CTGOP Files Election Complaints Against WFP

Posted on Monday, June 27th, 2011 by Connecticut Republicans
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For Immediate Release

Contact: Chris Healy (860) 826-7378

June 27, 2011

CTGOP Files Election Complaints Against WFP

The Connecticut Working Families Party has violated both state and federal election laws during its attempt to aid Democrat candidates for statewide offices last year according to a complaint filed by the Connecticut Republican Party Friday.

“The Working Families Party has been long known to be a hollow organization which merely exists to prop up Democrats by funneling money to liberal candidates,” said Republican State Party Chairman Chris Healy. “It appears the WFP doesn’t believe it has to play by the same rule.”

The complaints – filed with both the state Election Enforcement Commission and the Federal Election Commission – show that the WFP made unauthorized donations and transfers.

It made illegal campaign fund transfers to the campaigns of Gov. Dannel P. Malloy, Attorney General George Jepsen, Treasurer Denise Nappier, Comptroller Kevin Lembo  and Secretary of the State Denise Merrill.  Expenses were listed as coordinated with reimbursement sought but none of the campaigns made payments back to the WFP.

In addition, the WFP State Account made a total of $30,000 in transfers over the last year  to a federal Political Action Committee – CT Working Families Federal PAC-d.b.a.Take Back Congress. Those types of transfers can only be made to a federal “party” account. Regardless, the transfer never appeared as income on the FEC report for the WFP-Take Back Congress organization.

Two other statewide candidates were the beneficiaries of organizational contributions by the WFP but no campaigns were established by the candidates to receive them.

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TEXT OF THE COMPLAINT CAN BE FOUND BELOW:

June 21, 2011

Mr. Al Lenge, Executive Director

Connecticut State Elections Enforcement Commission

20 Trinity Street, Suite 501

Hartford, Connecticut 06106

Via: Hand Delivery

RE: Working Families Campaign Committee

Jepsen 2010

Merrill for Secretary of the State

Nappier for State Treasurer 2010

Lembo 2010

Canty 2010

Dear Mr. Lenge:

Please allow this letter and the enclosed exhibits marked 1-45 as a formal complaint against the above mentioned 2010 State-wide and General Assembly candidates and the Working Families Campaign Committee. My complaint alleges several campaign finance infractions made by the Working Families Campaign Committee, Mary Rydingsward of 176 Marcia Drive in Bristol, Connecticut as its Treasurer, on behalf of the aforementioned candidate committees.

The integrity of the election process is at stake as well as that of the Citizens Election Program. In 2008, at a meeting of Republican Town Chairmen and Treasurers, Beth Rodman stated that “if you don’t participate in the Citizens Election Program you don’t believe in fair and clean elections.” Some of these infractions delineated below in my complaint exhibit what is wrong with the program and the discrepancies outlined need to be corrected.

Below is a summary of my concerns:

1 – In exhibit “1” the Working Families Campaign Committee (hereinafter referred to WFCC) SEEC Form 20 for the period covering 4/1/10 – 6/30/10 Ms. Rydingsward on Page 14 lists expenditure to Grassroots Strategies in the amount of $6500.00. The description listed for this expenditure is “canvas/petition services.” The allocation of $928.57 was made to Lembo, Merrill, Jepsen, Nappier, Pratt, and Hoehne.

Mr. Al Lenge                                                                                                                                                                                   Page Two

The following issues arise:

-        The expenditure was $6500. If you take the allocation of $928.57 and multiply it by six candidates it totals $5571.42. Which candidate was allocated the remaining $928.58?

-        Under the type of expenditure Ms. Rydingsward checked off that this is a “coordinated expenditure with reimbursement sought,” as well as an organizational expense.

In exhibit “4”, Understanding Connecticut Campaign Finance Laws, published by the SEEC on page 66 reads “If an expenditure is coordinated by an individual or a committee with a participating candidate and payment or reimbursement is not made by the candidate committee within a reasonable time, the coordinated expenditure constitutes a non-qualifying in-kind contribution to that candidate’s campaign.

Exhibits “5-10” Lembo 2010, Exhibits “23-27”  Jepsen 2010, Exhibits “28-37” Merrill for Secretary of the State and Exhibits “11-22” Nappier for State Treasurer 2010 have not listed the above as an expense incurred and not yet paid or they do not show a payment to the WFCC for the expenditure or contribute.

I submit that this violates section 9-608 of the Connecticut General Statutes.

Also in exhibit “4” on pages 65-66 canvas and petition services is not listed as a permissible organization expense;

I therefore submit this violates section 9-608 of the Connecticut General Statutes.

In addition, Ms. Rydingsward lists that Pratt for Governor and Hoehne for LT. Governor received equal benefit of $928.57 for “canvassing and petition services.” However according to your website neither candidate has filed a campaign committee.

It is my understanding that once a candidate announces their campaign for office they have ten (10) days (as required by section 9-604(a)) to file a statement to that effect with the State Elections Enforcement Commission as required by section 9-603(a). Unfortunately, I cannot find a campaign committee established for each candidate.  I would also like to mention that I believe asking someone to sign your petition for Governor would constitute as an announcement of their campaign.

I believe this violates current campaign finance laws.

I submit this expenditure is a violation of Section 9-604 of the Connecticut General Statutes.

2- On page 16 Ms. Rydingsward lists under Sec. 8 “Expenses incurred but not paid during this period an incurred amount of $15,789.91 to Grassroots Strategies, Inc. on behalf of the following people:

Lembo (Comptroller); Nappier (Treasurer); Merrill (Secretary of the State); Jepsen (AG); Pratt (Governor); Hoehne (LG).

Mr. Al Lenge                                                                                                                                                                             Page 3

The type of expenditure checked off was “Coordinated without reimbursement sought.”

It appears from the individual campaign finance reports (exhibits 5-37) that the four candidates for Constitutional office read the law and reimbursed Grassroots Strategies, Inc, – $3714.29 each to cover the cost of the above mentioned expenditure.

However; if you divide the $15,789.91 by the six candidates that were listed in exhibit 1, page 16, and prorated the expense the total would amount to $2631.65 per campaign committee. Since Lembo 2010; Merrill for Secretary of the State; Nappier for State Treasurer and Jepsen 2010, each paid Grassroots Strategies, Inc. $3714.29 and the said company reimbursed the WFCC a total of $14857.16 (as listed in exhibit 2 page 6 and exhibit 3 page 6) did the above mentioned campaigns pay the pro-rated share for Pratt for Governor and Hohne for Lt. Governor?

Since no campaign committees were filed for Pratt for Governor and Hohne for Lt. Governor who are these people? Were they Connecticut campaigns?

In addition, the Lembo campaign and the Merrill campaign are listed in exhibit 2; page 6; section K “Miscellaneous Monetary Receipts not Considered Contributions from Grassroots Strategies, Inc. as reimbursement to WFCC of $3714.29 each. In exhibit 3; page 6 same sections and title; Grassroots Strategies, Inc reimbursed the WFCC $3714.29 for the Lembo for Treasurer Campaigns and Nappier for Treasurer Campaigns.

In the exhibits enclosed for the Lembo 2010 campaign (exhibits 5-10) only one payment to Grassroots Strategies, Inc is made for the above mentioned amount. In exhibit 26; page 35, the “Jepsen 2010” campaign made an expenditure of $3714.29 to Grassroots Strategies Inc. that is not shown in exhibits 1-3 as being repaid to the WFCC by Grassroots Strategies, Inc.

I submit that this violates section 9-608 of the Connecticut General Statutes.

3- In exhibit 2 page 13 A-2; the WFCC made two expenditures for “campaign org and strategy” of $2785.71 and $1680.00, respectfully, to the following committees:

Lembo (Comptroller); Nappier (Treasurer); Jepsen (Atty General); Merrill (Secretary of the State); and Canty (Rep).

Each expenditure was listed as “Coordinated with Reimbursement sought.”

In exhibits marked 5-10 “Lembo 2010”; 28-37 Merrill for Secretary of the State; 11-22 Nappier for State Treasurer 2010; 23-27 Jepsen 2010; and 38-44 Canty 2010 no expenditures in Section “S” are listed as Expenses incurred by the Committee and not paid during this period.” In addition, none of the marked exhibits list an organizational expense from WFCC to any campaign committee listed above.

Mr. Al Lenge                                                                                                                                                                                   Page 4

I submit that this violates Section 9-608 of the Connecticut General Statutes.

4- In exhibit 2 on Page 13A-3 Ms. Rydingsward lists an expenditure of $6500.00 made on 7/5/2010 check number 1359 to Grassroots Strategies, Inc as a “Coordinated with reimbursement sought” but lists no candidates that the expenditure supported.

I submit that this violates Section 9-608 of the Connecticut General Statutes.

5- In the same exhibit and page number listed in item 4 of my complaint, Ms. Rydingsward lists another expense of $6500.00 on 7/5/2010; check 1358; to the same company; as “coordinated with reimbursement sought” to support the following candidates:

Lembo (Comptroller); Jepsen (Atty General); Nappier (Treasurer); and Merrill (Secretary of the State.)

None of the exhibits submitted report an “Expense incurred by the committee but not paid during this period” nor does any of the exhibits report a reimbursement by the respective campaign committees to the WFCC.

I submit that this violates Section 9-608 of the Connecticut General Statutes.

6- Ms. Rydingsward listed in exhibit 2; Page 17 A-1 Section T “Itemization of Reimbursements to Committee Workers and Consultants,” a reimbursement to “Jack Gold” check #1376 of $24.87 as an organizational expense. The expense was for art supplies for placards with a code of “Office.” The organizational expense was in support of Malloy (Governor).

Since no date is listed on the expense, I cannot cross reference to see if it was reported by the Malloy campaign; however I do not believe under the statutes that an organizational expense can be made for office supplies.

I therefore submit that this violates Section 9-608 of the Connecticut General Statutes.

7- Please note in Exhibit 7, Page 25 the Lembo 2010 campaign made an expenditure of $300 on 10/15/2010 to Friends of Chris Dodd for research materials. It is my understanding that Friends of Chris Dodd is a federal campaign committee registered with the Federal Elections Commission.

In addition, I do not believe that a state candidate committee may donate to a federal campaign committee using CEP grant money.

Therefore, I submit that this violates section 9-607 and 9-608 of the Connecticut General Statutes.

8- In exhibit 13 on page 2, the Nappier for State treasurer 2010 committee reports an organization expense from the WFCC in the amount of $185.71 for “petition services.” Petition gathering is not an acceptable form of expenditure under the CEP.

Mr. Al Lenge                                                                                                                                                                                   Page 5

I submit that this is a violation of Section 9-608 of the Connecticut General Statutes.

9- I have enclosed as exhibit 45 my letter to the Federal Elections Commission alleging improprieties with the WFCC federal account. While this does not pertain to your agency, in exhibit 3 on page 13B, Ms. Rydingsward made the following payments:

November 26 – Check 1393 – CT Working Families Federal PAC – $7335.99

November 26 – Check 1394 – CT Working Families Federal PAC – $5057.57

December 16 – Check 1395 – CT Working Families Federal PAC – $4556.85

And in Exhibit #46  Page 13:

January 9 – Check 1398 – Ct Working Families Party Federal PAC – $3809.77

Page 14:

February 17 – Check #1405 – CT Working Families Party Federal PAC – 2528.78

The only committee that appears on the Federal Elections Commission website is: CT Working Families Party Federal PAC/ D.B.A. Take Congress Back. The WFCC was formed using an SEEC form 2 as a party committee. The federal party committee must be named the same. Under federal law a state party cannot give to a federal PAC (Political Action Committee.)

In addition, if you look at the CT Working Families Party Federal PAC on the FEC website; none of the above mentioned expenditures are listed as income.

The items listed in this complaint to your agency may well be attributed to “sloppy bookkeeping.” However, in the interest of fair and clean elections and with the amount of money that was invested into the 2010 elections, your agency has been assigned the task of maintaining the integrity of the campaign finance portion of government.

I submit the enclosed documentation to support my complaint and I look forward to your reply.

Sincerely

Christopher C. Healy

Chairman

Connecticut Republicans

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