RANKEN & SHNIDER A Law Corporation 

222 N. Church Street Wailuku, Maui, Hawaii 96793 (808) 244-7011 • Fax: 244-7022 

CEASE AND DESIST NOTICE December 8, 2025 

To: Shirlene Ostrov
State Chair
Hawai‘i Republican Party
Via email: shirlene.osterov@gmail.com 

RE: Cease and Desist – Unlawful Interference with Maui County Republican Party Governance, Overreach of Authority, And Retaliatory Actions In Violation Of Party Rules And Nonprofit Law 

Dear Chair Ostrov: 

The Maui County Republican Party Committee (“Maui County Committee”), in a duly noticed meeting held on November 26, 2024, where a quorum was present, voted to issue this formal Cease and Desist Notice regarding your actions taken on November 20 and 24, 2025, including the attempted suspension of County Chair Tammy Ash Perkins, the issuance of directives to the Maui County Committee, and the creation and utilization of a State “disciplinary committee” purported to exercise authority over county-level governance. 

After review of the Maui County Rules (2025), the Hawai‘i Republican Party Bylaws (2024), the HRP Rules and Regulations, and applicable nonprofit governance standards, the Maui County Committee finds the actions taken by you and/or the State Executive Committee to be unauthorized, ultra vires, retaliatory, and in direct violation of governing rules binding on all Party officers. 

This letter serves as formal notice that such actions must immediately cease. 

I. The State Executive Committee has no authority to discipline or suspend a county chair. 
Anthony L. Ranken anthony@rankenlaw.com 
Samuel P. Shnider sam@rankenlaw.com 
Under HRP Bylaw §316, disciplinary jurisdiction lies exclusively with the body that elected the officer. The Maui County Republican Committee duly elected Tammy Ash Perkins, and therefore only the Maui County Committee has the authority to discipline, suspend, or remove the County Chair. 

The State Executive Committee has no jurisdiction over County-level officers. Any attempt to suspend or direct the status of the County Chair is void on its face. 

II. Maui County’s rules are fully valid and protected under HRP Bylaw §111. 

HRP Bylaw §111 expressly authorizes committees—including counties—to adopt their own rules, so long as they do not conflict with the State Rules. 

Maui County’s rules were: 

• Adopted at a properly convened County Convention (Nov. 13, 2021) and amended at a properly convened County Convention (March 29, 2025). 

• Filed in accordance with HRP requirements 

• Never repealed 

• Fully consistent with HRP rules 

Therefore, the State Executive Committee has no authority to override, modify, suspend, or interfere with Maui County’s rules or governance. 

Your letter attempts to do all of these, in direct violation of §111. 

III. HRP rules may only be amended by delegates at a state or county convention. 

HRP Rules and Bylaws state that only delegates at a duly convened State or County Convention may amend the Party or County Rules. See HRP §109. 

Therefore:
• The State Executive Committee cannot create new disciplinary bodies
• The State Executive Committee cannot impose new authority structures • The State Executive Committee cannot modify county authority 

• The State Executive Committee cannot create disciplinary powers that do not exist 
Your creation of a State “Disciplinary Committee” is therefore not authorized, not recognized, outside the scope of any HRP rule, and legally void. 

IV. Maui County Article II, Section 1, Rule “P” explicitly limits state authority. Maui County Rule P states: 

“The Republican Party of Hawai‘i... is in the role of Supervisor, not Director. The State shall not overstep its authority... and shall not cause conflict or discord... between the County Chair and its members.” 

Your actions—including the attempted suspension of the County Chair and the directives issued to County members—constitute overstepping supervisory authority, interference with County governance, creation of conflict and discord, violation of Rule P’s protections. They are thus a breach of both County and State Rules. 

V. The temporary suspension you issued is ultra vires and void. 

The attempted suspension of Chair Perkins is contrary to HRP §316, contrary to Maui County Rules. It is also contrary to HRP §116, which sets forth due process requirements allowing for timely objections. It is outside the jurisdiction of the State Executive Committee; an unauthorized action taken in a Special Meeting without proper agenda notice; conducted without required procedural protections; and in violation of Robert’s Rules of Order (Special Meeting limitations). 

It thus has no legal force and is not recognized by the Maui County Committee. VI. Attempting to condition reinstatement on withdrawal of a lawsuit is 

Your letter conditions “reinstatement” upon the withdrawal of a legal complaint filed by Ms. Perkins. Conditioning official Party status or officer rights on the abandonment of legal claims is retaliatory and coercive. It is also unlawful under nonprofit law (including Haw. Rev. Stat. §414D-138 and related federal standards). It is a violation of public policy; a violation of the duty of good faith; and a violation of the duty to avoid creating legal liability for the Party. 

The Maui County Committee will not tolerate any further attempts to intimidate, coerce, or retaliate against County officers or members. 
retaliatory and illegal. 
VII. Cease and Desist Demand 

Effective immediately, you are hereby directed to: 

1. Cease and desist from representing that the State Executive Committee has the authority to suspend or discipline the Maui County Chair. 

2. Cease and desist from issuing directives to Maui County members that contradict County Rules or exceed State authority. 

3. Cease and desist from attempting to enforce any action arising from the unlawful November 20, 2025, vote. 

4. Cease and desist from any coercive or retaliatory communication tied to ongoing legal proceedings. 

5. Cease and desist from creating or using unauthorized disciplinary structures that were not created by convention or authorized by the Bylaws. 

Failure to comply will result in the Maui County Committee pursuing legal remedies, protective orders if warranted, formal complaints to oversight bodies, and any other action necessary to protect the County, its officers, and its members. 

VIII. Reservation of Rights 

The Maui County Republican Party Committee reserves all rights are provided under its Rules, under the HRP Bylaws, under Hawai‘i nonprofit law, under principles governing voluntary associations, and/or to seek judicial intervention should interference continue. 

Nothing in this letter waives any right or legal claim. Very truly yours, 

Samuel P. Shnider Samuel P. Shnider Counsel for 

Cc:
Andrea Rodgers, Vice Chair & Presiding Officer for Special Meeting Maui County Republican Party Committee
Star Beechick, County Secretary Maui County Republican Party Committee representativemcdermott@gmail.com