGOP’s County Central Committees to MTGOP and sent
them to her fake “GOP Montana” email address instead;
Whereas, Lisa Bennett is not authorized to speak for or represent MTGOP in any matter
before COPP. She is neither an employee nor officer of MTGOP;
Whereas, when MTGOP learned of Lisa Bennett’s actions, it sent her a cease and desist
letter on October 5, 2023. MTGOP also sent a clarification letter to COPP on October 11,

2023. MTGOP further requested that Lisa Bennett immediately remove the website
      address “gopmontana.com” and all associated email domains with the same name.
      Although Lisa Bennett did slightly alter the logos used on the website, she did not comply
      with MTGOP’s request;
      Whereas, Lisa Bennett, along with Karla Johnson and Levi McEuen, is affiliated with the
      so-called “Montana Association of Republican Central Committees” (“MARCCO”);
      Whereas, MARCCO is not a city, county, or state central committee. To the contrary,
      MTGOP views GOP Montana, MARCCO, and the individuals promoting them as
      undermining the message and work of the MTGOP and harming its right to freely
      associate to advocate for political candidates, ballots issues, and political messaging;
      Whereas, MTGOP has never recognized, authorized, endorsed, or sanctioned the
      political and fundraising activities of either GOP Montana or MARCCO;
      Whereas, MARCCO was registered as an assumed business name with the Montana
      Secretary of State on February 14, 2024, by Shirley Bennett. According to the GOP Data
      Center, Shirley Bennett is Lisa Bennett’s mother; she is 89 years old. Additionally, the
      phone number on the registration form is linked to Lisa Bennett’s 12-year-old daughter,
      Nicole Bennett;
      Whereas, Shirley Bennett also filed Articles of Correction with the Montana Secretary of
      State on behalf of another group in which Lisa Bennett is listed as a Director—the
      Montana Concerned Citizens Foundation Fund. In that filing, the phone number listed as
      a contact for Shirley Bennett is actually Lisa Bennett’s phone number. Lisa Bennett and
      Shirley Bennett are registered to vote at the same address: 110 Barlow Creek Rd., Luther,
      Montana, 59068;

Whereas, the current COPP, Chris Gallus, is listed as the Incorporator for the Montana
Concerned Citizens Foundation Fund in the records of the Secretary of State. However,
Mr. Gallus submitted an affidavit to the Secretary of State stating: “Despite my express
refusal to serve as incorporator, Ms. Bennett, or an agent of Montana Concerned Citizens
Foundation Fund, filed Articles of Incorporation with the Montana Secretary of State that
falsely claim me as the incorporator.”;
Whereas, based on this information, as well as MTGOP’s prior experiences with Lisa
Bennett misrepresenting her authority and motives, it appears that Lisa Bennett, not
Shirley Bennett, is the true force behind MARCCO, along with Johnson and McEuen;
Whereas, MARCCO co-hosting a town hall meeting titled “Politics & Pancakes” on April
27, 2024, at which it intended to raise money from donors;
Whereas, Neither GOP Montana nor the Montana Association of Republican Central
Committees have registered with COPP or filed a certification as required by Mont. Code
Ann. § 13-37-201 et seq.;
Whereas, Lisa Bennett and MARCCO have failed to keep detailed records of their
political committees or to file any financial reports with COPP as required by Mont. Code
Ann. § 13-37-208;
Whereas, Lisa Bennett and MARCCO have failed to file any contribution or expenditure
reports with COPP for the political committees as required by Mont. Code Ann. §§ 13-37-
225 and 13-37-229 even though the GOP Montana website contains a “Donate” button
and MARCCO purports to participate in fundraising activities;
Whereas, Lisa Bennett’s involvement in MARCCO is further shown by the fact that her
GOP Montana website is closely linked with MARCCO. The first image on the Home Page
contains buttons to “Join Us” and “Find A Central Committee.”;
Whereas, this language is highly misleading to the public because MARRCO is not
affiliated with the official Montana Republican Party or any county central committee;
Whereas, when a user clicks on the “Find A Central Committee” button, he is redirected
to the MARCCO website, marcco.org. This page purports to promote membership in local
central committees; however there is no contact information for any county central
committee listed. The page appears to reflect that all Montana county central committees
are affiliated with MARCCO, when in fact none of them are;
Whereas, central committees may or may not choose to publish their officer names and
contact information to the public. As this page currently sits, the Defendants could include
any information—whether true or not—about county central committees. This undermines
the official political party and its authority, including that of its local central committees;

Whereas, the MARCCO Home Page is nearly identical to the GOP Montana Home Page.
The MARCCO website also contains a “Donate” button. When a user clicks on the
“Donate” button, he is directed to a page asking for donations to the Montana Concerned
Citizens Foundation Fund, a non-profit organization of which Lisa Bennett is a Director.
No other information regarding Montana Concerned Citizens Foundation Fund is
provided;
Whereas, GOP Montana website also contains links under its “Resources” tab to
“Candidate Training,” “Central Committees,” “Conservative News,” “Elected Officials,”
“Legislative Guide,” and “Our Partners.” Under MARCCO’s “About” tab, there is a link to
“Our Platform,” which directed me to a page titled “What We Believe” and included the
Platform of the Montana Republican Party Adopted July 16, 2022;
Whereas, as with the other information included in this website, this is misleading as it
appears to reflect that MARCCO is connected in some way to the MTGOP, when MTGOP
does not endorse or authorize this organization in any way;
Whereas, both websites also contain “Sign In” buttons. It is unclear from the website how
a person acquires sign-in information from these groups;
Whereas, both GOP Montana and MARCCO continue to promote their political activities,
undermine the MTGOP as set forth above, and mislead the public through these websites
despite the issuance of a Temporary Restraining Order on April 19, 2024;
Whereas, leading up to the June 2025 State Party Officer’s Convention, Lisa Bennett—
without any authorization whatsoever from MTGOP—has been contacting central
committee officers and providing them with unsolicited advice and recommendations
about credentialing for the convention;
Whereas, some of the information Lisa Bennett has provided is not accurate and has led
to additional confusion and chaos;
Whereas, MTGOP has decided to dissociate Lisa Bennett from participating in MTGOP
activities to protect its freedom of association, protect the integrity of its message and
work in advocating for political candidates, ballots issues, choosing its own governance,
and political messaging;

Therefore, The Executive Committee Of The MTGOP Resolves To Make It Known
That:

1. Lisa Bennett and MARCCO have taken actions that damage, undercut, and defeat
   the efforts of the elected officials of the MTGOP and the Republican Party in
   general;
2. Lisa Bennett and MARCCO’s actions aim to weaken or destabilize the official
   MTGOP by engaging in activities reserved for official political parties or central
   committees under the auspices of the MTGOP;
3. Lisa Bennett and MARCCO’s actions violate Montana’s statutory framework,
   which vests authority in official political parties to govern their activities and central
   committees, thereby protecting against rogue factions;
4. Lisa Bennett is not considered by the MTGOP to be a member of the Montana
   Republican Party;
5. MARCCO is not affiliated in any way with MTGOP, nor does MTGOP support,
   condone, or sanction any of its activities;
6. Lisa Bennett and MARCCO are banned from participating in any MTGOP
   activities, including any activities of its subsidiary central committees or affiliates,
   including without limitation the Montana Federation of Republican Women and its
   local chapters;
7. Lisa Bennett may not attend any state party conventions or participate in any local
   central committee conventions;
8. Lisa Bennett and MARCCO are not authorized to speak for the MTGOP or any of
   its affiliates on any matter;
9. Lisa Bennett and MARCCO are not authorized by MTGOP to fundraise on behalf
   of any Republican candidate or cause;
10. The Executive Committee of the MTGOP, through its Chairman, shall notify all
    Republican central committees and all groups affiliated with the official MTGOP of
    this Resolution.