Complaint No. 1786738657 - 1468200883

Jena Marie Griswold
1700 Broadway, Suite 550
Denver, Colorado 80290

Statement

I state that Jena Griswold, while acting in her official capacity as Colorado Secretary of State and as the elected official responsible for the Colorado Department of State, abused the authority of her office by failing to ensure the preservation, integrity, accessibility, and lawful handling of government records and evidence under the control of her Department. I further state that Griswold failed to correct or prevent conduct within her office that obstructed access to evidence, impaired or destroyed evidence, and resulted in false or materially misleading representations concerning the existence, preservation, and availability of that evidence.

As Secretary of State, Griswold holds ultimate executive responsibility for the administration and conduct of the Department of State. After the underlying misconduct became known, she failed to take meaningful corrective action, failed to ensure that relevant evidence was preserved, and failed to provide an effective mechanism for independent review or accountability. Her failure to act allowed the conduct to continue and effectively ratified the obstruction, evidence misconduct, and lack of transparency occurring within her office.

I contend that this conduct deprived me of the ability to obtain and preserve an accurate governmental record and impaired my ability to seek meaningful review, redress, and accountability. The use of governmental authority to obstruct access to evidence, permit evidence to be destroyed or impaired, or allow materially false representations concerning government records undermines both the Colorado public-records framework and the basic obligation of public officials to administer government honestly, impartially, and transparently.

Griswold's conduct is particularly significant because the Secretary of State is not merely another employee within the Department. She is the elected constitutional officer responsible for its administration. When misconduct involving evidence, official records, false statements, or deprivation of rights occurs within that office and the Secretary knowingly fails to correct it, the resulting failure of supervision and accountability becomes an exercise of governmental authority in its own right.

I submit this complaint so that Griswold's abuse of authority, failure of duty, evidence misconduct, false or misleading representations, deprivation of rights, and failure to correct misconduct within the Department of State are preserved as potential impeachment material. These matters bear directly upon her credibility, candor, reliability, impartiality, exercise of official authority, and the integrity of any governmental representation, certification, record, testimony, or official action with which she may subsequently be associated.