The Recall Pfaff Effort

In addition to the Residency Issue, we are exploring a recall effort against Mr. Pfaff and, possibly, other Woodland Park Council Members.

As for Mr. Pfaff, the recall will be based on several factors including (1) his alleged election fraud and perjury; (2) his apparent intention to move on to “other places” as demonstrated, in part, by failing to establish a long-term commitment to the Woodland Park including by (a) living in a trailer in the Bristlecone Campground; and (b) several of his policy positions that conflict with the best long-term interests of Woodland Park residents including eliminating all zoning ordinances; (3) his stated intent to (a) close the resident approved Woodland Aquatic Center, and (b) repeal the resident approved sales tax supporting the Woodland Park School District; and (4) the disrespect and bullying he frequently demonstrates against City residents, City employees and other members of the City Council. We believe Mr. Pfaff intends to disrupt the nature of our community with his seemingly benign beliefs.

Bullying behavior will not be tolerated. Although Council members are unpaid citizen volunteers, their position does not excuse them from complying with the law, studying the past, listening to the citizens who make Woodland Park their home, and treating others with respect.

Woodland Park is governed by a charter and elections are non-partisan in nature. This is not a political effort. Rather, it is an effort to remove a person if he did not satisfy the requirements to run for office. Further, we believe Mr. Pfaff is a transitory person who has no intention to stay in our community. This is his pattern.

We are working on a Recall Plan and will also account for the current health concerns of some citizens in the process to every extent possible. We will notify the citizens if this plan is triggered. We do expect Mr. Pfaff to find an elegant way to exit our community.

Historical Context

Mr. Pfaff floats from state to state and city to city engaging in varying activities. Based on comments Mr. Pfaff made pursuant to an investigation conducted by the Office of the District Attorney, Fourth Judicial District, Mr. Pfaff’s recent past includes living in: (1) Castle Rock, CO; (2) Washington, D.C.; (3) Golden, CO; and (4) Fort Collins, CO.

Mr. Pfaff’s LinkedIn page shows 15 entries including 10 months spent as Colorado state director for the conservative advocacy group Americans for Prosperity; nearly two years as the chief of staff for the GOP caucus in the state House of Representatives; and as the chief of staff to two Republican congressmen from Kansas and Kentucky.

We also know he moved back to Indiana and ran for the US House of Representatives but did not complete that campaign. In fact, Mr. Pfaff was accused by one of his staffers, Mr. Paul Sapperstein, of election fraud during that campaign. Afterward, Mr. Pfaff then unsuccessfully ran for a seat in the Indiana Legislature.

Mr. Pfaff claims he moved to Woodland Park no later than April 7, 2019. Upon an investigation conducted by the Woodland Park Police Department, the WPPD obtained documents showing Mr. Pfaff moved a camper trailer into Bristlecone Campground on May 26, 2019. Mr. Pfaff never produced credible evidence that he was a Woodland Park resident before May 26, 2019. Mr. Pfaff claims he does not even own the camper trailer and, therefore, it still has Indiana license plates on it.

Via email dated January 30, 2020, to the Woodland Park City Clerk, Mr. Pfaff provided a screenshot of what is allegedly from his bank for check #5048 for $360 allegedly drawn on April 1 (year not shown) from Old National Bank in Evansville, IN. Missing from the screenshot is: (1) the account number; (2) the name of the account holder; and (3) the name of the payee. No further evidence was produced by Mr. Pfaff that check #5048 was actually written and delivered to (or cashed by) Bristlecone Campground. Even if a check was paid to Bristlecone Campground on April 1, 2019, it does not prove that Mr. Pfaff occupied the trailer on that date and started residency in Woodland Park.

Under Colorado law, living in a recreational vehicle in a campground is not a basis for establishing residency, unless, maybe, when someone is homeless. Mr. Pfaff is claiming “homelessness” as a basis for his Woodland Park residency. However, the “homeless” exception applies to electors (i.e., voters) when registering to vote. It does not apply to candidates for public office to establish residency. Further, during the December 3, 2020, on-line City Council meeting, at approximately 7:00 pm (Mountain Time), Mr. Pfaff admitted he was at his house in Indiana that he owned since 1998. His purported reason for being in Indiana was that his wife was there for an appointment with a doctor. Days later, Mr. Pfaff revised his reason for being in Indiana stating he was there because it was his anniversary. In any event, even if the “homeless exception” applies to candidates for public office to establish residency, it seems unlikely that “homelessness” can be used to establish residency when living in a recreational vehicle in a campground when the person owns a home.

In the Investigative Report issued by Philip Donner, the Investigator for the District Attorney, Fourth Judicial District Investigator, Mr. Donner states Mr. Pfaff’s Colorado Driver’s License was issued on January 23, 2019, and shows the Bristlecone Campground address. This seems implausible if: (1) Mr. Pfaff did not register at Bristlecone Campground until May 26, 2019; and (2) by his own admission in his January 30, 2020 email mentioned above, his first payment was not until April 1, 2019, at the earliest.

Mr. Pfaff changed the legal name of his company, Innovative Research and Data Solutions, LLC, a Colorado limited liability company (Entity ID# 2009119248) to his personal name on March 18, 2020 – shortly before the April 2020 election. He then changed the company name back to Innovative Research and Data Solutions, LLC on May 1, 2020 – shortly after the April 2020 election.

Mr. Pfaff uses his PO Box address when Colorado law requires a street address. For instance, on March 18, 2020, when filing Document # 20201245759 with the Colorado Secretary of State for Innovative Research and Data Solutions, LLC, as Registered Agent, Mr. Pfaff used his PO Box address of 743 Gold Hill Place, #46, Woodland Park, CO 80863.