Issue Committee Greeley Deserves Better Serves Cease and Desist to Opponents Following False and Reckless Statements Meant to Mislead and Confuse Voters
Greeley, Colo. (August 18, 2025)
Greeley Deserves Better, an issue campaign seeking to overturn Greeley’s funding mechanism for the proposed Greeley soccer stadium, served Thomas Donkle of the Greeley Forward campaign a cease and desist letter highlighting his campaign’s persistent violations of CRS §1-13-109. The Greeley Forward campaign committee has asserted false and reckless statements about the Greeley Deserves Better initiative almost since the inception of the campaign.
Among the alleged false claims disseminated by Greeley Forward are:
Coordination with nonprofit With Many Hands
Claims that petition signers were misled about the scope of the initiative
Multiple false statements regarding the signature collection process, such as a false “unlicensed company” claim when no such license is required by city signature gatherers; and more.
“While it’s expected that some mudslinging occurs during a campaign, the law does not permit patently false statements,” said Suzanne Taheri, former deputy Secretary of State, and legal counsel for Greeley Deserves Better. “Greeley Forward has repeatedly and with a pattern of knowing misrepresentation attempted to smear the many volunteers and citizens who want their voices heard on this important issue. There’s a reason the campaign submitted the highest number of signatures in Greeley’s municipal history; it’s because there is overwhelming grassroots support from all corners of the city. Greeley residents are no fools – they know a bad deal when they see one.”
From the cease and desist letter:
“These false statements establish a pattern of knowing misrepresentation designed to affect the vote on the ballot initiative. Greeley Forward is acting with "conscious disregard of the truth or falsity" of these statements, meeting the statutory definition of reckless conduct under C.R.S. § 1-13-109(2)(a).
“It is clear your organization intends to spend money on advertisements smearing the many volunteers and citizens that want their voices heard. The advertisements you are currently airing are blatantly false and were aired in Colorado with the intent to mislead voters. These advertisements are the reason Colorado has a law prohibiting false statements.
“No person shall knowingly make, publish, broadcast, or circulate or cause to be made, published, broadcasted, or circulated in any letter, circular, advertisement, or poster or in any other communication any false statement designed to affect the vote on any issue submitted to the electors at any election or relating to any candidate for election to public office. C.R.S. § 1-13-109(1)(a).
“No person shall recklessly make, publish, broadcast, or circulate or cause to be made, published, broadcasted, or circulated in any letter, circular, advertisement, or poster or in any other communication any false statement designed to affect the vote on any issue submitted to the electors at any election or relating to any candidate for election to public office... a person acts "recklessly" when he or she acts in conscious disregard of the truth or falsity of the statement made, published, broadcasted, or circulated. C.R.S. § 1-13-109(2)(a).”
The letter was delivered on August 17, 2025, via email to Thomas Dunkle, the registered agent for Greeley Forward, and a developer land use consultant.
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