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Delaware County Republican Finance Committee ; 323 West Front Street Delaware County Republican Finance Committee ; 323 West Front Street. Media, Pennsylvania 19063 El;;ii .. '.L LLGICTION vOrtMISSION • 610-566-9375 onmuA.. Fax:610.566-9377 20J0NOV22 P ^3 AiidicwJ.Rdlly CtartI J. Milter Chairman nr-f^^ ^ VfcvChn'r November 15,2010 Office of General Counsel Federal Election Conmiission 999 £ street, N.W. U33 Wasfaington, D.C. 20463 MUR# rvj Ot 1^ To tfae Office of General Counsel: 0 tH I am writing to formally request tfaat tfae Federal Elections Commission open an investigation into potential illegal campaign coordination and unreported campaign ^ contributioiis related to tfae campaigns of Democrat Bryan R. Lentz, operating under tfae 0 committee name of Lentz for Congress, and American Congress Party candidate James Schneller, operating imder tfae Jim Scfaneller for Congress Campaign Committee. Botfa HI candidates are running for Congress in Pennsylvania's 7^ Congressional District against Republican Patrick Meehan. In public comments on Octobdr 19, Demooatip candidate Bryan Lentz stated tfaat fais campaign workers and volunteers knowingly and intentionally provided assistance to tfae campaign of Jim Scfaneller for puiposes of furtfaering Lentz* own campaign for Congress.' Specifically, individuals associated witfa tfae Lentz campaign - including a number of prominent Democralic Party officials, as well as Lentz cunpaign volunteers, cireulated nominating papeis on behalf of Schnelter's tfaird party candidacy. Wheni Lentz was asked about his tfaought process in helping Schneller to get on tfae ballot, he specifically stated: "I did not think it was a bad thing for tfae process of my candidacy" wfaile acknowledging fae wanted to have someone nmning to Meehan's "rigfat" on tfae ballot Had it not been for tfae assistance of tfaose Democratic Party officials and Lentz supporters - who collected 4,814 signatures - Schneller - wfao collected rougihly 3,200 sigiutuin)^ rr would haiye fallen f^s short.pf tfae 4,200 statutorily required signatures to be placed on the ballot in tfae general election. ''Lentz' conmients occurred in an editorial IxMrd meef^ with l^«jbelwirare Coimty Daily Times, the • video of whidi can be viewed ak tiie riewspq)er*s wiebsite sA htln://dti5amMiml0.blopiiot.com/2010/10/lentz<dmitg-tD-a«igting-^^ Lentz' commenia were also widely reported by the Philadelphia Inquirer. Politico. Hie Hill newspqper. the Associated Press, and otiwrmedia outlets. These individuals include Colleen Guiney, the Chair of tfae Swartfamore Democratic Party^, wfao Lentz called "tfae hardest worker on my campaign"^; Abu Rahman, an official with the Delaware County Democratic Party and President of the Delaware County Asian American Democratic Association^; Matt Silva, District Leader of tfae Upper Darby Democratic Committee.^ Five Scfaneller petition circulatora also circulated nominating papers on befaalf of Bryan Lentz to be placed on the primary ballot. These petition circulators include tfae aforementioned Colleen Guiney and Matt Silva, as well as Richard Cairns, wfao according to press reports is Loitz' neighbor and served as a petitioner in a civil action on befaalf of tfae Lentz campaign to faave Lentz' opponentsJDemocrats Teresa Touey and Gail Conner removed fipom tfae Democrat primary ballot; Josepfa Gallaglier, a Delaware ^ County Democratic Party Conmiitteeman in Aston Town^p; and David Merle Lewis, Q anotfaer Delaware Connty Demociatic Party Committeeman in Aston Township. Otfaer circulators of Scfaneller's petition papers who are active in both tfae local ^ Democratic Party and/or work on the Lentz campaign include: Julie Klein an active ^ Lentz fimdraiser on Act Blue who was also photograpfaed at tfae opening of Bryan Lentz' ^ campaign office; AitfaurManos, a DeUware County Democratic Party Comiiiitteeman in rH Folcroft and a labor organizer witfa tfae United Food and Commercial Workera union; Timotfay WUlard, a fonner Pennsylvania House Democratic Campaign Conimittee eniployee wfao served as a volunteer coordinator on Lentz' 2006 campaign for state le^slature; Caroline Piefaer, tfae daugihterofHelenPicfaer, a Democrat Committeewoman from Nether Providence; Nicfaolas Alfasd, a Lentz intem sod tfae bttemet Director for tfae Swartiimore College Democrats^ and Rocco Polidoro, a former Democratic Party candidate for Delaware County Council and Iientz suppoiter wfao lias admitted to faosting a "notaiy party" in bis insurance office for individuais who circulated Scfaneller's petitions. According to a deposition by Kristen Kepics, a notaiy who notarized a number of petition papers at tfae "notaiy party," faer services were procured by Colleen G., ^o Polidoro later confirmed was Colleen Guiney. Guiney, again, was called tfae "faardest worker on my campaign" by Lentz. Kepics also stated in her deposition that she was paid $100 casfa in an envelope for her notaiy services that day. However, ui Scfaneller's deposition fae stated tfaat he did not pay the notaiy far faer services nor did fae ever receive a receipt Most certainly, SGhneller's campaign http://www.gwarthmoredemocratg.orB/Datteg/about.httnl |littp:/Avwwdaiartimeg«im/artidaB/20!0/D4m http://www.delcodems.eom/aboutus.htai#Paitv%200flicials ^ htip://www.upDe«larbvdems.comfleadera.hbn *http://www.gwarthmorephoenix.com/2010/D9/16/hew8/lentzs><ampaipn-uses-controveraM^ ^ Oral deposition of Kristen Kepics. notaiy public, on Aagust 23,2010. ' In tiie interest of full disolasure, I should note fliat there was one lone mdividual, aside from Schneller himsa% wbo cireulalndi petitions nn Schnellcr's befaalf who had no clear ties to die Lentz canipaign or the Demaeratic Party. Tint mdividual. David Ahamare, collected 13 signatures. benefitted fiom tfae notaiy's services tfaat day as it was a requirement to be placed on tfae ballot. Lentz, by fais own admission, has also benefitted from Schneller being placed on the ballot. Yet neither Schneller nor Lentz report the $100 payment to the notary as an in-kind contribution or as a disbnrsement from their campaign. Furtfaermore, given tfae extent of tfae Democratic Party officials and tfae Lentz campaign's involvement in and coordination of tfae petition process for Scfaneller, I am concemed tfaat botfa tfae party and tfae Lentz campaign have made in-kind contributions to Schneller in excess of tfae repoiting reqmrements. ^ Lentz is fond of pointing out fhat his efforts to place a tfaird party candidate to fiirtfaer fais own political career, although perfai^s unetfaical are not illegal. However, it is illegal to un fail to report in-kind contributions in excess of tfae required reporting tfaresfaolds in an 0 atteinpt cmiced coordiiiBtion and evade open records requirements. I believe botfa tfae Lentz and Scfaneller campaigns fiuled to meet tfaese requirements and would like tfae FEC ^ to open a fomiAl inveatigation into tfae matter. Q Sincerely, Andrew J. Reilly Chairman, Delaware County Republican Party Subscribed and swom to before me on tfais (5"^ day of ^"^Y-Cu^jy^^ju^ . 2010. NOTARY MAieto.|laiSiyMlD B5SK^f555^^SSI^•5BBS•fi5BSKl .
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