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APPEAL TO THE NEW YORK STATE ATHLETIC COMMISSION

February 15, 2017

Sent via e-mail and U.S. Mail to:

Anthony Giardina, Interim Executive Director

New York State Athletic Commission

123 William Street, 2nd Floor

New York, NY 10038

athletic@dos.ny.gov

Appeal of Referee’s Decision – UFC 208

Holm v. de Randamie February 11, 2017

Dear Mr. Giardina:

This firm represents Holly Holm. This letter serves as notice of Ms. Holm’s appeal of the outcome

of the UFC 208 Featherweight Title fight on February 11, 2017.

Ms. Holm seeks review of Referee Todd Anderson’s failure to deduct one or more points from

Germaine de Randamie following her repeated strikes thrown after the horn sounded to end

Rounds 2 and 3. Section 212.10(b)(27) of the New York State Athletic Commission (NYSAC)

Regulations provides that attacking an opponent after the bell has sounded the end of the period

of competition constitutes a foul in a professional mixed martial arts contest. Regulations also

make clear that when a foul is committed, the referee “shall then assess the foul to the offending

contestant and deduct points . . . if the referee deems it appropriate, and notify the commission,

the corners, the official scorekeeper of his decision on whether the foul was accidental or

intentional and whether any point deduction . . . is imposed.” NYSAC Reg. 212.10(a). Points may

be deducted whether or not a foul is intentional. NYSAC Reg. 212.11. While a referee had

discretion whether or not to impose a point deduction, he has no discretion under NYSAC

Regulations to disregard a foul where an opponent commits a foul clearly delineated in Section

212.10(b), including by attacking after the bell has sounded at the end of a round.

Referee Anderson only warned de Randamie following de Randamie’s foul at the end of Round 3,

rather than following the end of Round 2. At a minimum, Referee Anderson was required to assess

a foul against de Randamie and determine whether one or more points should be deducted

following the end of Round 2 as required by NYSAC Regulations. Because Referee Anderson did

not issue even a warning—much less assess a foul—at the end of Round 2, de Randamie

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