Scott Miller Lawsuit

ROBERT T. SPJUTE, ESQ.
(13866)
SHUMWAY VAN
8 East Broadway, Suite 550
Salt Lake City, Utah 84111
Phone: (801) 478-8080
Fax: (801) 478-8088
Tee@shumwayvan.com
Attorney for Plaintiff Scott Miller
IN THE THIRD JUDICIAL DISTRICT COURT OF SALT LAKE COUNTY,

SALT LAKE DEPARTMENT, STATE OF UTAH
SCOTT MILLER, an individual,

COMPLAINT
Plaintiff,
v.
Case No.:
SPENCER COX, an individual; DEIDRE
Judge:
HENDERSON, an individual; BRAD
WILSON, an individual; TODD WEILER, an Tier 3
individual; CANDICE PIERUCCI, an
individual; ANDY PIERUCCI, an individual;
MIA LOVE, an individual; JOHN CURTIS, an
individual; DANIEL BURTON, an individual;
CRAIG HALL, an individual; and V. LOWRY
SNOW, an individual; STUART ADAMS, an
individual; DAVID DAMSCHEN, an
individual; ANDREW GRUBER, an
individual; DEREK BROWN, an individual;
AMELIA POWERS GARDINER, an
individual; ADAM GARDINER, an
individual; JOHN DOUGALL, an individual;
MICHAEL MOWER, an individual’ HOLLY
RICHARDSON, an individual; CINDIE
QUINTANA, an individual, an individual;
JON PIERPONT, an individual; TANI PACK
DOWNING, an individual; KIMBERLY
COLEMAN, an individual; BARBARA
STALLONE, an individual; KAREN KWAN,
an individual; DAWN RAMSEY, an
individual; WAYNE CUSHING, an
individual; CARL ALBRECHT, an individual;
JENNIFER ROBISON, an individual; MARIE
Page 1 of 61
POULSON, an individual; DEBBIE
DUJANOVIC, an individual; HEATHER
ANDERSON, an individual; MICHAEL
WHITLOCK, an individual; ANDREW
STODDARD, an individual; TRACY
GRUBER, an individual; BECKY PICKLE, an
individual; BRAD BONHAM, an individual;
ZACH JACOB, an individual; BART
BARKER, an individual; ENID MICKLESEN,
an individual; DELAINA TONKS, an
individual; ALLY ISOM, an individual; SUE
DUCKWORTH, an individual; HANNAH
COLEMAN, an individual; JAKE
PARKINSON, an individual’ VAL HALE, an
individual; KERRI NAKAMURA, an
individual; MICHELLE QUIST, an individual;
ROZAN MITCHELL, an individual; BECKY
EDWARDS, an individual; CARL
DOWNING, an individual; JORDAN
TEUSCHER, an individual; SUSAN
PULSIPHER, an individual; JEFF
STENQUIST, an individual; ROBERT
SPENDLOVE, an individual; MICHAEL
WINDER, an individual; DANIEL
THATCHER, an individual; KIRK
CULLIMORE, an individual; LINCOLN
FILLMORE, an individual; RALPH
CHAMNESS, an individual; CAROL MOSS,
an individual; RICHARD JAUSSI, an
individual; JON COX, an individual; CHRIS
STAVROS, an individual; ANNETTE
STAVROS, an individual; AIMEE WINDER-
NEWTON, an individual; ABBY EVANS, an
individual; LAURIE STRNGHAM, an
individual; CHRIS NULL, an individual; A.
SCOTT ANDERSON, an individual; DEREK
MONSON, an individual; KARI
MALKOVICH, an individual; NINA
BARNES, an individual; ZAN
ZOGMAISTER, an individual; NEKA
ROUNDY, an individual; LORENE COX, an
individual; JUDY HOUSTON, an individual;
LESA SANDBERG, an individual; DARCY
KRUITBOSCH, an individual; KRISTEN
Page 2 of 61
CLARKE, an individual; HILLARY JESSUP,
an individual; BECKI BRONSON, an
individual; CHRISTA HINTON, an individual;
CAROLINA HERRING, an individual;
COURTNEY SINAGRA, an individual;
CHLOE ATKIN, an individual; LORI
BRINKERHOFF, an individual; DAN
HARRIE, an individual; RICHARD
MARKOSIAN, an individual; JENNIFER
NAPIER PEARCE, an individual; CHAD
PRITCHARD, an individual; JON DOES 1–
100; STATE OF UTAH; SALT LAKE
COUNTY; ZIONS BANCORPORATION
N.A.; ZIONS BANK; THE SUTHERLAND
INSTITUTE; UTAH FEDERATION OF
REPUBLICAN WOMAN; SALT LAKE
COUNTY REPUBLICAN PARTY; UTAH
REPUBLICAN PARTY; UTAH STORIES,
LL; UTAH POLICY; THE SALT LAKE
TRIBUNE, INC.; NEXSTAR MEDIA, INC;
ROE CORPORATIONS 1–100,
Defendants.
Plaintiff SCOTT MILLER (“Mr. Miller” or “Plaintiff”) through his counsel of record,
complains of and for his causes of action against the Defendants’ listed in the above captioned
matter as follows:
PARTIES AND JURISDICTION
1. Plaintiff SCOTT MILLER is, and at all times relevant herein was, a resident of
Salt Lake County, State of Utah.
2. Defendant SPENCER COX, upon information and belief is, and at all times
relevant herein was, a person living or regularly conducting business in Salt Lake County, State
Page 3 of 61
of Utah.
3. Defendant DEIDRE HENDERSON, upon information and belief is, and at all
times relevant herein was, a person living or regularly conducting business in Salt Lake County,
State of Utah.
4. Defendant BRAD WILSON, upon information and belief is, and at all times
of Utah.
5. Defendant TODD WEILER, upon information and belief is, and at all times
of Utah.
6. Defendant CANDICE PIERUCCI, upon information and belief is, and at all times
of Utah.
7. Defendant ANDY PIERUCCI, upon information and belief is, and at all times
of Utah.
8. Defendant MIA LOVE, upon information and belief is, and at all times relevant
herein was, a person living or regularly conducting business in Salt Lake County, State of Utah.
9. Defendant JOHN CURTIS, upon information and belief is, and at all times
of Utah.
10. Defendant DANIEL BURTON, upon information and belief is, and at all times
Page 4 of 61
of Utah.
11. Defendant CRAIG HALL, upon information and belief is, and at all times
of Utah.
12. Defendant V. LOWRY SNOW, upon information and belief is, and at all times
of Utah.
13. Defendant DAVID DAMSCHEN, upon information and belief is, and at all times
of Utah.
14. Defendant STUART ADAMS, upon information and belief is, and at all times
of Utah.
15. Defendant ANDREW GRUBER, upon information and belief is, and at all times
of Utah.
16. Defendant DEREK BROWN, upon information and belief is, and at all times
of Utah.
17. Defendant AMELIA POWERS GARDINER, upon information and belief is, and
at all times relevant herein was, a person living or regularly conducting business in Salt Lake
Page 5 of 61
County, State of Utah.
18. Defendant ADAM GARDINER, upon information and belief is, and at all times
of Utah.
19. Defendant JOHN DOUGALL, upon information and belief is, and at all times
of Utah.
20. Defendant MICHAEL MOWER, upon information and belief is, and at all times
of Utah.
21. Defendant HOLLY RICHARDSON, upon information and belief is, and at all
State of Utah.
22. Defendant LORENE COX, upon information and belief is, and at all times
of Utah.
23. Defendant CINDIE QUINTANA, upon information and belief is, and at all times
of Utah.
24. Defendant ANDY PEIRUCCI, upon information and belief is, and at all times
of Utah.
Page 6 of 61
25. Defendant JON PIERPONT, upon information and belief is, and at all times
of Utah.
26. Defendant TANI PACK DOWNING, upon information and belief is, and at all
State of Utah.
27. Defendant KIM COLEMAN, upon information and belief is, and at all times
of Utah.
28. Defendant BARBARA STALLONE, upon information and belief is, and at all
State of Utah.
29. Defendant KAREN KWAN, upon information and belief is, and at all times
of Utah.
30. Defendant DAWN RAMSEY, upon information and belief is, and at all times
of Utah.
31. Defendant WAYNE CUSHING, upon information and belief is, and at all times
of Utah.
32. Defendant CARL ALBRECHT, upon information and belief is, and at all times
Page 7 of 61
of Utah.
33. Defendant JENNIFER ROBISON, upon information and belief is, and at all times
of Utah.
34. Defendant MARIE POULSON, upon information and belief is, and at all times
of Utah.
35. Defendant DEBBIE DUJENOVIC, upon information and belief is, and at all
State of Utah.
36. Defendant HEATHER ANDERSON, upon information and belief is, and at all
State of Utah.
37. Defendant MICHAEL WHITLOCK, upon information and belief is, and at all
State of Utah.
38. Defendant ANDREW STODDARD, upon information and belief is, and at all
State of Utah.
39. Defendant TRACY GRUBER, upon information and belief is, and at all times
Page 8 of 61
of Utah.
40. Defendant BECKY PICKLE, upon information and belief is, and at all times
of Utah.
41. Defendant BRAD BONHAM, upon information and belief is, and at all times
of Utah.
42. Defendant ZACH JACOB, upon information and belief is, and at all times
of Utah.
43. Defendant BART BARKER, upon information and belief is, and at all times
of Utah.
44. Defendant ENID MICKLESEN, upon information and belief is, and at all times
of Utah.
45. Defendant DELAINA TONKS, upon information and belief is, and at all times
of Utah.
46. Defendant ALLY ISOM, upon information and belief is, and at all times relevant
47. Defendant SUE DUCKWORTH, upon information and belief is, and at all times
Page 9 of 61
of Utah.
48. Defendant HANNAH COLEMAN, upon information and belief is, and at all
State of Utah.
49. Defendant JAKE PARKINSON, upon information and belief is, and at all times
of Utah.
50. Defendant VALE HALE, upon information and belief is, and at all times relevant
51. Defendant KERRI NAKAMURA, upon information and belief is, and at all times
of Utah.
52. Defendant MICHELLE QUIST, upon information and belief is, and at all times
of Utah.
53. Defendant ROZAN MITCHELL, upon information and belief is, and at all times
of Utah.
54. Defendant BECKY EDWARDS, upon information and belief is, and at all times
of Utah.
Page 10 of 61
55. Defendant CARL DOWNING, upon information and belief is, and at all times
of Utah.
56. Defendant JORDAN TEUSCHER, upon information and belief is, and at all times
of Utah.
57. Defendant SUSAN PULSIPHER, upon information and belief is, and at all times
of Utah.
58. Defendant JEFF STENQUIST, upon information and belief is, and at all times
of Utah.
59. Defendant ROBERT SPENDLOVE, upon information and belief is, and at all
State of Utah.
60. Defendant MICHAEL WINDER, upon information and belief is, and at all times
of Utah.
61. Defendant CRAIG HALL, upon information and belief is, and at all times
of Utah.
62. Defendant DANIEL THATCHER, upon information and belief is, and at all times
Page 11 of 61
of Utah.
63. Defendant KIRK CULLIMORE, upon information and belief is, and at all times
of Utah.
64. Defendant LINCOLN FILLMORE, upon information and belief is, and at all
State of Utah.
65. Defendant RAPLH CHAMNESS, upon information and belief is, and at all times
of Utah.
66. Defendant DANIEL BURTON, upon information and belief is, and at all times
of Utah.
67. Defendant CAROL MOSS, upon information and belief is, and at all times
of Utah.
68. Defendant RICHARD JAUSSI, upon information and belief is, and at all times
of Utah.
69. Defendant JON COX, upon information and belief is, and at all times relevant
Page 12 of 61
70. Defendant CHRIS STAVROS, upon information and belief is, and at all times
of Utah.
71. Defendant ANNETTE STAVROS, upon information and belief is, and at all
State of Utah.
72. Defendant AIMEE WINDER-NEWTON, upon information and belief is, and at
all times relevant herein was, a person living or regularly conducting business in Salt Lake
73. Defendant ABBY EVANS, upon information and belief is, and at all times
of Utah.
74. Defendant LAURIE STRINGHAM, upon information and belief is, and at all
State of Utah.
75. 69. Defendant CHRIS NULL, upon information and belief is, and at all times
of Utah.
76. Defendant A. SCOTT ANDERSON, upon information and belief is, and at all
State of Utah.
77. Defendant DEREK MONSON, upon information and belief is, and at all times
Page 13 of 61
of Utah.
78. Defendant KARI MALKOVICH, upon information and belief is, and at all times
of Utah.
79. Defendant NINA BARNES, upon information and belief is, and at all times
of Utah.
80. Defendant ZAN ZOGMAISTER, upon information and belief is, and at all times
of Utah.
81. Defendant NEKA ROUNDY, upon information and belief is, and at all times
of Utah.
82. Defendant JUDY HOUSTON, upon information and belief is, and at all times
of Utah.
83. Defendant LESA SANDBERG, upon information and belief is, and at all times
of Utah.
84. Defendant DARCY KRUITBOSCH, upon information and belief is, and at all
Page 14 of 61
State of Utah.
85. Defendant KRISTEN CLARKE, upon information and belief is, and at all times
of Utah.
86. Defendant HILLARY JESSUP, upon information and belief is, and at all times
of Utah.
87. Defendant BECKI BRONSON, upon information and belief is, and at all times
of Utah.
88. Defendant CHRISTA HINTON, upon information and belief is, and at all times
of Utah.
89. Defendant CAROLINA HERRING, upon information and belief is, and at all
State of Utah.
90. Defendant COURTNEY SINAGRA, upon information and belief is, and at all
State of Utah.
91. Defendant CHLOE ATKIN, upon information and belief is, and at all times
of Utah.
Page 15 of 61
92. Defendant LORI BRINKERHOFF, upon information and belief is, and at all
State of Utah.
93. Defendant DAN HARRIE, upon information and belief is, and at all times
of Utah.
94. Defendant RICHARD MARKOSIAN, upon information and belief is, and at all
State of Utah.
95. Defendant JENNIFER NAPIER PEARCE, upon information and belief is, and at
all times relevant herein was, a person living or regularly conducting business in Salt Lake
96. Defendant CHAD PRITCHARD, upon information and belief is, and at all times
of Utah.
97. Defendants Doe 1 through 100 are persons presently unknown and/or not yet
specifically identified that have participated in a cause of action and Plaintiff reserves the right to
amend the complaint in the event that such Doe is discovered.
98. Defendant ZIONS BANCORPORATION N.A., upon information and belief is,
and at all times relevant herein was, a corporation regularly conducting business in Salt Lake
Page 16 of 61
99. Defendant THE SUTHERLAND INSTITUTE, upon information and belief is,
and at all times relevant herein was, a corporation regularly conducting business in Salt Lake
100. Defendant UTAH FEDERATION OF REPUBLICAN WOMEN upon
information and belief is, and at all times relevant herein was, an organization regularly
conducting business in Salt Lake County, State of Utah.
101. Defendant SALT LAKE COUNTY REPUBLICAN PARTY, upon information
and belief is, and at all times relevant herein was, an organization regularly conducting business
in Salt Lake County, State of Utah.
102. Defendant UTAH REPUBLICAN PARTY, upon information and belief is, and at
all times relevant herein was, an organization regularly conducting business in Salt Lake County,
State of Utah.
103. Defendant UTAH STORIES, LLC, upon information and belief is, and at all
times relevant herein was, an organization regularly conducting business in Salt Lake County,
State of Utah.
104. Defendant UTAH POLICY, upon information and belief is, and at all times
relevant herein was, an organization regularly conducting business in Salt Lake County, State of
Utah.
105. Defendant THE SALT LAKE TRIBUNE, INC, upon information and belief is,
and at all times relevant herein was, an organization regularly conducting business in Salt Lake
Page 17 of 61
106. Defendant ZIONS BANK, upon information and belief is, and at all times
relevant herein was, an organization regularly conducting business in Salt Lake County, State of
Utah.
107. Defendant NEXSTAR MEDIA, INC., upon information and belief is, and at all
times relevant herein was, an organization regularly conducting business in Salt Lake County,
State of Utah.
108. Defendants ROE CORPORATIONS 1 through 100 are corporations and/or
organizations presently unknown and/or not yet specifically identified that have participated in a
cause of action and Plaintiff reserves the right to amend the complaint in the event that such
ROE is discovered.
109. The events and circumstances giving rise to this Complaint occurred in Salt Lake
110. Pursuant to U.C.A. § 63G-7-401 a notice of claim has been provided to the State
of Utah and Salt Lake County.
111. Jurisdiction is proper pursuant to U.C.A. § 78A-5-102(1) and U.C.A. § 63G-7-
501.
112. Venue is proper pursuant to U.C.A. §§78B-3-302, 307 and U.C.A. § 63G-7-502.
INTRODUCTION
113. Scott Miller is arguably one of the most successful GOP Chairs in the history of
Salt Lake County. Miller’s unconventional approach to campaigns, focusing on local issues
instead of donor and lobbyist money and demands, led to success electing Republican
candidates.
Page 18 of 61
114. However, Miller’s approach and success apparently drew the ire of certain elected
officials, state employees, lobbyists, donors, and more. It appears these establishment individuals
committed much time, energy, and political capital to stop Miller’s growing influence in the
County and State Republican Party leadership and elections. It appears these individuals
coordinated efforts to undermine and slander Miller, ensuring he did not win re-election as the
County Republican Party Chair or election as the State Republican Party Chair.
115. Certain individuals threatened Miller, attempted to intimidate him, conspired, and
some utilized a biased reporter at the Salt Lake Tribune to publicly initiate attacks
against Miller.
116. Their efforts triggered a very public, social media and public trial through social
media of then Salt Lake County GOP Chairman Scott Miller.
BACKGROUND
117. On March 27, 2021, the Salt Lake Tribune ran a story titled, “Republican women
say they experienced a toxic environment in the Salt Lake County GOP”. The story was
written by Ms. Leia Larsen and featured 7 “reputable women”.
118. The initial allegations from these women led to many defamatory and salacious
statements against Mr. Miller, a private citizen, and volunteer. The condemnation of Mr.
Miller was quickly piled on by many elected officials, state employees, and others.
119. Within just a few hours, unfounded allegations against Miller spread quickly
through social media outlets, podcasts, print, television, etc.
120. Numerous prominent elected officials and state employees quickly
maligned Miller, posted, liked, shared, and forwarded these unfounded accusations against him
Page 19 of 61
to their combined hundreds of thousands of social media followers:
a. Lt. Governor Deidre Henderson
b. Brad Wilson – Speaker of the State House
c. Stuart Adams - President of the State Senate
d. David Damschen – Prior State Treasurer
e. Andrew Gruber – Executive Director Wasatch Front Regional Council
f. Derek Brown – Chairman of Utah Republican Party
g. Amelia Powers Gardner – Utah County Commissioner
h. Adam Gardiner – Utah Field operator for Senator Mitt Romney
i. John Dougall – State Treasurer
j. Michael Mower – Governor’s office
k. Holly Richardson – Utah Policy
l. Cindie Quintana – Governor Cabinet
m. Andy Pierucci – Manager at Northrop Grumman
n. Jon Pierpont – Chief of Staff for Governor Cox
o. Tani Pack Downing – Senior Policy Advisor to State Auditor John
Dougall
p. Kim Coleman – Prior State Representative and alleged victim
q. Barbara Stallone – Sister to Senator Daniel Thatcher and alleged victim
r. Karen Kwan – Utah House
s. Dawn Ramsey – Mayor South Jordan
t. Wayne Cushing – Salt Lake County Treasurer
Page 20 of 61
u. Carl Albrecht
v. Jennifer Robison
w. Marie Poulson
x. Debbie Dujanovic
y. Heather Anderson – Miss Utah
z. Michael Whitlock – Senator Hatch Comms/Director
aa. Andrew Stoddard – Utah House
bb. Tracy Gruber
cc. Becky Pickle
dd. Rep. John Curtis
ee. Mia Love
ff. Brad Bonham
gg. Zach Jacob
hh. Bart Barker - Then General Manager of the MSD
ii. Enid Mickelsen
jj. DeLaina Tonks
kk. Ally Isom
ll. V. Lowry Snow
mm. Sue Duckworth
nn. Hannah Coleman
oo. Jake Parkinson
pp. Val Hale
Page 21 of 61
qq. Kerri Nakamura
rr. Michelle Quist
ss. Rozan Mitchell
tt. Becky Edwards
uu. Carl Downing
vv. Candice B. Pierucci
ww. Jordan Teuscher – Utah House of Representatives
xx. Susan Pulsipher
yy. Jeff Stenquist – Utah House of Representatives
zz. Robert Spendlove
aaa. Michael Winder
bbb. Craig Hall
ccc. Todd Weiler
ddd. Daniel W. Thatcher,
eee. Kirk Cullimore,
fff. Lincoln Fillmore,
ggg. Ralph Chamness,
hhh. Daniel Burton,
iii. Carol Moss,
jjj. Richard Jaussi,
kkk. Jon Cox,
lll. Chris Stavros, and
Page 22 of 61
mmm. Annette Stavros
121. It appears that at no time did Governor Spencer Cox, Lt. Governor Deidre
Henderson, numerous State Legislators, elected officials, and/or state employees make any effort
to distinguish their personal attacks, statements, likes, shares, etc., against Miller from the work
they were doing in their official capacity.
122. A typical constituent could easily believe that these allegations had been proven
and endorsed by the government of Utah because the State of Utah’s name, office positions of
the employee and logo are and were regularly used when disseminating this false and misleading
information through social media, TV, the press, and more.
123. Although prominent elected officials, State employees, and many others were
enthusiastic participants spreading falsehoods against Miller, not one of them asked Miller to
verify or dispute the allegations against him.
124. One elected official did contact Miller, advised Miller to resign, and he even
drafted the following resignation letter for Miller:
125. The letter reads as follows:
From: Daniel McCay

Date: Sat, Mar 27, 2021 at 11:45 PM
Subject: Re: resignation
To: Scott Miller <smiller5106@gmail.com>
Dear Executive Committee Members,

Thank you for your service to the Salt Lake County Republican Party.
I’m writing to resign my position as Chair of the Salt Lake County Party.
I made a mistake with how I handled the complaints lodged by Republican
women leaders and my recent communications.
I’m sorry.
I hope others will learn from my experience and act quickly to put down any
form of harassment. Republican women are an important voice in the Party.
The Republican Party I know is a place of equality and unity of purpose. In the
Page 23 of 61
future I am committed to doing my part to make sure these values are held up
more frequently.
It's been an absolute privilege to serve as the Chair of the Salt Lake County
Republican Party. I have enjoyed being part of the election process and serving
along our many trusted elected officials and candidates.
126. In an effort to “do what is best for the party” and to shield his family from the
very public and humiliating false allegations, Miller regretfully followed the advice of an elected
official, whom he trusted at the time, and Miller submitted his letter of resignation.
127. Not long after, Miller publicly recanted his resignation statements and continues
to dispute the defamatory and vicious lies spread about him.
128. It appears there were several reasons the establishment in the County and State
GOP set out to destroy Miller. Some of those reasons include but are not limited to:
a. Upsetting Big Donors, and
b. Preventing Scott Miller from obtaining State Republican Party
Chairmanship.
129. It appears that to discredit Miller, prominent Republicans were willing to make
false accusations, spread lies, defame, attack Miller's character, destroy his reputation, and more.
Upsetting a big donor and political powerhouse
130. During the 2020 campaign cycle, A. Scott Anderson, President, and CEO of Zions
Bank inserted himself into the Congressional District 4 (“CD4”) race between then-Congressman
Ben McAdams and Burgess Owens. CD4 was one of the most critical Congressional races in the
County and having A. Scott Anderson’s public endorsement and enthusiastic support was a great
boost to the campaign of Democrat Ben McAdams.
131. It is the responsibility of the Salt Lake County GOP and the Utah GOP to elect its
Page 24 of 61
Republican candidates and CD4 is no exception. Without coordinating with the Burgess Owens
campaign, but with the approval of then-Chairman Miller, the Salt Lake County GOP released a
well-researched, factual video questioning Zions Public Finance’s role in the McAdams
Mountain Accord Transparency Report.
132. It appears certain portions of the transparency report are inaccurate and
misleading and that the report glossed over what appears to be McAdams' violation of the open
meetings law while he was the Mayor of Salt Lake County and Chairman of Mountain Accord.
133. The integrity of this report is important because:
a. Zions Public Finance is the bond advisor for the State of Utah, Salt Lake
County, and many Counties and municipalities around the state of Utah, and as such, they
are required to act in a manner that is scrupulously honest, and above reproach;
b. Zions Bank underwrites many of the bonds on which Zions Public Finance
advises;
c. Billions of taxpayer-backed bonds were at stake;
d. The Salt Lake County GOP election team has first-hand knowledge and
information that the Zions Vice President over the Mountain Accord Transparency
Report did not want to do the report;
e. The Vice President felt pressured to do the report;
f. The Vice President was instructed to NOT verify the information provided
to her but to issue the report.
134. The following are related timestamps:
a. 09/12/2020 (On or around) The McAdams/Zions Public Finance video
Page 25 of 61
was published on the Salt Lake County GOP Facebook page;
b. 09/17/2020 2:48 pm Via phone, State Chair Derek Brown to Scott Miller;
Scott Anderson threatens to sue “that woman” in the McAdams/Zions Public Finance
video;
c. 09/23/2020 1:00 pm Via phone, State Chair Derek Brown to Scott Miller;
the (McAdams/Zions Public Finance) video must be removed based on the idea that Scott
Anderson would sue Miller and his County elections team unless the removal took place;
d. 09/23/2020 Via text, Salt Lake County Council member Aimee Winder
Newton (“Winder Newton”) alleges; “Robinson bags on our good Republican donors,”
specifically naming as donors Scott Anderson of Zions Bank and Chris McCandless;
e. 09/23/2020 Via text, Winder Newton states; There will be no money for
our candidates if Robinson remains involved with their campaigns;
f. 09/23/2021 Via text/email Miller requested an email from Winder Newton
to outline her & others' concerns. Winder Newton refused;
g. 09/25/2020 2:20 pm Via phone, Erin Preston complains about Robinson
to Miller;
h. 09/26/2020 1:36 pm Via text, State Chair Derek Brown to Miller; Scott
Anderson reached out to Derek Brown regarding the McAdams/Zions video;
i. 09/26/2020 1:36 pm Via text, Miller tells Derek Brown; Miller will not
take down the McAdams/Zions Public Finance video;
j. 09/26/2020 1:36 pm Via text, State Chair Brown to Miller; Brown
confirms Anderson’s threats of litigation;
Page 26 of 61
k. 10/14/2020 Chair Miller sends letter to Zions Bank Executives alerting
them to the alleged threats of litigation against the Salt Lake County GOP made by its
President Scott Anderson;
l. 10/14/2020 Press release “Anderson threatens to sue SLCOGOP;”
m. 10/24/2020 A private citizen sends a request to Auditor John Dougall
(“Dougall”) regarding McAdams/Zions Public Finance Mountain Accord Transparency
Report. Earlier in the 2020 Election cycle, Auditor Dougall ran for Lt. Governor on the
same ticket with Winder Newton who ran for Governor;
n. 10/25/2020 Dougall was directly notified of the request regarding
McAdams/Zions/Mountain Accord;
o. 10/28/2020 The Provo Daily Herald ran a story regarding the request to
Dougall;
p. 11/3/2020 Despite Scott Anderson’s endorsement of McAdams, Burgess
Owens beats Ben McAdams, winning CD4;
q. 01/06/2021 In an off-year election cycle, Zions Bank PAC gives
$2,500.00 to Governor Spencer Cox’s campaign fund;
r. 01/07/2021 In an off-year election cycle, Zions Bank Corp gives
$50,000.00 to Governor Spencer Cox’s campaign fund;
s. 01/25/2021 Despite having been directly notified in late October, Dougall
claims he knows nothing of the McAdams/Zions/Mountain Accord investigation request;
t. 01/25/2021 The Initial request was resent to Dougall;
u. 03/20/2021 Miller announces his run for State GOP Chair;
Page 27 of 61
v. 03/23/2021 Phone call from Salt Lake Tribunes Leia Larsen to Miller
about her upcoming story;
w. 03/24/2021 Meeting with the Salt Lake Tribunes Leia Larsen and Editor
Dan Harrie;
x. 03/26/2021 Miller sends a newsletter to the state Republican delegates
explaining what transpired in the meeting with the Tribune and warning of an impending
hit piece;
y. 03/27/2021 Misleading news story published by the Salt Lake Tribune.
Zion’s Bank President and CEO Scott Anderson sits on Salt Lake Tribune’s Editorial
Board and Zion’s Bank is a Platinum Matching Donor of $225,000.00 to the Salt Lake
Tribune. The Salt Lake Tribune does not disclose these facts in the article;
z. 03/27/2021 Having received $52,500.00 for his campaign in January, in
a non-election year, from Zions Bank and its PAC, Governor Spencer Cox and Lt. Deidre
Governor Henderson now publicly condemn Miller and are joined by dozens of elected
officials, including Speaker Brad Wilson, Senate President Stuart Adams, Senator Weiler,
Senator Thatcher, and many more;
aa. 03/28/2021 State Chairman Derek Brown releases a press statement
calling Miller’s Communication Directors behavior abhorrent;
bb. 03/29/2021 Derek Brown was a guest on the Rod Arquette show and he
falsely alleges that Miller had “come after me (Derek Brown)”. However, it appears
instead that it was State Chairman Derek Brown, without disclosing his conflict of
interest, who “came after” Miller, knowingly spreading unsupported claims;
Page 28 of 61
cc. 04/19/2021 Miller requests that Dougall terminate any investigation into
McAdams/Mountain Accord/Zions due to Dougall’s and or those in his office’s conflict
of interest in originating, repeating, liking, and sharing false allegations against Miller,
and also Auditor Dougall’s close relationship with Winder Newton, one of the key
women spreading false accusations against Miller.
A. Scott Anderson of Zions Bank
135. According to Winder Newton, A. Scott Anderson of Zions Bank is one of her
“good Republican donors.” Mr. Anderson, an individual with enormous political clout and
wealth, publicly endorsed Democrat Ben McAdams for the Congressional District 4 race.
136. Miller’s election team countered Anderson’s endorsement with a factual video,
questioning the McAdams/Zion Public Finance/Mountain Accord Transparency Report.
137. According to phone calls and text messages, Mr. Anderson quickly went to
Republican State Chairman Derek Brown and demanded from Chairman Brown that County
Republican Chairman Miller “take down” the McAdams/Zions video. State GOP Chairman and
lobbyist Derek Brown, who lobbies for certain close associate(s) of Governor Spencer Cox,
contacted County Chairman Miller and relayed the information.
138. Chairman Miller refused to comply with the wishes of Zions Bank President A.
Scott Anderson. A. Scott Anderson then threatened to sue Miller and his team. This threat was
transmitted by Derek Brown to Miller. Miller held firm and said the video will not be
removed. Anderson’s endorsed candidate, incumbent Ben McAdams, lost the Congressional
District race to Burgess Owens.
139. Shortly thereafter, Zions Bank donated tens of thousands of dollars directly to
Page 29 of 61
Governor Cox’s campaign account.
140. A short time after these donations were made, the Salt Lake Tribune, of which A.
Scott Anderson is an Editorial Board member and Zions Bank, a major “Matching Donor”, ran
their defamatory story against Miller and Robinson, one of Miller's volunteers. Governor Cox,
Lt. Governor Henderson, State Chairman and lobbyist Derek Brown, and dozens of elected
officials, state employees, and others quickly, almost simultaneously, released condemning
statements against Miller.
141. It appears that at no time did Anderson publicly disclose his status as a board
member of the Salt Lake Tribune Board, his banks enormous “Matching Donor” status, nor the
enormous financial interest he has with the State of Utah via Zions Public Finance and Zions
Bank.
142. At no time did the state officials, who were so quick to condemn Miller,
apparently question the motives and integrity of donor Mr. Scott Anderson, his endorsement of
Democrat Ben McAdams, and the validity of the questions the County GOP raised regarding
Ben McAdams, his Mountain Accord, Zions Public Finance, and Zions Bank.
State GOP Chairman
143. Miller offered the Salt Lake Tribune writer Leia Larsen and her Editor Dan Harrie
unrestricted access to all emails, text messages, testimony, etc, to counter the wild allegations
against Miller, Ms. Larsen and Mr. Harrie declined, stating they have all the information they
need for their story.
144. A couple of years prior, on June 21, 2018, Scott Miller ran to become Chairman
of the Salt Lake County GOP. At the special election, various elected officials joined together on
Page 30 of 61
stage, standing behind and endorsing Miller's opponent, lobbyist Stan Lockhart.
145. This sign of solidarity by elected officials was intended to sway conservative
delegates to vote for Stan Lockhart. Miller won in a landslide, 60.78% to 39.13% of the vote.
146. In 2018, Senator Todd Weiler, Senator Daniel Thatcher, Salt Lake Tribunes
Michelle Quist, Aimee Winder Newton, and Barbara Stallone fanned the flames with the Salt
Lake Tribune which fed several negative articles by the Salt Lake Tribunes against his
communications volunteer Dave Robinson. Because of these attacks and Miller not caving to
their demands, these individuals eventually called for Chair Miller's resignation.
147. Miller firmly stated that he represents the delegates in Salt Lake County, not the
handful of elected naysayers, and Miller prevailed.
148. In early January 2021, after the 2020 election was over, Zions Bank gives
$52,500.00 to Governor Spencer Cox.
149. A couple of short months later, on March 20, 2021, then Salt Lake County GOP
Chairman Miller announced he was running for Chairman of the State GOP.
150. Two days later, Stewart Peay and Austin Cox announced their bid for the State
GOP Chair and Vice-Chair. Soon it was announced that Peay and Cox are Governor Cox’s, Lt.
Governor Henderson, Speaker Wilson, Senate President Adams, Senator Weiler, and others
endorsed candidates.
151. Just four days later, Miller sat in the Salt Lake Tribune offices and heard, for the
first time, wild and unsupported allegations against him and his campaign team.
152. Some of Miller’s fiercest critics are linked directly to the Salt Lake Tribune: A.
Scott Anderson, member of the Tribunes Editorial Board. Michelle Quist, columnist for the
Page 31 of 61
Tribune. Governor Cox’s Communications Director Jennifer Napier Pearce, prior Editor for the
Salt Lake Tribune.
153. Upon information and belief, several of those publicly spreading the unfounded
assertions in what appears to be prepared statements, social media posts, podcasts, radio
interviews, etc., condemning Miller was comprised of those who have previously tried to
oppose Miller and or were endorsing Miller's opponent for State GOP leadership.
154. These individuals include State Senators Todd Weiler and Daniel Thatcher,
Aimee Winder Newton, Erin Preston, Governor Spencer Cox, Lt. Governor Deidre Henderson,
Representative Michael Winder, Barbara Stallone (Senator Thatcher's sister), lobbyist Derek
Brown, and others
155. These individuals asserted unsupported allegations, encouraged, and, upon
information and belief, pressured or at least encouraged other elected officials and state
employees to sign their names with their official titles, forwarding, liking, and sharing their
allegations against Miller.
156. It appears there was an orchestrated effort to defame Miller.
157. Some important dates are as follows:
a. Between January 6 and 7, 2021, Zions Bank Donates $52,500 to Governor
Cox;
b. 3/22/2021 Miller announces he is running for State GOP Chair;
c. 3/24/2021 Stewart Peay and Austin Cox announce their campaign for
State GOP Chair (Their “team” includes Governor Spencer Cox, Lt. Gov. Henderson,
(KUTV), and they worked closely with retiring State GOP Chair Derek Brown (Utah
Page 32 of 61
Policy);
d. March 2021 A Salt Lake Tribune Reporter calls asking for quotes from
Miller and others;
e. March 2021 Miller meets with Reporters from the Salt Lake Tribune;
f. 3/27/2021 The Salt Lake Tribune story is published. Governor Cox, Lt.
Governor Henderson, and other establishment Republicans all condemn Miller;
g. Late March 2021 the Governor’s candidates are also endorsed by Wilson,
Adams, Weiler, V. Lowry Snow, Brad Bonham;
h. March/April 2021 Weiler Toddcast states, “evil will permeate
everywhere…” regarding if Miller is Chair;
i. April 2021 Gov Cox, Lt. Gov. Henderson publicly endorse Peay and Cox;
a. April 2021 Miller continues to reach delegates with targeted messaging;
b. April 2021 Miller withdraws his name and endorses a non-establishment
candidate;
c. April 2021 Cox’s endorsed candidate is eliminated, and Miller’s endorsed
candidate wins.
158. It is clear, great efforts went into keeping Miller from becoming the Chairman for
the State GOP. Elected officials, state employees, lobbyists, and more apparently used the press,
social media, radio, and their positions as elected officials and employees of the State of Utah,
etc., to punish and cast doubt on Miller, using an executed and orchestrated campaign to spread
vicious, hateful, and unfounded allegations against Miller.
Aimee Winder-Newton
Page 33 of 61
159. Upon knowledge and belief, Councilwoman Winder-Newton worked closely with
Erin Preston, Ms. Leia Larsen at the Salt Lake Tribune, Councilwoman Laurie Stringham, Sr.
Policy Advisor Abby Evans, Salt Lake County GOP Chairman Chris Null, State GOP Chairman
Derek Brown, and many others to organize and orchestrate the timely and false claims against
Miller and at least one member of Miller’s campaign team.
160. Councilwoman Winder-Newton has a long-standing bias against Miller and Dave
Robinson, an unpaid volunteer on Miller’s campaign team. For example, in September 2020,
Councilwoman Winder-Newton sent the following text to the Salt Lake County Mayor and
Council candidates:
Hey guys, sorry to text so late. I have donors who are scared off by Dave
Robinson's involvement in some of the county campaigns. Dave is a loose cannon
and I'm not willing to sacrifice my relationship or reputation with any of these
guys. I'll try to help where I can, but I'm not going to be able to get involved in
any campaigns where Dave is involved. Sorry to not be able to help more.
161. To which then-Chairman Miller replies to Councilwoman Winder-Newton:
This text is basically confirmation of what I had heard you were doing. I do not
appreciate you sharing your dirty laundry about my communications director in
public or directly to our county Campaigns. If you have issue with one of my
volunteers you should have brought it directly to my attention rather than
scurrying around behind the scenes. This behavior is inappropriate,
unprofessional and unwelcome. Yes, Dave is extremely effective and garnering
name recognition through several cultivated media sources, One of which you've
benefited from in Herriman last night. Next time I would appreciate it if you'd
bring your concerns directly to my attention and not run around behind my back
undermining campaigns we've worked so hard on.
162. To which Councilwoman Winder-Newton replied: “Dirty laundry?? I could make
you a list of republicans that Dave has harmed. Dave has bagged on some of our best donors --
Chris McCandless, Scott Anderson, etc…”
163. To which Miller replied: “Please explain your issues you have with Dave in the
Page 34 of 61
email of which you promised. That way I can review and address each Issue individually with
Dave directly.”
164. To which Councilwoman Winder-Newton replies: “I'm also going to hold off on
sending you and the party officers my email with the complaints about Dave. I will do this after
the election. I worry that if it gets leaked to the media it will hurt our party and the Republican
candidates prior to the election.”
165. Then, on Thursday, January 28, 2021, several months after Miller's repeated
requests for details, Councilmember Winder-Newton writes,
Hello SLCO GOP Executive Committee: ‘…Sadly, several of the candidates

came to me frustrated that they felt sexually harassed and bullied by Dave
Robinson. I tried to help them as best as I could when they were called horrible
names, locked out of their campaign email and website accounts, etc. I didn’t run
those campaigns, but tried to provide moral support during their races. It was
disappointing to hear that our party was actually harming these candidates. Some
in the party even knew about the harassment and still did nothing.’
Aimee Winder Newton
166. Miller was alarmed by these shocking allegations of sexual harassment, of locking
candidates out of their campaign email and website accounts, and of harming and
harassing candidates. Miller quickly responded to Ms. Winder-Newton with the
following:
On Sat, Jan 30, 2021 at 8:46 PM Scott Miller <smiller5106@gmail.com> wrote:

We have received your official complaint by email in regards to Dave Robinson’s
alleged sexual harassment. As this is the first time the SLCOGOP has received an
official complaint of this gravity, the officers and I wish to be sure that the
Executive Committee has received all relevant documentation, materials and
written witness testimony for its consideration. Is there any further
documentation, materials or testimony not in the position of the Salt Lake County
GOP that needs to be considered? If so, please remit all materials, written
testimony and documentation that the Executive Committee should consider in
this matter within the next 10 business days…
Page 35 of 61
167. After this email, Miller promptly scheduled a meeting with the Salt Lake County
Executive Committee. No allegations of sexual harassment were presented to the Executive
Committee.
168. At some point, Councilmember Winder-Newton joined forces with failed County
Recorder candidate Ms. Erin Preston in their campaign against Miller and Robinson. Once their
error-ridden, apparently orchestrated Salt Lake Tribune news story landed and Councilwoman
Winder-Newton, Councilwoman Laurie Stringham, Sr. Policy Advisor Abby Evans, Erin
Preston, and others ignited a wildfire of personal and salacious attacks against Miller.
169. Salt Lake County Councilwoman Winder-Newton’s close relationship with
Governor Spencer Cox, Lt. Governor Deidre Henderson, Sr. Staff Jennifer Robison, Auditor
John Dougall, and others proved essential to their contrived plan. According to Erin Preston, the
very public support and statements of Governor Spencer Cox, Lt. Governor Diedre Henderson,
and others sent a public message that “...we acknowledge that this actually happened…”
170. Within a few short hours, State Representative Candice Pierrucci announced on
her Twitter feed, “This is sexual harassment…”
171. Councilmember Winder Newton was quickly featured on TV, radio, social media,
and more as she publicly proclaimed, “I got the target on my back and they started going after
me.” Winder Newton continued, “I was reading that trib article the other day it hit me, wow I’m
one of the victims too and they did these things to me”. Councilmember Winder Newton also
pondered out loud to the Rod Arquette Shows vast audience, “...gosh does Dave have something
on Scott (Miller) and that’s why Scott continues to do his bidding?”
172. Channel 4 is an affiliate of Nexstar Media, Inc.
Page 36 of 61
173. On March 27, 2021, Councilmember Winder Newton and Erin Preston were
featured on Channel 4. The news story includes statements of: Two of the accusers told ABC4
the alleged behavior goes back several months. Newton said they faced sexual harassment from
Robinson since September and tried to come forward, but it was never dealt with.
174. However, current Chairman Chris Null who worked closely with the alleged
victims, texted Miller, “I never claimed it was sexual harassment either.”
175. To which Miller replied, “So you don’t have any evidence of sexual harassment
either?”
176. To which Null replied, “I have the same emails you do.”
177. It is interesting to note that Miller informed his Executive Committee that
Robinson had previously filed a sexual harassment claim that was working its way through the
proper legal channels. Robinson’s sexual harassment claim was filed against Arlington Place
Homeowners Association, Michael Johnson’s FCS Management Company, employee Devin
Lawrence, and others.
178. Michael Johnson is a supporter of Spencer Cox, and along with Councilwoman
Winder-Newton, he served on Spencer Cox’s transition team. Utah GOP Chairman Derek Brown
is Michael Johnson/FCS’s lobbyist, and County Councilman Jim Bradley’s son Nicholas sat on
the Arlington Place HOA Board at the time of the harassment. Councilman Bradley and his son
Nicholas seem to have ignored the sexual harassment claim.
179. Ms. Preston later proclaimed, “Aimee Winder-Newton, she’s my hero forever for
having stepped up, put her skin in the game on that”
Councilwoman Laurie Stringham
Page 37 of 61
180. In September 2020, without consulting with the Salt Lake County GOP campaign
team, Stringham released to the public, an email and video.
181. When questioned as to why it was sent, Stringham stated “I didn't even authorize
the video and letter to be sent out”. “I know, it was a mistake”. It appears someone at the State
GOP helped craft, create, and distribute Stringham’s unfortunate messaging and video.
182. Throughout Stringham’s campaign, she relied heavily on the Salt Lake County
GOP volunteer campaign team for her messaging, yard signs, OPED’s, emails, videos, etc.
Shortly after someone associated with Stringham publicly released the unfortunate email and
video, the GOP campaign team began receiving questions and negative comments from voters
regarding the subject email and video.
183. The feedback was neither favorable nor complimentary to Stringham. A County
GOP campaign team member contacted Stringham and firmly and abruptly relayed to Stringham
some of the voter comments. Apparently, Stringham was upset and she quickly called then
Chairman Scott Miller.
184. Over the course of several phone calls with Miller that day, Councilwoman
Stringham’s recollection of her phone call with Robinson changed several times. Miller
immediately talked directly with Robinson to get his account of the phone call. When Stringham
calmed down, she acknowledged the accuracy of Robinson’s recollection.
185. That same afternoon, Stringham texted a County GOP campaign member stating,
“Okay, I was calling about your last text, sorry, just saw it. That is, if you are still wanting to
communicate with me, if not please let me know.” Shortly thereafter, Stringham called Robinson
and asked if he will still help with her campaign. Robinson asked Stringham if she was done with
Page 38 of 61
self-inflicted mistakes.
186. Stringham said yes and Robinson agreed to continue to work with Stringham.
Their close working relationship continued as shown in hundreds of emails and text messages.
187. Stringham also continued to communicate with other Salt Lake County GOP
campaign volunteers, such as the following text messages,
188. Stringham - “What time would be good to pick up signs?”
189. Volunteer - “Anytime. They are in my driveway.”
190. Stringham - “Okay. I know where to find them. Thanks!”
191. Volunteer - “Great. Congrats on OpEd in Tribune!”
192. Volunteer - “Hi Laurie. Just wondering if we can do anything for you now in the
closing week? Others have sent out reminders how or where to vote, or summarized their news
stories, etc. I’d like to be sure we did everything we could to get you into office! Thanks and
Regards”
193. Stringham - “Can you believe it?”
194. Volunteer - “CONGRATULATIONS”
195. Stringham - “Thanks!”
196. Stringham won her race. Thereafter Miller followed up with Stringham on her
win.
197. On November 13, 2020, Miller Texted, “I hope I am the first to congratulate you
on your win. I hope we were of some assistance. “
198. Stringham texted, “How else could [I] have even had a chance. I really appreciate
all of your support Scott.” (It is important to remember, all services from the Salt Lake County
Page 39 of 61
GOP, including thousands of dollars of hard costs, were provided to Stringham at no cost to her
or her campaign)
199. November 24, 2020, In a follow up text from Stringham. “I think we are all
exhausted by this election cycle and maybe people's tempers are short. But what I do know is
that we pulled off an amazing win in multiple elections and seats. I know it was the combined
efforts of the county party, the state party and hundreds of volunteers. I am grateful for your
support. I want you to know that.”
200. Then on January 29, 2021, just a few hours after Councilwoman Winder-
Newton’s email to the County Executive Committee, alleging sexual harassment, Councilwoman
Stringham texts Miller:
What the heck is going on? I go out of town for several days and get back to a
slew of emails, texts and phone calls. I thought everything was calm when I left!
What got all this started? I will be talking to everyone and finding out what the
hell is going on. Sorry I have not called you back yet. Let me know when you are
available. I have a ton of reading to do to catch up on what is happening.
201. On February 13, 2021, the Salt Lake County Executive Committee met in a
closed-door session regarding the matter brought forward by Councilmember Winder-Newton.
202. The meeting occurred via ZOOM. Because of recent allegations and questions
against Miller, he recused himself. Vice-Chairman Scott Rosenbush ran the meeting.
203. Newly elected Councilwoman Laurie Stringham presented allegations against
volunteer Robinson, the same Robinson who played a vital role in Stringham’s successful
campaign and whom Stringham continued contacting for policy advice.
204. Mr. Chris Null, then Executive Board member, now Salt Lake County GOP
Chairman, presented “new” evidence against Robinson.
Page 40 of 61
205. The Executive Committee reviewed all submitted evidence and testimony and
they, including Councilwoman Stringham, voted unanimously, determining no investigation is
required.
206. Councilwoman Stringham then requested all recorded testimony of the Executive
Session be destroyed and or erased.
207. Councilwoman Stringham’s request to destroy evidence of her allegations and
testimony against Robinson were concerning enough to at least one Executive Committee
member, that she stated in an email, “Each of our meetings have been electronically recorded by
our secretary Reed Taylor to aid him in creating a good record for accurate minutes. At the end
of our session Laurie Stringham asked that this particular recording be deleted.”
208. A short time after the closed-door Executive Session, Miller thanked and
officially released all of his 2020 campaign volunteers. This was memorialized by Executive
Committee member Nathan Brown in an email he sent to Robinson, “In a closed Executive
Committee meeting we discussed this matter, and made recommendations… I consider the
matter closed with the Executive Committee”.
209. However, it appears that Councilwomen Stringham and Winder-Newton, along
with Stringham’s Sr. Policy Advisor Abby Evans continued their mission to publicly defame,
humiliate and destroy Miller and Robinson.
210. Councilwoman Stringham continued to change her story as she was featured
prominently in the press, social media, etc., in her false and defamatory allegations against Miller
and Robinson.
211. After several weeks of attacks against Miller and Robinson, Stringham took the
Page 41 of 61
opportunity to falsely condemn them once again.
212. Councilmember Stringham spoke to these allegations in an open Salt Lake
County Council meeting.
213. County Mayor Jenny Wilson also spoke to these allegations in that meeting. In
addition, Stringham used the Salt Lake County logo on her social media posts repeating these
spurious allegations.
214. Salt Lake County Council, its attorney, or the district attorney have made no
effort to ensure that County logos, websites, and resources, including Council meetings, are not
used to defame, harass or slander Miller.
215. In fact, some responsible at the County actually contributed to and publicly
"liked" unfounded allegations against Miller and Robinson on social media.
216. As a result, a reasonable person could easily believe that these allegations have
been vetted and/or are supported by the County. Councilwoman Stringham’s public statements
were quickly featured in the news.
217. Some of the women who brought ethics complaints to the former Chair of the Salt
Lake County Republican Party say they’re being threatened. They’re speaking out about the
demeaning comments that led to the complaints which sparked the formation of a new ethics
committee.
218. Salt Lake County Council member Laurie Stringham is one of the women who
stepped forward with their complaints. She made a virtual appearance during Tuesday’s council
meeting, saying the harassment started in September. When she complained to Party Chair Scott
Miller, those complaints went nowhere.
Page 42 of 61
219. Stringham said, “To those who dismissed abusive or harassing behavior, who told
us to grow a thicker skin or just take it because we work in politics, or who just ignored it, you
are complicit.” KSL News March 30, 2021.
220. It appears the unfounded and defamatory public allegations targeting Miller and
Robinson prompted one Executive Committee member to “tender her resignation” by sending
the following email to then-acting Chair Scott Rosenbush. This member wrote,
Date: Tue, Mar 30, 2021 at 9:59 PM

Subject: Resignation Senate Chair District 23
To:Scott<scottrosenbush@gmail.com>...Christopher Null
<chris.null@gmail.com>
Dear Acting Chair (Rosenbush) and Executive Committee:
I hereby tender my resignation from my seat on the executive committee as a
senate chair from Senate District 23. I also hereby tender my resignation from the
convention committee as the Credential Chair.
221. After reviewing recent publications and interviews by acting officers it appears
there have been material misstatements and misrepresentations surrounding allegations,
investigations and actions.
Salt Lake County Employee Abby Evans
222. On January 31, 2021, Salt Lake County employee Ms. Abby Evans, sent an
inaccurate and defamatory email to the Salt Lake County GOP Executive Committee. Ms. Evans
made false allegations such as;
a. “... Dave R (Robinson) who has control of Scott's email account which he
uses to manipulate Scott M (Miller).”
b. “...my cute pet name from Dave R is ‘Blond Bob-haired Midget C*nt.’”
Page 43 of 61
c. “This is where the harassment switched to abuse. Scott M was called but
he was quick to dismiss the episode, and continues to do so as Dave continues to harass
Laurie as a county council member.”
223. On March 27, 2021, Salt Lake County employee Abby Evans was featured in a
news story that stated, “Multiple women in the Salt Lake County GOP claim they were harassed
and bullied including Abby Evans pictured here. (KUTV) And their complaints were ignored by
Chairman Scott Miller.” Also, He just overtook the party. It’s like they sold their soul to him”,
said Evans Salt Lake County employee.
224. Abby Evans then appeared live on State Senator Todd Weiler’s ToddCast on
March 28, 2021. Ms. Evans stated; I want to say if he becomes, if Scott Miller, becomes the
State Party chair it will be Chairman Robinson and the same controlling abusive endless ranting
and…awful will be permeating everywhere…it will be chairman; Robinson Scott has sold his
soul; I don’t know if he has promised him investments in his business or something; I would like
a professional medical person to analyze I just don’t want to be the one who does that.
225. Then, according to KSL News, on March 31, 2021, “Stringham’s senior policy
advisor, Abby Evans, said things have intensified since Miller’s resignation. Evans said police
are investigating threats made toward her and Stringham, although she isn’t making any claims
about where those threats are coming from. She said officers arrived at her house and observed it
Monday night.”
Spreading Defamatory Statements
226. Under normal circumstances, one would expect that a political party would
elevate a hard-working, honest, campaign-winning County Chairman such as Scott Miller.
Page 44 of 61
227. However, instead of emulating Miller’s successful systems in other parts of the
state, it seems prominent elected officials, state employees, and lobbyists in his own party set out
to attack Miller, to destroy his reputation, his good name, and sweep his successes under the rug.
228. In order to accomplish this, it appears the attacking individuals threw their
principles out the window, denied Miller his first Amendment rights and his right to due process,
and proceeded to spew lies and falsehoods as fact. For example,
229. “Sincere apologies are owed to the women who have been victimized and we
admire their courage and strength in coming forward. That is not an easy thing to
do” (Governor Cox and Lt. Governor Henderson),
230. “I’m heartbroken to learn that women who stepped up to run for political office
faced harassment and discrimination from people who were supposed to be helping them. It’s
never ok to normalize, enable, or dismiss this kind of behavior,” the lieutenant governor wrote
in a tweet, accompanied by the hashtag #istandwithmysisters. (Lt. Governor Henderson)
231. “This is sexual harassment and bullying. The comments made to these women
are absolutely disgusting and degrading…Robinson should be expelled from ever holding a
position in the party and the chair removed for not taking this seriously.” (State Representative
Candice Pierucci)
232. Rep. Pierucci posted a joint statement from herself and seven other women in the
Utah legislature, Reps. Kera Birkeland, Christine Watkins, Susan Pulsipher, Marsha Judkins,
Karianne Lisonbee, Melissa Ballard, and Cheryl Acton. “As Republican female legislators, we
condemn bullying, harassment, sexism, and the misuse of party resources,” the statement read
in part. “These actions have no place within our party.”
Page 45 of 61
233. March 27, 2021, Lynda Cox from the State GOP stated, “This is entirely
intolerable” to which then-State Treasurer David Damschen commented, “So appalled to hear
so many of my good friends were treated this way. 100% unacceptable”.
234. State Senator Todd Weiler also commented by stating, “Disgusting. Sad day to
be a Republican in Utah. This behavior cannot be tolerated.”
235. State Representative Michael Winder, stated on his March 27, 2021, social media
post, “The actions and words of the volunteer Salt Lake County Republican Party
Communications Director were unacceptable…” and “…we condemn this behavior… Don’t
despair because of a couple bad apples. Be proud that State Party leaders and GOP elected
officials stand up against bullying and harassment”.
236. Senator Thatcher stated, “And so what was happening under the watch of Dave
Robinson and Scott Miller was an absolute betrayal of everything that Republicanism should
and does stand for when it is not being co-opted by tyrants and traitors”
237. Senator Thatcher stated, “And every single complaint that came forward was
blocked by Scott [Miller]”
238. Senator Thatcher stated, “I’m not suggesting that there be a witch hunt that we
throw everybody out of the party but I’ve seen an awful lot of celebratory, yeah the Republican
Party is cleaning house”
239. Senator Thatcher stated, “…the type of tyrannical dictatorship that they
(referring to Miller and Robinson) were trying to establish”.
240. Senator Weiler stated “How do we fix this within the Republican Party. I know
that this problem was with the Salt Lake County party”
Page 46 of 61
241. Senator Thatcher stated, “exactly but instead not only did he [Miller] refuse to
address the issue not only did he refuse to take care of the problems that were blatant that
were brought to him early and often from multiple credible sources not only did he refuse to
address any of those issues he doubled down and he piled on and attacking those who were
disloyal”.
242. Senator Thatcher stated, “…and that is what makes Scott Miller the villain of
this story. Dave Robinson did all the awful things but he was only able and allowed to do
them because Scott Miller empowered him. And every single person who had the ability to
speak up who had the ability to say this is wrong and didn’t until now is a part of that treason
against the Republican Party”.
243. Senator Thatcher stated, “Look I know I said I was done but what does, what
does Dave have on Scott [Miller]? I cannot see any functional human being with an IQ over
80 thinking yeah I want more of this…does he [Robinson] have pictures of something?”
244. Senator Thatcher stated “Look I am not trying to really speculate but thinking
maybe others should”
245. Chad Pritchard stated, “Should we try and extort him [Robinson] for a million
dollars?”
246. Abby Evans stated “I want to say if he becomes, if Scott Miller becomes the
State Party chair, it will be Chairman Robinson and the same controlling abusive endless
ranting”
247. Chad Pritchard stated, “Is he still running?”
248. Abby Evans stated, “Awful will be permeating everywhere”
Page 47 of 61
249. Lynda Cox stated, “As of now as of now he’s still running”
250. Abby Evans stated, “Scott [Miller] has sold his soul...”.
251. Senator Weiler stated, “Thank you so much this was a great discussion and
hopefully this will be the beginning of rooting out the sexism in Utah and especially in the
Republican Party”
252. March 28, 2021, Ms. Tani Pack Downing, prior legal counsel to Governor’s Jon
Huntsman Jr., and Gary Herbert, prior Executive Director of the Department of Administrative
Services, at the time of her posting was the Sr. Policy Advisor to State Auditor John Dougall,
and now is the attorney for the City of St. George, proclaimed:
I’m grateful for the powerful men and women who believed and supported my
female politician friends. These brave women complained to the SL GOP chair
about the communication director's terrible bullying, inappropriate comments
and behavior, and intentional failure to provide party support to them with their
campaigns if they didn't do what he wanted. The chair turned a blind eye to
their complaints, took no action and protected his friend. I honor my sisters for
their courage to speak out. It's just a shame that nothing happened to hold
these guys responsible for their actions until powerful men spoke out to add
their support to these women's voices. If you wonder why there aren't more
women running for office, this is just one example of the incredible uphill battle
women face. We need to continue to shine light on these bad actors and remove
them from their powerful positions or, better yet, not elect them in the first
place.
253. Scott Miller steadfastly and categorically refuted all of these pernicious
allegations made against him. Unfortunately, Scott Miller’s good name and reputation has been
permanently and recklessly destroyed by state elected officials, employees, lobbyists, and more.
254. The New York Times recently addressed the grave dangers of such behavior, that
of using social media “like” and “share” buttons to spread lies and misinformation. In its
October 25, 2021 article, it states, “...people misused key features or that those features
Page 48 of 61
amplified toxic content…. And it lets “misinformation...flourish on the site.” The article further
recognizes that the “share” button can “spread information quickly, so false or misleading
content went viral in seconds”.
255. One can quickly see the widespread negative and tragic impact the bullying and
slanderous actions of those Utah elected officials and employees caused Miller, his wife, family,
and others, by using social media to spread false, toxic, and defamatory content very quickly.
256. A short list and simple screen shots of elected officials and state employees
Twitter followers gives us a glimpse of their widespread impact and damages. For example,
a. Governor Cox with his 66.5k followers,
b. Lt. Governor Henderson 10.3k followers,
c. Speaker Brad Wilson 3.2k followers,
d. Senator Todd Weiler 7.4k followers,
e. Representative Candice Pierucci 1.5k followers,
f. Mia Love 91.7k followers,
g. US Representative John Curtis 7.3k followers,
h. Daniel Burton 3.4k followers,
i. Then Representative, now Judge Craig Hall 3.7k followers,
j. Representative V. Lowry Snow 2.8k follower.
257. Their number of followers on Facebook are,
a. Governor Cox 40k followers,
b. Lt. Governor Henderson 4k followers,
c. Auditor John Dougall 3.1k followers,
Page 49 of 61
d. then State Treasurer David Damschen (private),
e. Tani Pack Downing (private),
f. State Representative Michael Winder 6k followers,
g. Senate President Stuart Adams 1.7k followers,
h. Representative Steve Eliason 2k followers,
i. Senator Daniel Thatcher 2.3k follower.
258. The wild and unfounded allegations against Miller by these state elected officials,
employees, lobbyists and others are calloused, widespread, and appear to be orchestrated in a
manner to do the most harm while denying Scott Miller the benefit of “innocent until proven
guilty” and of due process.
Salt Lake Tribune
259. Instead, elected officials, state and county employees, and others alleged,
facilitated, and encouraged unsupported accusations and trials in the court of popular opinion
rather than providing a fair process and a thorough investigation.
260. It appears the March 27, 2021, Salt Lake Tribune story, filled with unsupported
allegations against Miller, was the springboard for Miller’s trial in the press and the court of
public opinion.
261. A couple of days prior to the Tribune story going public, Miller met with reporter
Ms. Leia Larsen and her Editor Mr. Dan Harrie.
262. In the meeting, Miller heard for the first time several allegations made related to
the alleged behaviors from Mr. Robinson him.
263. Due to the many apparent fabrications and inaccuracies relayed to Miller by Ms.
Page 50 of 61
Larsen and Editor Dan Harrie, Miller offered them full access to his laptop containing all his
campaign-related emails, which total into the hundreds, if not thousands
264. Based on Ms. Larsen and Editor Dan Harrie’s refusal to review related emails,
text messages, and interview third party witnesses, on March 26, 2021, Chairman Miller released
to the public a factual letter explaining what had transpired at the Tribune Meeting.
265. If Ms. Leia Larsen had taken the opportunity to review text messages and emails
offered to her by Miller prior to filing her one-sided, salacious story, she would have learned the
following and more, regarding the allegations she reported;
Governor Spencer Cox
266. On Saturday, March 27, 2021, Governor Spencer Cox and Lt. Governor Deidre
Henderson issued a statement in response to Chair Miller's March 26, 2021 email:
“We are deeply offended by the recent reprehensible communications to Salt

Lake County delegates. Let us be clear: This type of behavior should never
happen and when it does we will not tolerate it, ignore it, or explain it away. It
is unacceptable. The Republican Party needs women in our policymaking and
discussions. Sincere apologies are owed to the women who have been victimized
and we admire their courage and strength in coming forward. That is not an
easy thing to do.”
267. When Governor Cox and Lt. Governor Henderson released their unsupported and
condemning statements against Robinson and Miller, it seems to have validated the incorrect
accusations against them and opened the floodgates for elected officials and others to dog-pile
and condemn, all without due process for the accused.
268. In a June 11, 2020 Utah Policy Guest Opinion titled, “Spencer Cox: Protecting
Utah’s “Most Vulnerable’? Robinson states, “I believe Cox not only adopted the Democrat’s
Page 51 of 61
playbook of never allowing a crisis go to waste, but he went further; Cox outdid the Democrats
and actually helped create the crisis in order to take advantage of it”
The Sutherland Institute
269. On March 31, 2021, the Sutherland Institute printed a new story titled “Civic
virtue must be a priority after recent disturbing tale in Salt Lake County.”
270. The author of the article was Derek Monson.
271. The story specifically stated:
a. “Political leaders in both parties and at all levels have rightly spoken out in
defense of the women who came forward to news media with their stories and have
condemned the alleged behaviors of Miller and Robinson.”
b. “Both political antagonists in this story sought to parlay these tactics into
greater levels of influence – one to the Salt Lake County mayor’s office and the other to
state leadership of Utah’s dominant political party.”
c. “These kinds of corrupt behaviors from political leaders – ruthlessly attacking
and oppressing potential political threats and threatening to withhold support essential to
gaining office from potential political opponents – are poison to a healthy republic.”
d. So as Utahns seek to move forward (and hopefully upward) from the
unfortunate tale of Miller and Robinson.”
e. “…instead of simply in pursuit of their personal agendas for power, money
and influence.”
Utah Federation of Republican Women
Page 52 of 61
272. On March 30, 2021, the Utah Federation of Republican Women made public
statements of fact against Mr. Robinson and Mr. Miller.
273. The statement includes:
The Utah Federation of Republican Women (UFRW) Board Members, are deeply
disappointed and saddened to hear of the harassment and abuse that was aimed at
Republican women in the 2020 election cycle; both candidates and campaign
professionals. UFRW and its affiliated local clubs strive to empower women from
all backgrounds in the political process and this year, as with every year, we have
worked hard to recruit women to run for political office. It takes great courage to
call out the inappropriate behavior such as that of the “now past” Salt Lake
County Republican Party Chair, Scott Miller, and his Communications Director,
Dave Robinson and we applaud these women. We want to be very clear; this type
of behavior cannot and will not be tolerated. Women candidates expect to be
treated with dignity and respect, just as every candidate.
274. The signature to this statement are:
a. LoRene Cox;
b. Kari Malkovich;
c. Nina Barnes;
d. Zan Zogmaister;
e. Neka Roundy;
f. Judy Houston;
g. Lesa Sandberg;
h. Darcy Kruitbosch;
i. Lynda Cox;
j. Kristen Clarke;
k. Hillary Jessup;
l. Becki Bronson;
Page 53 of 61
m. Laurie Stringham;
n. Christa Hinton;
o. Carolina Herrin;
p. Courtney Sinagra;
q. Cleo Atkin;
r. Lori Brinkerhoff.
Erin Preston
275. On March 27, 2021, Erin Preston was attributed by ABC4.com as saying Mr.
Miller covered up such actions and comments from Mr. Robinson as:
a. That you [Ms. Preston] “faced sexual harassment from Robinson since
September [2020] and tried to come forward, but it was never dealt with.”
b. “That it wasn’t just sexual harassment … It was retaliation when you wouldn’t
plat along, it was withholding resources, it was putting out statements that weren’t ours
that we didn’t approve. It was things like that.”
276. That same day Ms. Preston was attributed by KUTV2 as saying:
a. “During the campaign, he [Mr. Robinson] began making comments just from
the state, I mean ‘Nice t*ts, nice a** on our first meeting.”
b. That Mr. Robinson said that “[Laurie Stringham] sounded like a whore, and
then he faked orgasm sounds.”
Leia Larsen
Page 54 of 61
277. On information and belief Leia Larsen was the author of the article in the Salt
Lake Tribune that first brought to public light the false allegations of sexual harassment from Mr.
Robinson and the alleged cover-up from Mr. Miller.
Utah Stories
278. On April 6, 2021, Richard Markosian authored an article to Utah Stories titled
“How Did Dave Robinson Get Away with Alleged Sexual Misconduct for So Long?”
279. In the article many false statements were published, including:
a. “How did Republican Chairman Scott Miller all Dave Robinson – the man
accused of sexual harassment by a half dozen women in Salt Lake County—to remain the
‘un-official Communication Director’ for the Republican Party with the Salt Lake County
for three years?”
b. “Dave Robinson was harassing women for years, whose complaints were
falling on deaf ears of Salt Lake County Chairman Scott Miller.”
c. “The question remains: How and Why did Robinson have protected status?
Not unlike Kerry Gibson who ran amok the Department of Agriculture for a year.
Robinson (under the protection of Chairman Miller) seemed to operate in a corrosive,
toxic manner with impunity.”
GRAMA Violations
280. Mr. Miller has made various requests for documents through GRAMA requests at
the State and County level. However, upon information and belief, many documents may have
been withheld from Miller. This issue is currently under review. Mr. Miller argues it is not the
personal device, but the content on the device that is subject to GRAMA and that they should be
Page 55 of 61
subject to additional damages or the ability to seek additional redress through the court systems.
FIRST CAUSE OF ACTION

Defamation against Defendants:
Brad Wilson, Stuart Adams, Don Willie,; Ryan Curtis, David Damschen, Andrew Gruber, Derek
Brown, Amelia Powers Gardner, Adam Gardiner, John Dougall, Michael Mower, Holly
Richardson, Cindie Quintana, Andy Pierucci, Spencer Cox, Deidre Henderson, Michael Mckell,
Jon Pierpont, Tani Pack Downing, Kimberly Coleman, Barbara Stallone, Matthew Lusty,
Marcus Jessop, Brian Maxwell, Sandy Dougall, Catherine Newton, Marion Mills, Bruce Cutler,
Karen Kwan, Dawn Ramsey, Wayne Cushing, Michael Fife, Shireen Ghorbani, Natalie Gordon,
Sarah Haley Nitta, Carl Albrecht, Jennifer Robison, Marie Poulson, Heather Anderson, Michael
Whitlock, Andrew Stoddard, Tracy Gruber, Elizabeth Weight, Becky Pickle, Michael Johnson,
Stan Lockhart, Alex Cook, John Curtis, Mia Love, Brad Bonham, Zach Jacob, Stan Summers,
Bart Barker, John English, Laura Warburton, Enid Mickelsen, Delaina Tonks, Ally Isom, Lowry
Snow, Sue Duckworth, Hannah Coleman, Kera Yates Birkeland, Jake Parkinson, Val Hale,
Suzanne Mulet, Nathan Evershed, Kerri Nakamura, Michelle Quist, Rozan Mitchell, Becky
Edwards, Clint Morriscarl Downing, Jennifer Scott, Jordan Hess, Jeremy Roberts, Abby
Hunsaker, Kent Winder, Jay Brummett, Candice B. Pierucci, Andy Pierucci, Jordan Teuscher,
Steve Christianson, Susan Pulsipher, Cheryl Acton, Jeff Stenquist, Robert Spendlove, Michael
Winder, Craig Hall Steve Eliason, Wayne Harper, Todd Weiler, Daniel W. Thatcher, Jim
Dunnigan, Kirk Cullimore, Lincoln Fillmore, Jake Anderegg, Ralph Chamnessdaniel Burton,
Carol Moss, Rosemary Lesser, Richard Jaussi, Jon Cox, Chris Stavros, Annette Stavros, Aimee
Winder-Newton, Abby Evans, Laurie Stringham, Chris Nulls, State Of Utah; Salt Lake County,
Lorene Cox, Scott Rosenbush, Steve Eliason, Lisa Bagley, Erin Preston, Leia Larsen, Derek
Monson, Kari Malkovich, Nina Barnes, Zan Zogmaister, Neka Roundy, Judy Houston, Lesa
Sandberg, Darcy Kruitbosch, Kristen Clarke, Hillary Jessup, Becki Bronso, Christa Hinton,
Carolina Herrin, Courtney Sinagra, Cleo Atkin, Lori Brinkerhoff, Derek Monson, Dan Harrie,
Richard Markosian, Jennifer Napier Pearce, Chad Pritchard, The Sutherland Institute, Utah
Federations of Republican Women, Salt Lake County Republican Party, Utah Republican Party,
Utah Stories LLC, Utah Policy, The Salt Lake Tribune, Inc, DOES 1–100, ROE Corporations 1–
100
281. Plaintiff incorporates by reference the allegations set forth above.
282. On information and belief, the “liking” of a Facebook post publishes the post to
other’s newsfeed.
283. On information and belief, “retweeting” a tweet on Twitter republishes the post to
other’s newsfeeds.
284. The actions and statements from many of the listed Defendants were done on their
Page 56 of 61
Facebook, Twitter, or other related accounts that are connected to their official public office or
position. This makes it difficult to determine if these statements were made in their official
position or as a private person.
285. On information and belief these statements were made on behalf of the State of
Utah and Salt Lake County.
286. As described above, by means of written/oral communication, the listed
Defendants defamed Mr. Miller.
287. The listed Defendants’ statements impugned Mr. Miller’s fitness to work in his
profession and/or employment and are libelous per se.
288. The listed Defendants’ false statements were not subject to privilege and were
made while the listed Defendants’ knew that they were false and that they would negatively
affect Mr. Miller’s reputation and/or economic relationships.
289. As a result of the listed Defendants libel and/or slander, Mr. Miller has suffered
damages in the amount of $40,000,000.00, or such greater amount to be proven at trial.
290. Because the listed Defendants statements were willful and malicious, and
motivated by spite, Mr. Miller is entitled to an award of punitive damages in an amount to be
determined at trial, but in no event less than three times Mr. Miller’s actual damages.
291. Judgment should be entered against the listed Defendants for general and special
damages in an amount to be proven at trial, but in no event less than $40,000,000.00, plus
punitive and special damages, plus pre- ad post judgment interest.
SECOND CAUSE OF ACTION

Conspiracy against Defendants:
Aimee Winder-Newton. Derek Brown, Abby Evans, Candice Pierucci, Todd Weiler, Laurie
Stringham, Chris Null, Erin Preston, Michael Winder, and Barbra Stallone, Leia Larsen, Lisa
Page 57 of 61
Bagley, Kim Coleman, Salt Lake Tribune, Dan Harrie Does 1–100, Roes Corporation 1–100
293. The listed Defendants’ organized and executed a plan with each other with the
intent of forcing Mr. Miller to resign from his position as the Chairman of the Salt Lake County
GOP and prevent him from running for the State GOP position.
294. As part of the plan, the listed Defendants had a meeting of the minds to spread
this false statement the Mr. Miller had been concealing sexual harassment complaints from
women in the Salt Lake County GOP for years and protecting Mr. Robinson from these
allegations.
295. The listed Defendants acted with the unlawful purpose to conspirer against Mr.
Miller to force him to resign from chairman of the Salt Lake County GOP.
296. As a result of the listed Defendants conspiring against Mr. Miller, he has suffered
297. Because the listed Defendants actions were willful and malicious, and motivated
by spite, Mr. Miller is entitled to an award of punitive damages in an amount to be determined at
trial, but in no event less than three times Mr. Miller actual damages
THIRD CAUSE OF ACTION

Interference with Election Efforts pursuant to U.C.A. §§ 20A-1-601 et al. against Defendants:
Spencer Cox, Deidre Henderson, Derek Brown, Chris Null, Kim Coleman, Daniel Thatcher,
Aimee Winder-Newton, Laurie Stringham, A. Scott Anderson, Zions Bank, Does 1–100, Roes
Corporation 1–100
299. The listed Defendants’ actively worked to conceal the bribery related the
Mountain Accord project.
Page 58 of 61
300. The listed Defendants’ demanded that a campaign video revealing the
concealment for the Mountain Accord project.
301. Defendants Spencer Cox and Deidre Henderson received campaign donations in
non-election years from A. Scott Anderson and his business.
302. The listed Defendants have failed to provide information and documents when
requested by Mr. Miller.
303. The listed Defendants unlawfully concealed their interference with the 2020
election cycle.
304. As a result of the listed Defendants concealing their efforts to interfere with the
2021 election Mr. Miller has force Mr. Miller to resign from his position and he has suffered
305. Because the listed Defendants actions were willful and malicious, and motivated
by spite, Mr. Miller is entitled to an award of punitive damages in an amount to be determined at
trial, but in no event less than three times Mr. Miller’s actual damages
FOURTH CAUSE OF ACTION

Violation of GRAMA Requests against Defendants:
Aimee Winder-Newton, Abby Evans, Laurie Stringham, Spencer Cox, Deidre Henderson, Tani
Downing, John Dougall, State of Utah, Salt Lake County, Does 1–100, Roes 1–100
307. Plaintiff has made a number of GRAMA requests pursuant to Utah Government
Records Access and Management Act.
308. The listed Defendants have failed to provided the requested information and
records.
309. The listed Defendants have failed to provide a response that the sought after
Page 59 of 61
information is private or protected information as defined by the Act.
310. Based on information and belief the information requested in not protected
information as defined in U.C.A. § 63G-2-302.
311. As a result of the listed Defendants failure to provided the requested information
pursuant to the Utah Government Records Access and Management Act Mr. Miller has suffered
312. Because the listed Defendants actions were willful and malicious, Mr. Miller is
entitled to an award of punitive damages in an amount to be determined at trial, but in no event
less than three times Mr. Miller’s actual damages.
FIFTH CAUSE OF ACTION

Violation of Civil and Constitutional Rights against Defendants:
Spencer Cox, Deidre Henderson, Aimee Winder-Newton, Laurie Stringham, State of Utah, and
Salt Lake County.
314. Due to the actions taken by the listed Defendants Mr. Miller has suffered a
flagrant violation of his constitutional rights.
315. Mr. Miller was not provided a hearing or due process during the alleged
investigation.
316. Mr. Miller was not allowed to speak against the allegation against him.
317. The existing remedies do not redress his injuries.
318. The equitable relief is wholly inadequate to protect Mr. Miller’s right or redress
his injuries.
319. As a result of the listed Defendants violated Mr. Miller’s constitutional rights and
he has suffered damages in the amount of $40,000,000.00, or such greater amount to be proven
Page 60 of 61
at trial.
320. Because the listed Defendants actions were willful and malicious, Mr. Miller is
entitled to an award of punitive damages in an amount to be determined at trial, but in no event
less than three times Mr. Miller’s actual damages
PRAYER FOR RELIEF
WHEREFORE, Plaintiff respectfully prays judgment against Defendants as follows:
a. For judgment in his favor on all of its causes of action;
b. For an award of an amount to be proven at trial exceeding $40,000,000.00;
c. For an award of attorney fees and costs incurred by Plaintiff, to the extent allowed
by law, including any costs of collection; and
d. For any relief the Court deems appropriate under the circumstances.
Dated this 27th day of January, 2022.
SHUMWAY VAN
/s/ Robert T. Spjute

ROBERT T. SPJUTE, ESQ.
Attorney for Plaintiff Scott Miller
Page 61 of 61

Scott Miller Lawsuit

Uploaded by

Document Information

Original Description:

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Scott Miller Lawsuit

Uploaded by

Copyright:

Available Formats

ROBERT T. SPJUTE, ESQ.

IN THE THIRD JUDICIAL DISTRICT COURT OF SALT LAKE COUNTY,

SCOTT MILLER, an individual,

PARTIES AND JURISDICTION

Salt Lake County, State of Utah.

County, State of Utah.

County, State of Utah.

amend the complaint in the event that such Doe is discovered.

County, State of Utah.

County, State of Utah.

100. Defendant UTAH FEDERATION OF REPUBLICAN WOMEN upon

conducting business in Salt Lake County, State of Utah.

101. Defendant SALT LAKE COUNTY REPUBLICAN PARTY, upon information

in Salt Lake County, State of Utah.

County, State of Utah.

108. Defendants ROE CORPORATIONS 1 through 100 are corporations and/or

County, State of Utah.

of Utah and Salt Lake County.

111. Jurisdiction is proper pursuant to U.C.A. § 78A-5-102(1) and U.C.A. § 63G-7-

media of then Salt Lake County GOP Chairman Scott Miller.

written by Ms. Leia Larsen and featured 7 “reputable women”.

through social media outlets, podcasts, print, television, etc.

120. Numerous prominent elected officials and state employees quickly

a. Lt. Governor Deidre Henderson

b. Brad Wilson – Speaker of the State House

c. Stuart Adams - President of the State Senate

d. David Damschen – Prior State Treasurer

e. Andrew Gruber – Executive Director Wasatch Front Regional Council

f. Derek Brown – Chairman of Utah Republican Party

g. Amelia Powers Gardner – Utah County Commissioner

h. Adam Gardiner – Utah Field operator for Senator Mitt Romney

i. John Dougall – State Treasurer

j. Michael Mower – Governor’s office

k. Holly Richardson – Utah Policy

l. Cindie Quintana – Governor Cabinet

m. Andy Pierucci – Manager at Northrop Grumman

n. Jon Pierpont – Chief of Staff for Governor Cox

o. Tani Pack Downing – Senior Policy Advisor to State Auditor John

p. Kim Coleman – Prior State Representative and alleged victim

q. Barbara Stallone – Sister to Senator Daniel Thatcher and alleged victim

r. Karen Kwan – Utah House

s. Dawn Ramsey – Mayor South Jordan

t. Wayne Cushing – Salt Lake County Treasurer

y. Heather Anderson – Miss Utah

z. Michael Whitlock – Senator Hatch Comms/Director

aa. Andrew Stoddard – Utah House

bb. Tracy Gruber

cc. Becky Pickle

dd. Rep. John Curtis

ee. Mia Love

ff. Brad Bonham

gg. Zach Jacob

hh. Bart Barker - Then General Manager of the MSD

ii. Enid Mickelsen

jj. DeLaina Tonks

kk. Ally Isom

ll. V. Lowry Snow

mm. Sue Duckworth

nn. Hannah Coleman

oo. Jake Parkinson

pp. Val Hale

rr. Michelle Quist

ss. Rozan Mitchell