P.O.

Box 27255
Raleigh, NC 27611
(866) 522-4723
www.ncsbe.gov

VIA EMAIL

Robert F. Orr
3434 Edwards Mill Rd.
Suite 112-372
Raleigh, N.C. 27612
orr@rforrlaw.com

August 7, 2023

Dear Justice Orr,

The members of the State Board of Elections have received the information provided by No
Labels on August 3, 2023, in response to the Board’s requests for information dated July 13,
2023. Members of the Board have further requested the information below to aid their
determination as to whether the petition has complied with the requirement in N.C.G.S. § 163-
96(b) that “the organizers and petition circulators shall inform the signers of the general purpose
and intent of the new party.”

1. Please refer to the interview of Nancy Jacobson, CEO of No Labels, by Vaughn Hillyard
and Dan Gallo of NBC News, posted July 18, 2023.1 In particular, please refer to the
following excerpts:

Minute 0:06 Jacobsen: No Labels is never gonna run a third-party presidential

ticket.

Minute 8:41 Jacobsen: First of all, we’re not a party. And second of all…
Hilliard: But you guys are registering as a party in states around
the county. And…
Jacobsen: That’s just the requirements of the state.

Minute 9:05 Hilliard: But you’re registering as a political party.

Jacobsen: That’s just language.

a. Did you explain this to the voters you asked to sign the petitions for new political
party status? If so, please provide information in support.

1
Available at https://www.nbcnews.com/politics/2024-election/no-labels-ceo-defends-2024-
ticket-spoiler-charges-rcna94378.
 b. What is the relationship between No Labels as a national, 501(c)(4) organization
which claims not to be a political party and has not registered as a political party,
and the group that is seeking political party status in North Carolina?

2. Referring to the affidavit of Ronner Williams that you submitted to the State Board on
August 3, 2023, the attachment labeled “Signature Gatherer/Petition Circulator
Expectations” is signed and dated July 31, 2023, which is after No Labels submitted its
petitions to the State Board. In the affidavits you submitted from other petition
circulators, this form is not dated and sometimes not signed. Can you please explain these
apparent discrepancies?

The Board requests that No Labels either provide this information in writing by August 11, 2023,
or through its representative at the State Board’s public meeting on August 13, 2023, in Concord,
North Carolina. If you choose to submit the information in writing, you may email it to the
undersigned counsel for the Board at paul.cox@ncsbe.gov.

With best regards,

Paul M. Cox
General Counsel, State Board of Elections

BCC: Members of the State Board of Elections