Response shows there was no coordination
Attached is a 9 page response to the Order Requiring Compliance in the matter of Tom Horne and Kathleen Winn. Here are the salient points:
- Under applicable law, Horne and Winn were free to communicate, as long as it was not about the independent expenditure, which it was not.
- Winn, who had over 25 years in the real estate business, was Horne’s principle advisor with respect to a complex real estate transaction which closed on October 29, 2010.
- The order falsely claims that phones calls between Winn and Horne spiked between October 13 and October 28, 2010, when the independent ad was being developed. (See false and misleading chart, page 11 of Order, Exhibit 4 to Response.) In fact, the FBI transcripts show that the ad was completed on October 21, and that the spike in phone calls occurred after the ad was completed, during the intense period of the closing of the real estate transaction. (See Exhibit 4, page 2, with corrections to the false and misleading chart.)
- The entire case is based on this kind of misleading speculation. There is no direct evidence of coordination, because there was none. This is shown in the 9 pages attached, and if necessary, will be proven in the legal proceedings.