OFFICE OF ADMINISTRATIVE COURTS,

STATE OF COLORADO
1525 Sherman Street, 4th Floor
Denver CO 80203
________________________________________________________________________________________________________

Complainant:
CAMPAIGN INTEGRITY WATCHDOG (CIW)
v.
Respondent:
DENVER COUNTY REPUBLICAN CENTRAL COURT USE ONLY
COMMITTEE (DCRCC)
Attorney or Party Without Attorney (Name and Address):
Matthew Arnold, Pro Se for Campaign Integrity Watchdog Case No.: OS 2017-0006
P.O. Box 372464, Denver CO 80237
(303) 995-5533
Email: campaignintegritywatchdog@gmail.com
NON-DISPARAGEMENT AGREEMENT

The parties having stipulated to entry of Stipulated Judgment to resolve all matters in dispute in
this action between them, additionally enter into this mutual Non-Disparagement Agreement,
binding on all parties inclusive officers of the respective organizations, as follows:

By signing this agreement, Matthew Arnold on behalf of Campaign Integrity Watchdog (CIW)
and officers Jake Viano (Chairman) and Kristina Cook (Vice-Chair) and Sue Rose Moore on
behalf of Denver County Republican Central Committee (DCRCC) agree not to engage in any
form of conduct, or make any statements or representations with regard to the past claims settled
or litigated in this case (OS 2017-0006) or in any other past cases involving Campaign Integrity
Watchdog (CIW) and/or Denver County Republican Central Committee (DCRCC) that disparage
or otherwise harm the others reputation or goodwill by word, statement, or deed.

The parties acknowledge that the remedies available at law for any breach of this agreement will,
by their nature, be inadequate. Accordingly, each Party may obtain injunctive or other equitable
relief to restrain a breach or threatened breach of this agreement or to specifically enforce this
agreement, without proving that any monetary damages have been sustained.

The parties agree that any such action to enforce this agreement will be brought in Colorados 2nd
Judicial District (Denver District Court).

The parties agree that enactment and entry into force of this agreement is contingent upon the
ALJs accepting and entering into the stipulated judgment jointly filed by the parties in this case.
Dated this 14th of June 2017,
Signed and agreed by parties as follows:

CAMPAIGN INTEGRITY WATCHDOG

By: __/signed/ Matt Arnold_______________

Matthew Arnold
PRO SE FOR COMPLAINANT

DENVER COUNTY REPUBLICAN CENTRAL COMMITTEE

By: __/signed/ ________________________

Jake Viano, DCRCC Chairman

By: __/signed/ ________________________

Kristina Cook, DCRCC Vice Chair

By: __/signed/ ________________________

Sue Rose Moore, DCRCC Chair emeritus