1 III. NATURE of ALLEGED VIOLATION Rep. Tom Craddick And

III. NATURE OF ALLEGED VIOLATION

Rep. Tom Craddick and Texas Railroad Commissioner Christi L. Craddick colluded to conceal a contribution of $25,000 made through Rep. Phil King to aid the campaign of Christi Craddick in the 2012 Republican Party primary runoff for Railroad Commission, in apparent violation of Texas Election Code Sec. 253.001 which prohibits contributions or expenditures in another’s name.

The $25,000 was subsequently forwarded by King to the third party Dallas-Fort Worth Conservative Voters PAC, which assisted Christi Craddick in the July 31, 2012 Republican Primary Runoff in Tarrant County; an area not within King’s district and during an election in which King was unopposed.

The $25,000 was not reported by Rep. Craddick until after the 2012 election, as a “political donation” from his campaign account to King, and should have appeared on King’s semiannual report filed January 15, 2013. King reported a $25,000 expenditure to the PAC on July 10, 2012, but the $25,000 contribution to King from Rep. Craddick has yet, as of the time of this complaint, to be reported by Rep. King. See Tex. Elec. Code § 254.031

The Craddicks had a motive for concealing the donation. At the time King transferred the money to the third party PAC, Christi Craddick was under increasing scrutiny for her reliance on her father’s support to carry her through the runoff in her race for Railroad Commissioner. In addition, the Craddicks’ past behavior indicates that they are not above manipulating state law to their benefit.

IV. STATEMENT OF ALLEGED FACTS

Tom Craddick, Christi Craddick and Phil King conspired to conceal a $25,000 contribution to aid Christi Craddick during a critical period in the 2012 Republican Party primary runoff. The act was meant to bypass criticism by Christi Craddick’s opponent, former Rep. Warren Chisum, who claimed she was over-dependent on her father’s financial assistance. The 2012 actions by Tom and Christi Craddick mirror past efforts to covertly benefit Christi Craddick’s financial and political standing.

Craddick Activity Foreshadows 2012 Shell-Game

In 2008, the Craddicks were the subject of an ethics complaint alleging that Rep. Craddick violated state law by paying Christi a $12,000 per month ($625,000 over six years) “consulting fee.” The violation came as a result of legislation (SB 1102) Craddick worked to pass in 1997 that would allow him to include Christi as a “dependent” for the purpose of providing her taxpayer-subsidized health insurance. State law prohibited paying a dependent from campaign funds. (Sources: http://eyeonwilliamson.org/wp-content/uploads/2008/12/craddick-complaint.pdf , and http://www.ktbs.com/story/22368596/activist-craddick-violates-law-by-paying-daughter) See Texas Election Code § 253.041(2)

In 2008, Sheila Beckett, former executive director of the Texas Employees Retirement System, told the Austin American Statesman that Rep. Craddick had indeed been behind the legislative effort that would classify his daughter as a dependent for the purpose of receiving state health care benefits:

There also is a question of what role, if any, Craddick played in changing a law in 1997 that allowed his daughter, then 26 and a lobbyist, to continue on state health insurance.

In 2002, Sheila Beckett, executive director of the Employees Retirement System of Texas, put the change in the law at the feet of Craddick.

"He initiated it," she told The Fort Worth Star-Telegram. "I was assuming he was concerned about the continuing insurance coverage for his daughter." (Source: Activist: Pay to Craddick's daughter violates law, Austin American- Statesman, December 3, 2008)

In October 2009, Texans for Public Justice, a government watchdog, filed a formal complaint with the Texas Ethics Commission alleging that Tom and Christi Craddick engaged in money laundering through the shell Texas Jobs & Opportunity Build a Secure Future PAC (Jobs PAC) to support Democratic House candidates loyal to Craddick. Craddick’s method of moving money from his campaign through a PAC is disturbingly similar to the shell game he appears to have carried out in 2012. According to TPJ:

According to its own reports, Jobs PAC wrote three checks of $50,000 apiece to the campaigns of Reps. Bailey, Flores and Pena on January 11, 2008. By its own accounting, at the time Texas Jobs wrote these checks its sole source of funding was the $250,000 that it received the day before from the Craddick campaign. (Source: Complaint Alleges Texas Jobs PAC, Laundered Craddick Money in 2008, News from TPJ, Texans for Public Justice, October 5, 2009, http://info.tpj.org/press_releases/pdf/JobsTEC.PR.Oct09.pdf )

According to press reports in 2008, Rep. Craddick’s attorney admitted that Christi Craddick was instrumental in assisting her father in administering the funds transfer through the Jobs PAC to the candidates:

A lawyer for Texas House Speaker Tom Craddick reversed himself Tuesday, saying the Midland Republican specified that he wanted his $250,000 donation to a political committee to go to several House Democrats who supported him.

When Travis County prosecutors began investigating the donations last month, Austin lawyer Roy Minton denied that Craddick had directed how the donation to the committee, Texas Jobs & Opportunity Build a Secure Future, should be spent.

On Tuesday, Minton said Christi Craddick, the speaker's daughter, who runs his political operation, wrote the Texas Jobs committee a letter in January asking it to give $50,000 each to four Democratic incumbents [emphasis added] who had opponents in the March 4 primaries.

"Of course, they were happy to do it," Minton said. "Tom knew everything that was going on."

Minton said that his remarks last month were his mistake and that he had turned Christi Craddick's letter over to prosecutors as part of a package of records that had been subpoenaed. (Source: Craddick directed who got cash, lawyer now says, Austin American- Statesman (Texas), March 19, 2008)

2012 Republican Runoff

In May 2012, the Fort Worth Star-Telegram spelled trouble for Christi Craddick’s campaign in Tarrant County by endorsing her opponent, Rep. Warren Chisum, for the Texas Railroad Commission:

The three standouts in the race are longtime state Rep. Warren Chisum of Pampa, attorney and independent businesswoman Christi Craddick of Austin (daughter of a former House speaker, state Rep. Tom Craddick of Midland) and oil and gas industry attorney Roland Sledge of Houston.

Chisum, with experience as an energy producer and oilfield services operator and a long history of public service, including on House committees overseeing matters important to the industry and to Texans, is the best pick. He's known as a staunch conservative and a what-you-see-is-what-you-get legislator.

The Star-Telegram recommends Warren Chisum for the full term on the Railroad Commission. [emphasis added] (Source: Serious oil and gas regulators needed in boom times, Fort Worth Star- Telegram, May 7, 2012)

In July 2012, Rep. Chisum continued to level charges against Christi Craddick’s campaign for depending on her father’s money; despite the younger Craddick’s effort to distance herself on the trail:

“It’s clear her father, Tom Craddick, is helping her,” the veteran Pampa lawmaker said in reference to the former speaker of the Texas House of Representatives.

“I’m still not convinced Christi has the experience that is necessary for this position since she has yet to release a detailed resume and now she seems to be hiding her father’s involvement in her campaign,” Chisum said.

“I don’t know what Christi’s definition of out front is, but over $320,000 in campaign contributions is pretty out front to me,” Chisum said in reference to a television news story in which Craddick reportedly said her father was not involved in her campaign.

However, in her campaign contribution report of three months ago Christi Craddick reported a $300,000 donation from her well-known father, nearly a third of the more than $1 million she had raised since entering the race. (Source: Texas Railroad Commission race gets intense as attacks fly, July 14, 2012, http://amarillo.com/news/local-news/2012-07-14/railroad-race-gets-intense-attacks-fly)

Up to the time Christi Craddick began receiving financial support from Rep. Craddick for her campaign for the Railroad Commission, she was receiving a substantial salary and other compensation from her father’s campaign account. Between February 2003 and June 2011, Christi Craddick received over $1 million from Rep. Craddick’s campaign. The elder Craddick’s support for his daughter’s campaign began just a few weeks after he stopped paying her as a campaign staffer (see below):

Report Filer's Name Payee's Name Amount Date Description # 227998 Craddick, Tom Craddick, Christi L. $ 12,000.00 2/14/2003 Salary 227998 Craddick, Tom Craddick, Christi L. $ 8,000.00 3/14/2003 Salary 227998 Craddick, Tom Craddick, Christi L. $ 8,000.00 4/15/2003 Salary

Report Filer's Name Payee's Name Amount Date Description # 227998 Craddick, Tom Craddick, Christi L. $ 8,000.00 5/15/2003 Salary 227998 Craddick, Tom Craddick, Christi L. $ 8,000.00 6/13/2003 Salary 227998 Craddick, Tom Craddick, Christi L. $ 1,368.55 6/30/2003 Travel 239144 Craddick, Tom Craddick, Christi L. $ 8,000.00 7/15/2003 Salary 239144 Craddick, Tom Craddick, Christi L. $ 8,000.00 8/15/2003 Salary 239144 Craddick, Tom Craddick, Christi L. $ 45.81 8/22/2003 Meals 239144 Craddick, Tom Craddick, Christi L. $ 8,000.00 9/15/2003 Salary 239144 Craddick, Tom Craddick, Christi L. $ 10,000.00 10/15/2003 Salary 239144 Craddick, Tom Craddick, Christi L. $ 503.37 11/14/2003 Travel Meals 239144 Craddick, Tom Craddick, Christi L. $ 10,000.00 11/15/2003 Salary 239144 Craddick, Tom Craddick, Christi L. $ 10,000.00 12/15/2003 Salary 239144 Craddick, Tom Craddick, Christi L. $ 1,315.37 12/30/2003 Travel Office Supplies 254607 Craddick, Tom Craddick, Christi L. $ 6,925.42 1/14/2004 Salary 254607 Craddick, Tom Craddick, Christi L. $ 6,925.42 2/17/2004 Salary 254607 Craddick, Tom Craddick, Christi L. $ 6,925.42 3/15/2004 Salary 254607 Craddick, Tom Craddick, Christi L. $ 6,925.42 4/15/2004 Salary 254607 Craddick, Tom Craddick, Christi L. $ 6,925.42 5/14/2004 Salary 254607 Craddick, Tom Craddick, Christi L. $ 6,925.42 6/15/2004 Salary 268755 Craddick, Tom Craddick, Christi L. $ 6,925.42 7/15/2004 Salary 268755 Craddick, Tom Craddick, Christi L. $ 6,925.42 8/15/2004 Salary 268755 Craddick, Tom Craddick, Christi L. $ 7,055.62 9/15/2004 Salary 268755 Craddick, Tom Craddick, Christi L. $ 7,545.42 10/15/2004 Salary 268755 Craddick, Tom Craddick, Christi L. $ 7,545.42 11/15/2004 Salary 268755 Craddick, Tom Craddick, Christi L. $ 14,220.00 12/15/2004 Salary 284180 Craddick, Tom Craddick, Christi L. $ 8,221.79 1/15/2005 Salary

284180 Craddick, Tom Craddick, Christi L. $ 8,221.79 2/15/2005 Salary

284180 Craddick, Tom Craddick, Christi L. $ 8,221.79 3/15/2005 Salary

284180 Craddick, Tom Craddick, Christi L. $ 8,221.79 4/15/2005 Salary

284180 Craddick, Tom Craddick, Christi L. $ 8,221.79 5/15/2005 Salary 284180 Craddick, Tom Craddick, Christi L. $ 8,221.79 6/15/2005 Salary 298534 Craddick, Tom Craddick, Christi L. $ 8,221.79 7/15/2005 Salary 298534 Craddick, Tom Craddick, Christi L. $ 8,593.79 8/15/2005 Salary

Report Filer's Name Payee's Name Amount Date Description # 298534 Craddick, Tom Craddick, Christi L. $ 8,965.79 9/15/2005 Salary 298534 Craddick, Tom Craddick, Christi L. $ 8,965.79 10/15/2005 Salary 298534 Craddick, Tom Craddick, Christi L. $ 8,965.79 11/15/2005 Salary 298534 Craddick, Tom Craddick, Christi L. $ 15,553.92 12/15/2005 Salary 315324 Craddick, Tom Craddick, Christi L. $ 8,237.54 1/13/2006 Salary 315324 Craddick, Tom Craddick, Christi L. $ 8,237.54 2/15/2006 Salary 315324 Craddick, Tom Craddick, Christi L. $ 8,237.54 3/15/2006 Salary 315324 Craddick, Tom Craddick, Christi L. $ 8,237.54 4/14/2006 Salary 315324 Craddick, Tom Craddick, Christi L. $ 8,237.54 5/15/2006 Salary 315324 Craddick, Tom Craddick, Christi L. $ 8,237.54 6/15/2006 Salary

332040 Craddick, Tom Craddick, Christi L. $ 8,237.54 7/15/2006 Salary

332040 Craddick, Tom Craddick, Christi L. $ 8,349.14 8/15/2006 Salary

332040 Craddick, Tom Craddick, Christi L. $ 8,981.54 9/15/2006 Salary

332040 Craddick, Tom Craddick, Christi L. $ 8,981.54 10/12/2006 Salary

332040 Craddick, Tom Craddick, Christi L. $ 8,981.54 11/15/2006 Salary

332040 Craddick, Tom Craddick, Christi L. $ 15,589.25 12/15/2006 Salary

346708 Craddick, Tom Craddick, Christi L. $ 10,117.10 1/15/2007 Salary

346708 Craddick, Tom Craddick, Christi L. $ 10,117.10 2/15/2007 Salary

346708 Craddick, Tom Craddick, Christi L. $ 10,117.10 3/13/2007 Salary

346708 Craddick, Tom Craddick, Christi L. $ 10,117.10 4/12/2007 Salary

346708 Craddick, Tom Craddick, Christi L. $ 10,117.10 5/11/2007 Salary

346708 Craddick, Tom Craddick, Christi L. $ 10,117.10 6/14/2007 Salary Payment Of Staff

346708 Craddick, Tom Craddick, Christi L. $ 534.71 6/30/2007 Reimbursement Loan

360487 Craddick, Tom Craddick, Christi L. $ 10,582.10 7/12/2007 Salary

360487 Craddick, Tom Craddick, Christi L. $ 11,047.10 8/15/2007 Salary

360487 Craddick, Tom Craddick, Christi L. $ 11,047.10 9/14/2007 Salary

360487 Craddick, Tom Craddick, Christi L. $ 11,047.10 10/15/2007 Salary

360487 Craddick, Tom Craddick, Christi L. $ 11,047.10 11/15/2007 Salary

360487 Craddick, Tom Craddick, Christi L. $ 17,602.10 12/14/2007 Salary 380211 Craddick, Tom Craddick, Christi L. $ 10,143.56 1/15/2008 Salary 380211 Craddick, Tom Craddick, Christi L. $ 10,143.56 2/15/2008 Salary

Report Filer's Name Payee's Name Amount Date Description # 380211 Craddick, Tom Craddick, Christi L. $ 10,143.56 3/14/2008 Salary 380211 Craddick, Tom Craddick, Christi L. $ 10,440.31 4/15/2008 Salary 380211 Craddick, Tom Craddick, Christi L. $ 11,033.81 5/15/2008 Salary 380211 Craddick, Tom Craddick, Christi L. $ 11,033.81 6/16/2008 Salary 386901 Craddick, Tom Craddick, Christi L. $ 11,529.81 7/15/2008 Salary 386901 Craddick, Tom Craddick, Christi L. $ 12,056.81 8/15/2008 Salary 386901 Craddick, Tom Craddick, Christi L. $ 12,056.81 9/15/2008 Salary 389719 Craddick, Tom Craddick, Christi L. $ 12,056.81 10/15/2008 Salary 400576 Craddick, Tom Craddick, Christi L. $ 12,056.81 11/14/2008 Salary 400576 Craddick, Tom Craddick, Christi L. $ 18,611.81 12/15/2008 Salary 420530 Craddick, Tom Craddick, Christi L. $ 11,087.25 1/15/2009 Salary 420530 Craddick, Tom Craddick, Christi L. $ 11,087.25 2/15/2009 Salary 420530 Craddick, Tom Craddick, Christi L. $ 11,087.24 3/13/2009 Salary 420530 Craddick, Tom Craddick, Christi L. $ 11,087.24 4/15/2009 Salary 420530 Craddick, Tom Craddick, Christi L. $ 11,087.24 5/15/2009 Salary 420530 Craddick, Tom Craddick, Christi L. $ 11,087.24 6/15/2009 Salary 438508 Craddick, Tom Craddick, Christi L. $ 11,626.64 7/15/2009 Salary 438508 Craddick, Tom Craddick, Christi L. $ 12,110.24 8/14/2009 Salary 438508 Craddick, Tom Craddick, Christi L. $ 12,110.24 9/15/2009 Salary 438508 Craddick, Tom Craddick, Christi L. $ 12,110.24 10/15/2009 Salary 438508 Craddick, Tom Craddick, Christi L. $ 12,110.24 11/13/2009 Salary 438508 Craddick, Tom Craddick, Christi L. $ 18,665.24 12/15/2009 Salary 457330 Craddick, Tom Craddick, Christi L. $ 11,089.40 1/15/2010 Salary 457330 Craddick, Tom Craddick, Christi L. $ 11,089.40 2/15/2010 Salary 457330 Craddick, Tom Craddick, Christi L. $ 11,089.40 3/15/2010 Salary 457330 Craddick, Tom Craddick, Christi L. $ 11,089.40 4/15/2010 Salary 457330 Craddick, Tom Craddick, Christi L. $ 11,089.40 5/15/2010 Salary 457330 Craddick, Tom Craddick, Christi L. $ 11,089.40 6/15/2010 Salary Manage Campaign And 477789 Craddick, Tom Craddick, Christi L. $ 11,628.80 7/15/2010 Office Holder Duties Manage Campaign And 477789 Craddick, Tom Craddick, Christi L. $ 12,112.40 8/16/2010 Office Holder Duties 477789 Craddick, Tom Craddick, Christi L. $ 12,112.40 9/15/2010 Manage Campaign And

Report Filer's Name Payee's Name Amount Date Description # Office Holder Duties Manage Campaign And 477789 Craddick, Tom Craddick, Christi L. $ 12,112.40 10/15/2010 Office Holder Duties Manage Campaign And 477789 Craddick, Tom Craddick, Christi L. $ 12,112.40 11/15/2010 Office Holder Duties Manage Campaign And 477789 Craddick, Tom Craddick, Christi L. $ 18,667.40 12/15/2010 Office Holder Duties Manage Campaign And

498201 Craddick, Tom Craddick, Christi L. $ 7,215.92 1/14/2011 Office Holder Duties Manage Campaign And

498201 Craddick, Tom Craddick, Christi L. $ 7,215.92 2/13/2011 Office Holder Duties Manage Campaign And

498201 Craddick, Tom Craddick, Christi L. $ 7,215.92 3/15/2011 Office Holder Duties Manage Campaign And

498201 Craddick, Tom Craddick, Christi L. $ 7,215.92 4/15/2011 Office Holder Duties Manage Campaign And

498201 Craddick, Tom Craddick, Christi L. $ 7,215.92 5/15/2011 Office Holder Duties Manage Campaign And

498201 Craddick, Tom Craddick, Christi L. $ 3,834.17 6/15/2011 Office Holder Duties Total $1,015,515.97

According to Texas Ethics Commission records, Christi Craddick’s father and mother provided $616,061.45 in direct and in-kind contributions to her campaign between July 2011 and July 2012:

Contributor's Contribution Report # Filer's Name Date Description Name Amount

515604 Craddick, Christi L. Craddick, Tom $ 500.00 7/06/2011 Tfrw Convention Ad

515604 Craddick, Christi L. Craddick, Tom $ 1,000.00 7/22/2011 Tfrw Convention Ad Computer Equipment,

515604 Craddick, Christi L. Craddick, Tom $ 2,500.00 8/11/2011 Software, And Data Craddick, Tom

515604 Craddick, Christi L. $ 10,000.00 9/28/2011 And Nadine

515604 Craddick, Christi L. Craddick, Tom $ 1,325.48 11/15/2011 Air Travel To Dallas Event

515604 Craddick, Christi L. Craddick, Tom $ 1,325.48 11/16/2011 Air Travel To Houston Event Air Travel To Weatherford

526689 Craddick, Christi L. Craddick, Tom $ 540.00 1/13/2012 Event

526689 Craddick, Christi L. Craddick, Tom $ 520.00 1/19/2012 Air Travel To Houston Event

Contributor's Contribution Report # Filer's Name Date Description Name Amount

526689 Craddick, Christi L. Craddick, Tom $ 2,400.00 1/20/2012 Texas Insider Advertisement

526689 Craddick, Christi L. Craddick, Tom $ 4,401.52 2/07/2012 Air Travel To Lubbock Event Air Travel To Fort Bend

526689 Craddick, Christi L. Craddick, Tom $ 495.00 2/11/2012 County Event Air Travel To Fort Worth

526689 Craddick, Christi L. Craddick, Tom $ 535.00 2/25/2012 Event Air Travel To Corpus Christi

526689 Craddick, Christi L. Craddick, Tom $ 595.00 3/03/2012 Event

526689 Craddick, Christi L. Craddick, Tom $ 2,400.00 3/16/2012 Texas Insider Advertisement

534288 Craddick, Christi L. Craddick, Tom $ 300,000.00 5/11/2012

534288 Craddick, Christi L. Craddick, Tom $ 58.83 5/16/2012 Fedex Shipment

538212 Craddick, Christi L. Craddick, Tom $ 2,400.00 6/06/2012 Texas Insider Advertisement

538212 Craddick, Christi L. Craddick, Tom $ 65.14 6/14/2012 Fedex Shipment Craddick, Tom

538212 Craddick, Christi L. $ 10,000.00 6/14/2012 And Nadine

546109 Craddick, Christi L. Craddick, Tom $ 160,000.00 7/24/2012

546109 Craddick, Christi L. Craddick, Tom $ 115,000.00 7/31/2012 Total $616,061.45 (Source: Texas Ethics Commission)

ENTER REP. PHIL KING AND DFW CONSERVATIVE VOTERS PAC

On July 10, 2012, between the Republican Primary and the Republican Primary runoff, Rep. Phil King’s Campaign made a $25,000 contribution to the Dallas/Fort Worth Conservative Voters Political Action Committee (PAC), Filer ID 00050436. (October 9, 2012, 30 Days Before Election Report, http://204.65.203.5/public/546377.pdf )

(Source: Texas Ethics Commission, http://204.65.203.5/public/546377.pdf)

Rep. Phil King has been a staunch supporter of Rep. Craddick, both in helping to secure votes for his speakership and since Craddick was forced out as speaker. Craddick, in turn, has helped King hold onto his seat, donating $10,000 to him in 2008 when opponents attacked King for his ties to utility companies:

In rural Weatherford, Republican Rep. Phil King has been under fire for his close ties to utility companies as electric bills continue to increase. He fended off a challenge from former Mayor Joe Tison with the help of a $25,000 from Perry and $10,000 from a Craddick-supported political action committee. [emphasis added] (Source: Craddick supporters withstand primaries, The Eagle, February 18, 2009, http://www.theeagle.com/news/local/article_7b7f2aaa-7893-58fb-b143- 0eb83345b915.html?mode=jqm)

On July 18, 2012, the Dallas/Fort Worth Conservative Voters PAC paid a total of $25,243.48 for printing and mailing expense according to their amended report. (July 23, 2012, Corrected Runoff Report, http://204.65.203.5/public/540454.pdf)

On July 22, 2012, the Dallas/Fort Worth Conservative Voters PAC filed their runoff report #539593. The report lists only one itemized donation from Phil King in the amount of $25,000.00 along with another donation of $5.00 and $3,180.00 maintained from the last reporting period. The report for the General PAC does not list any candidates they support or oppose and does not list any officeholders they assisted. (July 23, 2012, Runoff Report, http://204.65.203.5/public/539593.pdf)

(Source: Texas Ethics Commission, http://204.65.203.5/public/539593.pdf)

On July 31, 2012, the Dallas/Fort Worth Conservative Voters PAC filed a corrected runoff report # 540454 which did not change any contribution or expenditure information, but added the names of endorsed candidates Christi Craddick, Barry Smitherman, David Medina, and Stephanie Klick along with three county constable candidates. (July 23, 2012, Corrected Runoff Report, http://204.65.203.5/public/540454.pdf)

(Source: Texas Ethics Commission, http://204.65.203.5/public/540454.pdf)

On October 9, 2012, King filed report # 546377 which itemizes the $25,000.00 expenditure to Dallas/Fort Worth Conservative Voters PAC. King’s report indicates the donation is for campaign support. (October 9, 2012, 30 Days Before Election Report, http://204.65.203.5/public/546377.pdf )

King’s description of this expenditure as “campaign support” is curious because the PAC’s website at http://www.dfwconservativevoters.net/ states on their homepage:

“DFW Conservative Voters offers recommendations of the most conservative candidates on the ballot in the Republican primary in Tarrant County, Texas.

The primary system can be confusing, because none of the candidates on the ballot has a party label next to his name; they’re all supposed to be Republicans. Voters who haven’t decided on a race have no clues to a candidate’s political philosophy from the ballot itself. To make matters more challenging, liberals and Democrats often run as Republicans in the Tarrant County Republican primary, regardless of their real political philosophy.

We list our recommendations for each race on a small green postcard. The small cards are simple, listing the races in the order they appear on the ballot. They are easy to read, and it’s legal to carry them into the voting booth. To comply with Texas election laws, we formed DFW Conservative Voters PAC (political action committee) so that we could spend money to print and distribute the cards.

We mail to Republican primary voters. The quantity depends on the funds available. We’ve also started this website to make our choices more easily available and to verify our choices when counterfeit cards are distributed (yes, it has happened!) We do permit duplication of our cards, provided that NO CHANGES are made….”

In addition to being a Tarrant County PAC who is not in a position to provide campaign support to King, a Parker/Wise County legislator, the Dallas/Fort Worth Conservative Voters PAC (Filer ID 00050436) report #529486 filed immediately before the Republican primary does not list King among candidates they supported or assisted. King was not on the ballot during the runoff. (May 21st, 2012, Eight Day Before Election Report, http://204.65.203.5/public/529486.pdf)

It wasn’t until his January 15, 2013 report with the Texas Ethics Commission that Tom Craddick, Filer ID 0002005, reported a $25,000.00 political contribution to Phil King’s Campaign, Filer ID 00036483. However, Craddick reported that the “political donation” to the unopposed King was made on November 26, 2012. (Tom Craddick January Semiannual Report #560607 filed on January 15, 2013, http://204.65.203.5/public/560607.pdf)

On January 15, 2013, Phil King filed his January Semiannual report # 560408 covering periods from October 28, 2012 through December 31, 2012. King failed to report the $25,000.00 donated by Tom Craddick on November 26, 2012 and has failed to report the contribution ever since. (January 15, 2013, Semiannual Report, http://204.65.203.5/public/549363.pdf)

These $25,000.00 transactions are atypical of King’s reports. On King’s reports covering donations and expenditures on or after January 1, 2011, the largest donation not itemized above is $10,000.00 and the largest expenditure is a series of five “campaign support” donations totaling $10,000.00 made by King on March 16, 2012. The March 16, 2012 donations were for $2,000.00 each to the campaigns of Wayne Christian, Bryan Hughes, Jim Landtroop, Bill Zedler, and Dan Flynn. (July 16th, 2012, July Semiannual Election Report. http://204.65.203.5/public/538587.pdf)

CONCLUSION

This pattern of conduct makes clear that Railroad Commissioner Christi Craddick, Rep. Tom Craddick, and Rep. Phil King violated multiple sections of the Texas Elections Code in concealing a $25,000 donation to the DFW Conservative Voters PAC to assist Commissioner Craddick in the July 31, 2012 Republican Primary Runoff Election. The parties should face appropriate penalties and sanctions for their violations of Texas Election law.

V. LISTING OF DOCUMENTS AND OTHER MATERIALS Texas Ethics Commission report number 560408 (Jan. 15, 2013); and Texas Ethics Commission report number 560607 (Jan. 15, 2013).

251.001(2) "Contribution" means a direct or indirect transfer of money, goods, services, or any other thing of value and includes an agreement made or other obligation incurred, whether legally enforceable or not, to make a transfer. The term includes a loan or extension of credit, other than those expressly excluded by this subdivision, and a guarantee of a loan or extension of credit, including a loan described by this subdivision. The term does not include: (A) a loan made in the due course of business by a corporation that is legally engaged in the business of lending money and that has conducted the business continuously for more than one year before the loan is made; or (B) an expenditure required to be reported under Section 305.006(b), Government Code.

Sec. 254.031. GENERAL CONTENTS OF REPORTS. (a) Except as otherwise provided by this chapter, each report filed under this chapter must include: (1) the amount of political contributions from each person that in the aggregate exceed $50 and that are accepted during the reporting period by the person or committee required to file a report under this chapter, the full name and address of the person making the contributions, and the dates of the contributions; (2) the amount of loans that are made during the reporting period to the legislative caucus and that in the aggregate exceed $50, the dates the loans are made, the interest rate, the maturity date, the type of collateral for the loans, if any, the full name and address of the person or financial institution making the loans, the full name and address, principal occupation, and name of the employer of each guarantor of the loans, the amount of the loans guaranteed by each guarantor, and the aggregate principal amount of all outstanding loans as of the last day of the reporting period;

(7) the name of each candidate or officeholder who benefits from a direct campaign expenditure made during the reporting period by the person or committee required to file the report, and the office sought or held, excluding a direct campaign expenditure that is made by the principal political committee of a political party on behalf of a slate of two or more nominees of that party;

Sec. 254.041. CRIMINAL PENALTY FOR UNTIMELY OR INCOMPLETE REPORT. (a) A person who is required by this chapter to file a report commits an offense if the person knowingly fails: (1) to file the report on time; (2) to file a report by computer diskette, modem, or other means of electronic transfer, if the person is required to file reports that comply with Section 254.036(b); or (3) to include in the report information that is required by this title to be included.

(b) Except as provided by Subsection (c), an offense under this section is a Class C misdemeanor. (c) A violation of Subsection (a)(3) by a candidate or officeholder is a Class A misdemeanor if the report fails to include information required by Section 254.061(3) or Section 254.091(2), as applicable. (d) It is an exception to the application of Subsection (a)(3) that: (1) the information was required to be included in a semiannual report; and (2) the person amended the report within the time prescribed by Section 254.0405(b) or under the circumstances described by Section 254.0405(c).

Sec. 253.001. CONTRIBUTION OR EXPENDITURE IN ANOTHER'S NAME PROHIBITED. (a) A person may not knowingly make or authorize a political contribution in the name of or on behalf of another unless the person discloses in writing to the recipient the name and address of the person actually making the contribution in order for the recipient to make the proper disclosure. (b) A person may not knowingly make or authorize a political expenditure in the name of or on behalf of another unless the person discloses in writing to the person on whose behalf the expenditure is made the name and address of the person actually making the expenditure in order for the person on whose behalf the expenditure is made to make the proper disclosure. (c) A person who violates this section commits an offense. An offense under this section is a Class A misdemeanor.

Sec. 253.004. UNLAWFULLY MAKING EXPENDITURE. (a) A person may not knowingly make or authorize a political expenditure in violation of this chapter. (b) This section does not apply to a political expenditure made or authorized in violation of Subchapter F. (c) A person who violates this section commits an offense. An offense under this section is a Class A misdemeanor.

Sec. 253.041. RESTRICTIONS ON CERTAIN PAYMENTS. (a) A candidate or officeholder or a specific-purpose committee for supporting, opposing, or assisting the candidate or officeholder may not knowingly make or authorize a payment from a political contribution if the payment is made for personal services rendered by the candidate or officeholder or by the spouse or dependent child of the candidate or officeholder to:

(1) a business in which the candidate or officeholder has a participating interest of more than 10 percent, holds a position on the governing body of the business, or serves as an officer of the business; or

(2) the candidate or officeholder or the spouse or dependent child of the candidate or officeholder.