I:);I ZG11JUL25 PM
Total Page:16
File Type:pdf, Size:1020Kb
I'.:.. :.i .iJ Iraj J. Zand Raymond Sehayek FL!;!!:;!/--. r:.!-;;r;OM cc;:.::sL;;i:);i ZG11JUL25 PM Federal Election Commission 0 F TIC ^ " ^ ?• T",! R A L Oflice of General Counsel C 0 U; i 3 i: L 999 E Street, N.W. Washington, D.C. 20463 Re: MUR 6463 - Second Supplemental Filing of Information Relating to FEC Campaign Finance Violations by Jack Antaramian and Mona Antaramian o Dear Mr. Jordan: 0 Please accept this letter as a second supplemental addition (the "Second Supplemental Complaint") to the packet of infonnation we provided to you dated March 21, 2011 (the "Complaint") as supplemented by the ^ packet of information we provided to you dated June 14, 2011 (the ^^Supplemental Complaint**) regarding IO suspected FEC Campaign Finance Violations by Jack J. Antaramian ("Mr. Antaramian"), Mona Antaramian ^ (**Mrs. Antaramian'*), and others. Although the Complaint and Supplemental Complaint both dealt specifically ^ with circumstances arising in the 2010 election cycle, we would lite to call your attention to certain campaign CD finance violations diat also occurred during the 2008 electi(»i cycle. rsj We have previously provided to you as Exhibit *'B*' to the Complaint, a copy of a report populated by the FEC entitled ''Individual Contributions Arranged by Type, Giver, Then Recipient** for Mr. Antaramian. Additionally, Exhibit ''C" to the Complaint provides the same report for Mrs. Antaramian. As you are aware, ths 2008 biennial limit for contributions by an individual was set at $108,200.00 (the ''Biennial Limit**). Attached as Exhibit "A** to this Second Supplementel Complaint is a copy of a spreadsheet created solely from the contributions listed in Exhibit "B** and Exhibit "C** from the Complaint. This spreadsheet shows that the Biennial Limit was exceeded during the 2008 cycle by both Mr. and Mrs. Antanunian. In &ct, the entire Biennial Limit was met and exceeded during the 2008 calendar year alone. We suspect that the FEC does not have a methodology in place to police all contributors to ensure that excessive contributions violating campaign finance laws are not made. However, we want to call your attention to this matter now, in light of the circumstances surrounding the 2010 election cycle previously reported to you in the Complaint and the Supplemental Complaint. Although the ultimate determination rests with the FEC on whether Mr. and Mrs. Antaramian have acted knowingly and willfiilly in tiying to sidestep campaign finance laws, the totality of the circumstances surrounding the recurring contributions that began, in large part, in October of 2008 and continued in firequency through December 2008, raises suspicion that Mr. and Mrs. Anteramian were acting intentionally with respect to the numerous contributions shown in Exhibit "A". Additimially, we call your attention to an unreported in-kind contribution provided by Mr. Antaramian during this 2008 contribution cycle. On October 08, 2008, Joe Biden visited Naples, Florida and made a stop at the Naples Bay Resort during his tour. See Composite Exhibit "B** atteched. The Naples Bay Resort is owned, in part, by Mr. Antaramian or entities in which Mr. Antaramian holds ownership interest or control. The information surrounding this unreported in-kind contribution raises suspicions that Mr. Antaramian acted knowingly in attempting to conceal the contribution from others. As set forth in a Catering Event Order for BEO # 177, the Obama Victory Fund used the Yacht Gub Main Dining Room fiom 3:00PM - 6:00PM on October 8,2008. A copy ofthe Catering Event Order for BEO #177 is atteched as Exhibit "C*. Additionally, a copy ofthe Club Banquet receipt for BEO #177 toteling $16,711.54 is attached as Exhibit "D**. As shown in Exhibit "D**, Mr. Antanunian paid for BEO #177 through a Member Charge to his Club Account This supplemental information has been provided to you based on facts, infomiation, and belief, and we provide you with the opportunity to investigate the circumstances of tiiese contributions in relation to the information already provided to you, and we hope this infomiation and the attached exhibits prove helpfiil in your review. 0 Raymond Sehayek rH fVi STATE OF FLORIDA ) IO )SS: COUNTY OF COLLIER ) Q SWORN to under oath and subscribed before me this lH.»u. day of T^^.v^ 2011. rsi by Iraj J. Zand. He is personally known to me. BRIAN O-HENOnCKS Notary PuSfiE^ MY COMMBSIQNfDO 904268 SEAL EXPIRES: July 31,2013 Banded ItauNol^rPuUeUndmrtM Printed Name OQ «l«H>-lrV- Commission No. Expiration Date STATE OF FLORIDA ) )SS: COUNTY OF COLLIER ) SWORN to under oath and subscribed before me this -Wvu day of "^^A^ 2011, by Raymond Sehayek. He is personally known to me. BRIAN 0. HENDRICKS Notary^iiBlic MY COMMISSION I DD 004268 SEAL EXPIRES: July 31.2013 Banded TlHU Notaiy PuWc UndenMBen Printed Name Commission No. Expiratioixpiraii n Date DNC Confirms Vice President Biden plans Naples stop for private fund raiser : marconew... Page 1 of 1 JLMarcoEagle PriiMOf fri'i-nd.'y Si'.o'y marconews.com Raad mora at inaroonews.com DNC Confirms Vice President Biden plans Naples stop for private fund raiser By Naples Daily News staff report Originally published 12:15 p.m., January 14,2010 Updated 06:22 p.m., January 14, 2010 Q Vice President Joe Biden will visit South Florida this weekend, including a stop in rM Naples on Sunday for a private fundraiser. (N Biden and his wife Jill Biden plan to meet with members of the Haitian-American ^ community on the state's east coast Saturday regarding U.S. response to the crisis in ^ Haiti after this week's earthquake. The Bidens will meet with responders supporting 0 and mobilizing relief efforts in Haiti. rM A Secret Service contingent already plans to visit Naples this week and Rikki Boparai, general manager for the Naples Bay Resort, said Wednesday night that the Secret Service has blocked off rooms at the resort in the coming days. Boparai could not disclose how many rooms have been reserved, or how long those rooms are reserved for. Naples developer Jack Antaramian. who developed Naples Bay Resort and has hosted fundraisers for President Barack Obama and Biden, could not comment on any upcoming executive branch visits. In an e-mail to bcal Democrats Thursday, Jean A Doherty, Director ofthe Secretary's OfFice ofthe Democratic National Committee said Biden wiil be in Naples Sunday for a private fund raiser. Biden was in Naples in October 2008, just weeks before the 2008 presidential election. During the October 2008 swing, Biden visited the Naples Bay Resort for a fundraiser hosted by Antaramian. ^^•'^^ 6 2011 Scripps Newspaper Group — Online Exhibit "B-1" http://www.marconews.com/news/2010/jan/14/vice-president-joe-biden-naples-florida-visit/... 7/5/2011 BLOG: Biden's visit to SW Florida » Naples Daily News Page 1 of 18 Login I Manage Accouni | Mobile | Contact Us | Customer Seivica | e-Daily site Wbb Search powered by VAHOOI SEARCH News Sports Business Opinion Entertainment Lifestyles Media Jobs Homes Cars Classified Today Local Boniia State NationainVorld Crime Education Weatliar Columnists Community Obituaries ro O CELEBRATING INDEPENDENCE DAY How did .vou celebrate the Fourth of July? » Sec hundreds of photos inside rM rH BLOG: Biden's visit to SW Florida rM By Naples Daily News staff report ro Posted Octotier 8,2008 at 1:15 p.m., updated October 8,2008 at 7:10 p.m. 0 Email Discuss Share » Print AAA rM Democratic VP NOTE FROM STAFF: V\to had technical problems with candidate Joe Biden our live video feed from Alioo Arena and apologize fbr visits SW Florida not having it online at this time. 7:07 p.m. Joe Biden ended his speech at Alice Arena with cheers from the crowd. 6:44 p.m. 10(29 Debut of a new Democratic zinger? "You can't ever call yourself a Most Popular maverick if all you've ever been is a viewed Commented Emailed sidelcick," Biden told the crowd. Casey Anthony not guilty of murdering 2- year-oM daugntar He attributes the line to fellow updated 7/5/2011 at 2:42 p.in. 114 conmnta Democratic senator Bob Casey Jr. of Overdue rent lawsuit may fbrce out popular Pennsylvania. The crowd eats it up. downtown Naples restaurant The Jolly CricKflt PulKished 7/4/2011 at 1 -00 p.m. 39 comments 6:32 p.m. FHP: 106-inph drive down l-TS lands two teens in Jail on drug charges Senator Bill Nelson takes the stage. Published 7/4/2011 at 1:09 p.m 14 c He praises his fellow senators, BMen Layofb pos8ll)ly coming to East Naples Fire and Obama. Nelson also notes that Updated 7/5/2011 at 2:57 pm. 4S( both he and Obama are on Biden's Police beat: Juiy 4.2011 MUG SHOTS iWap Foreign Relations committee in the Senate. Published 7/4/2011 at 11 -39 a.ni. 01 Alice Arena Nelson introduces BMen and someone who's coming on 10501 FGCU Blvd. South, Fort Myers, FL to stage with-Nancy Sauer, a local citizen. The crowd roars as the two come on stage. Exhibit "B-2" Page I of 18 http://www.naplesnews.com/news/2008/oct/08/live-biog-bidens-visit-sw-florida/ 7/5/2011 BLOG: Biden's visit to SW Florida » Naples Daily News Page2on8 kfl|boiMBer« Photo Galleries pension, and a home thaft idBlw^u{^Un^tSiaaft The past eight years, she said#ave notfleen a good one. This is a common line In jie Oba^-BMen campaign, that a McCain adl^ireffatioi id be similar to a Bush It administration. Naples Fourth Naples Fourth Your Pholow of July of July parade Naples Fourth Firework..