Chetly Zarko
Zarko Research & Consulting
Editor, www.OutsideLansing.com
Clawson, MI 48017 November 7, 2007
Michigan Department of State
Legal and Regulatory Services Administration
Richard H. Austin Building - 4th Floor
430 West Allegan Street
Lansing, Michigan 48918
RE: Campaign Finance Complaint Against Communities Voting Together ID #513537-1
Dear Secretary of State & Bureau of Elections Staff:
Attached find enclosed my campaign finance complaint against Communities Voting Together ID # 513537-1, along with my signed certifications and a separately typed statement of facts and violations.
Should you have any questions, my contact information is above.
Thank you.
Truly,
Chetly Zarko
CAZ/caz
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Statement of Apparent Facts & Violations of Campaign Finance Laws
The most significant clear violation is a failure to file within 10 days of first contribution (8/17) or expenditure (8/21). The original attempt to file was made on 9/27/2007 with no legal signature, address, or execution. Subsequent attempts resulted in an address and then finally a different address with signature on 10/11/2007. But no valid Statement of Organization has yet been filed containing the out-of-state irrevocable written stipulation. Even assuming the best case scenario of 8/17 through 9/27, a period of roughly 40 days elapsed and the corresponding daily fines should be assessed. This a clear-cut and undeniable violation of the law.
None of three Statements of Organization contain the requisite out-of-state irrevocable written stipulation. The Statements of Organization are therefore still incomplete.
The only two donations - for amounts of roughly $10,000 and $50,000 - both fail to comply with regulations identifying the employer of the donor.
One of the donations, from John Stryker (or Jon Stryker - clarification should be sought), lists a PO Box in Kalamazoo, Michigan. An address should be provided.
The Treasurer, Richard Leal, originally filed under a New Orleans address but later used a Washington DC address, and in an amended reference to a donation by the Treasurer uses a Washington DC address. Some form of certification as to which address or addresses are accurate should be made.
Upon information and belief from three amended sequences of donations there is reasonable cause to believe that contribution data is not accurate or should be substantiated with an actual paper trail (the Amended reports are extremely inconsistent and suggest that the accounts are highly fluid). The first Tri-annual report lists CTV as its own donor and own vendor in expenditure of all moneys. The second report lists individuals and the accounting and legal services firm of CCI. The final report lists completely different individual donors with the same expenditures. The nature of the relationship between the expenditures and contributions - that of a brand new committee incurring accounting fees for nearly a third of its total contributions suggests additionally that the Secretary of State should investigative whether the expenditures purposes are in fact for this committee's purposes or some other purpose or previous committee's work.
The evidence of these violations is wholly contained within existing reports.
I attest to these facts and/or beliefs based on a visual inspection of the online campaign finance reports for Committee 513537 known as "Communities Voting Together" and no other personal knowledge.
______________________________,
11/7/2007, by Chetly Zarko
