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E SEP ?5 N Natkwal Republican Coagressioaal Commtttee Ton Cote, M.C. Pete Klrkkam E SEP ?5 n <(: 09 Executive. Director September 25.2008 MUR# 7 Thomasenia Duncan, Esquire Oeneral Counsel Federal Election Commission 999 E Street, NW Washington, DC 20463 CO IS) Re: Complaint Against Democratic Freshmen PAC, et al. CD Dear Ms. Duncan: > o Pursuant to 2 U.S.C. § 437g(aXl) and 11 C.F.R. § 111.4, please accept this letter as a Complaint against Democratic Freshmen Political Action CommitteeC'Democratic Freshmen"), Democrats Win Seats Political Action Committee ("DWS PAC"), Victory In November Election Political Action Committee ("VINE PACn), Representative Debbie Wasserman Schultz and Representative Mike Thompson. Democratic Freshman, DWS PAC, and VINE PAC are operating in violation of the Federal Election Campaign Act of 1971, as amended (the "Act"), and Federal Election Commission C'FEC" or "Commission") regulations by failing to register and report with the Commission as affiliated political committees, accepting excessive contributions and making excessive contributions to candidates. Wasserman Schultz and Thompson are in essence running three P ACs. They both have leaderahipPACs and are now honorary co-<±aimen of 1^ As evidenced by the pattern of contributions and expenditures of the three committees, Wasserman Schultz and Thompson are doing nothing more than circumventing the contribution limits in their effort to curry favor and support from their Democrat colleagues. According to its website, www.democraticfreshmen.orff. Democratic Freshmen was established in 2006 to raise money for the re-election of freshmen Democratic Representatives in 2008. 320 Pint Street, S.E. Waihiaifoii, D.C 20003 (202)479-7000 Paid for by the National Republican Congressional Committee and not Authorized by any Candidate or Candidate1! Committee. www.nrcc.orf Not Printed at Government Expense. According to an article in Roll Call, the PAC held its first fundraiser in January 2007. The Democratic Freshmen website lists the honorary co-chairs of the PAC as Thompson and Wasserman SchuHz. Additionally, Thompson has been quoted by The Washington Times as tiic co-chairman of Democratic Freshmen.1 In addition to his principal campaign committee, Thompson established VINE PAC in 2002 which allows him to make contributions to federal candidates. See Exhibit B. Similarly, Wasserman Schultz established DWS PAC in 2006 in order to make contributions to federal candidates. Sec Exhibit C. Contributions from Democratic Freshmen, DWS PAC and VINE PAC all but mirror one another. Twenty nine candidates received contributions from Democratic Freshmen and twenty eight of those candidates also received contributions from DWS PAC. Similarly, twenty four candidates that received contributions from Democratic Freshmen received contributions from VINE PAC. Importantly, several of these contributions when aggregated, exceed the contribution limits. For example, DWS PAC contributed $7,500 to Tun Mahoney for Florida and Democratic Freshmen contributed an additional $3,000 for a total of $10,500. Similarly, VINE PAC contributed $10,000 to McNerney for Congress and Democratic Freshmen contributed an additional $3,000 for a total of $13,000. See Exhibit D. Furthermore, the same contributors are donating to all three PACS. Democratic Freshmen and DWS PAC have thirteen contributors in common. Similariy, Democratic Freshmen and VINE PAC have ten common contributors. Of those contributors, there are at least two instances where contributions were made to Democratic Freshmen and VINE PAC on the same date. See Exhibit E. Commission regulations state that "all committees...established, financed, maintained or controlled by the same.. .person, or group of persons.. .are affiliated." 11 C.F.R. § 100.5(gX2)- The Act states that "all contributions made by political committees established or financed or maintained or controlled by any...person, or by any group of...persons, shall be considered to have been made by a single political committee." 2 U.S.C. f 441a(aX5). Commission regulations also state that "all contributions made or received by more than one affiliated committee, regardless of whether they are political committees under 11 § C.F.R. 100.5, shall be considered made or received by one political committee." 11 §C.F.R. 110.3, Furthermore, the Act explicitly forbids any person from making contributions ".. .to any other political committee...in any calendar year which, hi aggregate, exceed $5,000." 2 U.S.C. § 441(aXlXA). Wasserman Schultz and Thompson circumvent the contribution limits of the Act and Commission regulations and raise more money for then1 colleagues than they could individually with their own leadership PACs by using Democratic Freshmen as nothing more than a vehicle for excessive contributions. 1A copy of Democratic Freshmen's me* i»cem ITC Fonn 1, copies of to website, the ajtictefa^ the artkkfhmi 7^ IFarA^gf^TYiiitf ire attached to thb Com Exhibit A. Accordingly, we respectfully request that the Commission conduct an immediate investigate into the violations outlined above and impose the propqtmim penalty under law. The foregoing is correct and accurate to the best of my knowledge, information and belief. Respectfully submitted, Elizabeth N. Beacham Sworn to and subscribed before me this 2*U\Jay of September, 2008. ,2QQD Notary Public •*••.!• My Commission Expires: 01flOO00717:« STATEMENT OF FORM1 ORGANIZATION i. I I I I I I I I I I I I I I I I I I I I I I I 00 I I I i I I I I I I I en rsi i i i i I I I I I rsi I . - .. O eoyMTTEBBBMML 0) I.... lii.i.ii ii i i i i i . i i GOMHTTEB6 WEB RftOE i HBHV i i i i i i i i I l l l i i i i i i i i i i ,TT.. i i • • i*n fll BO ZDOT C CBftttMHf 4. iaT»a*rATBUMT x Hi MUM HMhy itth AMTQWMEIN HFORIiOTIOH(MOULPBB lOmTIIDMIITHM IB DJW Oriy Exhibit A FMtamf (R«M H I III III t il ii i iii H TN» dlv MOT i NHMflT I I I I III III II II I I I I (9 (or term Tito 9BMNBW hft bid 0) * Tito ltnd<rp«ty II I I I I II I I I I I I j I I CIIT1 A III III in I ion RINm —r:r r^ ~T— i i i i i i i j i 1100 00 rsi in—B_«__- OTYJ ttTATEA VCOKJL rsi IpNHW MllllD0f •• OpHoniQ flff VW VHflUMTflff •VODRVnHBBf MM uM VA CffVA iTATEA n»«rFo«aiiv OTTA ITATBA I III I i I III I J I M1H7K • i i i i i LL i i i i i 1 001 III II I I 9° i ? -I • rsi CITY* MATE* O CD Democratic Frafamen Page 1 of1 fM i .. •«• About DFPI Democratic Freshmen Page 1 ofI Ita OffM Ml O Nl rsi VWhywri W MMl OOnMlW IB MM «Bf VH IvH BHHnHI ifcrew HriL nd dMHrirtDnvfii Whr ki B"hiilP —--' lolta. MtaMM -^— MM VIM VM n^^ MIM I^M IV MHMHRi WBIMN yDV MV MM MPV WB MR CHra OH )^U lOdi Join our Tta Homray Ce-Ctata of MM DtMocwUc PiMNiMn PAC mm llM^ IMM) TnOmplBn (CArl) f •• 111 II. I jr. f A MA MAMA Page 1 of1 22 of 570 DOCUMENTS Roll Call January 23, 2007 Tuesday Nation; House Democratic Frosh Hosting PAC Fundraiser *T O nCVZOH: AT THE RACES 1*1 (N UEMQn: 264 words <T ™ The 41 freahnan Democrats ia the House have formed a new political action *T committee, and the PAC is scheduled to have its first fundraiser Wednesday evening. O The Demoexetio Vfceehmen PAC is hosting its inaugural reception at Charlie Palmer 0* Steak on Capitol Hill. Tickets cost 85,000 to become a member of the new PAC's fM steering committee. PACs are being asked to pony up $2,500, and an individual ticket costs $1,000. In a related development, new Democratic Congressional Campaign Committee Chairman Chris Van Hollen (Md.) announced Monday that he has tappsd Rep. Debbie Nassarman Schultz (Fla.) to head the DCCC's Frontline program, which works to protect potentially vulnerable Members. The DCCC is giving its Frontline mecbers specific fundraising goals for the early part of the election cycle, ranging from $650,000 to $1 million for the amount of money they should have banked by June 30. Frontline members also are being told that they must put together aggressive outreach and volunteer programs as well as a vigorous fundraising schedule. Van Hollen said he has asked veteran Democratic Members in tough districts, such as Raps. Jim Matheson (Utah) and Dennis Moore (Kan.), to serve as mentors to the Frontliners. In a memo, Van Holien said some potentially vulnerable Democratic freshmen, such as Reps. Kirsten Gillibrand (N.Y.), Harry Mitchell (Ariz.), Patrick Murphy (Pa.) and Heath Shuler (N.C.), already are battle-tested, "and head into 2008 with a more solid grasp of the political landscape of their districts and a strong understanding of what it takes to win." - Josh Kurtz LOAD-BAB: January 24, 2007 TAMBHAQK.I ENGLISH PUBLICATION-TYPE! Newspaper Copyright 2007 Roll Call, Inc. Page 1 of3 1 of 570 DOCUMENTS The Washington Times May 31, 2007 Thursday Correction Appended Freshman Democrats work with 'rainmaker1 HUME: By Eric Pfeiffer, THE WASHINGTON TIMES OCCTZOST: PAGE ONE; A01 11 1038 words The class of 41 freshman House Democrats has selected a registered lobbyist to form its political action committee, in what ethics watchdogs and Republicans are calling a contradiction of their promise to end a "culture of corruption* in Washington. The custodian of the Democratic Freshmen PAC is William C. Oldaker, 65, whose most-recent lobbying clients include the oil industry, the tobacco lobby, pharmaceutical industries and American Indian gambling interests.
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