Michael J. Dl'eikorn Case No.: FEC 14-138

STAIE OF FLORIDA FLORIDA ELECTIONS COMMISSION

In Re: Michael J. Dl'eikorn Case No.: FEC 14-138

TO: Michael l Dreikom Fidel Balan 5697 Bay Point Road 8300 Silver Birch Way Bokeelia, FL 33922 Lehigh Acres, FL 33971

NOTICE OF HEARING (INFORMAL HEARING)

A hearing will be held in this case before the Florida Elections Commission on August 26, 2015, at 8:30 am, or as soon thereafter as the parties can be heard, at the following location: Seuate Oflice Buildfog, Room 110-S, 404 South Monroe Street, I allahassee, FL 32399.

Failme to appear in accordance with this notice will constitute a waiver of your right to participate in the hearing Continuances will be granted only upon a showing of good cause

This hearing will be conducted pursuant to Section 106..25, Florida Statutes, which governs your participation as follows:

If you are the Respondent, you may attend the hearing, and you or your attorney will have 5 minutes to present your case to the Commission However, some cases (including those in which consent orders or recommendations for no probable cause are being considered) may be decided by an en masse vote and, unless you request to be heard or the Commission requests that your case be considered separately on the day of the hearing, your case will not be individually heard.

If you are the Complainant, you may attend the hearing, but you will not be permitted to address the Commission. In addition, some cases (including those in which consent orders or recommendations for no probable cause are being considered) may be decided by an en masse vote and, unless the Respondent requests to be heard or the Commission requests that the case be considered separately on the day of the hearing, the case will not be individually heard

If you are an Appellant, and you have requested a hearing, you may attend the hearing, and you or your attorney will have 5 minutes to present your case to the Commission

Please be advised that both confidential and public cases are scheduled to be heard by the Florida Elections Commission on this date As an Appellant, Respondent or Complainant in one case, you will not be permitted to attend the hearings on other confidential cases

The Commission will electronically record the meeting. Although the Commission's recording is considered the official record of the hearing, the Respondent may provide, at his own expense, a certified court reporter to also record the hearing

If you require an accommodation due to a disability, contact Donna Ann Malphurs at (850) 922-4539 or by mail at 107 West Gaines Street, The Collins Building, Suite 224, Tallahassee, Florida 32399, at least 5 days before the hearing.

See further instructions on the reverse side.

Jl.my :Mc'.l(pever Toman Executive Director Florida Elections Commission August 11, 2015

NOH FEC #14-138 I'

FLORIDA ELECTIONS COMMISSION 107 W. Gaines Street, Snite 224 Collins Building I allahassee, Florida 32399-1050 (850) 922-4539

May 29, 2015

Michael J. Dreikom 5697 Bay Point Road Bokeelia, FL 33922 RE: Case No.: FEC 14-1.38; Respondent: Michael J. Dr·eikorn

Dear Mr .. Dreikom:

The Flotida Elections Commission at its last regularly scheduled meeting was unable to heat this case .. Therefore, this case has been rescheduled for its next meeting, which is scheduled for August 18-19, 2015 in Tallahassee A notice of hearing will be mailed approximately 14 days befote the heating If you have any questions, please contact us at the number listed above or at [email protected].

Sincerely,

/sf.fl.my :Mc'l(flever

AMI/dam cc: Fidel Balan, Complainant

Aut029(!2/08) STATE OF FLORIDA FLORIDA ELECTIONS COMMISSION

In Re: Michael J. Dreikorn Case No.: FEC 14-138

TO: Michael J. Dreikom Fidel Balan 5697 Bay Point Road 8300 Silver Birch Way Bokeelia, FL 33922 Lehigh Acres, FL 33971

NOTICE OF HEARING (INFORMAL HEARING)

A hearing will be held in this case before the Florida Elections Commission on May 20, 2015, at 8:.30 am, or as soon thereafter as the parties can be heard, at the following location: Department of Business and Professional Regulation, 1940 North Mourne Street, Tallahassee FL 32399.

Failure to appear in accordance with this notice will constitute a waiver of your right to participate in the hearing .. Continuances will be granted only upon a showing of good cause.

This heating will be conducted pursuant to Section 106 25, Florida Statutes, which governs your participation as follows:

If you are the Respondent, you may attend the hearing, and you or your attorney will have 5 minutes to present your case to the Connnission. Howevet, sonre cases (including those in which consent ordets-or-rec<:nnimenchrt'ions-!i()r-'.OO-prt>bable---t cause are being considered) may be decided by an en masse vote and, unless you request to be heard or the Commission requests. that your case be considered separately on the day of the hearing, your case will not be individually heard

If you are the Complainant, you may attend the hearing, but you will not be permitted to address the Commission In addition, some cases (including those in which consent orders or recommendations for no probable cause are being considered) may be decided by an en masse vote and, unless the Respondent requests to be heard or the Commission requests that the case be considered separately on the day of the hearing, the case will not be individually heard

If you are au Appellant, and you have requested a hearing, you may attend the hearing, and you or your attorney will have 5 minutes to present your case to the Commission

If you require an accommodation due to a disability, contact Donna Ann Malphurs at (850) 922-4539 or by mail at 107 West Gai~es Street, The Collins Building, Suite 224, Tallahassee, Florida 32399, at least 5 days before the hearing.

See further instructions on the reverse side.

)'I.my :MCJ(jever 'l'oman Executive Director Florida Elections Commission May 5, 2015

NOH FEC #14-138 Please refor to the information below for further instrnctions related to your particulai hearing:

If this is a hearing to consider an appeal from an aut()matic fine, the Filing Officer has imposed a fine on you for your failure to file a campaign treasurer's report on the designated due date and, by filing an appeal, you have asked the Commission to consider either (1) that the report was in fact timely filed; or (2) that there were unusual circumstances that excused the failure to file the report timely. You are required to prove your case.. If the Commission finds that the report was filed timely or that there were unusual circumstances that excused the failure, it may waive the fine, in whole or in part The Commission may reduce a fine after considering the factors in Section 106265, Florida Statutes If the Commission finds that the report was not timely filed and there were no unusual circumstances, the fine will be upheld.

If this is a hearing to consider a consent order before a determination of probable cause has been made, the Commission will decide whether to accept or reject the consent order If the Commission accepts the consent order, the case will be closed and become public.. If the Commission rejects the consent order or does not make a decision to accept or deny the consent order, the case will remain confidential, unless confidentiality has been waived ..

If this is a hearing to consider a consent order after a determination of probable cause has been made, the Commission will decide whether to accept or reject the consent order.. If the Commission accepts the consent order, the case will be closed.. If the Commission r«jects the consent order or does not make a decision to accept or deny. the consent. . order, the Respondent will be entitled to another hearing to determine if

If this is a probable cause hearing, the Commission will decide if there is probable cause to believe that the Respondent committed a violation of Florida's election laws Respondent should be prepared to explain how the staff in its recommendation inco11ectly applied the law to the facts of the case Respondent may not testify, call others to testify, or introduce any documentary or othe1 evidence at the probable cause hearing The Commission will only decide whether Respondent should be charged with a violation and, before the Commission determines whether a violation has occurred or a fine should be imposed, Respondent will have an opportunity for another hearing at which evidence may be introduced

If this is an informal hearing, it will be conducted pursuant Sections 120.569 and 12057(2), Florida Statutes; Chapter 28 and Commission Rule 2B- l. 004, Florida Administrative Code At the hearing, the Commission will decide whether the Respondent committed the violation(s) charged in the Order of Prnbable Cause .. The Respondent will be permitted to testify However the Respondent may not call witnesses to testify.

Respondent may argue why the established facts in the Staff Recommendation do not support the violations charged in the Order of Probable Cause.. At Respondent's request, the Commission may determine whether Respondent's actions in the case were willfol.. The Respondent may also address the appropriateness of the recommended fine If Respondent claims that his limited resources make him unable to pay the statutory fine, he must provide the Commission with written proof of his financial resources at the hearing A financial affidavit form is available from the Commission Clerk 15 MAR 20 AM 3: Sb

S'f:2~TE UF FLORIDA ELECTIONS COMMISSION STATE OF FLORIDA FLORIDA ELECTIONS COMMISSION

Florida Elections Commission, Petitioner, Case No.: FEC 14-138 v.

Michael J. Dreikorn, Respondent.

ORDER OF PROBABLE CAUSE

THIS MATTER was hea1d by the Florida Elections Commission (Commission) at its regularly scheduled meeting on February 25, 2015, in I allahassee, Florida ..

Based on the Complaint, Report of Investigation, Staffs Recommendation, and oral statements made at the probable cause hearing, the Commission finds that there is probable cause to charge Respondent with the following violations:

Count 1:

On 01 about May 6, 2014, Michael Dreikorn violated Section 106..02l(l)(a), Florida Statutes, when he solicited campaign contributions and made campaign expenditures before appointing a treasurer or designating a campaign deposito1y Count 2: On or about May 6, 2014, Michael Dreikom violated Section 106..11(4), Florida Statutes, when he incuned one or more expenses for the purchase of goods or se1vices without sufficient fonds on deposit in the p1imary depository account Count3: On 01 about May 28, 2014, Michael Dreikom violated Section 106.11(4), Flodda Statutes, when he incurred one or more expenses for the purchase of goods or services without sufficient

P:/Order of Probable Cause docx (07/14) FEC Case# 14-138 funds on deposit in the primary depository account Count 4: On or about May 6, 2014, Michael Dreikom violated Section 106J9(1)(d), Florida Statutes, when he made or authmized one or more expenditures prohibited by Chapter 106, Florida Statutes Count 5: On or about May 28, 2014, Michael Dreikom violated Section 106 19(1 )( d), Florida Statutes, when he made or authorized one or more expenditmes prohibited by Chapter I 06, Florida Statutes

DONE AND ORDERED by the Florida Elections Commission on February 25, 2015 .

.----.------·· A'-"--,-~~/- Tim Hollaaay, Chairman Florida Elections Commis

Copies famished to: Jaakan A Williams, Assistant General Counsel Michael J Dreikom, Respondent Fidel Balan, Complainant

P:/Order of Probable Cause docx (07/14) FEC Case# 14-138 •

NOTICE OF RIGHT TO A HEARING I As the Respondent, you may elect to resolve this case in several ways First, you may elect to resolve this case by consent order where you and Commission staff agree to resolve the violation(s)s and :;igree to the amount of the fine. The consent order is then presented to the Commission for its approval To discuss a consent order, contact the FEC attorney identified in the Order of Probable Cause Second, you may request an informal hearing held before the Commission, if you do not dispute any material fact in the Staff Recommendation You have 30 days from the date the Order of Probable Cause is filed with the Commission to request such a hearing The date this order was filed appears in the upper right-hand corner of the first page of the order At the hearing, you will have the right to make written or oral arguments to the Commission concerning the legal issues related to the violation(s) and the potential fine At the request of Respondent, the Commission will consider and determine willfulness at an informal hearing.. Otherwise, live witness testimony is unnecessary Third, you may request a formal hearing held before an administrative law judge in the Division of Administrative Hearings (DOAH), if you dispute any material fact in the Staff Recommendation .. You have 30 days fiom the date the Order of Probable Cause is filed with the Commission to request such a hearing The date this order was filed appears in the upper right hand corner of the first page of the order At the hearing, you will have the right to present evidence relevant to the violation(s) listed in this order, to cross-examine opposing witnesses, to impeach any witness, and to rebut the evidence presented against you.

If you do not elect to resolve the case by consent order 01 request a formal hearing at the DOAH 01 an informal hearing before the Commission within 30 days of the date this Order of Probable Cause is filed with the Commission, the case will be sent to the Commission for a formal or informal hearing, depending on whether the facts are in dispute The date this order was filed appears in the upper right-hand corner of the first page of the order To request a hearing, please send a written request to the Commission Clerk, Donna Ann Malphurs .. The address of the Commission Clerk is 107 W Gaines Street, Collins Building, Suite 224, Tallahassee, Florida 32399-1050 The telephone number is (850) 922-4539 The Clerk will provide you with a copy of Chapter 28-106, Florida Administrative Code, and other applicable rules upon request No mediation is available

P:/Order of Probable Cause docx (07/14) FEC Case# 14-138 STATE OF FLORIDA FLORIDA ELECTIONS COMMISSION

In Re: Michael J. Dreikorn Case No.: FEC 14-138

TO: Michael J Dreikorn Fidel Balan 5697 Bay Point Road 8300 Silver Birch Way Bokeelia, FL 33922 Lehigh Acres, FL 33971

NOTICE OF HEARING (PROBABLE CAUSE DETERMINATION)

A hearing will be held in this case befo1e the Florida Elections Commission on February 25, 2015, at 8:30 am, or as soon thereafter as the parties can be heard, at the following location: Senate Oflice Building, Room 110-S, 404 South Mourne Street, Tallahassee, FL 32399 ..

Failure to appear in accmdance with this notice will constitute a waiver of your right to participate in the hearing. Continuances will be granted only upon a showing of good cause

This hearing will be conducted pursuant to Section 106..25, Florida Statutes, which governs your participation as follows:

If you are the Respondent, you may attend the hearing, and you 01 your attorney will have 5 minutes to present you1 case to the Commission. However, some cases (including those in which consent orde1s 01 recommendations fo1 no probable cause are being considered) may be decided by an en masse vote and, unless you request to be heard or the Commission requests that your case be considered separately on the day of the hearing, your case will not be individually heard

If you are an Appellant, and you have requested a hearing, you may attend the hearing, and you or your attorney will have 5 minutes to present your case to the Commission

The Commission will electronically record the meeting Although the Commission's recmding is considered the official record of the hearing, the Respondent may provide, at his own expense, a certified court reporter to also record the hearing

If you require an accommodation due to a disability, contact Donna Ann Malphurs at (850) 922-4539 01 by mail at I 07 West Gaines Street, The Collins Building, Suite 224, Tallahassee, Florida 32399, at least 5 days before the hearing

Sec fu1the1 instructions on the 1everse side.

limY :Mc'l(~1Wer

NOH FEC #14-138 Please refor to the information below for further instrnctions related to yom paiticular hearing:

If this is a heaiing to consider an appeal from an automatic fine, the Filing Officer has imposed a fine on you for yom failure to file a cainpaign treasmer 's report on the designated due date and, by filing an appeal, you have asked the Commission to consider either (!) that the report was in fact timely filed; or (2) that there were unusual circumstances that excused the failme to file the report timely. You me required to prnve yom case If the Commission finds that the report was filed timely or that ther~ were unusual circumstances that excused the failme, it may waive the fine, in whole or in part. The Commission may reduce a fine after considering the factors in Section 106 265, Florida Statutes.. If the Commission finds that the report was not timely filed and there were no unusual circumstances, the fine will be upheld

If this is a heaiing to consider a consent order before a determination of probable cause has been made, the Commission will decide whether to accept or reject the consent Oider If the Commission accepts the consent order, the case will be closed and become public.. If the Commission rejects the consent order or does not make a decision to accept or deny the consent order, the case will remain confidential, unless confidentiality has been waived

If this is a hearing to consider a consent order after a determination of probable cause has been made, the Commission will decide whether to accept or reject the consent order If the Commission accepts the consent order, the case will be closed If the Commission rejects the consent order or does not make a decision to accept or deny the consent order, the Respondent will be entitled to another hearing to determine if the Respondent committed the violation( s) alleged

If this is a probable cause hearing, the Commission will decide if there is probable cause to believe that the Respondent committed a violation of Florida's election laws Respondent should be prepaied to explain how the staff in its recommendation incorrectly applied the law to the facts of the case. Respondent may not testiJY, call others to testify, or introduce any documentary or other evidence at the probable cause hearing The Commission will only decide whether Respondent should be charged with a violation and, before the Commission determines whether a violation has occuned or a fine should be imposed, Respondent will have an opportunity for another hearing at which evidence may be intrnduced

If this is an informal hearing, it will be conducted pmsuant Sections 120 569 and 120 57(2), Florida Statutes; Chapter 28 and Commission Rule 2B-l 004, Florida Administrntive Code At the heaiing, the Commission will decide whether the Respondent committed the violation(s) charged in the Order of Probable Cause .. The Respondent will be permitted to testify .. However the Respondent may not call witnesses to testify

Respondent may aigue why the established facts in the Staff Recommendation do not support the violations charged in the Order of Probable Cause .. At Respondent's request, the Commission may determine whether Respondent's actions in the case were willful. The Respondent may also address the appropriateness of the recommended fine If Respondent claims that his limited resources make him unable to pay the statutory fine, he must provide the Commission with written proof of his financial resources at the hearing A financial affidavit form is available from the Commission Clerk STATE OF FLORIDA FLORIDA ELECTIONS COMMISSION

In Re: Michael J. Dreikorn Case No.: FEC 14-138 ------' STAFF RECOMMENDATION FOLLOWING INVESTIGATION

Pursuant to Section 106 25(4)(c), Flmida Statutes, unde1signed staff counsel files this written recommendation for disposition of the sworn complaint in this case recommending that the1e is probable cause to chmge Respondent with violating Sections 106 .. 021(l)(a), 106.11(4), and 106.19(1)(d), Florida Statutes, and there is no probable cause to chmge Respondent with violating Section 106.143(1)(a), Florida Statutes .. Based upon a thorough review of the Repo1t of Investigation submitted on December 22, 2014, the following facts and law support this staff recommendation:

1 On May 28, 2014, the Florida Elections Commission ("Commission") received a sworn complaint alleging that Michael J Dreikom ("Respondent") violated Chapter 106, Florida Statutes.

2 Respondent was a candidate for the F101ida Senate, District 30, in the 2014 election cycle, and he served as deputy treasurer dUJing his campaign (ROI Exhibit 2) 1

3 Complainant rnised the following allegations for Commission review: Respondent failed to appoint a campaign treasure1 and designate a campaign depository prior to making expenditures or accepting an in-kind contribution for the production of a cainpaign video; Respondent failed to include the statutmily required disclaime1 on a political advertisement; and Respondent made or authorized one or more expenditures prohibited by Chapter 106, Flot ida Statutes ·

4 By lette1 dated June 26, 2014, the Executive Dhecto1 notified Respondent that Commission staff would investigate the following statuto1y provisions:

Section 106.021(l)(a), Florida Statutes: Michael J Dreikom, candidate fo1 Florida Senate, District 30, in the November 2014 election, solicited campaign contributions and made campaign expenditures before appointing a treasurer 01 designating a cainpaign depository, as alleged in the complaint

Section 106.11(4), Florida Statutes: Michael J Dreikom, candidate for Flo1ida Senate, District 30, in the November 2014 election, incurred one or more expenses for the purchase of goods

1 Report oflnvestigation referred to herein as "ROI "

Staff Recommendation FEC 14-138 1 ( '

or services, without sufficient fonds on deposit in the primary depository account, as alleged in the complaint

Section 106.143(1), Florida Statutes: Michael L Dreikom, candidate for Florida Senate, District 30, in the November 2014 election, failed to include the statutorily required disclaimer on a political advertisement, as alleged in the complaint

Section 106.19(l)(d), Florida Statutes: Michael L Dreikom, candidate for Florida Senate, District 30, in the November 2014 election, made or authorized one or more expenditures prohibited by Chapter 106, Florida Statutes, as alleged in the complaint

Alleged Violation: Section 106.021(l)(a), Florida Statutes

5 Respondent filed his State of Florida Appointment of Campaign I reasurer and Designation of Campaign Depository for Candidates form (DS-DE 9) on May 19, 2014 designating Darlene Marie Soler as treasurer and himself as deputy treasurer. (ROI Exhibit 2)

6 By letter dated May 20, 2014, Kristi Bronson, Chief, Bureau of Election Records, informed Respondent that her office was in receipt of Respondent's DS-DE 9 form and that Respondent's name had been placed on the 2014 active candidate list (ROI Exhibit 8)

7 Ms.. Bronson's letter also informed Respondent that all of the Division's publications and reporting forms were available on its website, and the letter advised Respondent that it was his responsibility to read, understand, and follow the requirements of Florida's election laws Respondent was also advised to print copies of Chapters 104 and 106, Florida Statutes, and the 2014 Candidate and Campaign Treasurer Handbook. Id

8 In a sworn-affidavit dated December 3, 2014, Respondent affirmed that he had read the Candidate and Campaign Treasurer Handbook Respondent stated that he filed his campaign documents elect10nically on May 12, 2014, and he received a "Read Receipt" from DOE representatives Lawson and Johnson on May 13, 2014, and on May 14, 2014 fiom B10nson. ''Paper originals were mailed on May 12 and again ''overnighted" via USPS on May 14" Respondent stated that he had several email and phone conversations with DOE Representatives between May 12 and May 19, 2014, but he was not made aware that his documentation package "had not been accepted" (ROI Exhibit 5, page 3)

9.. Rule lS-2 0001(l)(b)-(2)(a), Florida Administrative Code, states, "All qualifying papers required to be filed with the Department of State as the office where the candidate is required to qualify shall be filed with the Division of Elections .. [A]ny qualifying paper filed with a qualifying office . must be an original and signatures thereon must also be made in ink" (ROI Exhibit 7)

10.. The Division did not receive Respondent's original documents with signatures in ink until May 19, 2014, thus Respondent's qualifying papers were not "filed" pursuant to Rule

Staff Recommendation FEC 14~138 2 (

1S-2 .. 0001(2)(b), Florida Administrntive Code, until May 19, 2014 Despite Respondent's efforts to expedite the process, elect10nically filed documents are not accepted as qualifying papers, pursuant to Rule 1S-2.0001(2)(b) (ROI Exhibits 2 and 7)

11 I orchlight Productions, LLC, (''Torchlight") produced a campaign video for Respondent (ROI Exhibit 10) On May 9, 2014, Matt Hurley (Torchlight Productions) emailed a link (www youtube .. com/watch?v=hBB_mrk9epc) to the video to Respondent with the following message included, "Please keep this private Do not want anyone getting a hold of this .. Only those with this link can see this" (ROI Exhibit 10, page 3) In a responsive email to Matt Hurley, Respondent stated, "Ditto, Absolutely awesome!!! I can't wait to have this go viral" (ROI Exhibit 10, page 4) On that same day, I orchlight created an invoice for 2 Respondent in the amount of $2,950 00 , with a payment due date of May 24, 2014. (ROI Exhibit 11, page 1) On May 12, 2014, the video was posted online .. (ROI Exhibit 5, page 4)

12 However, Respondent stated "As of May 19, no goods or services were accepted by my campaign and no expenditures made All efforts by Torchlight (aka SouthEastern Strategies) were at their risk and cost .My camp,aign purchased the subject video on June 19th and paid for it on June 24th and clearing the 25t> .. " (ROI Exhibit 5, page 7) Respondent also claimed, ''(T]he subject video was not an approved expenditure at the time and was not accepted by the campaign until early June Torchlight's production of the video was based on speculation that my campaign would accept the video. Once the video was accepted by the campaign, expenditure was authorized (June 24 )" (ROI Exhibit 5, question #16)

13 Respondent's contention that no goods or services were accepted by his campaign is not credible .. Emails sent between Respondent and Torchlight staff undeniably indicates that both parties were working in unison towards completing Respondent's campaign video (ROI Exhibits 9 and 10) Respondent's response after watching the video, "Ditto, Absolutely awesome!!! I can't wait to have this go viral," certainly suggests Respondent's approval of Torchlight's services. (ROI Exhibit 10, page 4) .After a series of emails between Respondent and Matt Hurley discussing the date to put on the invoice for the video, I orchlight created a second invoice dated May 19, 2014, and billed Respondent $1,262 for their work on the video .. (ROI Exhibit 11, pages 3-7 and ROI Exhibit 14, page 2)

14 Therefore, it appears that complainant is correct Torchlight produced a campaign video for Respondent, which was posted on Youtube before May 19, 2014 Although Respondent did not pay Torchlight until June 23, 2014, Torchlight began creating Respondent's video as early as May 6, 2014, and completed production on May 9, 2014 (ROI Exhibits 9 and 10) The video was posted on or about May 12, 2014 (ROI Exhibit 5, page 4) Despite Respondent's contention otherwise, Respondent's original DS-DE 9 form was not filed with the Division until May 19, 2014 Because Respondent incurred campaign expenditures for a

2 Itemized on the invoice were a $1,200 00 foe for custom web design; $500.00 foe for hosting of the website; $250.00 foe for video editing; $250.00 foe for video shoot; and a $750 00 foe for graphic design (ROI Exhibit 11, page I)

Staff Recommendation FEC 14-138 3 (

campaign video befo1e appointing a treasure1 01 designating a campaign deposito1y, Respondent has violated Section 106 021(1)(a), Flo1ida Statutes, as alleged in the complaint

Alleged Violation: Section 106.11(4), Florida Statutes

15 Complainant alleged that Respondent incurred expenses fm the pu1chase of a campaign video without sufficient fonds on deposit in his campaign account

16. In an 01iginal invoice dated May 9, 2014, Io1chlight billed Respondent $1,250 00 for production video costs (ROI Exhibit 11, pages 1-2)3 However, Respondent's campaign depositmy was not opened until May 16, 2014, with an initial deposit of $100 not being made until May 21, 2014 (ROI Exhibit 12, pages 1 · 5) Table 1 1efrrenced below indicates the availability of funds in Respondent's campaign account when expenses we1e incuned. 4

I ransaction Check# Description ofl ransaction Amount Funds Available Date to Campaign

05109114 Torchlight creates an invoice with this date, charging Respondent $0.00 $1,250 for video production

05112/14 Respondent's campaign video posted on the internet (campaign website and You Tube) in public view 05113114 Complainant views Respondent's campaign video $0 .. 00 05116114 Respondent's campaign account opened at Sun I rust Bank $0 00 05119114 Respondent's original Forms OS-DE 9 filed with his filing officer; $0 .. 00 the filing officer acknowledged receipt by her letter dated May 20, 2014 (Exhibits 2 and 8) At Respondent's request, Torchlight creates an invoice with this date, charging Respondent $1,250 (plus a $12 transaction foe) for video prnduction 05/21/14 Respondent's initial Deposit $100 00 $100 .. 00 05/21/14 Deposit Couection (Debit Item) $100 00 $0.00 05/21/14 Deposit Correction Fee (Debit Item) $6 00 ($6.00)

3 A second invoice dated May 19, 2014, includes the same billable services for video production that are included on the May 9, 2014 invoice, but does not include the charges related to web design and hosting. (ROI Exhibit 14, page 2) It appears that Respondent may also have incurred expenses for website design and hosting before he appointed a treasurer or opened a campaign depository, but that expense is not at issue in this complaint 4 Please refor to page 6 of the ROI to view Respondent's full campaign activity post-complaint

Staff Recommendation FEC 14~ 138 4 (

05127114 Miscellaneous Credit $6 .. 00 $0.00 05/27/14 Matt Hm ley provided Invoice number $1,250 00 ($1,250.00) 67967 dated May 9, 2014 to Respondent by email. (Exhibit 11) 05/28/14 Imprinted Check Order/Deposit $24 .. 95 ($1,274 .. 95) Charge 05/30/14 Deposit-ONLINE BANKING $1,000.00 ($274.95) TRANSFER

05131114 Point-of~Sale Debit-SHELL Service $35 .. 00 ($309 .. 95) 05/31/14 Check Card Purchase- $6 57 ($316..52) MCDONALDS

17 Respondent argues that thete was no commitment to accept the su1Jject video until mid-June .. "My camfaign purchased the subject video on June 19°' and paid fot it on June 24111 1 and cleating the 25 " However, Respondent's response, "Ditto, Absolutely awesome!!! I can't wait to have this go viral,'' after reviewing his campaign video on Y outube, suggests that Respondent had accepted the video even if he was not planning to pay for it until mid-June .. (ROI Exhibit S, pages 7-8 and ROI Exhibit 10, pages 3-4) Respondent's campaign incurred expenses as early as May 6, 2014, when Torchlight began the video shoot, video editing, etc, regaidless of when Respondent decided to pay .. (ROI Exhibit 9 and ROI Exhibit 11, pages 1-2) When those expenses were incurred, Respondent's campaign depository was nonexistent (ROI Exhibit 12)

18 In a series of emails between Respondent and Matt Hurley, it appears that Respondent attempted to induce Mr.. Hmley to change the dates on the invoice, although production of Respondent's campaign video took place beginning on May 6, 2014 In one email, Respondent stated, ''Matt: We need to look at the dates the invoice" (ROI Exhibit 11, page 3) Mr Hmley tesponded, "Sure thing, what date do you want on it?" (ROI Exhibit 11, page 4) On May 30, 2014, Mr.. Hurley sent another email to Respondent asking, "Michael, Any idea what date you want me to put on that invoice Trying to make sure everyone is covered" (ROI Exhibit 11, page 5)

19. In a final email dated June 16, 2014 fiom Mr Hurley to Respondent, Mt Hurley states, ''Michael, This is getting out of hand.. I need an answer on this It has been over a month. If you have to pay it out of pocket and then in-kind it, I am fine with that People are asking questions .. " (ROI Exhibit 11, page 9) At some point, Torchlight issued a new invoice with the same items telating to the video production as on the earlier invoice, but dated May 19, 2014, in compliance with Respondent's demands (ROI Exhibit 14, page 2) The emails referenced above certainly suggest that Torchlight had no intention of making an in-kind contribution to Respondent's campaign for the value of the video, and that they were expecting payment for their services

20 On May 14, 2014, Division staff told Respondent that a complaint might be in the works, and Respondent stated that, "[he] immediately removed the subject video from You Tube and suspended all campaign activities" (ROI Exhibit 5, question 15) By Respondent's own

Staff Recommendation f·EC 14~138 5 admission in his sworn affidavit, Respondent engaged in campaign activities and incurred expenses before he opened his campaign account on May 16, 2014 (ROI Exhibit 12, page 1)

21 It appears that complainant is conect Respondent incurred expenses for the production of his campaign video before May 16, 2014, which is the day he first opened his campaign depository without depositing any funds.. Respondent did not make a deposit into the account until May 21, 2014, and, in fact, it appears that the campaign depository did not have a positive balance until June 11, 2014 (ROI I able 1) Section 106 11(4), Florida Statutes, states that "[n]o candidate deputy tJeasurer .. shall authorize any expenses, nor shall any campaign treasurer or deputy t1easure1 sign a check drawn on the primary campaign account for any purpose unless the1e are sufficient fonds on deposit in the primaiy deposito1y account of the candidate ... to pay the full amount of the auth01ized expense " When Respondent incuned the expense fo1 his campaign video, his campaign account had not been opened and so there were no fonds on deposit; therefo1e, he committed a violation of Section 10611(4), Florida Statutes.

22 In addition to the campaign video expenditure, Respondent also authorized a campaign expenditure for "Imp1inted Check 01der/Deposit Chaige" on May 28, 2014 without having sufficient funds on deposit in his campaign deposit01y.. (ROI I able 1) When Respondent incurred this expense, his campaign account had a negative balance; the1efo1e, he committed a violation of Section 106.11(4), Florida Statutes. 5

Alleged Violation: Section 106.143(l)(a), Florida Statutes

23 Complainant alleged that Respondent failed to include with his campaign video a prnper political adve1tisement disclaimer

24 Respondent's campaign video disclaimer reads as follows: ''APPROVED AND PAID FOR BY MICHAEL DREIKORN FOR STAIE SENA IE" (ROI Exhibit 4) Pursuant to Section 106 143(1)(a), Florida Statutes, a prnper political disclaimer should have read as follows:

(a) Political advertisement paid fo1 and approved by Michael Dreikorn, Republican, for State Senate; or

(b) Paid by Michael Dreikorn, Republican, for State Senate

25 In his response, Respondent stated, "As prnvided in Section 106 143(10)(d) content "[p] laced at no cost on an Internet website for which there is no cost to post content for public users'' does not require political disclaimers .. (ROI Exhibit 5, question 30)

26.. It appears that Respondent is co11ect Although Respondent's political disclaimer does not conform to the specific language in either of the permitted variations allowed by statute,

5 While the bank records received in connection with this investigation suggest that Respondent continued to authorize expenditures without sufficient funds on deposit, the present complaint was filed with the Commission on May 28, 2014 As such, this recommendation does not consider any potential violations beyond that date

Staff Recommendation F·EC 14 .. 133 6 (

an exception is made in the statute for political advertisements that are placed at no cost on an internet website for which there is no cost to post content for public use1 s Respondent's campaign video was uploaded to Youtube by I orchlight free of charge, and the public has access to Youtube free of charge Ihe1efore, it appears that Respondent has not committed a violation of Section I 06 143(1 )(a), Florida Statutes

Alleged Violation: Section 106 .. 19(1 )(d), Florida Statutes

27 Complainant alleged that Respondent made or authorized one 01 more expenditures prohibited by Chapter 106, Florida Statutes.

28. Respondent's campaign deposito1y was not opened until May 16, 2014, and he did not have sufficient fonds available on May 6, 2014, when his campaign video production began, or on May 9, 2014 when the video was apparently completed, 01 on May 12, 2014 when the video was apparently posted. He also did not have sufficient fonds on deposit in his campaign account on May 28, 2014, when he authorized an expenditure for imprinted checks .. Iherefo1e, Respondent has committed two violations of Section I 06 19(1 )( d), for authorizing an expenditme in violation of Section 106 ..11(4), Florida Statutes, as alleged in the complaint

29 "P10bable Cause" is defined as 1easonable grounds of suspicion supported by circumstances sufficiently strong to warrant a cautious person in the belief that the person has committed the offense charged .. Schmitt v State, 590 So.2d 404, 409 (Fla .. 1991) P10bable cause exists where the facts and circumstances, of which an [investigator] has reasonably trustworthy information, are sufficient in themselves for a reasonable man to reach the conclusion that an offense has been committed Department of Highway Safety and Motor Vehicles v Favino, 667 So.2d 305, 309 (Fla I st DCA 1995)

30.. The facts set forth above show that Respondent was a candidate for the Florida Senate, District 30, dming the 2014 election cycle, and he served as his own deputy treasurer During Respondent's campaign, Respondent authorized and incurred expenses for the production of a campaign video and ordered checks without having sufficient fonds on deposit in a campaign account Respondent authorized those campaign expenditmes prior to appointing a treasurer 01 designating a campaign depository

Based upon these facts and circumstances, I recommend that the Commission find no probable cause to charge Respondent with violating Section 106..143(l)(a), Florida Statutes, and I farther recommend the Commission find probable cause to charge Respondent with violating the following statutory provisions:

Count 1:

On or about May 6, 2014, Michael Dreikom, violated Section 106 02l(l)(a), Florida Statutes, when he solicited campaign contributions and made campaign expenditmes before appointing a treasmer or designating a campaign depository.

Stan Recommendation FEC 14-138 7 Count 2:

On or about May 6, 2014, Michael Dreikorn, violated Section 106 11 (4), Florida Statutes, when he incurred one or more expenses for the purchase of goods or services, without sufficient fonds on deposit in the primary depository account

Count3:

On or about May 28, 2014, Michael Dreikorn, violated Section 10611(4), Florida Statutes, when he incurred one or more expenses for the purchase of goods or services, without sufficient funds on deposit in the primary depository account

Count 4:

On or about May 6, 2014, Michael Dreikorn, violated Section 106 ..19(1)(d), Florida Statutes, when he made or authorized one or more expenditures prohibited by Chapter 106, Florida Statutes

Count 5:

On or about May 28, 2014, Michael Dreikorn, violated Section 106 19(1)(d), Florida Statutes, when he made or authorized one or more expenditures prohibited by Chapter 106, Florida Statutes

Respectfolly submitted on Januaryd

hUrkan A Williams Assistant General Counsel

Amy McKeever Executive Dir ctor

Staff Recommendation fEC 14-138 8 /.- •. I I

FLORIDA ELECTIONS COMMISSION REPORT OF INVESTIGATION Case No.: FEC 14-138

Respondent: Michael J Dreikorn Counsel for Respondent: none Complainant: Fidel Balan Counsel for Complainant: none

On May 28, 2014, the Florida Elections Commission (Commission) received a sworn complaint alleging that Respondent violated Chapter I 06, Florida Statutes. Commission staff investigated whether Respondent violated the following statutes:

Section !0602l(l)(a), Florida Statutes, prohibiting a candidate from accepting contributions or making expenditures before appointing a campaign treasurer and designating a campaign depository; Section 106 11(4), Florida Statutes, prohibiting a candidate from incuning an expense for the purchase of goods or services without sufficient funds on deposit in the primary depository account; Section I 06 143(1 )(a), Florida Statutes, failure of a candidate who made an expenditure for and published a political advertisement before the election to prominently mark the advertisement with the required disclaimer; and Section 106J9(l)(d), Florida Statutes, prohibiting a person or organization from making or authorizing any expenditure prohibited by Chapter I 06, Florida Statutes I. Preliminary Information: I.. Respondent was a candidate for the Florida Senate, District 30; he was defeated in the August 26, 2014 primary election He served his 2014 campaign as deputy treasurer On May 12, 2014, Darlene Marie Soler accepted appointment as his 2014 campaign treasurer Respondent's Statement of Candidate and Forms DS-DE 9, (the form indicating the appointment of his campaign treasurer or deputy treasurer, and designation of his campaign depository), were dated May 12, 2014, and filed on May 19, 2014 .. (Note Respondent filed a total of four copies of his Form DS-DE 9 with his filing officer on May 19, 2014; two copies were date-and-time stamped on May 19, 2014, at 10:03 am, and two copies were date-and-time stamped on May 19, 2014, at 11 :29 a .. m., respectively) Io review his Statement of Candidate, refer to Exhibit I Io review his Forms DS-DE 9, refer to Exhibit 2 2 Respondent is not a first-time candidate He was a 2014 candidate for the United States House of Representatives, Congressional District 19; he was defeated in the April 22, 2014 Special Primary Election. 3. Respondent is managing member of the IPL Group, LLC, a Florida for-profit limited liability company in Lee County, Florida The IPL Group, LLC is a consulting,

Inv002 (7/08) I engineering, auditing, and training firm providing services to the aviation, space, defense, and nuclear industries 4.. Ms Kristi Reid-Bronson, Chief of the Bureau of Election Records, the Division of Elections (DOE), was Respondent's filing officer 5 Complainant is a special investigations unit insurance investigator and a private investigat01 in Lee County, Florida. He is a former law enforcement officer from New York On September 18, 2014, Complainant requested by telephone to withdraw his complaint; however, after I informed him his request must be made in writing, he failed to respond. To review the phone log, refer to Exhibit 3, entry number 10. II. Alleged Violation of Section 106.02l(l)(a), Florida Statutes: 6 I investigated whether Respondent violated this section of the elections laws by making an expenditure or accepting an in-kind contribution for the production of a campaign video posted on You Tube 1 prior to appointing a campaign treasurer and designating a campaign depository 7 Complainant alleges that Respondent commissioned the creation of a professional advertising video that was posted on You Tube on May 13, 2014, at approximately 11:41 am, prior to filing the requisite paperwork with the DOE on May 19, 2014 Complainant printed a copy of the opening view of the campaign video for our review To review the relevant page of Respondent's campaign video with a political advertisement disclaimer, refer to Exhibit 4.. To review Respondent's Forms DS-DE 9, refer to Exhibit 2 8. In his sworn affidavit-questionnaire dated December 3, 2014, Respondent explained that the campaign treasurer was appointed on May 12, 2014; the subject video was not an approved expenditure at the time; and was not accepted by his campaign until early June He continued, "Torchlight's production of the video was based on speculation that my campaign would accept the video.. Once the video was accepted by the campaign, expenditure was authorized (June 24)" To review Respondent's sworn affidavit-questionnaire, refer to Exhibit 5, question number 16 9.. Respondent explained that he had several email and phone conversations with DOE representatives (Teni Lawson, Kristi Bronson and Randy Johnson) between May 12 and 19, 2014 .. His campaign documents were provided to the DOE electronically on May 12, 2014, ([email protected] .. com). Respondent resent the documents electronically on May 13, 2014; paper originals were mailed on May 12, 2014, and "overnighted" via USPS on May 14, 2014 "A 'Read Receipt' was received on May 13 from DOE representatives Lawson and Johnson, and on May 14 from Bronson.... " (Note Lawson and Johnson as no longer employed by the DOE) To review Respondent's sworn affidavit-questionnaire, refer to Exhibit 5, question number 15 10 Respondent continued, "On May 14, I called DOE representative Johnson, at this time I had no confirmation from DOE that my documentation package had not been accepted, yet Johnson confirmed that they were aware of my electronic submittal and that a complaint might be in the works.. I immediately removed the subject video from You Tube and suspended

1 Note the campaign video Complainant viewed on You Tube was also posted on Respondent's campaign website.

Inv002 (7 /08) 2 1.. all campaign activities .. " "On the 19th, Johnson confirmed receipt and acceptance Johnson also indicated that the office would not pursue action against me, unless there was a complaint" Io review Respondent's sworn affidavit-questionnaire, refer to Exhibit 5, question number 15 .. 11 In his sworn response to the complaint dated July 29, 2014, Respondent explained that he contacted the DOE on May 14, 2014, inquired as to the required method of submission for his (Appointment of Campaign Treasurer and Designation of Campaign Depository for Candidates, Form DS-DE 9) form application, and was informed that the submissions needed to be provided as paper original copies He affirmed, "I immediately removed the subject 'Youiube' video fiom my campaign website and re-submitted the documents via USPS overnight delivery " Io review his sworn response to the complaint, refer to Exhibit 6. 12 Pursuant to the DOE's Rule IS-2 .. 000I(l)(a), Florida Administrative Code (FAC.), "All qualifying papers required to be filed with the Department of State as the office where the candidate is required to qualify shall be filed with the Division of Elections" And any qualifying paper to be filed by candidates must be an original with an original signature made in ink pursuant to the DOE's Rule 1S-2 .. 0001(2)(a), F.A.C Io review the DOE's Rule IS-2 .. 0001, FA.C., refer to Exhibit 7. 13 Therefore, it appears Respondent's Forms DS-DE 9 submitted electronically on May 12 and 13, 2014 were not accepted and not considered filed by his filing officer until the original Forms DS-DE 9 were date-and-time stamped by the DOE, Bureau of Election Records, on May 19, 2014, (two copies at 10:03 am; and two copies at 11:29 a.m.), and acknowledged by Respondent's filing officer by her letter dated May 20, 2014.. Io review his Forms DS-DE 9, refer to Exhibit 2 .. To review the filing officer's letter dated May 20, 2014, refer to Exhibit 8 14. Torchlight Productions, LLC ("Torchlight") produced Respondent's campaign video.. By email dated I uesday, May 6, 2014, at 1 :58 p.m, Matthew J Hurley (Managing Member) of I orchlight informed Respondent that he (Hurley) has "the ad agency working now on developing a 90 second Web ad that we will release fir st thing Monday [May 12, 2014] morning.. " To review Hurley's email to Respondent dated May 6, 2014, at 1 :58 pm, refer to Exhibit 9 .. 15.. By email on May 9, 2014, at 10:19 am., Alex Aldieri, Director of Motion Media at Torchlight, provided Hurley a link to Respondent's campaign video advertisement. At 10:39, Respondent declared, "We will also need to place the 'Paid for' bar in there" Then at 12: 15 p.m .. , on May 9, 2014, Hurley provided the link to Respondent At 1:13 pm, on May 9, 2014, Respondent declared, "Absolutely awesome!!! I can't wait to have this go viral" Io review the relevant emails dated May 9, 2014, refer to Exhibit 10 .. 16. Through a series of emails between Respondent and I orchlight, the following is disclosed: On May 27, 2014 at 5:43 pm., Respondent received the invoice for the campaign website and campaign video and responded to Hurley's email dated May 27, 2014 at 5:30 pm, and said, "Matt: We need to look at the dates on the invoice .. " On May 28, 2014, at 11 :03 am, Matt Hurley responded, "Sure thing, what date do you want on it?"

lnv002 (7 /08) 3 On May 30, 2014, at 12:06 pm., Matt Hurley sent Respondent and email regarding the Invoice, "Any idea what date you want me to put on that invoice I1ying to make sure eve1yone is covered " On June 4, 2014, at 1:21 p .. m., Matt Hurley sent Respondent an email regarding the Invoice, "Did you ever decide on how you wanted to handle the invoice?" On June 6, 2014, at 12:07 p.m .. , Matt Hurley sent Respondent an email regarding the Invoice, "Any update?" On June 7, 2014, at 8:37 p.m .. , Respondent sent Matt Hurley an email. 1egarding the Invoice, "There are a number of things we need to resolve " On June 16, 2014, at 9:42 a.m, Matt Hurley sent Respondent an email regarding the Invoice, "I his is getting out of hand I need an ansv.er on this It has been over a month. If you have to pay it out of pocket and then in-kind it, I am fine with that.. " To review the email dated May 27, 2014 with the invoice and Respondent's response, refer to Exhibit 11, pages 1 through 3.. To review the email dated May 28, 2014, refer to Exhibit 11, page 4 To review the email dated May 30, 2014, refer to Exhibit 11, page 5 Io review the email dated June 4, 2014, refer to Exhibit 11, page 6 .. To review the email dated June 6, 2014, refe1 to Exhibit 11, page 7 To review the email dated June 7, 2014, refer to Exhibit 11, page 8 To review the email dated June 16, 2014, refe1 to Exhibit 11, page 9 .. 17 Bank records were obtained from SunTrnst Bank by subpoena .. I compared the monthly Bank statements of Respondent's campaign depository for May and June 2014 to his contributions and expenditures disclosed in his relevant campaign treasurer reports to identify the payment for Respondent's campaign video To review the relevant bank records, refer to Exhibit 12 .. To review Respondent's relevant contributions and expenditures, refe1 to Exhibit 13 18 A review of the bank records reveals they do not ag1ee with his 2014 MS, and Pl Repmts Respondent disclosed a $200 .. 00 contribution from himself dated May 19, 2014; however, the first deposit was credited to his campaign depositmy on May 21, 2014, in the amount of $100 00.. (Note thtee checks were missing from the Bank records including check numbe1s 1490, 1491 and 1492; however, a copy of check # 1492, issued by Respondent's campaign for his qualifying foe, was obtained from the DOE.) To review the relevant bank records and campaign check number 1492, refer to Exhibit 12 To review Respondent's relevant contdbutions and expenditures, refe1 to Exhibit 13 19. It appears small contribution amounts (one at $1 00 and six at $0.01 each) disclosed in Respondent's 2014 Pl Repo1t were not found in the bank records .. To review the relevant bank records, refer to Exhibit 12 To review Respondent's ielevant contributions and expenditures, refe1 to Exhibit 13 .. 20 The table below illustiates the activity in Respondent's campaign account The table shows the time line of events, including when Respondent's campaign video was first available to the public; when expenses were incuned including the invoicing for Respondent's campaign video (video editing, video shoot and graphic design); and the funds available in Respondent's campaign depository (Note the only ielevant items on invoices presented to Respondent and of concern to Complainant are items related to Respondent's campaign video ..) To review the email dated May 27, 2014 and Invoice, refer to Exhibit 11, pages 1 through 3 To

Inv002 (7/08) 4 (

review Respondent's 1elevant campaign contributions and expenditures, refer to Exhibit 1.3 To review the revised Invoice totaling $1,262 .. 00 mruked "PAID," refer to Exhibit 14

· · to C:illlipaign

05/12/14 Amount of funds Available to Campaign 2 $0.00

05/12/14 Respondent's campaign video posted on the internet (campaign website and Youiube) in public view. 05/13/14 Complainant views Respondent's campaign video $0 .. 00 05/16/14 Respondent's campaign account opened at Sun I rust Bank $0 00 05/19/14 Respondent's original Forms DS-DE 9 filed with his filing officer; $0 .. 00 the filing officer acknowledged receipt by her letter dated May 20, 2014 (Exhibits 2 and 8) 05/21/14 Respondent's initial Deposit $100.00 $100 .. 00 05/21/14 Deposit Conection (Debit Item) $100 00 $0 00 05/21/14 Deposit Correction Fee (Debit Item) $6.00 ($6.00) 05/27/14 Miscellaneous Credit $6 00 $0 00 05/27/14, 5:30 Matt Hurley provided Invoice number $1,250 003 ($1,250.00) pm. 67967 dated May 9, 2014 to Respondent by email This amount originally invoiced to Respondent for video (plus additional $12 .. 00 bank transaction fee) paid on June 23, 2014 .. (Exhibit II) 05/28/14 Imprinted Check Order/Deposit $24.95 ($1,274.,95) Char·ge 05/30/14 Deposit-ONLINE BANKING $1,000 00 ($274,,95) TRANSFER

05/31/14 Point-of~Sale Debit-SHELL Service $35.00 ($309 .. 95) 05/31/14 Check Card Purchase- $657 ($316.,52)

2 Note the amount indicated is the starting point for the table Respondent's Forms DS-DE 9 are signed, dated and sent electrnnically to the filing officer; however, they were not accepted by the filing officer until the originals were received on May 19, 2014, at 10:03 am Respondent has not opened his campaign account but his campaign video is available for public viewing 3 Note relevant items identified on the Invoice of concem to Complainant were the following: video editing, video shoot and graphic design for the campaign video advertisement totaling $1,250 00

Inv002 (7 /08) 5 MCDONALDS 06/02/14 Correction Credit $100.00 ($216.52) 06103114 Electronic/ACH Debit-AUTHNET $10.65 ($227.17) GATEWAY BILLING 06105101 Check Card Purchase--- $11899 ($346.16) VistaPrint.com 06105114 1490 Attype, Inc $196 IO ($542.26) 06106114 1491 Christine Barratt $150 .. 00 ($692.26) 06/08/14 Respondent sent an email to Hurley requesting to "work out ($692.26) payment details" for the video chruges (Exhibit I I, page 8) 06108114 Check Crud Purchase---"Lee $22 .. 00 ($714.26) Republic" 06/09/14 Deposit-ONLINE BANKING $25 00 ($689.26) TRANSFER 06109114 Deposit- $100 00 ($589.26) 0611III4 Deposit-ONLINE BANKING $900 00 $310 74 TRANSFER 06112114 Check Crud Credit- PayPal $22 00 $332 ..74 LEEREPUBLIC 06/16/14 Check Card Purchase-PayPal $60 .. 00 $272 74 PSDCENIERLL 06/16/14 1492 Department of State for Qualifying $1,781 82 ($1,509 .. 08) Fee 06/17/14 Deposit-ONLINE BANKING $1,000 00 ($509.08) TRANSFER 06/19/14 Returned Item Fee4 $38.00 ($547.08) 06/19/14 Check Card Purchase---FEDEX $25 50 ($572.58)

06/20/14 Deposit-ONLINE BANKING $1,500 .. 00 $927 42 TRANSFER 06120114 Point-of-Sale Debit-OFFICE MA $214.08 $71334 olc.. 501 06120114 Check Cat d Purchase--- $22 33 $691 01 NAIIONBUILDER 06/21/14 Check Card Purchase---CAPE $300 00 $39101 CORAL PARKS AND R

4 Note Respondent's account was chruged a "retwned item fee"; however, it's unclear which item resulted in the fee

Inv002 (7 /08) 6 , .. ' I \ 1.

06/23/14 Deposit-ONLINE BANKING $1,000 00 $1,39101 TRANSFER 06/23/14 Check Card Purchase- $1,262 00 $129 .. 01 TORCHLIGHT PRODUCT 06/24/14 Deposit-ONLINE BANKING $210 00 $339 .01 TRANSFER

06/27/14 Point-of~Sale Debit-OFFICE MA $15 89 $323 12 501

06130114 Point-of~Sale Debit-Shell Service $40 09 $283.03

21 By email to me dated December 3, 2014, Respondent explained, "Included in this conespondence is a non-signed revised consulting contract and the initial invoice provided by M1. Hurley after he te1minated his supp01t I'd like to point out that the drnft ag1eement contemplated the consultant (South Eastern Strategies/Hurley) to engage in fundraising eff01ts and they were to be paid as a result of their fund-1aising perfo1mance .. (Pai a 3) If funds were not raised the consultant was not entitled to any payment There aie no provisions for payment for paitial w01k product, such as web site, business cards, video, press releases, printing, etc ... " Io review Respondent's email to me dated December 3, 2014 with attachments, refer to Exhibit 15, pages I through 10 Io review the non-executed contract, refer to Exhibit 15, pages 11 through 17. 22 Respondent continued, "The subject You I ube video was not specified in the revised agreement, nor was any budget or value associated with any such work effort The geniuses of the subject Youlube video and all related wo1k eff01t was solely that of Torchlight As I have previously disclosed, after the relationship between the paities dissolved, the video was still the prope1ty of I orchlight Productions.. As I desired to use the video, my cainpaign sought to negotiate a price for the video, and that is why there aie numerous versions of invoices provided by Torchlight" (Note the original invoice included the custom design and hosting of a cainpaign website that was never accepted by Respondent based upon his asse1tions; it appeais all invoices have the saine chaiges indicated for the campaign video, totaling $1,250 00.) Io review Respondent's email to me dated December 3, 2014 with attachments, refer to Exhibit 15, pages I tluough 10 23.. On page tluee of her acknowledgment letter dated May 20, 2014, the filing officer declaied, "All of the Division's publications and repo1ting fo1ms aie available on the Division of Elections' website at http://elections.myflorida.com " Respondent was admonished by his filing officer, "It is yow responsibility to read, understand, and follow the requirements of F101ida's election laws.. Therefore, please print a copy of the following documents: Chapters I 04 and I 06, Florida Statutes, 2014 Candidate and Campaign Treasurer Handbook, 2014 Calendar of Reporting Dates, and Rule IS-2 017, [Rep01ting Requirements for Cainpaign Ireasure1's Repo1t], Flo1ida Administrative Code" (Note this paiagraph of her letter appeais in bold font.) Io review her lette1 dated May 20, 2014, refo1 to Exhibit 8.. 24.. In a sworn questionnaire submitted by email on December 3, 2014, Respondent acknowledged receiving and reading Chapters I 04 and I 06, Florida Statutes, and the November

Inv002 (7/08) 7 . I (

2013 Candidate and Campaign Treasurer Handbook Io review Respondent's sworn affidavit questionnaire, refer to Exhibit 5 25 I found no record of previous complaints to indicate that Respondent has violated this section of Florida's election laws .. III. Alleged Violation of Section 106.11(4), Florida Statutes: 26 I investigated whether Respondent violated this section of the election laws by incuning expenses for a campaign video without sufficient funds on deposit in his campaign depository. 27. Complainant alleges that Respondent "obligated funds" to be expended for a campaign video without sufficient funds in his campaign depository. 28 Io review information regarding this section of the election laws, refer to paragtaphs 7 through 24 in this report 29. I found no record of previous complaints to indicate that Respondent has violated this section of Florida's election laws .. IV. Alleged Violation of Section 106.14.3(1)(a), Florida Statutes: 30 I investigated whether Respondent violated this section of the election laws by failing to include with his campaign video containing express advocacy a proper political advertisement disclaimer .. 31 Complainant alleges Respondent's political advertisement-Youiube video- contains a deficient disclaimer, "APPROVED AND PAID FOR BY MICHAEL DREIKORN FOR STAIE SENA IE" 32. Because Respondent was a candidate, his political advertisements must contain the language provided in Section 106J43(l)(a), Florida Statutes (2014), as follows: Any political advertisement that is paid for by a candidate, except a write-in candidate, and that is published, displayed, or circulated before, or on the day of; any election must prominently state: 1 . "Political advertisement paid for and approved by (name of candidate) , (party affiliation) , for (office sought) "; or 2 "Paid by (name of candidate) , (party affiliation) , for (office sought) " Io review Section 106143(l)(a), Florida Statutes, refer to Exhibit 16

33.. The following are proper disclaimers: Political advertisement paid for and apprnved by Michael Dreikorn, Republican, for State Senate; and Paid by Michael Dreikorn, Republican, for State Senate.

Io review Section 106J43(l)(a), Florida Statutes, refer to Exhibit 16 ..

lnv002 (7 /08) 8 5 34.. By email dated May 30, 2014 , at 3:11 pm, Respondent notified Torchlight staff by email, "The video that is attached to the Bio page [on Respondent's campaign website] needs to have the following statement applied either at the beginning or end of the film: 'Political advertisement paid for and approved by Dr.. Michael J Dreikorn, Republican for State Senate, District 30 .. ' I am thinking, simply overlay it to the video at the end, last 5 seconds or so .. " (Note Respondent's campaign video was posted on his campaign website and Youiube.) Io review Respondent's email dated May 30, 2014, at 3:11 p .. m, refer to Exhibit 17. 35. In his sworn affidavit-questionnaire dated Decembe1 3, 2014, Respondent explained, "As previously described in writing to your office, the subject video was exempt from the disclaimer requirements As provided in Section 106 143(10)(d), [F .S] content '[p]laced at no cost on an Internet website for which there is no cost to post content for public users' does not require political disclaimers The su~ject internet based video is not su~ject to the requirements of Section 106J 43(1) and does not require the noted disclaimer However, voluntarily, the su~ject video was modified priOI to being reposted on 'Youiube' as ifhad had been subject to the statutory required disclaimer language of relevant political advertising The alleged nonconforming video was on You Tube from the afternoon of May 12 to May 14 .. The video was reposted again on Youiube on or about May 20 .. " Io review Respondent's sworn affidavit questionnaire, refer to Exhibit 5, question number 17. 36. However, as previously discussed in this repo1t, by email on May 9, 2014, at 10:39 am, Respondent declared, "We will also need to place the 'Paid for' bar in there .. " Therefore, Respondent must have believed the campaign video required a political adve1tisement disclaime1 when he was communicating with the vendor. And Respondent's 2014 campaign paid Torchlight $1,262.00 for the campaign video which was posted on Youiube and Respondent's website .. Io review the relevant email dated May 9, 2014, refer to Exhibit 10 .. Io review the paid invoice, 1efe1 to Exhibit 14 37.. In his sworn affidavit-questionnaire dated December 3, 2014, Respondent acknowledged receiving and reading Chapters 104 and 106, Florida Statutes, and the November 2013 Candidate and Campaign Treasurer Handbook Io review Respondent's non-sworn questionnaire, refer to Exhibit 5. 38 I found no record of previous complaints to indicate that Respondent has violated this section of Florida's election laws V Alleged Violation of Section 106.19(1)(d), Florida Statutes: 39 I investigated whether Respondent violated this section of the election laws by making or authorizing one or more expenditures p10hibited by Chapter 106, F101ida Statutes, as alleged in the complaint 40. Complainant alleges that Respondent "obligated funds" to be expended fo1 a campaign video without sufficient funds in his campaign depository. 4 L Io review information regarding this section of the election laws, refer to paragrnphs 7 through 24 and 26 th10ugh 28 in this repo1t

5 Note the complaint by Mr.. Balan was sworn to on May 23, 2014; it was filed with the FEC on May 28, 2014

lnv002 (7 /08) 9 42. I found no record of previous complaints to indicate that Respondent has violated this section ofFlotida's election laws VI. FEC History: 43. Respondent has no histoty of additional complaints filed against him with the Commission at the time of this complaint · Conclusion: 44.. On Decembe1 3, 2014, I phoned Respondent to conduct a final inte1view by telephone and give him an oppo1tunity to 1espond to the info1mation gathered dming the course of the investigation concerning the allegations made in the complaint; I reviewed with him the info1mation I had gathe1ed during my investigation Respondent said my repo1t seemed ve1y one-sided; I offered Respondent the oppottunity to submit additional documents Respondent submitted additional documents by email including an executed sworn affidavit-questionnaire, emails and an unexecuted contrnct To review the phone log, refer to Exhibit 3, entiy number 20 .. 45 After reviewing Respondent's additional documents, I phoned Respondent to review my findings with him on Decembe1 19, 2014 .. Respondent said Commission staff has nothing; he made no contrnct and did not authodze the production of the video. I noted his email wishing the campaign video would "go viral" and expressing his approval; Respondent said, "That's hearsay" To review the phone log, refer to Exhibit 3, entiy number 25 46 As previously discussed in this repmt in paragraph 23, on page three of her acknowledgment letter dated May 20, 2014, the filing officer declared, "All of the Division's publications and repo1ting fo1ms are available on the Division of Elections' website at http://elections.myflorida.com" Respondent was admonished, "It is yom iesponsibility to 1ead, understand, and follow the requirements of Florida's election laws. Therefore, please print a copy of the following documents: Chapte1s 104 and 106, Floiida Statutes, 2014 Candidate and Campaign Treasurer Handbook, 2014 Calendar of Reporting Dates, and Rule lS-2.017, [Repotting Requirements for Campaign Treasurer's Repo1t], Florida Administiative Code" (Note this paragraph of her lette1 appeais in bold font) To review her letter dated May 20, 2014, refer to Exhibit 8 47 Respondent acknowledged receiving and reading Chapters 104 and 106, Flo1ida Statutes, and the November 2013 Candidate and Campaign Treasurer Handbook. Respondent signed the Statement of Candidate on May 12, 2014 and it was filed with the DOE on May 19, 2014 To review Respondent's sworn affidavit-questionnaire, refer to Exhibit 5. To review Respondent's Statement of Candidate, 1efor to Exhibit 1

Respectfully submitted on December 22(:2014

.·~.~· Helen Hinson Investigation Specialist

Inv002 (7/08) 10 I I \

Di Michael l Dreikom Mr Fidel Balan 5697 Bay Point Road 8300 Silve1 Birch Way Bokeelia, Florida 33922 Lehigh Acres, Flmida 33971

Ms Ktisti Reid Bionson Chief~ Bureau of Election Records 500 South Bronough Street, Room 316 I allahassee, Floiida 32399-0250

Copy furnished to: Mt .. David B Flagg, Investigations Manager

Inv002 (7/08) 11 (

FLORIDA ELECTIONS COMMISSION REPORT OF INVESTIGATION Michael J. Dreikorn -- FEC 14-138

\ spes'iription !)f Exhibits Exhibit 1 Respondent's Statement of Candidate Exhibit 2 Respondent's Fo1ms DS-DE 9, Appointment of Campaign Treasure1 and Designation of Campaign Deposito1y for Candidates Exhibit 3 Phone Log Exhibit 4 Relevant page of Respondent's campaign video with a political advertisement disclaimer Exhibit 5 Respondent's sworn affidavit-questionnaire dated Decembe1 3, 2014 Exhibit 6 Respondent's sworn 1esponse to the complaint dated July 29, 2014 Exhibit 7 The Division of Elections' Rule 1S-2 0001, F.A.C Exhibit 8 The Filing Office1's acknowledgment lette1 dated May 20, 2014 Exhibit 9 Matthew Hurley's email to Respondent dated May 6, 2014, at 1:58 p.m Exhibit 10 Matthew Hmley's and Respondent's exchange of emails dated May 9, 2014, at 10:19 am. and 10:39 a.m .. , and 12:15 p .. m. and 1:13 pm Exhibit 11 Relevant emails between Matthew HUiley and Respondent: dated May 27, 2014, with Invoice Number 67967; May 28, and May 30, 2014, and June 4, 6, and 7, 2014 Exhibit 12 Respondent's relevant Bank 1eco1ds and check number 1492 Exhibit 13 Respondent's 1elevant contributions and expenditmes Exhibit 14 Email to Commission staff from Matthew Hutley with updated Invoice NU!llber 67967 maiked "PAID" Exhibit 15 Respondent's email dated Decembe1 3, 2014 with invoices, additional emails and non-executed contract Exhibit 16 Section 106 143, Florida StatUies Exhibit 17 Respondent's email dated May 30, 2014, at 3:11 p .. m.

Inv004 (5/08) OFFICE USE ONLY RfCEIVED STATEMENT OF 1;E",,_1·: ::1n oF s1A11: CANDIDATE 2014 HAY 19 AH IQ: 03 (Section 106 .. 023, F .S .) (Please print or type)

I, Michael John Dreikorn

candidate for the office of Florida State Senate District 30

have been provided access to read and understand the requirements of

Chapter 106, Florida Statutes.

...... -.... ~·

'--·--·· x ( 14 May 2014 ignature of Candidate Date

Each candidate must file a statement with the qualifying officer within 1O days after the Appointment of Campaign Treasurer and Designation of Campaign Depository is filed Willful failure to file this form is a first degree misdemeanor and a civil violation of the Campaign Financing Act which may result in a fine of up to $1.000, (ss 10619(1)(c), 106 265(1) Florida Statutes).

JJS-L>E 84 ( 05111)

EXHIBIT-·---- I ( ! I,

RECEIVED DEPM ·;·, :::tff OF SlAI l APPOINTMENT OF CAMPAIGN TREASURER AND DESIGNATION OF CAMPAIGN DEPOSITORY FOR CANDIDATES 2014 HAY 19 AH to: 03 (Section 106 021(1), F S) ,:11,;s;G ~OF ELFCTIONS (PLEASE PRINT OR TYPE) f/;l 1\HASSEc. FL

NOTE: This form must be on file with the qualifying officer' before ooeninq the campaiqn account. OFFICE USE ONLY 1. CHECK APPROPRIATE BOX(ES): IE] Initial Filing of Form Re-filing to Change: 0 Treasurer/Deputy 0 Depository 0 Office D Party 2 Name of Candidate (in this order: First Middle Last) 3 Address (include post office box or street, city, state, zip code) Michael John Dreikorn ·- P 0 Box 654 4 Telephone 5 E-mail address Bokeelia, FL 33922 (239 ) 283-2197 MD@MichaelDreikorn com 6 Office sought (include district, circuit group number) 7 If a candidate for a nonpartisan office, check if Florida State Senate District 30 applicable: D My intent is to run as a Write-In candidate --~· ·- 8 lf a candidate for a partisan office, check block and fill in name of party as applicable: My intent is to run as a Republican D Write-In D No Party Affiliation ~ Party candidate 9 I have appointed the following person to act as my ~ Campaign Treasurer D Deputy Treasurer 10 Name of Treasurer or Deputy Treasurer Darlene Marie Soler 11 , Mailing Address 12 Telephone PO, Box 654 ( 239 ) 283-2197 - ·~-- 13 City 14 County 15 State 16 Zip Code 17 E,·mail address Bokeelia Lee FL 33922 [email protected] 18 I have designated the following bank as my D Primary Depository 0 Secondary Depository - ·--- 19 .. Name of Bank 20 Address -----·- SunTrust 10202 Stringfellow Rd. 21 City 22 County 23 State --· 24 Zip Code St. James City Lee FL 33922

UNDER PENALTIES OF PERJURY, I DECLARE THAT I HAVE READ THE FOREGOING FORM FOR APPOINTMENT OF CAMPAIGN TREASURER ANO DESIGNATION OF CAMPAIGN DEPOSITORY AND THAT THE FACTS STATED IN IT ARE TRUE

25 Date 26 Signatp 14 May 2014 x 11 . . \ -a··-· .. 27 Treasurer's Acceptance of Appointment (fill in the~ lanKs and check the appropriate block)

I, Darlene Marie Soler .. . do hereby accept the appointment (Please Print or Type Name)

designated above as: ~ Campaign Treasurer ,...,o D:puty 9••;urer ~ 14 May 2014 x /, 'J (ii,. 1 ~~) A Date •signature of Campa1gn1 reasure o~Deput Treasurer - OS-DE 9 (Rev .. 10110L ·J ( J>, 1) Rule 15-2,,0001, FAC.. EXHIBIT_6;.._1 OJ ,.., RCCEJVED APPOINTMENT OF CAMPAIGN TREASURER 1)F!>. '

(PLEASE PRINT OR TYPE) .:'iV;S!!lli OF E.E.CflOHS ift l .AllASSfE. FL NOTE: This form must be on file with the qualifying officer before oaening the campaian account. OFFICE USE ONLY 1. CHECK APPROPRIATE BOX(ES): 181 Initial Filing of Form Re-filing to Change: D Treasurer/Deputy 0 Depository D Office D Party 2 Name of Candidate (in this order: First, Middle Last) 3 Address (include post office box or street city, state zip code) Michael John Dreikorn P 0 Box 654 4 Telephone.... ~ 5 E-mail address Bokeelia,Fl. 33922 (239 )_ 283-2197 MD@Michae!Dreikom com. 6. Office sought (include district, circuit. group number) 7 If a candidate for a nonpartisan office, check If Florida State Senate District 30 applicable: D My intent is to run as a Write-In candidate 8 If a candidate for a partisan office, check block and fill in name of party as applicable: My intent is to run as a -- D Write-In 0 No Party Affiliation 181 Republican Party candidate 9 I have appointed the following person to act as my D Campaign Treasurer !XI Deputy Treasurer ~- 10 Name of Treasurer or Deputy Treasurer ·- Michael John Dreikorn - 11. Mailing Address - - 12 Telephone P 0. Box 654 .• ( 239 ) 283-2197 13 City - 14 County 15 State 16 Zip Code 17 E-mail address Bokeelia Lee FL 33922 [email protected] 18 I have designated the following bank as my ~ Primary Depository 0 Secor1dary Depository 19 Name of Bank 20 Address SunTrust 10202 Stringfellow Rd. 21 City 22. County 23 State 24 Zip Code ·- St James City Lee FL 33922

UNDER PENAL TIES OF PERJURY, I DECLARE THAT I HAVE READ THE FOREGOING FORM FOR APPOINTMENT OF CAMPAIGN TREASURER AND ,_.,. DESIGNATION OF CAMPAIGN DEPOSITORY AND THAT THE FACTS STATED IN IT ARE TRUE 25 Date 2~-- Sig~r;r,f Cana · 14 May 2014 x /' "':---- I 27 Treasurer's Acceptance of Appointment (fill in the ~lanks ar1d check the appropriate""' block)

I Michael John Dreikorn _ , do hereby accept the appointment ""'""'"~'~"~'' designated above as: D Campaign Treasurer uuty Trea·~1 ~-- ,...? ~ .. · ·c __ .. 14 May 2014 X Date Signature of Campaign Treasurer Of'Ueputy Treasurer - 05-DE 9 Rev, 10/1 . Rule 15-2.0001, F AC.. ~XH!BIT---·"'' ~(:L G•f 4) (

APPOINTMENT OF CAMPAIGN TREASURER AND DESIGNATION OF CAMPAIGN _ RECEIVEu DEPOSITORY FOR CANDIDATES 1.{PtJITMLN r U' :· r ~ i: (Section 106 021(1), F S) 201HfAY 19 AM fl: 29 (PLEASE PRINT OR TYPE) "' •1•it.~i1;, I ...\t,;t~ NOTE: This form must be on file with the qualifying LiiYiSiON OF E!. ECTIONS officer before openina the camo.aian account. OFFICE USE ONLY 1. CHECK APPROPRIATE BOX(ES): l8l Initial Filing of Form Re-filing to Change: D Treasurer/Deputy D Depository 0 Office 0 Party 2 Name Of Candidate (in this order: First, Middle Last) 3 Address (include post office box or street, city state .. zip code) Michael John Dreikom P 0 Box 654 4 _Telephone 5 E-mail address Bokeelia, FL 33922 (239 ) 283-2197 MD@MichaelDreikorn com f.---... -- 6. Office sought (include district, circuit group number) 7 If a candidate for a nonoartlsan office, check if Florida State Senate District 30 applicable: D My intent is to run as a Write-In candidate. -- - ·····----- 8 If a candidate for a partisan office, check block and fill in name of party as applicable: My intent is to run as a D Write-In D No Party Affiliation l8l Republican Party candidate 9 I have appointed the following person to act as my Campaign Treasurer Deputy Treasurer -- lXl D 10 Name of Treasurer or Deputy Treasurer Darlene Marie Soler .. ·--- ··-·- 11 Mailing Address -- 12 Telephone P 0 Box 654 ( 239 ) 283·-2197 13 City ----14 County 15 State 16 Zip Code 17 E-mail address Bokeelia Lee FL 33922 [email protected] 18. I have designated the following bank as my D Primary Depository 0 Secondary Depository - - - -· -- 19 Name of Bank 20 Address SunTrust - 10202 Stringfellow Rd.--·-·---· 21 City 22 County 23 State 24. Zip Code St. James City Lee FL 33922

UNDER PENALTIES OF PERJURY, I DECLARE THAT I HAVE READ THE FOREGOING FORM FOR APPOINTMENT OF CAMPAJGN TREASURER AND DESIGNATION OF CAMPAJGN DEPOSITORY AND THAT THE FACTS STATED IN IT ARE TRUE .. ..,__ __ , 25. Date -- 26 Si~~];J;~-7 12 May 2014 x ' ·- 27 Treasurer's Acceptance of Appointment (fill in the bl~nks and check the appropriate block)

I, Darlene Marie Soler ·---- , do hereby accept the appointment -- (Please Print or Type Name)

designated above as: ~ campaign T;su:o ~easurer- ~u_ 12 May 2014 Date Signature of Campaign Treasurer or Deputy'l'reasurer

OS-DE 9 (Rev 10/10) Rule 1S·2.0001, F.AC.

r-VLJIOIT ,. ( j I" '

APPOINTMENT OF CAMPAIGN TREASURER AND DESIGNATION OF CAMPAIGN ·. f?E.cc: .. DEPOSITORY FOR CANDIDATES lrEPARTMtN/r~E, p (Section 106 021(1), F.S ..) 20f4HAY 19 ' ' '.: (PLEASE PRINT OR TYPE) . 411//:29 i"\J'".."'' HI . . NOTE: This form must be on file with the qualifying ,, v1s 10 ~ ,,_,_, 1 , • . officer before opening the camoaign account. ' OF EUr,':_11;/:;_ OFFICE USE ONLY . '., 1. CHECK APPROPRIATE BOX(ES): IE.I Initial Filing of Form Re-filing to Change: 0 Treasurer/Deputy O Depository D Office D Party 2. Name of Candidate (in this order: First, Middle, Last) 3 .. Address (include post office box or street, city, state, zip code) Michael John Dreikorn PO Box654 4. Telephone 5 E-mail address - Bokeelia, FL 33922 (239 ) 283-2839 [email protected] '" 6 Office sought (include district, circuit, group number) 7.. If a candidate for a nonpartisan office, check if Florida State Senate District 30 applicable: D My intent is to run as a Write-In candidate ... - -- 8 If a candidate for a partisan office, check block and fill in name of party as applicable: My intent is to run as a D Write-In D No Party Affiliation [8J Republican Party candidate 9 I have appointed the following person to act as my D Campaign Treasurer D Deputy...• Treasurer 10 Name of Treasurer or DeputyTreas

UNDER PENAL TIES OF PERJURY, I DECLARE THAT I HAVE READ THE FOREGOING FORM FOR APPOINTMENT OF CAMPAIGN TREASURER AND DESIGNATION OF CAMPAIGN DEPOSITORY AND THAT THE FACTS STATED IN IT ARE TRUE. "--" 25 Date 26 $~nature t Ca~::t - 12 May 2014 x -~ ,/ G---. -·-- 27 Treasurer's Acceptance of Appointment (fill in the blal ks and check the appropriate block) Michael John Dreikom I --- . do hereby accept the appointment (Please Print or Type Name) designated above as: D Campaign Treasurer l8J Deputy Treas~. 12 May 2014 ---· --·· x~ s>«/7 --- Date ~ oTCampaign Treasurer or Deputy Treasurer Rule 1s.. 2 .. 0001, FAC DS·DE9(Rev.. 10/10) . ·,/ _f' tl EXHIBIT 2-c-'r =-1-f; FLORIDA ELECTIONS COMMISSION PHONE LOG Case No,.: FEC 14-138

Respondent: Michael J. Dreikorn Complainant: Fidel Balan

L Date and time: 09/16/14; 10:34 Name: Fidel Balan-Complainant Phone#: 239-292-9372 Summary: I phoned and reached his voice-mailbox; I identified myself, provided my contact number and requested he return my call regarding the complaint he filed against Respondent Dr Dreikorn. Memo to File? No Entered by: HH

2 Date and time: 09/16/14; 10:36 am Name: Dr Michael J Dreikorn-Respondent Phone#: 239-558-8525 Summary: I phoned the number identified on the complaint, arrd reached a voice mailbox; I identified myself, provided my contact number and requested he/R return my call regarding the complaint filed against him/R Memo to File? No Entered by: HH

3. Date and time: 09/16/14; 10:42 a.m. Name: Dr Michael J Dreikom-Respondent Phone#: 239-283-2197 Summary: I phoned, reached his voice-mail message informing me that I had reached his campaign office for State Senate, and requested that I leave a message; I identified myself, provided contact information and requested he return my call regarding the complaint filed against him Memo to File? No Entered by: HH

4.. Date and time: 09/16/14; 11: 15 a. m Name: D1. Michael L Dreikorn-Respondent Phone #: 239-283-2197 (caller ID .. ) Summary: Respondent returned my call; I explained that I had previously left a message at PH: 239-558-8525; Respondent said he did not recognize that number Respondent believes the You I ube video is not required to have a disclaimer since there is no cost to upload a video on You Tube, a fiee Internet website, pursuant to s 106 143(\0)(d), F .S.

Respondent explained that a local vendor Torchlight Productions produced the video; it was not solicited by him, there was never arry implied or explicit agreement, etc.. They produced it as an inducement for him to enter into a contract with them for services to his campaign Respondent said the vendor uploaded the video without a couect disclaimer;

EXHIBIT 3 (/ o\29) lnvOOI (10/07) / ) I• (

then after the media attention, one was added; however, the disclaimer was inconect; later, he informed the vendor to provide the conected disclaimer that is currently on the video .. After all of the media attention and complaint, he paid the vendor $1,000-$1,200 and they parted ways. Respondent believes the campaign expenditure to Torchlight Productions was disclosed in his June 2014 report

Respondent declared that no one from the division (DOE) picked up a phone to let him know they would not accept his Form DS-DE 9 by fax And it took seven days (May 12 - 19, 2014) by mail to reach Tallahassee I requested he provide copies of any co11espondence and filings to the division including emails and faxes; he agreed to provide same Respondent said he ran for Congress (special election, US House, District 19) five months before qualifying for the Florida Senate seat, Dist1ict 30 ..

Respondent said the RPOF supported his opponent and he could not believe the RPOF would take sides and support one Republican over another Republican Respondent said his neighbor's received mailings fi:om US Senator Marco Rubio in support of his opponent Respondent was disappointed that the RPOF spent so much money (over $100,000 .00) prior to the primaiy election in support of his opponent-the incumbent (Senator Lizbeth Benacquisto) I verified Respondent's conect mailing address, and Respondent p10vided his email address: [email protected] Memo to File? No Entered by: HH

5 Date and time: 09/16/14; 12:42 Name: T01chlight Productions, LLC Phone#: 1-877-75-TORCH (86724) Summary: I phoned identified myself and requested to speak with the project manager for Torchlight Productions who worked with Dr Michael J Dreikorn; my call was t1ansforred to "Matt" He asked why I was calling; I explained that I wished to know what services were provided by Torchlight P1oductions to Dr Dreikorn.. "Matt" explained he believes Chris Berardi was the project manager and p10vided his contact number, PH: 239-209-3861 However, he noted that he would have to confirm that Chris was the project manage1, and relay my message to him Memo to File? No Entered by: HH

6 Date and time: 09/16/14; 12:58 p.m Name: Matthew J. Hurley, Managing Membe1, Torchlight P1oductions, LLC Phone#: UNK Summary: He phoned and explained that their clients work with them "on a non disclosure agreement" and he wished to know why I was requesting information; I explained that my investigation is confidential and release of any information, including info1ming D1 D1eikom of my request, is a violation of State law He p1ovided his personal cell phone number, PH: 239-223-8941; and his email address: [email protected] Memo to File? No Entered by: HH

EXHIBIT_9 ('.2.&'i) INVOOI (12/01) 2 7.. Date and time: 09/16/14; 1:30 pm. Name: Matthew J Hurley, Managing Member, I orchlight Productions, LLC Phone#: 239-223-8941 Summary: I phoned and reached his voice-mailbox; I identified myself, provided my contact information and explained that I was working on a records request/subpoena and requested he return my call and again, provided my contact number. Memo to File? No Enter·ed by: HH

8.. Date and time: 09/17/14; 12:38 pm Name: Matthew l. Hurley, Managing Member, I orchlight Productions, LLC Phone#: UNK Summary: He phoned and reached my voice-mailbox; he identified himself, explained that he wished me to retum his call regarding my email (subpoena) and provided his contact number, PH: 239-223-8941 Memo to File? No Entered by: HH

9.. Date and time: 09/18/14; 9:27 am. Name: Matthew J. Hurley, Managing Member, Torchlight Productions, LLC Phone#: 239-223-8941 Summary: I returned his call and reached his voice-mailbox; I identified myself~ provided my contact information, explained that I was returning his call regarding my subpoena and again, provided my contact information Memo to File? No Entered by: HH

I 0. Date and time: 09/18/14; 11 :03 am Name: Fidel Balan-Complainant Phone#: 239-292-9372 Summary: Complainant returned my call; he wishes to withdraw his complaint since I informed him it may take several months before this case is heard by the Commission to determine probable cause or no probable cause. C explained that it sounds like trying to punish a child for a wrongfol act that occuned 7 or 8 months earlier; he believes the punishment must be immediate to be effective.. I informed C that I need his request to withdraw his complaint in wiiting, and it will be presented to the Commission; I noted they may agree and dismiss the complaint or they may find that there is reason to continue the investigation, etc C said he'd been contacted by the media regarding the complaint; however, he said he informed them that the complaint speaks for itself; C is unaware if R has addressed the complaint in the media.. C said that he'll discuss his withdrawal of the complaint with some of his friends and get back to me later. Memo to File? No Entered by: HH

11.. Date and time: 09/18/14; 2:3 7 p.m Name: Matthew J. Hurley, Managing Member, I orchlight Productions, LLC Phone#: 239-223-8941

EXHIBIT 5 (3 ;!__0i) INVOOI (12/01) 3 (

Summary: I returned his call and reached his voice-mailbox; I identified myself, provided my contact information, and explained that I was returning his calL Memo to File? No Entered by: HH

12.. Date and time: 09/23/14; 12:55 Name: Matthew J Hurley, Managing Member, Torchlight Prnductions, LLC Phone#: 239-938-3341 Summary: I phoned, identified myself and requested to speak with Mr, Hmley; my call was transfoned to Mr Hurley. I identified myself and asked if there would be a problem in my receiving the subpoena production by tomorrow, September 24, 2014; he said that would be no problem I asked about the "Dreikom Agreement" dated April 29, 2014, that was attached to an email that was provided to me earlier Mr Hurley explained that there was no signed (executed) contract; however, he would comply and provide legible copies of any and all invoices, payment instruments, etc .. , as requested in the subpoena Memo to File? No Entered by: HH

13 Date and time: 10/06/14; 5:12 pm .. Name: SunTrust Bank subpoena services Phone#: 1-877-220-9402, X-6 Summary: I phoned, reached the voice-mailbox and was directed to leave a message; I identified myself by name, title and name of agency, provided my subpoena number and stated that production was due by September 30, 2014, and I've received no records or request for extension of time in which to provide them Again, I provided my contact number Memo to File? No Entered by: HH

14 Date and time: 10/07/14; 3:12 p.m. Name: Vernicher ("V") Nicholas, SunTrust Bank subpoena services Phone#: 407-762-5585 (caller LD) Summary: She identified herself and explained that she was returning my call from my message left on their voice-mailbox; she apologized for the delay in producing the records; however, they were mailed out this morning and I should receive them no later than Friday, October 10, 2014 She noted they rely on third-party vendors and have been inundated with subpoenas I asked how many records were produced; she said 21 pages Memo to File? No Entered by: HH

15 Date and time: 10/14/14; 12:19 pm Name: SunTrust Bank subpoena services Phone#: 1-877-220-9402, x-6 Summary: I phoned the number identified on the caller I.D for the previous telephone entry number 14, PH: 407-762-5585; however, I received the message that I had "reached a non-working SunTrust number" Then I called the number indicated above, and received the voice-mailbox message to leave a message, which I did; I identified myself, provided EXHIBIT--- -3 ( 4-cJ· Cf) INVOOI (12/01) 4 ( \

my contact information, explained that the records provided were incomplete regarding subpoena number: 14-138-42, and noted that I had a certificate completed by Miriam L Perez, and requested someone to please return my calL Memo to File? No Entered by: HH

16. Date and time: 10/14/14; 1:59 pm Name: Miriam Perez, SunTrust Bank subpoena services Phone#: 407-762-5578 (caller ID) Summary: She returned my call; she explained that she did not complete a search for the records but briefly reviewed and mailed the records.. She confirmed her direct contact number as identified above, but noted she will be there for 13 working days and then she retires She requested that I put my request in writing, an email is sufficient, and reference "SS-58698" and identify the missing records-"[r]ecords disclosing the current status of the account and the date when the account was closed, if applicable .. " I noted that I am usually provided the last bank statement or the cur1ent bank statement when an account remains open Ms. Perez provided her email address: [email protected]. Memo to File? No Entered by: HH

17 Date and time: 11/07/14; 12:48 p.m Name: Joel Mynard at the DOE Phone #: 245-6245 Summary: I phoned in response to his email declaring there were "[n]o notes found " I identified myself and explained to Mr .. Mynard that I believe that Terri Lawson, Randy Johnson and Kiisti Bronson communicated with candidate# 62175/Respondent between May 12 and 19, 2014, including by email Mr Mynard explained that he is unable to view the history notes on his system, and had to obtain that information from Donna Brown; he placed my call on hold briefly and then transfe!led it to Donna Brown (245-6243)

I explained to Ms .. Brown that the candidate/Respondent said he had several email and phone conversations with Teni Lawson, Randy Johnson and Kiisti Bronson including emails to [email protected] between May 12 and May 19, 2014 Ms Brown explained that she is able to review notes at [email protected] going back to September when she was given access, and none are available; however, she is unable to access records for Lawson and Johnson since they are no longer employed by the Bureau Therefore, she will check farther (presumably with IT and or Ms .. Bronson) and will return my call; we exchanged contact information (Note she identified [email protected] as the general email contact for the Bureau of Election Records) Memo to File? No Entered by: HH

18. Date and time: 11125/14; 4:15 pm Name: Donna Brown, the DOE, Bureau of Election Records Phone#: 245-6243

EXHIBIT 3 (5 of 1J !NVOOl (12/01) 5 (

Summary: I phoned, identified myself, refreshed her memory regarding the records I had requested on November 7, 2014 .. Ms Brown explained that Kristi had informed her that no emails were available for Teni Sue Lawson and Randy Johnson since they were no longer working for the DOE; she and I both thought the emails were maintained by IT pursuant to public records requirements. I explained that my que1y also included [email protected]. She believed that Kristi was going to respond to me but since she has not, she will make anothe1 que1y on Monday, when Ms. Bronson returns to WOik Memo to File? No Entered by: HH

19 Date and time: 11/26/14; 1 :03 p.m Name: Donna Brown, the DOE, Bureau of Election Records Phone#: 245-6243 ( calle1 LD) Summary: She phoned and explained that "Kristi" found three emails and fo1warded them to her, Ms Brown; Ms. Brown requested and I p10vided my email add1ess so she may fo1waid then to me. Memo to File? No Entered by: HH

20 Date and time: 12/03/14; 12:01 pm Name: Dr.. Michael J D1eikorn-Respondent Phone#: 239-283-2197 Summary: I phoned Respondent to conduct a final inte1view by telephone and give him an oppo1tunity to respond to the information gathe1ed during the couISe of the investigation concerning the allegations made in the complaint, and I asked R if now is convenient fot him; R agreed. During my 1eview of my ROI, I 1eviewed with R the DOE's Rule lS-2.000l(l)(a), and lS-2 0001(2)(a), FAC During my review of section 106 11 ( 4 ), F S., I noted that many candidates make an initial loan to their cainpaign to jumpsta1t it so they will not rnn afoul of the election laws; R said he was "tapped out" after completing a congressional campaign R intimated that he was promised many cont1ibutions that never mate1ialized; R's opponent (Sen Lizbeth Benacquisto) had almost $1 million in contributions to his $15,000 plus; and she received 59 5% of the votes to his 40.5% of the votes

R said my repo1t seems very one-sided; I noted that his non-sworn response to the complaint dated June 12, 2014, his sworn response to the complaint dated July 29, 2014, and his non-sworn questionnaire I received by email, on October 20, 2014, will be included as exhibits in my ROI, and available to the Commission I noted that I have not received his executed affidavit-questionnaire, only his typed responses entered on the questionnaire-not signed, dated or notarized; R said since he missed the deadline (October 31, 2014) he decided to not have it executed and submit it Also, I noted that he had oppo1tunities to p1ovide reco1ds and input; however, nothing additional was received R asked ifl subpoenaed the records from I orchlight; I affomed

R said this f

EXHIBIT -3 ( (,, ~ 'i) !NVOOI (12/01) 6 / (

from the state is $200,000.. R suggested that I don't even have a valid complaint; R said Complainant "Fidel" is dead I said I have spoken with Complainant and assured R that he/C was not dead when I spoke with him/C earlier in my investigation. And I assured R that I have a properly executed complaint-including signed, dated and notarized Oiiginal. R offered that C was paid by his opponent and an agent of her campaign. I explained to R that the Commission and staff are well aware that many of the complaints we receive are politically motivated

R asked if I knew that Torchlight/SE Strategies were three "minors"; I explained that was unknown to me; however, it appears they are not minors but at least 18 years old as they are principals in an entity registered with the Division of Corporations; R said they are 19 OJ 20 year old kids .. I offered then they are "not minors" R said I should depose them. R alleges that the terms of the (unexecuted) contract required TOichlight to raise money for his campaign, meet certain thresholds and since they failed to do so he had no obligation to pay them

I agreed to accept his executed affidavit-questionnaire, a copy of the unexecuted contract between him and Torchlight, and any additional information confirming that he refosed to accept their/Torchlight's services, etc, if submitted to me by Friday, December 5, 2014, and incorporate the additional information in my ROI, and update my ROI, if needed.. I noted that my ROI is due very soon in order to make the February 2015 agenda. I also noted that R should have my email address since I had emailed the affidavit-questionnaire to him several months ago; I again provided my email address and R said he should find the contract within the hour and email it to me

R intimated that a federal candidate (??-Kurt Clawson) who was recently elected and is now a fiiend of R's warned R that they/Torchlight caused him (the federal candidate) major problems due to their handling of the federal candidate's campaign arrd he/R should have no dealings with them. Memo to File? No Entered by: HH

21 Date and time: 12/17/14; 11:25 am Name: Dr .. Michael J Dreikorn-Respondent Phone#: 239-283-2197 Summary: I phoned, his assistant Ms Darlene Soler (also campaign treasure1) answered his phone, info1med me that he was out of the office until later this evening and would return my call tomonow, Thursday, Decembe1 18, 2014, if I wished to leave a voice-mail message; I agreed and my call was transferred to his voice-mailbox; I identified myself, prnvided my contact information, explained that I have reviewed his submissions including those dated on or about December 3, 2014, and believe he may benefit from ente1ing into negotiations with our legal staff directed towaid settlement, and requested he return my call Memo to File? No Entered by: HH

22 Date and time: 12/18/14; 12:30 pm.

EXHIBIT 3 (7 cf'q)

INVOOl (12/01) 7 Name: SunTrust Bank subpoena services Phone#: 1-877-220-9402, x-6 Summary: I phoned and reached theiI voice-mailbox; I identified myself; provided my contact number and referenced "SS-58698"; I explained that my former contact, the subpoena coordinator at Sun Trust Bank subpoena services, Miriam Perez, has retired and I wish someone to return my call, and I again provided my contact number.. [Copies of deposit slips/tickets, if available, and checks (cleared in June 2014) including check numbers 1490 in the amount of $196.10; 1491 in the amount of $150.00; and 1492 in the amountof$1,781.82 .. ] Memo to File? No Enter·ed by: HH

23. Date and time: 12/18/14; 3 :56 p m. Name: Jamese Sconiers, SunTrust Bank subpoena services Phone#: UNK Summary: She returned my call and I explained that I am missing three checks; she requested that I fax my request to her identifying the check numbers, amounts, etc , so she -may properly identify them I noted deposits were made by "online banking transaction:" She said there would be no paper record (such as deposit slips/tickets) other than what appears on the bank statements. She provided her contact information, PH: 407-762- 5575; FAX: 877-220-9403 I asked how soon I may have the records; she noted if she receives my request today, she will complete it tomonow -Memo to File? No Entel'ed by: HH

24. Date and time: Friday, 12/19/14; 11:30 am Name: Ms. Jamese Sconiers, SunTrust Bank subpoena services Phone#: 407-762-5575 Summary: I phoned and reached her voice-mailbox message providing her contact information including address at 7455 Chancellor Dr., Orlando, FL 32809; I identified myself, provided my contact number and asked her to confirm her receipt of my fax from yesterday; if she required any additional information; and when I should expect my records Memo to File? No Entered by: HH

25 Date and time: 12/19/14; 12:20 p.m Name: Dr Michael J. Dreikom-Respondent Phone#: 239-283-2197 Summary: I phoned, Respondent answered the phone, I identified myself and he explained that he was in Boston all day and wasn't able to return my call. I explained that after reviewing his submissions and records I had obtained during my investigation, it appears he had benefit of the video (beginning on May 12) on his campaign website and YouTube, did not have his campaign depository opened and no deposit was made until May 21, 2014, and he did not have sufficient fonds on deposit to cover the amount identified in the Invoice he received by email on May 27, 2014, for the campaign video

INVOOI (12/01) 8 / I I (

(video editing, video shoot and graphic design in the amount of $1,250 .. 00) until later in June when he paid the vendo1 (Torchlight)

Respondent said we have nothing; he made no contract and did not authorize the production of the video.. I noted his email wishing the campaign video would "go viral" and expressing his approval; he explained that he wishes Santa Clause would come and drop a bunch of money to him on the 25th but he doesn't expect that to happen. In reference to the email, R said, "That's hearsay." Respondent declared that he used to be a "fodernl investigator" and then continued Respondent declared that he will fight this all the way and demands a heaiing.. Respondent declared that he will not settle

I 1equested that Respondent keep Commission staff informed of any changes in contact information especially if he requests a DOAH heaiing since he declaied he was going to fight this all the way; R wished to know what "DOAH" meant I explained that is the Division of Administrative Hea1ings and there rue two types of hearings after a finding by the Commission of prnbable cause: Respondent's may request a fo1mal heaiing befo1e DOAH; or an informal heaiing befo1e the Commission .. I noted this case should be on the Febrnaiy agenda and the agency clerk will prnvide a Notice of Hearing identifying the date, time and location of the meeting. Memo to File? No Entered by: HH

26 Date and time: Name: Phone#: Summary: Memo to File? No Entered by:

27. Date and time: Name: Phone#: Summary: Memo to File? No Entered by:

28 Date and time: Name: Phone#: Summary: Memo to File? No Entered by:

29 Date and time: Name: Phone#: Summary:

EXHIBIT -3 ('1of'11) INVOOl (12/01) 9 (

Exhibit A

http.s://www.youtube.com/watch?v=B2BiRUW]7Sg

EXHIBIT'...... ;;./- __ Page 1of1 ( ' Notarized Response Dr Michael Dreikom to: Helen Hinson (Helen.Hinson@myflo1idalegaLcom) 12/03/2014 01 :57 PM Show Details

1 Attachment ~ Affidavit ofM Dreikom background info- FEC 14-138 signed.pd!

Helen: Please see the attached notarized response

Regards, Michael

Michael J. Dreikorn, Ed ..D 5697 Bay Point Rd. I Bokeelia, FL 33922 .. 0 2392832839 I F 239 283.2197 I c 239 8987660 Email: [email protected] Linkedln: www.linkedin.com/pub/michael-dreikorn-ed-d/8/876/b4a/

''Never doubt that a small group of thoughtful committed citizens can change the world Indeed it is the only thing that ever has · - Margaret Mead

Legal Notice.:· This e--moil is intende·d only for the· above addressee ft may contain privilege·d information If you are not the addressee you must not copy, distribute, disclose or use any of the Information in it If you hove received it in €'((Or please delete it and immediately notify the sender Security Notice;· All e-mai( sent to or from this address. may be· accessed by someone other than the recipient, for syste·m management and security re·asons This access is controlled under Re-gu/ation of Investigatory Powers Act 2000, lawful Business Practices J.J Please consider your environmental responsibility before printing this e.mail

file:///C:/Users/Hinsonh/AppData/Local/T emp/notesFCBCEE/-web9721.htm 12/19/2014 ( I I '

AFFIDAVIT OF BACKGROUND INFORMATION Case Number: FEC 14-138

STATE OF FLORIDA County of Lee

Michael John Dreikom, being duly sworn, says:

I This affidavit is made upon my personal knowledge. 2 I am of legal age and competent to testify to the matters stated herein.. I am cunently employed by SELF as SELF.

3 Have you ever run for public office? If so, please name the office(s) you ran for; the date(s) of the election(s) you ran in; and the outcome(s) of the election(s); also, include any races from which you withdrew as a candidate noting if you withdrew before or after qualifying Yes. US. Congress, Special Election 2014 for CD-19. Florida State Senate, district .30, open primary.

4 Have you ever been appointed to act as a campaign treasurer and/or deputy treasurer for a candidate? If so, please name the candidate(s) you se1ved as treasurer/deputy treasurer including your candidacy; the office(s) the candidate ran for; and the dates of the election(s). Deputy treasurer in both of the above campaigns..

5 Have you ever held the office of chairperson or campaign treasurer (or deputy treasurer) for a political committee? If so, please list the names and addresses of the committees, the position you held, and dates you held the position(s) No"

6 Have you ever held the office of chairperson or campaign treasurer (or deputy treasurer) for a committee of continuous existence (CCE)? (Committee of continuous existence is defined in Section 106.04, Florida Statutes (2012).) If so, please list the name and addresses of the committees, the position(s) you held, and date(s) when you held the position(s) No.

7. What action have you taken to determine your responsibilities as a candidate under Florida's election laws? (Please explain what you did to determine what was required of you as a candidate under Florida's election laws, such as the following: contact your filing officer; contact the County Supervisor of Elections (SOE); contact an attorney; review documents provided by the filing officer; review documents and or publications available on the SOE's website; review documents and or publications on the Division of Elections' website; etc .. Please identi(y persons you contacted, the date(s) they were contacted and or documents/publications you reviewed, and when, etc

EXHIBIT_§ (J.cfl() lnv040 (6/08) I have read the statutes, called the FEC for guidance, read the FEC guidance documents and complied with r·equisite requirements ..

8. Please explain if you sought guidance from anyone (county supervisor of elections, Division of Elections, an attorney, etc ..) prior to obtaining the video that is of concern to Complainant If so, please include in your explanation the following: when you sought guidance; flom whom you sought guidance; and the specific guidance they ptovided concerning Florida's election laws No.

9. Do you possess a copy of Chapter 106, F lotida Statutes? [g) Yes 0 No 10.. lfso, when did you obtain it? __May, 2014______11 Have you 1ead Chapter 106, Florida Statutes? [g) Yes 0 No 12. Do you possess a copy of the Candidate and Campaign [g) Yes 0 No Treasurer Handbook? 13.. lfso, when did you obtain it? __Nov 2013 ______14 Have you read the Candidate and Campaign Treasurer [gj Yes 0 No Handbook?

15. Please desctibe any discussions or cotrespondence you had with the filing officet 01 a member of her/his staff during your 2014 campaign, and include the date(s) of the contact(s); identify the subject matter, and 1eason for the contact(s)

Between May 12 and May 19, 2014, I had several email and phone conversations with DOE representatives (Teni Lawson, Kristi Bronson and Randy Johnson.) On May 12'\ my campaign documents were electronically provided to the DOE (,'elecr·ecords@dos .. myflorida .. com') and r·eceived without any subsequent notice of rejection. The electrnnic document package was subsequently resent on May 13.. Paper originals were mailed on May 12 and again "overnighted" via USPS on May 14. A "Read Receipt" was received on May 13 from DOE representatives Lawson and Johnson, and on May 14 from Bronson. On May 14, I called DOE representative Johnson, at this time I had no confirmation from DOE that my documentation package had not been accepted, yet Johnson confirmed that they were aware of my electronic submittal and that a complaint might be in the works. I immediately removed the subject video from YouTube and suspended all campaign activities. On May 15, 16 and 19, I called Johnson inquiring as to the status of my application package. On the 19'\ Johnson confirmed receipt and acceptance.. Johnson also indicated that the office would not pursue action against me, unless there was a complaint..

Once the complaint was received by the DOE from a supporter of my opponent, I was informed via letter and this r·esponse process was initiated.

EXHIBIT S' (3 of 10 lnv040 (6/08) 2 /

16. Complainant alleged that you were required to appoint a campaign treasurer and designate a campaign depository (Form DS-DE 9, Appointment of Campaign Treasurer and Designation of Campaign Depository for Candidates) prior to making expenditures or accepting an in-kind contribution for the prnduction of a campaign video, but failed to do so .. And you may have incurred campaign expenses prior to having sufficient fonds on deposit in a campaign depository (Alleged violations of Sections I 06 021 (I )(a), I 06. I I(4), and I 06.19(1 )(d), Florida Statutes) Aside from the initial filing of the complaint, to the best of my knowledge, the complainant has failed to respond to DOE inquiries. As the details associated with the complaint made by this complainant are speculative, he has failed to substantiate with evidence the char·ges .. As pr·eviously explained in written responses to your office, the campaign treasurer· was appointed on May 12 and officially accepted by DOE on May 19. The statute requires 1 appointment by the candidate, and that was accomplished on the 12 h of May,, The subject video was not an approved expenditure at the time, and was not accepted by the campaign until eady June. Torchlight's production of the video was based on speculation that my campaign would accept the video. Once the video was accepted by the campaign, expenditure was authorized (June 24).

17. Also, Complainant alleged that you failed to include with your campaign video a proper political advertisement disclaimer (Alleged violation of Section I 06 .. 143(1 )(a), Florida Statutes ) [Note a prnper disclaimer is as follows: 1 "Political advertisement paid for and apprnved by (name of candidate), (patty affiliation), for (office sought)"; m:: 2 "Paid by (name of candidate) , (party affiliation) , for (office sought) "]

As previously described in writing to your· office, the sub.iect video was exempt from the disclaimer· requirements., As provided in Section 106.143(10)(d), content "[p]laced at no cost on an Internet website for which there is no cost to post content for public users" does not require political disclaimers. The subject internet based video is not subject to the requirements of Section 106.143(1) and does not require the noted disclaimer. However', voluntarily, the sub ..iect video was modified prior to being reposted on "YouTube" as ifhad had been subject to the statutory required disclaimer language of relevant political advertising,, The alleged nonconforming video was on YouTube from the afternoon of May 12 to May 14 .. The video was reposted again on YouTube on or about May 20.,

18. It appears you contacted the Division of Elections ("DOE") on May 15, 2014 by telephone, and requested the status of your Form DS-DE 9 that had previously been faxed and or electronically transmitted to the DOE; the DOE acknowledged receipt of your Form DS-DE 9 by letter dated May 20, 2014 .. Please describe and explain the steps you took to determine how to file your Form DS-DE 9, and by what means, with the DOE including, but not limited to, any websites you visited and publications you reviewed ..

EXHIBIT s'(fa-Fr r) Inv040 (6/08) 3 / (

• In r-esponse to Item 18, I incorporate the r-esponse of item 15.. In addition, I reviewed multiple times a day the DOE website to query my application status,

19.. Please describe and explain each step you took to file your Form DS-DE 9, and by what means, with your filing officer at the DOE.

Incorporate the responses of items 15 and 18. In total, the application package was prnvided four times to the DOE, twice electronically, once via normal USPS, and once "overnight" USPS. Appar·ently, the internal mail system at the DOE does not efficiently deliver· mail to its various offices, nor does it provide for notification of rejection for possible improper electronic filing ..

20 Please describe and explain the steps you took to determine that your Form DS-DE 9 was filed with the filing officer at the DOE including, but not limited to, visits to the DOE website, telephone calls, faxes, and or emails to the DOE staff Please provide copies of any supporting documents Incorporate responses to items 15, 18 and 19..

21 Please describe and explain what services were provided, and when, to your 2014 campaign for State Senate by Tor ch light Productions, LLC.

Prior to May 20, 2014, I engaged in various conversations with Torchlight Productions (aka SouthEastern Strategies}. The discussions r·elated to campaign management services they wished to offor me.. As a promotional offering, Torchlight developed the subject video, at their cost and risk. On May 12, Torchlight posted the subject video on YouTube with no expectation of being compensated for the video. As it turned out, Torchlight (aka SouthEastern Strategies) did not eventually represent my campaign. However, I desired to rntain use of the video and agreed, in June, to purchase it from Torchlight the video .. Prior· to pur·chasing the video, several changes were r·equired to be made for my acceptance..

The complainant alleged that I commissioned the development of a "television advertisement". I made no such commission, and he is making an inaccurate characterization of the video that is r·eforeuced.. The complainant has failed to respond in this matter and/or provide objective evidence of his allegations.,

22 It appears that email communications between you and the vendor, Torchlight Productions, LLC, occurred as early as Apr ii 28, 2014, and included an agreement that may not have been executed.. However, it appears the vendor developed your campaign website on or about May 8, 2014, and the campaign video on or before May 12, 2014. (Please note it appears the DOE informed you it did not have your Form DS-DE 9 on May 15, 2014; and acknowledged receipt of your Form DS-DE 9 on May 20, 2014 ..) Please respond to the allegation that you incurred an expense for the campaign video ptior to filing your Form DS-DE 9 with the DOE on May 19, 2014

EXHIBIT. 5'.f:I .,f 11) Inv040 (6/08) 4 /

Incorporate responses from items 15, 18, 19 and 21. Ther·e was never an executed agreement between Tor·chlight and my campaign.. In addition to the subject video, Tor·chlight developed a website, at their cost and risk, which we never· accepted. The website was not capable of accepting donations and had other quality flaws.. In June, I cr·eated a website for the campaign, using "Nationbuilder" as the platform.. There has never· been a formal or executed business relationship between my campaign and Torchlight. If the DOE and/or· FEC had evidence to the contrary, such is requested to be provided to me.

23 Please describe and explain how and when you obtained the campaign video and indicate when any payment for the campaign video was made to Torchlight Productions, LLG.

My campaign does not have control over the placement of the subject video. Torchlight created the YouTube account and posted it. Torchlight still has "Admin" control over that YouTube account. We never had any discussion about scope of video, cost of video, or· terms for· payment of a video.. When it became apparent that we would not be utilizing Torch light's services (mid-May), I inquired as to the price of maintaining the video .. These 1 discussions occurred after May 20 h.

24. Invoice No 67967, totaling $2,950 00, and dated May 9, 2014, indicates that payment was due in "FULL" by May 24, 2014.. The goods and or services provided by Torchlight Productions, LLC to your campaign included the following: custom web design; hosting (yearly hosting fee); video editing; video shoot; and graphic design. Please describe and explain if and when this invoice was paid and provide copies of any payment instruments; if payment was not made by you and or your campaign, please describe and explain why not

This invoice was never accepted by our campaign and did not r·eflect to oral discussions that we had with Torchlight. Any documents that may have been provided by Torchlight to your office have not been substantiated as accurate or complete"

25 A subsequent Invoice No 67967, totaling $1,262.00, and dated May 19, 2014, indicates that payment was due in "FULL" by June 19, 2014 The goods and or services provided by I orchlight Productions, LLC to your campaign included the following: video editing; video shoot; graphic design; and bank transaction fee Please describe and explain why and when charges for your campaign website were removed from Invoice No 67967; also, identify when goods and or services for the campaign website were paid, and include a copy of the payment instrument

Note that the invoice number is the same as in item 24. Incorporate website r·esponse from item 22.

EXHIBIT S-@ t>t' I() Inv040 (6/08) = - · 5 / I

As FEC has various f'evisions of the same invoice number', I f'equest to have all rncords FEC has obtained from Torchlight Of' from other sources, so that I can adequately rnspond to questions,. As of May 19, no goods or services were accepted by my campaign and no expenditures made, All efforts by Torchlight (aka SouthEastern Strategies) were at their risk and cost The only promotional product that my campaign eventually accepted from Tof'chlight was the subject video. My campaign puf'chased the subject video on June 19th and paid for it on June 241h and clearing the 25th (see attached bank statement)..

26 Invoice No 67967, totaling $1,262 00, and dated May 19, 2014, indicates that payment was due in "FULL" by June 19, 2014 The goods and or services provided by Torchlight Productions, LLC to your campaign included the following: video editing; video shoot; graphic design; and bank transaction foe.. Please describe and explain why Invoice No 67967 from Torchlight Ptoductions, LLC was re-issued with only charges related to the campaign video included on the invoice

My campaign is not and was not in control of Torchlight's invoicing or business practices, By incorporating my response in item 25, the invoices show Torchlight's attempts to salvage wor'k efforts that were not authof'ized by the campaign in scope or expenditure., In order for the campaign to use the video, we reached an agreement to pay Tof'chlight $1,262.00 to rntain the video on YouTube. Expenditure was approved on June 19th and paid on June 19th with check, and processed again on the 24th with a campaign bank card, which cleared on the 25th, (Note: The campaign account had sufficient fonds at the times of transactions.)

27. Invoice No. 67967, totaling $1,262 00, and dated May 19, 2014, indicates that payment was due in "FULL" by June 19, 2014 The goods and 01 services p1ovided by Torchlight Productions, LLC to your campaign included the following: video editing; video shoot; graphic design; and bank transaction foe.. Please describe and explain why charges totaling $12 00 for "Bank Transaction Fee" were added to Invoice No. 67967 from Torchlight Productions, LLC.

As previously stated, I have no control over Torchlight's invoice dating practices. However, the $12 bank foe was a f'esult of fonds being available in the deposit campaign account, but not transferred over to the campaign checking account, The campaign account had sullicient fonds at the time., The $12 was a bank fee for rnturning a check to Torchlight (reference response to 26)., As shown by Torchlight's practice of f'eusing previous invoice num hers and simply modifying invoice content multiple times, their invoices cannot be recognized as accurate or credible. Tof'chlight was paid using a campaign debit card on June 24th.,

28 It appears the campaign video was produced on 01 before May 12, 2014, and based upon your campaign treasurer's report (CTR) for that period, (your 2014 MS Report), there were no fonds on deposit until May 19, 2014, when you disclosed a $200 contribution from yourself

Inv040(6~H!BIT_,~ (7Qf 11) 6 (

Please respond to the allegation that you incurred campaign expenses for the campaign video prior to having sufficient funds on deposit in the campaign account

There is no refor·ence in our CTR to the subject video prior to late-June. There was no commitment to accept the subject video until mid-June. Our· June 24 CTR reflects the video acceptance.

29 Please explain why you disclosed a campaign expenditure totaling $1,262.00, dated June 24, 2014, to Torchlight Productions, LLC on your 2014 P2 Report (covering the period of June 21, 2014 through July 4, 2014) for "video production"

Incorporate responses 26 through 28.

30 Please respond to the allegation that your campaign video fails to have a proper disclaimer, "APPROVED AND PAID FOR BY MICHAEL DREIKORN J'.OR STATE SENATE" (Note the disclaimer language must be verbatim as quoted in s .. 106 143, F S. Variations are prohibited by law. Please refor to page 31 of the Candidate and Campaign Treasurer Handbook available on the Division of Elections' website)

Incorporate r·esponse 17 .. Reference: As pr·ovided in Section 106 ..143(10)(d), content "[p]laced at no cost on an Internet website for which there is no cost to post content for public users" does not require political disclaimers.

31. Please desctibe and explain how, when and from whom your 2014 campaign video obtained the specific disclaimet language, "APPROVED AND PAID FOR BY MICHAEL DREIKORN FOR STATE SENA TE." Identify any publications you reviewed or person(s) you contacted to determine the disclaime1 language required on your 2014 campaign video.

Incorporate response 30 .. Disclaimer and video content was in complete control of Torchlight..

32 It appears you contacted the vendor by email on or about May 30, 2014, to have the political disclaime1 changed on your campaign video Please describe and explain how, when and by whom your 2014 campaign video obtained the specific disclaimet language, "POLITICAL ADVERTISEMENT PAID FOR AND APPROVED BY DR MICHAEL J DREIKORN, REPUBLICAN FOR STATE SENTA TE."

Incorporate response 31. Please provide any materials you may be refoni.ng to and provide explanation as to how the FEC would be in possession of such documents. I I

33.. Identify any publications you reviewed and or person(s) you contacted to determine the disclaimer language required on your 2014 campaign video and explain when this was done

Incorporate response 32. Refol'ence: As provided in Section 106 .. 143(10)(d), content "[p)laced at no cost on an Internet website f(ff which there is no cost to post content for public users" does not require political disclaimers. Subsequent changes made to video were voluntary ..

34.. Please provide copies of any and all conttacts and or addendums; agreements; billing statements; invoices; receipts; proofa; work orders; and or list of goods and services, etc , related to the 2014 campaign video produced by Torchlight Productions, LLC

There was no noncompliance and this matter' is not subject to the rules of discovery. The complainant has not substantiated the allegations with their own evidence and has failed to respond to the FEC for farther· details .. Them were no documented agr·eements for services between my campaign and Torchlight. As previously descdbed, my campaign agreed to pay Torchlight for the subject video in June. Prior to such, my campaign made no obligations to Torchlight and any work they conducted was at their risk,

35. Please provide a copy of the "Dreikom Agreement" between you and Torchlight Productions, LLC and ptovided to you by email from Matthew Hurley on or about April 28, 2014

This document does not exist. There was never an agreement between "Michael Dr·eikom" and "Torchlight Productions, LLC"

36 Please provide copies of your written approval and or authorization to Torchlight Productions, LLC for the campaign video

This document does not exist There was never an agreement between "Michael Dreikom" and "Torchlight Productions, LLC." If the FEC is in possession of such a document, please provide to me ..

3 7 Please provide copies of your written request fot and 01 approval of the political disclaimer(s) added to the campaign video

Incor·porate r·esponse 34 ..

8 38 Please provide a legible copy (front and back) of the payment instrnment and or cancelled check you authorized as payment and disclosed on your campaign treasurer's report totaling $1,262 00 for the 2014 campaign video.

See attached bank statement

39.. Please provide a copy of your email submission on May 13, 2014, and the delivery receipt by the Division of Elections you referred to in your sworn response to the complaint regarding the filing of your Form DS-DE 9..

See attachments ..

40.. Please identify each staff member at the Division of Elections with whom you discussed filing your Form DS-DE 9; describe any discussions or correspondence (including fax, and emails) you had with the filing officer or a member of her/his staff during your 2014 campaign regarding filing your Form DS-DE 9, and include the date(s) of the contact(s)

Reference response 15.

41 Please describe the review process and/or any checks and balances in place to ensure that each CIR accurately reflected the campaign contributions (including in-kind contributions) received and the campaign expenditures made by your 2014 campaign prior to certifying each CIR

Campaign Treasurer reviews all agreements prior to making a commitment and approves transactions ensuring the campaign has sufficient fonds.

42. Please provide any additional comments you wish to make in the space below

If the FEC has obtained any documents from Torchlight directly, I request copies of such documents be provided to me.. Torchlight's practices of modifying documents (dates, invoice numbers, foes, etc) cause concem about the accuracy of documents as represented to the FEC.

1 At no time prior to May 19 h, 2014 did my campaign obligate itself to any expenditures .. The subject video was developed at risk of not being accepted, as all other proposed services wer·e rejected. An agreement to accept the video was made in June and paid for on June 24•h.

It is important to keep in mind, the subject application was provided to the DOE on May 12, 2014 .. There are records of rnceipt of these documents by DOE. At no time prior to me

9 (

contacting the DOE on May 14, did the DOE make any effort to notify me of' enms in processing of my application.

1he scope of the FEC investigation has extended beyond the original compliant. As the complainant has failed to respond to the FEC, the relevancy of this complaint is questioned by me. The complainant is a known suppo1ter, and sometimes employee (private investigator'), of' the opponent in this past Senate race and was politically motivated to issue this complaint.. Ibis complaint has no merit and there is no obvious public interest for· furthe1· investigation.

l HEREBY SWEAR OR AFFIRM THAI THE FOREGOING INF'ORMr.RUE ANO CORRECT TO """'••~~ow~oc' ~ff-~b_ .. __ sign~f~mant ':l s\Xtc e:::ed~bsR before m• •hi• ~00) of _io---~-·-sruA Signatu~,Q;: Sta;M~J.i-"''-''-=-'-'"'-""'-'...__ Prine., 'T)pC, or Stamp Commissioned Name of Notary Public

"• . DARLENE M.. SOLER . l ;.\ Notary Public • State of F1olida ·~ , t, 'iMyComm 1:Xplre~Sep11,201s

""""'<';~()l'f\V,~\ =~l eommlsslon ii EE 129310 fl~,.,, ....i~ Bonded Through National Notary Assn.

Personal!> Kno .... n ~ or Produced Identification ___ fypc ofklcntification Producl.!'d: ___,,,,,.~ ... ---·-"'-" .. ___

Case Investigator: HH

10 ,. '•) I ( (

Michael J. Dreikorn, Ed.D

:VUCHAEL PO Box 654 tel.: 239 283 2197 DREIKORN Bokee\ia, FL 33922 MD@Michae\Dreikorn com FOR I LORIDA SE"\JAIE

Florida Elections Commission r-n,- :;:l ""~>:1 Attn: Ms. Helen Hinson .· ..:'-\ ~J) -;;: .... ~ .:;-;·-\ 107 W Gains Street -\!.'~ --:.~~ 2:: rn Suite 224 Collins Building ~:~rn en ('") Tallahassee, FL 32399-1050 ,_.._.~;::;CJ ' fi\'l <_::-> ~n ·--·· ~:~r- - July 29, 2014 ·-·'•· ('._) '):.> < :-~~- -;v rn (f)2) ,9 \'..) Ref: Case No. FEC 14-138 :-.:.:vo (.)"\ ()"\ Dear Ms. Hinson:

In response to a letter from your office, date June 26, 2014, I am offering the following information to further your investigation The subject letter outlines four alleged violations to various Florida statutes, though the complainant only made one compliant (e.g., "Charge #1). deny the allegations outlined in your letter and as made by the complainant

Alleged violation No .. 1: It is alleged that I violated Section 106.021(1)(a) by soliciting campaign contributions or making campaign expenditures before appointing a treasurer or designating a campaign depository. On May 12, 2014, I notified, by appropriate form application, the Florida Division of Elections of my candidacy for the 30th State Senate district My campaign treasurer was appointed on this same day and the campaign depository identified. On May 19, 2014, the Florida Division of Elections formally accepted my campaign application. As certified in my initial campaign finance report (May 2014), no expenditures were made and contributions solicited or accepted, prior to May 19, 2014.

In reference to Section 99, there are no specific statutory provisions for the method of delivering the relevant documents identified above to the Division of Elections. As the Division of Elections provides for electronic submission of documents, this method was chosen Delivery receipt of email submission was obtained on May 13th, from a second email submission to the Division of Elections No notification was ever made by the Division of Elections to me that the method of submission was improper. On May 14th, I contacted the Division of Elections and inquired as to required method submission of my documents and was instructed that they needed to be provided as paper original copies Upon said instruction, I immediately removed the subject "YouTube" video from my campaign website and re-submitted the documents via USPS overnight service.

No contributions or expenditures were made prior the Division of Elections acceptance of my application documents.

Alleged violation No .. 2: It is alleged that I violated Section 106 .. 11(4), in that I incurred expenses without sufficient funds on deposit in the primary deposit account As stated above, there were no expenditures in the time in question .. There is no evidence that I violated the stated statute .

Page 1 of 2 ( /

Alleged violation No .. 3: It is alleged that I violated Section 106 143(1), in that I failed to provide a statutory required disclaimer on a political advertisement As provided by the complainant, it is alleged that I commissioned the development of a "television advertisement". made no such commission, and he is making an inaccurate characterization of the video that is referenced. The video is a "YouTube" video that was created by a local consulting firm that was soliciting me as a potential client. On their own accord, as a promotional demonstration piece, the local consulting firm, created at their own expense a video and posted it on a no-fee internet site. The "YouTube" video has never been provided from any location other than from the free "YouTube" internet service. As provided in Section 106.143(10)(d), content "[p]laced at no cost on an Internet website for which there is no cost to post content for public users" does not require political disclaimers. The subject internet based video is not subject to the requirements of Section 106 143(1) and does not require the noted disclaimer However, voluntarily, the subject video was modified prior to being reposted on "YouTube" as if had had been subject to the statutory required disclaimer language of relevant political advertising.

Alleged violation No .. 4: It is alleged that I violated Section 106.19(1)(d), in that I made or authorized one or more expenditures prohibited by Chapter 106 As described above, there were no expenditures made in the time of question There was no violation to the stated statute.

As provided in my previous correspondence with your office, there were no violations, as alleged by the complainant.

Please feel free to contact me with questions or comments at any time ..... -, Best Regards, 1:. ;: _;~-~--~-- ____ :.:: .... :;,,,~;.. ~-·-·-···

Michael Dreikorn, Ed D Veteran, Businessman and Candidate for Florida State Senate District 30

FOR AN OATH OR AFFIRMATION;· STATE OF FLORIDA COUNTY OF LEE

Sworn to (or affirmed) and subscribed before me this 29'h day of July, 2014, by Michael J Dreikorn

~~~~~~t'•,,, DARLENE M. SOLER '.": p~t)}~t-\ Notary Public _.. Sta. te of Florida 1~0oJLJ(,, .. _.. ~-tzl , ~fvvt_ :•-ti ~-·:MyComm ExpiresSep11,2015 -'·· -, ' ~~•,,>, (I~!·/ -u~f129310 (Signature of Notary Public-State of Florida) Darlene M Soler

(NOTARY SEAL)

./ Personally Known _L'--- OR Produced Identification ___ Type of ldentificationPrOduced ______

Page 2 of 2 lS-2 0001 Designation of Division of Elections as Filing Office for Department of State; Requirements for Candidate Qualifying Papers; Withdrawal of Candidacy. (!)Designation of Division of Elections as a filing office (a) The Division of Elections, Room 316, R A Gray Building, 500 South Bronough Street, Tallahassee, Florida 32399-0250 is hereby designated on behalfofthe Department of State as the filing or qualifying office, that is, the official address and the location for candidates seeking to qualify for nomination or election to any federal, state, legislative, multicounty or judicial office with the exception of county comt judge Candidates for the office of county co mt judge shall qualify with the supervisor of elections for that county. (b) All qualifying papers required to be filed with the Department of State as the office where the candidate is required to qualify shall be filed with the Division of Elections. (2) Qualifying papers. (a) Except as noted herein, any qualifying paper filed with a qualifying office, whether the Division of Elections or a supervisor of elections, must be an original and signatures thereon must also be made in ink (b) A facsimile, email, photocopy, scanned copy or any type of electronically transmitted document shall not be accepted as a qualifying paper, except a candidate who has filed a cmrent full and public disclosure or statement of financial interests with the Commission on Ethics or the supervisor of elections prior to qualifying for office may file a copy of that disclosure at the time of qualifying. A current foll and public disclosure or statement of financial interests is one that covers the immediately preceding calendar or tax year. For example, for a qualifying period that occurs in 2014, the current foll and public disclosme or statement of financial interests form would be one that covers the 2013 calendar or tax year (3) Filing timeline Qualifying papers shall be deemed filed by the qualifying office upon the date of actual receipt by the qualifying office, except for those qualifying papers accepted and held dming the 14-day period before the beginning of the qualifying period to be processed and filed dming the qualifying period pursuant to Section 99 061(8), F .S The qualifying papers that are received and held during the 14-day period before the beginning of the qualifying period shall not be deemed filed until the beginning of the qualifying period (4) Forms. (a) The following qualifying forms for candidates required by Sections 99.061, 103 022 and 105.031, F S, are hereby incorporated by r·eference: 1 DS-DE 9 (Rev 10110) (http://www.flrules.org/Gatewavlreference.asp?NtFRef'00292), entitled, "Appointment of Campaign Treasurer and Designation of Campaign Depository for Candidates " 2 DS-DE 24 (Rev 5/11) (http://www.flrulcs.org/Gatcway/rcforcncc.asp?No~Ref'00293), entitled, "Candidate Oath - Candidate with Party Affiliation " 3 DS-DE 24A (Rev 5/11) (http://www.flrules.org/Gateway/referencc.asp?No=Ref'00294), entitled, "Candidate Oath - Write In Candidate" 4 DS-DE 24B (Rev. 5111) (http:/1www.flrulcs.org/Gatcway/reference.asp?No~Rcf'00295), entitled, "Candidate Oath - Candidate with No Party Affiliation" 5 DS-DE 24C (Rev 5/11) (http://www.flrules .. org/Gatcway/rcforence.asp?No~RcfC00296), entitled, "Candidate Oath- Precinct Committeemen and Committeewomen." 6 DS-DE 24D (Rev. 5/11) (http:liwww.flrules.org/Gatcway/reforence.asp?No~Rcf'00314), entitled, "Candidate Oath - District Committeemen and Committeewomen." 7 DS-DE 24E (Rev 5/11) (http:/1www.tlrules.org1Gatcwavlrcforcnccasp?No~Rct'00315), entitled, "Candidate Oath - State Committeemen and Committeewomen." 8 DS-DE 24F (Rev 5111) (http:1/www.tlrules.org,Gatewav1reforence.asp?No~RctC00316), entitled, "Candidate Oath-School Board Write-In Candidate" 9 DS-DE 25 (Rev. 5/11) (http://www.flrules.org;Gatewav/reforence.asp?No~RefC00297), entitled, "Candidate Oath - Nonpartisan Office " 10 DS-DE 25A (Rev 5111) Q1ttp:/1www.flrules.org/Gatewaylreforence.asp?No~Ref-00298), entitled "Candidate Oath - School Board Nonpartisan Office." 11 DS-DE 26 (Rev. 5/11) (http://www.tlrules.org,Gatewav"eforence.asp?No~RefC00299), entitled, "Judicial Office Candidate Oath .. "

EXHIBIT 7 (i of 1) 12 DS-DE 26A (Rev 5/11) (http://www.flrules.org/Gateway/reference asp?No=Ref'00300), entitled, "Judicial Office Candidate Oath - Write-In Candidate." 13 DS-DE 27 (Rev 5/11) (http://www.flrules.org/Gatcway/reforence.asp?No=Ref-00301), entitled "Federal Candidate Oath - Candidate with Party Affiliation " 14 DS-DE 27 A (Rev 5/11) (http://www.flrules.org/Gateway/reforence.asp?No=Ref-00302), entitled "Federal Candidate Oath - Write-In Candidate" 15 .. DS-DE 27B (Rev 5/11) (http:i!www.flrules.org/Gateway/reforence.asp?No=Ref'00303), entitled "Federal Candidate Oath Candidate with No Party Affiliation " 16 .. DS-DE 85 (Rev 10/10) (http://www.flrulcs.org1Gateway/rcfcrcnce.asp?No=Ref'00304), entitled, "Oath of Candidate Write In for President and Vice President." (b) The forms in paragraph (a) are available from the Division of Elections, R A Gray Building, Room 316, 500 South Bronough Street, Tallahassee, Florida 32399-0250, by contact at (850) 245-6200, or by download from the Division's webpage at: http://election.dos state fl us/forms/index.shtml (5) Candidate withdrawal A candidate may withdraw his or her candidacy by submitting a document specifying the candidate's withdrawal from the particular public office he or she seeks to the qualifying office before which he or she qualifies (or has qualified) by mail, facsimile, email, photocopy, scanned copy or other type of electronic transmission that contains the signature of the candidate The withdrawal is not effective until it is received by the qualifying office

Rulemaking Authority 2005(1}(e) 2010(1) 97012(1) 99061(10) 101022 FS Law Implemented 2005(/)(b) 99061 99095 103022, 105 031(1), /05 035 FS History-New 12-6-84, Formerly IC-7 001 IC-7 0001 Amended 2-13-90 11-7-10. 9-7-11 1-1-14 ( (

~~-~ FLoRIDA DEPARTMENT of SIAT~ RICK SCOTT KENDETZNER Governor Secretary of State

May 20, 2014

Michael John Dreikom Post Office Box 654 Bokeelia, Florida 33922

Dear Mr Dteikorn:

This will acknowledge receipt of the Appointment of Campaign Treasurer and Designation of Campaign Depository for the office of State Senator, which was placed on file in our office on May 19, 2014 Your name has been placed on the 2014 active candidate list

Campaign_Treasur~i::'s Reports

Your first campaign treasurer's report will be due on June 10, 2014. The report will cover the period of May 1··31, 20!4(M5) .. All candidates who file reports with the Division of Elections are required to file by means of the Division's Electronic Filing System (EFS) ..

Credentials and Sign-ons

Below is the web address to access the EFS and your user identification number The enclosed sealed envelope contains your initial password Once you have logged in using the initial password, you will be immediately prompted to change it to a confidential sign-on You, your campaign treasurer, and deputy treasurers are responsible for protecting this password from disclosure and are responsible for all filings using these credentials, unless the Division is notified that youx credentials have been compromised

EFS Website Address: https://efS.dos stateflus Identification Number·: 62175

Division of Elections R.A. Gray Building, Suite 316 • 500 South Bronough Street • Tallahassee, Florida 32399 "'£1 850.. 245 6200 • 850.245.. 6217 (Fax) electlon .. dos.state.fi.us FLORIDA:'/ *ll1\l,t11,,1I* ~ PT'Omoting F l ori d a's History and Cu Ztur·e Vi'7a Flo rida.org ElECTIONS ' VIVA FLORIDA C:Vl-llRIT &" (i o£3) ( I'

Michael John Dreikorn May 20, 2014 Page Two

Pin Numben

Pin numbers are confidential secure credentials that allow you to submit repo1ts and update pe1sonal information The enclosed sealed envelope contains confidential pin numbers for you By copy of this lette1, a confidential pin number to access the EFS was sent to your treasurer

Each candidate is required to provide the Division of Elections with confidential personal information that may be used to allow access in the event this passwo1d is forgotten or lost When you enter the campaign account screen, there will be a drop down box where you pick a question (such as What is your mother's maiden name?) and supply an answe1 All passwords and answe1s to questions aie stored as encrypted data and cannot be viewed by Division staff and given out over the phone. Please notify the Division ifyou1 credentials have been compromised

Timely Filing

All reports filed must be completed and filed through the EFS not later than midnight of the due date Reports not filed by midnight of the due date are late filed and subject to the penalties in Section 106.07(8), Flmida Statutes In the event that the EFS is inopeiable on the due date, the report will be accepted as timely filed if filed no later than midnight of the first business day the EFS becomes opernble. No fine will be levied during the petiod the EFS was inoperable

Any candidate failing to file a repoit on the designated due date shall be subject to a fine of $50 pee day for the first 3 days late and, thereafter, $500 per day for each late day, not to exceed 25% of the total receipts or expenditures, whichever is greater, for the period covered by the late report However, fo1 reports immediately preceding each primary and general election, the fine shall be $500 per day for each late day, not to exceed 25% of the total receipts or expenditures, whichever is greater, for the period covered by the late report.

Elei;tmnic Receipts

The person submitting the report on the EFS will be issued an electronic receipt indicating and verifying the 1eport was filed. Each campaign treasurer's report filed by means of the EFS is considered to be under oath by the candidate and campaign ueasurer and such persons are subject to the provisions of Section 106.07(5), Florida Statutes.

EXHIBIT ~ (.i of3) Michael John Dreikom May 20, 2014 Page Three

Instructions and Assistance

An online instmction guide is available to you on the EFS to assist with navigation, data entry, and submission of repo1ts The Division of Elections will also provide assistance to all users by contacting the EFS Help Desk at (850) 245-6280 ..

All of the Division's publications and reporting f'or'ms are available on the Division of Elections' website at httmLf~tions.m:y.florida.com. It is your responsibility to read, understand, and follow the requirements of Florida's election laws. Therefor·e, please print a copy of the following documents: Chapters 104 and 106, Florida Statutes, 2014 Candidate and Campaign Treasurer Handbook, 2014 Calendar of Reporting Dates, and Rule IS-2.017, Florida Administrative Code.

Please let me know if you need additional information

Sincerely, ~ A~t:, 4<-l;::~-:.£--

Klisti Reid Bronson, Chief Bureau of Election Records

KRB/ljr

Enclosures pc: Darlene Marie Soler, Treasurer

EXHIBIT ?' ( 3 of 3) ~,cm: Matt Hurley hurloy~Vtarch!ightpro.e-0n1 cf Sutj:oc1: Private-Do Not Disclose,, ;)•lo: May6, 2014 at1:58 PM Ye: Dr:. Michael Oreikom dreikorn

Mi¢hael,

Great shoot today

Things are really shaping up,

Keep the attached image held close. Don't want it getting spread around

We will see you at 1OAM for the rest of our shoot

I have the ad agency working now on developing a 90 second Web ad that we will release first thing Monday morning We will need to cut Iha VO of this ASAP Chris Is working on a script now,

We will send over soon ..

Matt Hurley Partner-Torchlight Productions

7500 College Parkway Fort Myers FL 33907 OffK:e- 239·938·-3341 Cell· 239-223·-8941 www .. torchllghtpro.com Hurley@torchlightprooom

EXHlBIT_ _i,, __ l ' I

Prom: Alex Afdlerl [email protected] Subj"Cd:: Michael Dreikorn: Voice of the People cfh~•>: May 9, 2014 at 10:19 AM ;Q; MattHurley huiler$ID!'CJ'l.1i-:J.li.fi•'ocom https://www.youtube.com/watch?v=hBB mrk9epc

Thank you, . Alex Aldieri Director of Motion Media Torchlight Productions, LLC 201.3 Best of Fort Myers Award for Internet Marketing Service Office: (239) 938 3341. From: Dr. Mfchael Drelkorn di'6ikoni19theiplgroup .com Sub,ect: RE: Sttaight From· Media l'eam ihl<'·: May 12, 2014at10:39 AM '!'o: Matt Hurley hurley@'.~orc~lig.iTtpro-c-.;m Cc: Bill Holderby bmho,C:01·byf:'.t.7nz.il c:::11, Chrfs Berardi 0Di'::a:cti~:ft'lxt:i~"J":~;:;fl.: c.;m

We will also need to place the "Paid for" bar ln there.

EXHIBIT f 0 (~ :f 4J

·------··-·------· ---·------·--··----- ·------··------·--·---- :=r·or.t: Matt Hurley hur'.9y©torchligiltpro corr. Subfe-.c!: Straight From Med1a Team DolZ: May 9, 2014at12:15 PM Bl Tc: Dr:. Michael Ol'eikom drei:

Please keep thiS private. Do not want anyone getting a hold of this. https:ftwww.youtube.com/watch ?v:::::hBB_ mrk9eoc

Only those v.ith the link can see this.

Malt Hurley Partnel'·Toi'Chlight Productions

7500 College Parkway Fort MyelS FL 33907 Office· 229·93a·e341 Cell· 239·223 8941 www.torchHghtoro.com lJ!l!:l!W@torchlightpJQCOm

EXHIBIT___ ~_o (3 ot 1..{) (

f'rom: Dr. Michael DreH .. c::>ni Cc: Chris Berardi c~·ranfl '§ torch~ightr::'ro.con

Ditto!

Absolutely awesome I!!

I can't wait to have this go viral..

M From: Steven Mcintyre mclntyre@torchl!ghtpro.cnm # Su~)c<.'i: Invoice (No. 67967) • from Torohlight Productions, LLC, M!chael Oreikom Campaign #1 Date: May27,2014at,5:14PM "fQ: Matt Huriey 1.~r1£)1@tcrchlig!'Ji:p,·o.-Xi~n

Dear Michael Dreikom Campaign,

Your invoice is attached and Includes payment-due information Please let us know if you have any questions. Thank you for your business

Sincerely, Torchlight Productions, LLC

Invoice .. Torchlight Productions, LLC

7500 C<>liege P~ fort My

Bill 'l'<>! Mk:h.oel Dreikom C'!11'>P"ign

icuatomWeb~ Design and Do•~'11ern ol a Wei: Site 1.200.00 1200.00 I Hos~ng \Spark) "'""1y Hosting Fee 500 .. 0ll 500.00 Vi-Euriy !'oo 10 7500 750 ..00 1 I ! I

EXHIBIT_. jJ_ ( f of 1) f-- i (

' ! l ! I i -·----·--···------·J.----·--·------· --·--··-·-·-'"' --·+"-"""'_.J._ ·------.. ~ jTotal $2,!l50Jll>j -·~····;~·o;.:;--$Z850.oo1 ~----· '

EXHIBIT r f (~f 9) I'

fl'\'1t)'f: Dr. Michael Drelkom QrcU:vrn@thsiplg1·0:1p.corll ~ Sur1jccl: FW: Invoice (No .. 67967) - ll'om Torchlight Productions, LJ..C, Michael Oreikom campaign #1 Oat~: May 27, 2014 at 5:43 PM Ta: Matt Hurley (hurley®torchllghtpro .com) h";ley .~· tcrchlighl(lro .com

Matt: We need to look at the dates on the invoice.

From: Torchlight Productions [mailto:sales@torchllghtpro .. com] sent: Tuesday, May 27, 2014 5:30 PM To: D~. Michael Dreikorn Subject: Fwd: Invoice (No. 67967) - from Torchlight Productions, LLC, Michael Dreikorn campaign #1

To1chlight Productions

7500 College Prukway Pott Myers FL 33907 Office- 239-938-3341

EXHIBIT_" ( (3_of 1) (

:=ron1: Matt Hurley hufr3y.1::9torchlightpro. com S~l>jocl: Re: Invoice (No. 67967) • from Torchlight Productions, LLC, Michael Dreikom Campaign 111 Riii :'l""'3: May28, 2014at11:03 AM r~i y.,71: Or:. Michael Dreikom <1raik0;·aQ.;:i-;neiplg;oup >.;om

Sure 1hing, what date do you want on it?

Matt Hurley Partner-Torohlight Productions

7500 College Parkway Fort Myers FL 33907 Offic&· 239-938-3341 Ceil .. 239-223-8941 www.torchlightpro.com [email protected] (

From: Matt Hurley hurley@tcrch!igh\pro com Subject: invoice? Date: May30, 2014at 12:06 PM J'iil: Dr:. Michael Draikom dreikt-

Michael,

Any Idea what date you want me to put on that invoice, Trying to make sure everyone Is covered,

Matt Hurley Partner,·Torchlight Productions

7500 College Parkway Fort Myers FL 33907 Office- 239·938·'3341 Cell- 239-2238941 www,torchllghtpro.com Hurley@torchlightpro,,com / (

?rom: Matt Hurley hur!~y@tor~hiight~wo com S!lhJect: Invoice?? '.'ol•'' June4, 2014at1:21 PM ::~: Dr Michael Dreikorn dreli•crn<:Utheip!group. corr:

Michael,

Did you ever decide on how you wanted to handle the Invoice?

MattHu~ey Partner-Torchlight Productions

7500 College Parkway Fort Myers Fl 33907 Office- 239·93&G341 Cell- 239-223··8941 www torchlightpro.com Hurtey@torohlightpro.. com

EXHIBIT ~i'om: Matt Hurley ~·Jrloy~')torchlightpro.com Sul>ject: Invoice? O•te: June 6, 2014 at 12:07 PM To: Dr'. Michael Oreikom dre!)(orili~thelp:-:grou-~.cvli'

Any update?

Matt Hurley Partner-Torohlight Productions

7500 College Parl

EXHIBIT_ I { (1 of 9) (

from: Or. Michael Drelkorn drelkorn@theiri:group oom Subjc.i:::t: RE: Invoice? Dote: June 7, 2014 at 8:37 PM ..~o~ Matt Hurley hurlayr1>:.tcrcl1lifiirtpro com

Matt: We should talk on lhe phone to work out payment details

There are a number of things we need to resolve. ' 1) I see my domain mlchaaldreikorn ..com has been moved to Go Oaddy. .I assume this was for hosting under your management. I would Uke to have aooess to that domain, so I can move it under my control .. I thought you were only going to repolnt lhe dns ..

2) I do not heve a print quality file of lhe campaign logo,. Can this please be provided in a hlgh·res

3) The Transaxt account appears to have been closed However, we did not download any donor information, And, donations that i know were made never made It to our bank account. There iS no way for me to account for anything to the State. I need to know what happened here, as well as gain access to the data

4) The campaign video Is postsd on YouTube and I do not have lhe login infonnatlon for !hat account.

5) As we had a large number of photo images taken, I'd like to have a few to uae for the campaign

You and your team did an awesome job on lhe campaign video. And, for 1hat I am very apprecialiVe,, As we have already taped a lot of content I'd like to use your aervlces tor other messaging in the coming weeks However, for the website, I plan to migrate the content over to Natlonbuilder. The site you provided does not offer any statics or user data collection,

All the best,

Michael

Michael J. Dreikom, Ed.D Candidate tor SW Florida's Senate District 30 PO Box 654 Bokeelia, FL 33922 T. 239 283.2197 Email: MD@MlchaelDrelkorn com Website: www.MlchaslDreikom com Faceoook: https:l/www.facebook com/dr michael.dreikorn Twitter: @MlchaelDreikom

PaJd for by Drelkom For Senate

EXHIBIT_ I I ('6 cJ-9) ,/'

r-mm: ~ti.Hurley. hu~ey.ll>.torclil!ghtpro .com $L''>Jei;t:. lnv0l~'r .•. . . · 1):•tc: Jun$16;i2614ii!S.:42AI!! ...r.fJlt ·to: Dr. MichaeJ-Orefk,Of'l'.l\dt:Eifi.om@_ti1cipt9rou;i,.c~n1

Mli:h~. This is getting out o~.h!l(ld. I need an answer on 1111$. It has been over a month lf you have to. pay lt.Out'of pocket and. then 1Jl::k\nd It, (.am fine with that

People are asking qtle$1ions

Matt Hurley Partner-Torchlight Productions

7500 CoUege PalkwaY Fort Myers FL 33907 Office·· 239··938··3341 Cell .. 239,223.8941 .W)VW:,torchllghlpro .. com Hurtey@torchllghtpro.. com

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The undersigned in Section IX or X MrePy ce.· rttty to SunTrust BMk ('Bank'") that the above named Business Entity is organized and existing undar the laws of the State Ot · ·Florida ·. and has been registered in the n'.tannet.preacribens. access infor'mation, u~e Bank's services, perfomi transactions, enter into agreements ancl delegate authOrlty on behalf of Business Entity Resolved, mat Bank be and is hereby designated a depository foi the Business Entity; that any one of tMe individuals or entities named in Section Ill below is an' Authorized Signer" and is autho~zed.to act, give Instructions, access Information, us.. Banks services, and perform transactions on behalf of Business Entity wi'th respect to any Accounts of Business Entity with Bank or services provided to Business Entity by the Bank, to enter Into on behalf of the 13:ustness Entity any of Bank's agreements including checking, savings, certificates of deposit, wire or electronic funds transfer, night deposit, cash management. or other treasury management services agreements and to delegate to any other individual or entity his or her authority to act. ·give instructions, access information, use Bank's services pet1onn transactions, and enter into agreements on behalf of the Business Entity, including agreements that delegate his or her authority to other individuals or entities with respect to the Suslnese Entity'.o Accounts or Bank's services; that the Business Entity shall ba bound by the terTns and conditions of all such agreements and Banks Rules and Regulations for Deposit Accounts related thereto, all as now existing of as amended from time to time; and that any Autliortzed Signer named In Section Ill, is authorized on behalf of this Business Entity to sign and to endorse for deposit, negotiation or collection, any and all checks, drafts, certificates of deposit savings certificates. Items or other instruments or written ordets for the payment of money p?.iyable by or to the order of this Busfness Entity Signatures and enctorse.rnents if any, may· be in writing, by stamp, or otherwise affixed, with or without designation or signature of the person so endorsing, it being understood that all prior endorsements on such items are guaranteed by this Business Entity. regardless of the lack of an express guarantee in the endorsement of this Business Entity Further Resolved, Bank Is hereby directed to honor, pay and charge to the Accounts of this Business Entity, without inquiry as to the circumstances of the issuance or appllcatlon of the proceeds of, any checks, drafts, items or oth€H' written orders on any of this Business Entity's Accounts with Bank, whether payable to, endorsed or negotiated by or for the credit of any person signing the same or any other of the Authort

User ID [QFMG39 J Account Number

310617(01111) ORES SunT1ust Comorate Forms Pagc1of3 EXHIBIT r:i._ \2 of l'J.) --~---~· Name MICflAEL DREIKORN DARLENE MARIE SOLER

'··' ..... -,...... -

·-····-· ---·------

-- ·-·· --·------·--.-· .. -.--.. ·- ..:,: -·-· --·-

IV. ~;.;imllesiij~~i~~~-(co~plete this ~etlon ~-;;!¥';;;,~~hi~~ rit;~e'Jiriii;iija~tJ ;;;matures are to be ~;don items. l Further Resolved that Bank is hereby requested, authcirilz.ed.and directed;tQ·hono.c'aiiY:;(iheck, draft, item or other wfitten order on any of this Busine~s Entity's Accounts with Bank when)i~_iii1.v9 or puo:por,iiilgto. ~~iit :ih~d911pwi0g authorized machine or facsimile signature of any of the above named individuals ~hO.$:~ ·~1gryatu1'~$ ate repr~~i~c.eci·,b~ltj~.;,.~~"gardless of by whom or by what means the actual or purported machine odacsimile signatiir('Sm~y.havi'i btien affixE>d 'The;l!!ti~i-~.$$8 Entity shall indemnify and hold the Bank harmless. from any and all claif:os, expenses. lo..

------·-·

V. Additional Signatories on Business Entity's Accounts Further resolv.~ct t~~ following individual(s) are authorized as additional signatones g tci sign and to endorse for deposit or collection any checks, drafts or other instruments or written orders for the payment of money payable to lhe order of the Busloess Entity and to sign checks, drafts, items or other written orders, and initiate wire or funds transfers and execute Bank's Funds Transfer Authorization wire tequest and disclosure form on any of the Business Entity's Accounts with Bank (Instruction; If an additional signatory is !JJll authOrized to sign on all Accounts, specify the Account Number applicable to the signatory as indicated below J RGfer to th<> Signature Card(s) on tho Account(s) for· signatures of the Additional Signatories. · Additional Signatory's Name Position with Entity Specific Deposit Account Number(s) Applicable to Signatory (Complete only if signatory is Jl.lll authorized on all accounts) ------..------

VI. Qualification Certlflcallon for Public Fund, Organi:tallon, Polltlcal Organization, Homeowners and Condominium Owners AssOc::iation ot Corporation Not Operated for p,ofit to earn interest on a checking account (NOW Account) Mark this section with an "X" QQ1Y if Business Entity js eligible to earn interes.t on a checking account 0 I/We further certify that the above named Business Entity is eligible to earn interest on a checking account (referred to as a Negotiable Order of Withdrawal or NOW Account) in compliance with Regulation 0 of the Federal Reserve Act (12CFR 204) as a Public Fund or a Non-Profit Organization that Is operated primarily for Religious Philanthropic. ChariU.ble. Educational, Political or other similar purposes under one of the following sections; Organization - Section 501 (C) (3) through (13), and (19) of the Internal Revenue Code (26 USC (IRC 1954) 501 (C) (3) - (13) and (19) Political Organization-. Section 527 of the Internal Revenue Code (26 USC (IRC 1954) 527) Homeowners and Condominium Owners Associations - Section 528 of the Internal Revenue Code (26 use (IRC 1954) s2a) · VIL Power to Act. The undersigned certifies that there are no limits to the undersigned's powers to adopt this Authorization and to attest tha.t the resolutions stated herein are accurate and that this Deposit Account Resolution and Aothorization is in conformity with the provisK)ns of the organizational instruments, which include the Business Entity's charter. bylaws, operating agreement partnership agreem~nt, shareholders' agreement or similar agreements by which the Business Entity or the undersigned party may be bound and does not violate the provision~ thereof VIit Pr;ior· Acts .. All previous acts of or on behalf of the Business Entity as provided tor above are hereby approved and ratified IX.. certlfication·-Corporatlon or Professional Co!'poration. l the undersigned hereby certify to Bank that the above is a true copy of resolutions a.nd authorizations of said Business Entity and that such resolutions and authorizations iilre in full force and effect and have not been amended or rescinded User ID [UFMG39 .=:J Account Number

318617 (01111) ORES Su11Trutt Corporata For mi; Page 2 of3 EXHIBIT_,,.~~~~ IJ..) 'I VV I

In witness whereof I have hereunto subscribed my na,:,;e; a.let ttie sii

(Affix Seal here, K available)

-1\l~rne aQ~'l'~i.d6ti~r9iil'l~rit, s&ciii'Y. AisistanTsecr&tii;;y·;;i • QtiierOfficet'Jlii'.'di>~lgnated in the Corporation's Bylaws X. Certificatior>-·Llmlted Liability Company, Partrte!'S~lp, Pubii~ Furid(s.~\~ Pr,;i>(ietorship, Unincorporalecl Organization or ASsocia!lon, or Other Entity I/We the undel'.!iigni\~. •h~reb.y Certilftq E\a~k ifiatthe above is a true copy of resolutions and authorizations of said Business Entity an.q that s.ui:h.'.~:Soljj(io"tiS ·are lf:l fi.;tlffci.'rCS;:and ·S:ffett and have not been amended or rescind.e(f [Instruction: 11 the General Partner Member or Ma~iilieiis)alsa ,ailentify (i>:gCa i:orporation, LLC, or partnership), the name of the entity and the word "By" are entered in the colurhn 'hi>6~~iJ '.Sighature"; 'toil'ifol.dividu~I signing on behalf of that entity signs directly below ~he name of the entity; and the name of~e 'in:9iVjQ1if;il. ah_(findiVidu_afS'tit1e,·or Position are entered in the column headed "Title" The Individual must provide a resolution on that ehtitY 'ie~pfiri4'the 'indi'/idulil's

Signature Requirement IMlructions 'T'he following signatures are required to complete and certify the Deposit Account Resolution and Author·ization to be cor·rect: c Comorations: Corporate Officers authol'iz.ed to act on behalf of the corpora~on narned in Sectlon Ill should Include the President and Secretary and any other applicable corporate officers, suCh as Vice President or Treasurer.. The President, Secretary, Assistant Secretar'Y, or other corpora.to officer as designated in the bylaws of the corporation is requited to certify the Deposit Account Resolutio.n and Authorization under Section IX • Limited Liability Companies: Section Ill and X require the signatures of all members/managers/board members, unless the Operating Agre~ment authorizes one or more members/managers/board members: to conduct banking business, In which case the signatures of .. all such authorized members/managers/board members are suffident • pyblic Fund .E.o..fil.S: Section ftt requires the signatures of individuats authorized to $Cign on behalf of the Pub1ic F1.,1nd Entity as designated by the governing unit e.g., Soard of County Commissioners, Mayor, Secretary of State. etc The individual(s) authorized to represent the governing unit is required to certify the Depo&it Account Resolufon and Authorization under Section X • Partnerships: Section Ill and X require the signatures of !l.!! General Partners unless the Partnership Agreement designates one or more partners to conduct banking l;lusiness and perfom1 banking transactions. In such cases, the designated general partner(s} are named in Section Ill as the General Partners authotii::ed to act on behalf of the entity and these same General Partners wiU certify the Deposit Account Resolution and Authorization under Section X • Sola Proprietorships: Section fll and X reQuire the signature of the ptoprietor (owner) or in the case of a spousal proprietorship, the signatures of the husband and wife who own the Business Entity

ci Unincoroorated Organizations or Associations: sect1on Ill requires the signatures of the Officers or Positions designated in the Organization or Association's bylaws or charter as ~uthorized to act on behalf of the organization or association The PresldGnt .Q! Secretary Of the organization or associ~tion (or olhf:r individual designated to do so) is required to certify the Deposit Account Resolution and Authorization under Section X · Bank Use Only - --] ' ---··-,···-·-· ____ _,...... -··------··---,----~--~·-,_ ~~~t~Om~er '-----···--:. < •~~81f~'CJ::'ber .. ·-.._···._ . ~e~ilfE1sLA_N[) OF~!CE -·- 0 Pi'ellarect Eli Meli~s~ kdieri · · · · i'139efs3'b.fo54 ___. _L.-.·~te··.· __?._51.1.~12014 ___ ·__ 'A¢count Noi:tibe({s) · ·· ·· ------.---

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.'31BS17 (01111) ORES SunTtuslCorpo111te l=orms Page 3 of3 EXHlBIT (

EXHIBIT 11(5 - of fQ.J EXHIBIT ril!c of ri) ----~-- I '

EXHIBIT 12.(7 cf: t:L) ·--··- EXHIBIT------/'L('?. oftl) SUNTRUST BANK PAGE 1 OF 1 PO BOX 305183 36/E00/017S/O NASHVILLE TN 37Z30-S183 05/31/2014

ACCOUNT STATEMENT

DREIKORN FOR SENATE QUESTIONS'? PLEASE CALL CAMPAIGN ACCOUNT 1-800-786-8787 S697 BAY POINT RD BOKEELIA Fl 339Z2

A SUNTRUST ACCESS 3 EQUITY LINE OF CREDIT IS A SMART, FLEXIBLE AND AFFORDABLE WAY TO USE YOUR HOHE"S EQUITY TO PAV FOR THE IMPORTANT THINGS IN YOUR LIFE, AND NOW YOU CAN TAKE ADVANTAGE OF OUR NEW SPECIAL LOW RATES .. CALL 877.SDl.5555, VISIT SUNTRUST .. COH/EQUITYLINE, OR STOP BY A LOCAL SUNTRUST BRANCH TO APPLY ..

ACCOUNT SUMMARY ACCOUNT TYPE ACCOUNT NUMBER STATEMENT PERIOD TAXPAYER ID

PRIMARY BUSINESS CHECKING 05/16/Z014 - OS/31/Z014

DESCRIPTION AMOUNT DESCRIPTION AMOUNT BEGINNING BALANCE $, 00 AVERAGE BALANCE $169.47 DEPOSITS/CREDITS $1, 106., 00 AVERAGE COLLECTED BALANCE $169 .. 47 CHECKS $, 00 NUMBER OF DAYS IN STATEMENT PERIOD 16 WITHDRAWALS/DEBITS $130 ,95 ENDING BALANCE $975 .. 0S

DEPOSITS/CREDITS

DATE AMOUNT SERIAL # SR BATCH DATE AMOUNT SERIAL # SR BATCH 05/21 100 .oo DEPOSIT 20 30154832

05/27 6,00 MISCELLANEOUS CREDIT 20 29125399 05/30 1,000 .00 ONLINE BANKING TRANSFER FROH 74

DEPOSITS/CREDITS: 3 TOTAL ITEMS DEPOSITED: l

WITHDRAWALS/DEBITS DATE AMOUNT SERIAL # DESCRIPTION SR BATCH PAID

05/21 6 .. 00 DEPOSIT CORRECTION FEE 00 05/21 100 .00 751835 DEPOSIT CORRECTION 20 30154833 05/28 24 .. 95 IMPRINTED CHECK/DEPOSIT CHARGE 30 47011140625 DELUXE CHECK CHK ORDERS

WITHDRAWALS/DEBITS: 3

BALANCE ACTIVITY HISTORY DATE BALANCE COLLECTED DATE BALANCE COLLECTED BALANCE BALANCE 05/16 .. oo .. 00 05/Z8 -24 .. 95 -24 .. 95 05/21 ,OQ .oo OS/30 975 .. 05 975 .. 05 05/27 -· "00 -· .. oo

MEMBER FDIC SUNTRUST BANK PAGE l OF 2 PD BOX 305183 36/E00/0175/0 /4~'/ NASHVILLE TN 37230-5183 06/30/2014

ACCOUNT STATEMENT

DREIKORN FOR SENATE QUESTIONS? PLEASE CALL CAMPAIGN ACCOUNT 1-800-786-8787 5697 BAY POINT RD BOKEELIA Fl 33922

HOW CAN WE HELP YOU HAKE THE RIGHT FINANCIAL CHOICES FOR TODAY AND TOMORROW? WITH OUR VARIETY OF SOLUTIONS AND FINANCAL GUIDANCE. WE VALUE VDU AS A CLIENT AND WANT TD' HELP YOU BANK THE WAY THAT FITS YOUR LIFE,, LEARN MORE AT SUNTRUST .. CDH ..

ACCOUNT SUMMARY ACCOUNT TYPE ACCOUNT NUMBER STATEMENT PERIOD TAXPAYER ID

PRIMARY BUSINESS CHECKING 06/01/2014 - 06/30/2014

DESCRIPTION AMOUNT DESCRIPTION AMOUNT BEGINNING BALANCE $975 .OS AVERAGE BALANCE $1,612 .. 24

DEPOSITS/CREDITS $4,857 .. 00 AVERAGE COLLECTED BALANCE $1 1 608,07 CHECKS $2,127 .. 92 NUMBER OF DAYS IN STATEMENT PERIOD 30 WITHDRAWALS/DEBITS $2,171 .. 10 ENDING BALANCE $1,533 .. 03

DEPOSITS/CREDITS

DATE AHOUNT SERIAL # SR BATCH DATE AHOUNT SERIAL 4t SR BATCH 06/09 25 .. 00 DEPOSIT 20 30379194 06/09 100 .. 00 DEPOSIT 20 30380200

06/02 100 ., 00 CORRECTION CREDIT 0001452890 67 1452890 06/11 900,, 00 ONLINE BANKING TRANSFER FROH 0175 74 06/12 22 .00 CHECK CARD CREDIT TR DATE 06/10 83 PAVPAL MLEEREPUBLIC 4029357733 CA 06/17 1,000 '00 ONLINE BANKING TRANSFER FROM 0175 74 06/20 1,500 .oo ONLINE BANKING TRANSFER FROM 0175 74 06/23 1,000 ,00 ONLINE BANKING TRANSFER FROM 0175 74 061'24 210 .. 00 ONLINE BANKING TRANSFER FROM 0175 1 74

DEPOSITS/CREDITS: 9 TOTAL ITEMS DEPOSITED: 2

CHECKS CHECK AHOUNT DATE SR BATCH CHECK AMOUNT DATE SR BATCH NUMBER PAID NUHBER PAID 1490 196 .. 10 06/09 20 76247939 1492 1,781 .. 82 06/19 20 77151342 1491 150 .. 00 06/27 20 74054303

CHECKS: 3

WITHDRAWALS/DEBITS DATE AHOUNT SERIAL ft DESCRIPTION SR SATCH PAID

06/02 35 .. 00 POINT OF SALE DEBIT TR DATE 05/31 82 SHELL Service CAPE CORAL FL 61537201 06/03 10 .. 65 ELECTRONIC/ACH DEBIT 30 54005155129 AUTHNET GATEWAY BILLING 33950285 06/03 6 .. 57 CHECK CARD PURCHASE TR DATE 05/31 83 HCDONALD"S Fl3880 CAPE CORAL FL 06/09 118 .. 99 CHECK CARD PURCHASE TR DATE 06/05 83 VISTAPRMVISTAPRINT .COH 866-6148002 CA

HEHBER FDIC CONTINUED ON NEXT PAGE SUNTRUST BANK PAGE 2 OF 2 ,-- PO BOX 305183 36/E00/0175/0 141'1 NASHVILLE TN 37Z30-5183 \ 06/30/2014

ACCOUNT STATEMENT

WITHDRAWALS/DEBITS DATE AMOUNT SERIAL # DESCRIPTION SR BATCH PAID 06/10 22 . 00 CHECK CARD PURCHASE TR DATE 06/08 83 PAYPAL MLEEREPUBLIC 4029357733 CA 06/18 60 00 CHECK CARD PURCHASE TR DATE 06/16 83 PAYPAL MPSDCENTERLL 4029357733 CA 06/19 38 .. 00 RETURNED ITEH FEE 00 06/20 214 .. 08 POINT OF SALE DEBIT TR DATE 06/20 82 OFFICE MA 501 CAPE CORAL Fl 13640001 06/23 22 .. 33 CHECK CARD PURCHASE TR DATE 06/20 83 NATIONBUILDER 02133944623 CA 06/23 2S .so CHECK CARD PURCHASE TR DATE 06/19 83 FEDEX 770332478442 HEHPHIS TN 06/23 300 .00 CHECK CARD PURCHASE TR DATE 06/21 83 CAPE CORAL PARKS AND R CAPE CORAL Fl 06/25 1,262 .oo CHECK CARD PURCHASE TR DATE 06/23 83 SQ MTORCHLIGHT PRODUCT FORT HYERS Fl 06/27 15 .. 89 POINT OF SALE DEBIT TR DATE 06/27 82 OFFICE HA 501 CAPE CORAL Fl 13640002 06/30 40 .. 09 POINT OF SALE DEBIT TR DATE 06/30 82 SHELL Service SAINT .JAHES CFL 61539801

WITHDRAWALS/DEBITS: 14

BALANCE ACTIVITY HISTORY DATE BALANCE COLLECTED DATE BALANCE COLLECTED BALANCE BALANCE 06/01 975 .OS 975,,05 06/18 2,672 74 2,672 .. 74 06/02 1,040 .OS 1,040 .. 0S 06/19 852 .92 852 .. 92 06/03 1,022.83 2 .. 022 .. 83 06/20 2,13& .84 2,138 .. 84 06/09 832 .. 74 707 .,74 06/23 2 .. 191 .01 2 .. 191 01 06/10 810.74 810.,74 06/24 3 .. 001 01 3 .. 001 .. 01 06/ll 1.0710 .. 74 1 .. 710 .. 74 06/25 1.0739 .01 1 .. 739 .. 01 06/12 l.0732.74 1.0732,,74 06/27 1 .. 573 12 1,573 .. 12 06/17 2,732 .. 74 2 .. 132,,14 06/30 1.0533 .. 03 1,533,.03

MEMBER FDIC EXHIBIT l::L(ll zf !'J--) --·.~ ... ~.~ RECEIVED OEPARTHEHT OF STATS 14 JUN 16 AH 10: 00 DIVISION OF ELECTIONS TALLAttASSEli. Fb.

(.. z..1 ? s--·

63-215/601 14 9 2 DRE!KORN FOR SENATE -1-J~· . 5697 BAY POINT RD. f ,.~ ! L-(- ~ BOKEELIA FL 33922 Date . ._JiL _ yShleld 0 =~~J.;~0\"•~~=-of S:\it:ltJ $ / 7 8/, l3i2__ ·~-'-

Florida Department of State . Division of Elections e. Campaign Contributions

2014 General Election Michael J .. Dreikom (REP) State Senator

About the Campaign Finance Pata Base

Rpt Yr Rpt Type Date Amount Contribute%· Name Address City State Zip Occupation Typ InKind Desc

2014 MS 05/19/2014 200 00 DREIKORN MICHAEL JOHN 5697 BAY POINT ROAD BOKEELIA, FL 33922 CONSULTANT I THE IP!, MO

2014 MS 05/27/2014 1,000 00 WALKER WILHAM HAROLD 527 E. GULF DRIVE #204 SANIBEL, FL 33957 BROADCAST MANAGER CHE

1,200.00 2 Contribution(s) Selected

Query the Campaign Finance Pata Base

[Department of State] [Division of Elections] [Candidates and Races] [Campaign Finance Information]

EXH!BIT_!_3 (lof0)

'- ~-- - "-•- -...: -- ..1~ ...... +... +,,. +1 ,,eo/,,.,.;_ hinfT rf'J; in.exef 12/18/2014 2:46:44 PMl Campaign Expenditures - Division of Elections - f i/· Department of State r, (

Florida Department of State Division of Elections

Campaign Expenditures

2014 General Election Michael J .. Dreikorn (REP) State Senator

This information is being provided as a convenience to the public, l1as been processed by the Division of Elections and should be cross referenced with the original report on file with the Division of Elections in case of questions About the Campaign Ejnance Qata Base

Rpt Yx Rpt. Type Date Amount Expense Paid To Address City State Zip Pur:pose TYP Reimb

2014 MS 05/28/2014 24 95 DELUXE CHECK CORPORAIE 3680 VICTORIA SIREEI NORTH SHOREVIEW, MN 55126 CAMPAIGN CH!:CKS MON

24 .. 95 1 Expenditure(s) Selected Query the Campajgn Ejnance Pata Base

[Department of State] (Oivisjon of E!ectjons] [Candjdates and Races] (Campajgn Finance Information]

EXHIBIT_ /3 (.2cif t) htto:l/electiondos ..state.fl.uslcgi-bin!TreF in .exe[l 2118/2014 2:47:33 PM] Campaign Contributions - Division of Elections - Ft Department of State (

Florida Department of State :.- Division of Elections Campaign Contributions

2014 General Election Michael J .. Dreikorn (RE.P) State Senator

About the Campajgn Ejoance pata Base

Rpt Yr Rpt Type Date Amount Contr·ibutor· Name Address City State Zip Occupation Typ InKind Desc

2014 Fl 06/02/2014 1 00 IOURCHLIGHI PRODUCTIONS 1485 LINHARI AVE FORT MYERS, FL 33901 CHE

2014 Pl 06/03/2014 0 01 DREIKORN MICHAEL 5697 BAY POINI ROAD BOKEELIA, FL 33922 CONSULIANT/ IHE IPL CHE

2014 Pl 06/03/2014 0.01 OSBORNE COLLIN 968 7 WILSHIRE LAKES BIND NAPLES, [L 39104 CHE

2014 Fl 06/03/2014 0 .. 01 OSBORNE COLLIN 968 7 WILSHIRE LAKES BLVD NAPLES, fL 39104 CHE

2014 Pl 06/03/2014 0 01 OSBORNE COLLIN 9687 WILSHIRE LAKES BLVD NAPIES, [L 39104 CHE

2014 Pl 06/03/2014 0 01 OSBORNE COLLIN 9687 WILSHIRE LAKES BLVD NAPLES, FL 33916 CHE

2014 Pl 06/09/2014 25, 00 MONIAGINNO PATRICIA 5309 SW 11 AVE CAPE CORAL, Fl 33914 CHE

2014 Pl 06/09/2014 100. 00 VALOR R.EAL ESTAIE SERVICE, INC 324 NICHOLAS PARKWAx CAPE CORAL, FL 33991 CHE

2014 Fl 06/10/2014 1,000.00 QUACKENBUSH RIIA 9045 PROSPERI! t WA't FORT MYERS, [L 33913 REAl!OR CHE

2014 Pl 06/16/2014 1,000.00 CAMPBclI JOSEPH 16251 N. CLEVELAND AVE .. SUIIE J NORTH FORI MYERS, f L 33903 PODIATRISI CHE

2014 Pl 06/ 16/2014 0, 01 DREI!(ORN MICHAEL 5697 BAX PO!NI ROAD BOKEELIA, fL 33922 CONSULIANT/ !HE IPL CHE

2014 Pl 06/17 /2014 25. 00 MEWBORN JOAN 12 7 59IH ER RACE CAPE CORAL, fL 33914 CHE

2014 Pl 06/19/2014 1,000.00 AIM HOME HEALIH 6238 PRESIDENIS COURI #lA fORT MYERS, fL 33919 HOME CARE CHE

20U Pl 06119/2014 500.00 KREEGAL PAIGE 3081 SANDY PIIJE DRIVE PUNJA GORDA, IL 33982 MEDICAL DOC!OR CHE

2014 Pl 06/19/2014 1,000 .. 00 MORRIS Di\RELD 13710 MEIR.0 AVE #108 fORT MYERS, IL 33912 PHYSICIAN CHE

4,65106 15 Contribution(s) Selected

Query the Campajgn Ejnance Data Base EXHlB!T-·--- 13 (3 of{,) htto://e lection. dos .. state .. fl..us/ cgi-bin/I reF in .exe[ 12/18/20 14 2:48:24 PM] Campaign Expenditures~ Division of Elections 8 Ff'/ -Department of State '

Florida Department of State Division of Elections

Campaign Expenditures

2014 General Election Michael J .. Dreikorn (REP) State Senator

Rpt Y< Rpt Type Date Amount Expense Paid To Address City St.ate Zip Pu1:pose Typ Reimb

2014 Pl 06/01/2014 35 00 CIRCLE !( 1603 CAPE CORAL PARKWAY CAPE CORAL, FL 33904 AUIO FUEL MON 2014 Pl 06/01/2014 10 65 AU!HORIZE NEI PO BOX 947 AMERICA FORK, UI 84003 MERCHANI SERVICE MON 2014 Pl 06/01/2014 6 57 MCDONAIDS 1604 W CAPE CORAIL PARKWAY CAPE CORAL, FL 33914 FOOD MON 2014 n 06/05/2014 196 10 AR!fPE, INC 3530 WOR!( DRIVE FORT MYERS, IL 33916 REMITIANCE ENVELOPES MON 2011 Pl 06/05/2014 118 99 VISIA PF.IN! 95 HAYDEN AVE LEXINGTON, MA 02421 BUSINESS CARDS MON 2014 Pl 06/06/2014 150. 00 BARRA! I CHRISIINE 1672 21SI ST NOR!H AP! 5 ARLINGTON, VA 22209 WEBSIIE DESIGN MON 2014 Pl 06/10/2014 53 95 SUNIRlJSI MERCHANT SERVICES PO BOX 6600 HAGERSTOWN, MD 21 '40 MERCHANI SERVICES MON 2014 Pl 06/10/2014 22. 00 LEE REPUBLICAN WOMEN FEDERATED PO BOX 61964 FORT MYERS, FL 33906 MEETING MON 2014 Pl 06/12/2014 -22 00 ITC REPUBLICAN WOMEN EEDCRAIED PO BOX61964 fORT MYERS, FL 33906 DUPLICATE REF 2014 Pl 06/16/2014 60.00 PSD CEN!ER lLC 605 CAMERON WALK COURT CHARLOTTE, NC 28217 WEBSilE SUPPORT MON 2014 Pl 06/16/2014 1, 781. 82 FLORIDA DEPARIMENT OF STATE DE 500 S BRONOUGH SI rALLAHASSEE, FL 32399 FILING FEE MON 2014 Pl 06/17 /2014 25. 50 FED EX 11751 S CLEVELAND AVE FORT MYERS, FL 33901 SHIPPING MON 2014 Pl 06/19/2014 38.00 SUNIRUSI BANT PO BOX 291286 NAHVILLE, IN 37229 BANK FEE MON 2014 Pl 06/20/2014 214. os orrrcE MAX 501 SW PINE ISLAND ROAD CAPE CORAL, FL 33991 IONER, PAPER MON

2,690 .. 66 14 Cxpenditure(sl Selected Query the Campajgn Fjnance Data Base

[Department of State] [Division of Elections] [Candidates and Races] [Campaign Finance Information]

EXHIB!T f3 (";./of~) -~----· htto://election.dos ..state. flus/cgi-bin/TreF in .exe[l2/l 8/2014 2:49:00 PM] Campaign Contributions - Division of Elections - F} ' :Department of State I,

Florida Department of State Division of Elections -~ Campaign Contributions

2014 General Election Michael J .. Dreikorn (REP) State Senator

About the Campaign Finance Pata Base

Rpt Y< Rpt Type Date Amount Contributo%· Name Address Ci t.y St.ate Zip Occupation Typ InKind Desc

2014 P2 06/21/2014 10 .00 GLAAB FRANK 2019 NW 14IH AVE CAPE CORAL, [L 33993 CHE 2014 P2 06/21/2014 200 .00 VALOR REAL ESIArE SERVICE, INC 324 NICHOLAS PARKWAY CAPE CORAL, FL 33991 REALTOR CHE 2014 P2 06/21/2014 100 .00 fEICHJHALER ERIC 1717 CAPE CORAL PARKWAY E CAPE CORAL, FL 33914 CHE 2011 P2 06/26/2014 100 00 BOBAK ANIHONY 5684 BOLLA COURI FORT MYERS, [L 33919 CHE

2014 P2 07/02/2014 100 00 SOL CR HE:RIBERIO 2184 LOCUS! GROVE FD CARLISLE, I'V'· 40311 CHE

510 .. 00 S Contribution(s) Selected

Query the Campaign Finance Data Base

[Oeoartment of State] [Division of Elections] [Candidates and Races] [Campaign Finance Information]

i..-.,..11,,1.,.t>tinn .-1,...,

Florida Department of State Division of Elections .

Campaign• Expenditures

2014 General Election Michael J .. Dreikom (REP) State Senator

This information is being provided as a convenience to the public, has been processed by the Division of Elections and should be cross referenced with t11e original report on file with the Division of Elections in case of questions. About the Campaign Finance pata Base

Rpt Yx Rpt Type Date Amount Expense Paid To Address City State Zip Pux·pose Typ Reimb

2014 P2 06/23/2014 300 .00 CIIY Of CAPE CORAL PARKS AND R PO BOX 150027 CAPE CORAL, fl 33915 MARKETING CVENI MON 2014 P2 06/23/2014 22 33 NATIONBUILDER 448 S HILL SI #200 LOS ANGELES, CA 90013 WEBSIIC FEE MON 2014 P2 06/24/2014 1,262 00 IORCHLIGHI PRODUCTIONS LLC 7500 COLLEGE PA.RKWAY FORI MYERS, FL 33917 VIDEO PRODUCIION MON 2014 P2 06/27/2014 15 89 OffICE MAX 501 SW PINE ISLAND ROAD CAPE CORAL, FL 33991 EVCNT SUPPLIES MON 2014 F2 06/27 /2014 15 00 IIGLR BAY CLUB or SOUTHWEST FL PO BOX 9294 !ORI MYERS, fL 33902 POLITICAL MEflING MON 2014 P2 06/30/2014 40. 09 CIRCLI: K 10499 STRINGFI:LlOW RD SI JAMES CIIY, fL 33956 fUEL MON 20H F2 06/30/2014 26 49 SPOR!S AUIHORI1Y 1810 PINE ISLAND ROAD CAPE CORAL, fL 33909 MARKETING MON 2014 P2 07/02/2014 11 .26 AUTHORIZE NET PO BOX 947 A.MERICA fORK, UI 94003 MERCHANT SERVICE MON 2014 F2 07 /02/2014 50 00 REPUBLICAN WOMEN OF SOUTHWEST PO BOX 8161 NAPLES, fL 34101 MEETING MON 2014 P2 07/03/2014 50 .. 10 HOME DEPOT 2508 SKYLINE BLVD CAPE CORAL, FL 33914 EVENT SUPPLIES MON 1,823 .. 16 10 Expenditure (s) Selected Query the Campaign Finance Pata Base

[Department of State] [Division of Elections] [Candidates and Races] [Campajgn Finance Information] Fwd: Invoice (No .. 67967) - from Torchlight Productions, LLC, Michael Dreikorn Campaign Matt Hurley to: Helen Hinson 09/24/2014 07:31 AM ... History: This message has been replied to. ---·------·------· ---·-·---·--··--··-·---·-··-··--·----·---·---····--··-·····-·-·----····---····-····-···--··--·--- 1 attachment ------.

attrtioc pdf

Matt Hurley Partner-Torchlight Productions 7500 College Parkway Fort Myers FL 33907 Office- 239-938-3341 Cell- 239-223-8941 www.torchlightpro.com [email protected]

Begin forwarded message:

Frnm: Steven Mcintyre Date: September 23, 2014 at 8:48:32 PM EDT To: Matt Hurley Subject: Invoice (No. 67967) - from Torchlight Productions, LLC, Michael Dreikorn Campaign /;?7)1! Invoice c___. i Torchlight Productions, llC

7500 College PKWY Fort Myers, FL 33907

Bill To: Michael Dreikorn Campaign

Date Invoice No, Terms REP Due Date 05/19/14 67967 FULL MHurl 06/19/14

Video Editing Editing of Existing Footage 250 00 250.00 Video Shoot Video Shot on Site or in Stu <:!~B;;, 250 00 250 00 Graphic Design Hourly Fee 1·~·;~ ;3!~~·>~, 10 75 00 750 00 Bank Transaction Fee '~::-r '.'\•:: 1 12,00 12 00

Total $1,262.00

Balance Due $0,,00 J Page 1 of 1 ('

Fwd: Dteikom video Matt Hurley to: Helen Hinson 09/23/2014 05:06 PM Show Details

Matt Hurley Partnet-Torchlight Productions

7500 College Patkway Fort Myers FL 33907 Office- 239-938-3341 Cell- 239-223-8941 www.torchlightpro.com [email protected]

Begin forwarded message:

From: "Torchlight Productions: Department of Motion Media" Date: Septembe123,2014 at 4:37:24 PM EDT To: hur ley(ii)torchlightpro.com Subject: Dreikorn video

fi voiceofthepeople_update.wmv

Thank you,

Motion Media Department Torchlight Prnductions Design and Development 2013 & 2014 Best ofFmt Myers Award for Internet Marketing Service Office: (239) 938-3341 'Like' us on Facebook: Facebook.com/torchlightpro Subscribe to us on Y ouTube: YouT ube.com/usei/torchli ghtproF L

Please do not reply to this emaiL Fm any questions or concerns, please contact Alex Aldie1i, Directm of Motion Media at aaldieriliiltorchlightpro.com or by calling (239) 938-3341. Additional documents in the Dreikorn Matter . h "k t Helen Hinson Dr. Mic ae 10 rei orn o: ([email protected]) 12/03/2014 01 :46 PM

~~~~~~~-~~~~~~~~~~ 5 attachments ~ ~ Invoice (No. 67967)-from Torchlight Productions, LLC, Michael Dreikorn Campaign #1 pdf ATT00001 htm ~ iJ Invoice (No 67967) - from Torchlight Productions, LLC, Michael Dreikorn Campaign #1 pdf ATTOOOO 1 htm ~ Dreikorn Agreement 05-XX-14 doc

Helen: Thank you for your time and patience on our call this morning. As discussed, I am providing additional correspondence between Mr Hurley and myself Included in this correspondence is a non-signed revised consulting contract and the initial invoice provided by Mr Hurley after he terminated his support. I'd like to point out that the draft agreement contemplated the consultant (South Eastern Strategies/Hurley) to engage in fund raising efforts and they were to be paid as a result of their fund-raising performance .. (Para 3) If funds were not raised the consultant was not entitled to any payment There are no provisions for payment for partial work product, such as web site, business cards, video, press releases, printing, etc. And, there are no single line-item deliverables other than fund-raising that had monetary value associated If any additional campaign expenses were to be incurred, such must be approved prior to the expenditure by the campaign treasurer (ref Para 2e).

"Consultant will be responsible for documenting and updating campaign budget Candidate is responsible for review and approval of campaign budget All campaign expenditures must be approved by the designated campaign treasurer."

And, the consultant was to be self-directed and any work-effort was at its own risk. "The manner in which the Services are to be performed and the specific hours to be worked by Consultant shall be determined by Consultant" (Ref Para. 1)

The subject YouTube video was not specified in the revised agreement, nor was any budget or value associated with any such work effort The geniuses of the subject YouTube video and all related work effort was solely that ofTorchlight As I have previously disclosed, after the relationship between the parties dissolved, the video was still the property of Torchlight Productions. As I desired to use the video, my campaign sought to negotiate a price for the video, and that is why there are numerous versions of invoices provided by Torchlight

I am not aware of what documents Torchlight produced to your office However, in the attached correspondence is a copy on the original invoice provided by Torchlight. The invoice was attached to an email sent from Mr Hurley to myself on May 27, 2014. The invoice itself is dated May 19, 2014 You may also notice in the email body I question the dates on the invoice and in subsequent emails the acceptance of certain services and the prices associated with the Torchlight services .. Please note that the revised agreement previously discussed provides no provisions for these individual services and no such authorization was made by the campaign during the time in question

In the attached Jun 07, 2014 email correspondence, I am describing to Mr Hurley by dissatisfaction with many of the services he is attempting to invoice me for.

The Jun 09, 2014 email correspondence shows the conveyance of log-in information to the YouTube page where the video is located This represents the first date that the "campaign" had any control over the video broadcasting

The Jun 17, 2014 email represents Mr. Hurley resending an invoice that contained services that I was not willing to accept (website) or pay for The accuracy of dates on the various versions of the Torchlight invoices are substantiated as unreliable and cannot be relied upon as dates services were agreed upon or accepted

In review of this entire matter, it comes down to a question of the root cause of an alleged violation. Had the campaign application been accepted on May 12 '" , all other issues would be moot The video was live on YouTube from the afternoon of May 12 to the morning of May 14 - less than 48 hours on a free internet site. The Dept of Elections never notified me (the candidate) that they had not accepted my electronic application .. Once I was made aware (by the media) that an "original ink signature" was required for the form to be accepted, I engaged all relevant corrective measures immediately

I have been open and transparent in this investigation and hope to resolve this issue

Regards, Michael

-----Message from Matt Hurley on Tue, 17 Jun 2014 19:10:43 +0000 ----

Matt Hmley Paitne1-Torchlight P10ductions 7500 College Pa1kway Fort Myers FL 33907 Office- 239-938-3341 Cell- 239-223-8941 www.torchlightmo.com Hm [email protected]

Begin fo1waided message:

15 (::i.. of' r1) """'"' ~"""'~-··" _,._, ... ~.....- .... r·

From: Steven Mcintyre Date: June 17, 2014 at 3:07:14 PM EDT To: Matt Huiley Subject: Invoice (No. 67967) - from Torchlight Productions, LLC, Michael Dreikorn Campaign #1

Dear Michael Dreikom Campaign, Y om invoice is attached and includes payment-due information .. Please let us know if you have any questions Thank you for yom business Sincerely, Torchlight Productions, LLC

-----Message from Alex Aldieri on Mon, 9 Jun 2014 19:04:45 +0000---- "Dr.. Michael Dreikom" < dre1 'k om @h. t eip 1 group com> :To

Michael, here is your log in information for your YouTube account: Email: [email protected] Password: Staff2014

And here is the link to a Dropbox folder containing all of the photos that we have taken of you https:/lwww.dropbox.com/sh/ygjp4wau5g7a6kb/AAAoNxknPaZHkxJ31VlwSdVJa

Please let us know if you have any problems

Thank you, Alex Aldieri Director of Motion Media Torchlight Productions, LLC 2013 & 2014 Best of Fort Myers Award for Internet Marketing Service Office: (239) 938-3341

-----Message from Matt Hurley on Mon, 9 Jun 2014 14:57:14 +0000 ---- "Dr Michael Dreikom" :To

Michael, I .Let me know where you would like the domain moved I will make sure this happens We simply place it under our management so that we can make changes as needed should atlything need to be done on a timely basis 2 .. Collin, Please provide Michael with a high res version of his logo Make sure he gets a number of different variations 3 T0 the best of my knowledge, the transact account is still open. the login should be [email protected] PW: election2014 4 .. I will have Alex send this along shmtly 5 .. Alex will also p10vide these 6 .. We can supply you with any and all statistics you would like on the current site You are more than able to have us upload and make new additions at anytime ..

Matt Hurley Partner-Torchlight Productions 7500 College Parkway Fmt Myers FL 33907 Office- 239-938-3341 Cell- 239-223-8941 www.torchlightpro.com [email protected] On Jun 7, 2014, at 8:37 PM, Dr Michael Dreikom wrote: Matt: We should talk on the phone to wmk out payment details

There are a number of things we need to resolve

1) I see my domain michaeldreikom.com has been moved to Go Daddy I assume this was for hosting under your management. I would like to have access to that domain, so I can move it under my cont10l I thought you were only going to repoint the dns.

2) I do not have a print quality file of the campaign logo Can this please be provided in a high-res

3) The Iransaxt account appears to have been closed .. However, we did not download arry donOI information.. And, donations that I know were made never made it to our bank accoUI1t There is no way for me to account for anything to the State I need to know what happened here, as well as gain access to the data

4) The campaign video is posted on You Tube and I do not have the login information for that account

5) As we had a laige number of photo images taken, I'd like to have a few to use for the campaign

You and your team did an awesome job on the campaign video And, for that I am very appreciative .. As we have already taped a lot of content, I'd like to use your services for other messaging in the coming weeks .. However, for the website, I plarr to migrate the content over to Nationbuilder The site you provided does not offor any statics or user ( ( data collection

All the best,

Michael

Michael J Dreikom, Ed.D Candidate for SW Florida's Senate District 30 P 0 Box 654 Bokeelia, FL 33922 I 239283.2197 Email: [email protected] Website: www .MichaelDreikom.com Facebook: https://www.facebook.com/dr.michael.dreikom Twitter: @MichaelDreikom

Paid for by Dreikom For Senate

-----Original Message----- From: Matt Hurley [mailto:[email protected]] Sent: Friday, June 06, 2014 12:08 PM Io: Dr Michael Dreikom Subject: Invoice?

Any update?

Matt Hurley Partner-I orchlight Productions

7500 College Parkway Fmt Myers FL 33907 Office- 239-938-3 341 Cell- 239-223-8941 www.torchlightpro.com Hurley@torchlightprn com Message from "Dr .. Michael Dreikorn" on Sun, 8 Jun 2014 00:37:54 ---- ----- 0000+ Matt Hurley ·To · Subject ?RE. : 1nvo1ce . Matt: We should talk on the phone to work out payment details ..

'I'here are a number of things we need to resolve

1) I see my domain michaeldreikorn .. com has been moved ;:o Go Daddy I assume this was for hosting under your management I would like to have access to that domain, so I can move it under my control.. I thought you were only going to repoint the dns 2) I do not have a print quality file of the campaign logo Can this please be provided in a high-res

3) The Transaxt account appears to have been closed. However, we did not download any donor information. And, donations that I know were made never made it to our bank account. There is no way for me to account for anything to the State I need to know what happened here, as well as gain access to the data .. 4) The campaign video is posted on You'Iube and I do not have the login information for that account, 5) As we had a large number of photo images taken, I'd like to have a few to use for the campaign You and your team did an awesome job on the campaign video. And, for that I am very appreciative.. As we have already taped a lot of content, I'd like to use your services for other messaging in the coming weeks.. However, for the website, I plan to migrate the content over to Nationbuilder rhe site you provided does not offer any statics or user data collection. All the best, Michael

Michael J .. Dreikorn, Ed.D Candidate for SW Florida's Senate District 30 P O Box 654 Bokeelia, FL 33922 T 239.283 2197 Email: MD@MichaelDreikorn com Website: www.MichaelDreikorn.com Facebook: https://www.facebookcom/dr.michael dreikorn Twitter: @MichaelDreikorn

Paid for by Dreikorn For Senate ( (

-----Original Message----- From: Matt Hurley [mailto:[email protected]] Sent: Friday, June 06, 2014 12:08 PM To: Dr.. Michael Dreikorn Subject: Invoice'?

Any update?

Matt Hurley Partner-Torchlight Productions

7500 College Parkway Fort Myers FL 33907 Office- 239-938-3341 Cell- 239-223-8941 www. torchlightpro .. com [email protected]

-----Message from Matt Hurley on Tue, 3 Jun 2014 18:33:37 +0000 ---- "D1 Michael D1eikom" T : 0 . Subject Re: Prnblem on Website ·

Michael, I met with my team about this early today. It seems as though they got it straightened out I hope all is going well Please foe! free to 1each out with any othe1 questions you may have

Matt Hurley Paitner-T 01chlight Productions 7500 College Pa1kway Fo1t Myers FL 33907 Office- 239-938-3341 Cell- 239-223-8941 www.torchlightmo.com [email protected]

On Jun 2, 2014, at 10:27 PM, "D1 Michael Dreikom" wrote:

Matt: We are still fumbling with the donation functionality on the website I have heard from numerous folks tonight that they can't donate because the submit button does not work. Can you please look into this personally, as you know, without donations I am dead in the water

Regards, Michael

Message from "Dr Michael Dreikorn" on Tue, 27 May 2014 21:43:18 ---- ----- 0000+

.. 1!:>('7of1'7) · ·. _c-·o~C'-'---~~=...... '!...2'.::.'i

From: Torchlight Productions [mailto:sales@torchlightpro .. com] Sent: Tuesday, May 27, 2014 5:30 PM To: Dr .. Michael Dreikorn Subject: Fwd: Invoice (No .. 67967) - from Torchlight Productions, LLC, Michael Dreikorn campaign #1

I orchlight Productions

7500 College Parkway Fort Myers FL 33907 Office- 239-938-3341

Dear Michael Dreikorn Campaign,

Your invoice is attached and includes payment-due information Please let us know if you have any questions Thank you for your business

Sincerely, Torchlight Productions, LLC

Message from "Dr Michael Dreikorn" on Tue, 20 May 2014 21 :09:26 ---- ----- 0000+ ,· Chris Berardi ·cc · . S . Subject RE : W e b an d C onsu 1trng ervrces .

Matt: We need to talk about this

From: Matt Hurley [mailto:hurley@torchlightpro .. com] Sent: Tuesday, May 20, 2014 4:54 PM To: Dr.. Michael Dreikorn Cc: Bill Holderby; Chris Berardi Subject: Web and Consulting Services

Michael,

On behalf of the entire Torchlight Productions team, I would like to thank you for contracting (

with us fo1 the design and hosting of your website As a valued customer, we look forward to assisting with changes, additions or maintenance of your site via our 24/7 custome1 support netwo1k. Access information is provided at the end of this email. Regarding campaign consulting services, SouthEastem Strategies has made a difficult decision and it is the consensus of the members of our organization to not pursue these services for the Dreikorn for Senate campaign .. There were marry factors that entered into this decision making process .. We believe that you are a well-qualified candidate and wish you the best ofluck in your endeavors, however we do not believe that a consultant/client 1elationship is viable at this time I and my entire team will be here to assist with your web p1esence in any and all ways possible .. Again, best of luck in your effo1ts!

Regards, For Customer Suppmt regarding your website, emails or arry other related services.

Please visit us at: http://mytorchlightsite.com

Your Log In: [email protected] Password: election2014

MattHuiley Partner-I orchlight Productions

7500 College Parkway Fmt Myers FL 33907 Office- 239-93 8-3341 Cell- 239-223-8941 www.torchlightpro.com [email protected]

Message from "Dr .. Michael Dreikorn" on Fri, 2 May 2014 01:27:32 ---- ----- 0000+ , Bill Holderby :cc Sub1"ect RE: Agreement ·

Matt: I reworked the agreement a bit to ensure we have all, or at least most, the expectations on the table '!here are a few areas that still need to be defined, as indicated Please review and provide your comments

Regards, Michael

-----Original Message----- From: Matt Hurley [mailto:hurley@torchlightpro com] Sent: Tuesday, April 29, 2014 8:20 AM

: 15' (9 cf 11) -=..,·<~~'-'-·-·'', /'--~ I

To: Michael Dreikorn Cc: Chris Berardi Subject: Agreement

Here is an updates agreement / I

POLITICAL CONSULTING AGREEMENT Torchlight Productions, l.LC

This Marketing Consulting Ag1eement "Agreement" is made effective as of May XX, 2014, by and between Dr Michael I Dreikom ("Candidate"), and Torchlight Productions, aka, South Eastem Strategies ("Consultant"), of 14501 Grande Cay Ch #2702, Fo1t Myers, Florida 33908

I orchlight Productions, LLC is registered with the State of F101ida with FEI Number 45- 5057185 (provide legal address) South Eastem Strategies is 1egistered with the State of Florida .. please provide legal status here ... EIN, Sunbiz number, DUNS, etc .dba registration .... provide legal address

For the pmposes of this agreement, Di.. Michael l Dreikom is a private person in a political campaign in the State ofFlo1ida for the Senate position in Dist1ict 30 Candidate's mailing address is P 0 Box 654, Bokeelia, Florida 33922 ..

Consultant has a background in political campaign marketing and is willing to provide se1vices to Candidate based on this background ..

Candidate desi1 es to have se1vices provided by Consultant

Iherefo1e, the paities ag1ee as follows:

1. DESCRIPTION OF SERVICES. Beginning on May XX, 2014, Consultant will provide the following services (collectively, the "Se1vices"): a Assist with Campaign Development; b Analyze Opposition Reseaich; c Develop Campaign Message; d Provide Modem and Efficient Campaign I actics; e Develop Marketing Plans and Budget (Under direction of Campaign I reasurer); f Paiticipate in Campaign Press Relationships (All press releases are to be released by Cainpaign Communications Director); g Paiticipate as a Senior Advisor to Campaign Activity and to Cooperate with other Senior Campaign Advisors, as directed by the Candidate; h Develop Web-based Campaign Communications (including website, mobile applications, and social media); Develop Printed Campaign Communications; and j Develop and Execute Fundrnising Plan.

Political Consulting Agreement Page 1 of7 Ag1eed to: Consultant__ _ Candidate ___ '"""' 1101-r 15' (( r of- i'I\ ' ( 1. i '

The manner in which the Services are to be performed and the specific homs to be worked by Consultant shall be determined by Consultant. Candidate will rely on Consultant to work as many hours as may be reasonably necessaiy to fulfill Consultant's obligations under this Agreement Consultant will apply a standaid of best-effort to ensure Services are effective and efficient Consultant will apply state of~the-art technologies for provided solutions.

2. OBLIGATIONS OF CONSULTANT. Consultant shall be responsible for:

a Assist with Cainpaign Development. Define b Analyze Opposition Research. Define ... c Develop Campaign Message. Define .. d Provide Modern and Efficient Campaign I actics. Define e Develop Marketing Plans and Budget (Under direction of Cainpaign Treasurer}. Consultant and Candidate will cooperate to develop appropriate campaign maiketing and budget plans to ensure a winning campaign Consultant will be responsible for docmnenting and updating cainpaign budget Candidate is responsible for review and approval of cainpaign budget All campaign expenditures must be approved by the designated campaign treasurer f Participate in Campaign Press Relationships. Consultant will develop and publish campaign communication materials All press releases are to be approved by Cainpaign Communications Director, prior to release/publishing .. g Participate as a Senior Advisor to Cainpaign Activity and to Cooperate with other Senior Cainpaign Advisors, as directed by the Candidate. Consultant will perform as the primary Senior Advisor to the Candidate and will work with other Senior Advisors, as directed by the Candidate h Develop Web-based Campaign Communications (including website, mobile applications, and social media); Consultant will develop and deploy web based campaign communication vehicles to ensure sufficient coverage within the campaign district Vehicles and solutions include a state-of~the-art cainpaign website that manages donations and volunteers (e.g.. , Nationbuilder), mobile applications that provide voters with relevant cainpaign information on mobile devices, and presence and fonctionality on relevant social media sites Consultant may engage Candidate's existing web developer to modify Candidate's existing cainpaign website; Develop Printed Cainpaign Communications; Consultant will develop and deploy print media strategy, to include mailers, yard signs, and other printed materials .. All print jobs rue to be offered to Artype If Artype is unwilling or unable to provide related print services, Consultant will find the best vendor (quality and cost) to provide such services All expenditmes must be approved by the Campaign I reasurer prior to placing orders or making commitments with vendors; and

Political Consulting Agreement Page 2of7 Candidate ___ EXH!BlT .. !5 Cr;:)...# n) Agreed to: Consultant__ /. / I r'. I '

j. Develop and Execute Funchaising Plan.. Consultant shall be responsible for raising a minimum of $25,000.00 per each Relevant Month (fundrnising) Relevant Months are May 2014, June 2014, July 2014, and August 2014 The measure ofthe minimum funchaising will be calculated at the first calendar day of each month and conclude at the last day of each month and will only include monies directly attributable to Consultant's efforts (does not include donations made by Candidate's family and existing friends)..

3. PAYMENT TERMS. Candidate will pay a foe to Consultant for the Services monthly. The payments will be due on the 1" of the month The payments will be due before the Services are rendered for the month.

Candidate will owe Consultant $2,500 .00 per month though the month of August 2014 ..

If the Candidate is successful in winning the Primaiy Election on August 26th 2014, Consultant will be owed $10,000.00 as a "Win Bonus" The Win Bonus will be due by September l't2014 .. Ifthe Consultant is able to raise more than a cumulative $500,000 from May to August, the Win Bonus will be $25,000.

No payment will be due if$25,000 was not raised the preceding Relevant Month, and Consultant will continue to provide services at no chai ge for the Relevant Month Any money raised for during any Relevant Month over the minimum amount may be cairied over and used in subsequent Relevant Month calculations (will still be reported in the proper reporting cycle for reporting pwposes) All campaign finances aie to occur exclusively under the supervision of the Campaign Treaswer, as defined by the Candidate The Consultant and Candidate shall never have direct access to any campaign monies

4. TERMffERMINATION,. This agreement will be canceled automatically for any of the following reasons on the date of their occwrence: a Candidate loses the Primaiy Election on August 26, 2014; b Consultant violates any of the terms of this agreement; c Consultant or any of its employees are violate the confidentially of the campaign; or d Consultant engages in a business relationship with another candidate that is perceived as a conflict of interest (perception is measured by a reasonable voter)

If the above does not occur, the agreement may be canceled automatically upon payment of the win bonus At the discretion of the Candidate, the agreement may be extended past August to include the General election in November 2014 ..

Political Consulting Agreement Page 3 of 7 "\ Agreed to: Consultant__ _ Candidate ___ .... - ,..,. i< ( r:"'J di- I '1 i I ' I

If Candidate chooses to terminate the Agreement for reasons other than those shown above, Candidate will owe Consultant a $2,500.00 cancelation fee ..

5. RELATIONSHIP OF PARTIES. It is understood by the parties that Consultant is an independent contractor with respect to Candidate, and not an employee of Candidate.. Candidate will not provide fringe benefits, including health insurance benefits, paid vacation, or any other employee benefit, for the benefit of Consultant

6. EMPLOYEES. Consultant's employees, if any, who perform services for Candidate under this Agreement shall also be bound by the provisions of this Agreement

7. INTELLECTUAL PROPERTY. The following ptovisions shall apply with tespect to copyrightable works, ideas, discoveries, inventions, applications for patents, and patents (collectively, "Intellectual Propeity"): a Consultant's Intellectual Property Consultant does not personally hold any interest in any Intellectual Property .. b Candidate 's Intellectual Property Candidate owns all rights to campaign materials, including images, web content, publications, and logos

8. MUTUAL NONDISCLOSURE AGREEMENT. "Confidential Information" means any information disclosed by either party to the other party, either directly or indirectly, in writing, orally or by inspection of tangible objects, including without limitation documents, prototypes, samples, plant and equipment, research, product plans, products, services, customer lists, software, developments, inventions, processes, designs, drawings, engineering, hardware configuration, marketing materials or finances, which is designated as "Confidential," "Proprietary" or some similar designation. Information related to campaign strategy and relevant information shall be considered Confidential Information Confidential Information may also include information disclosed to a disclosing party by third parties. Confidential Information shall not, however, include any information which (i) was publicly known and made generally available in the public domain prior to the time of disclosure by the disclosing party; (ii) becomes publicly known and made generally available after disclosure by the disclosing party to the receiving party through no action or inaction of the receiving party; or (iii) is required by law to be disclosed by the receiving party, provided that the receiving party gives the disclosing party prompt written notice of such requirement prior to such disclosure and assistance in obtaining an order protecting the information ftom public disclosure a Non-disclosure .. Each party shall not use the Confidential Information of the other party for any purpose except to meet the business requirements provided in this agreement. Neither party shall disclose any Confidential Information of the other party to third parties If any party makes copies of the Confidential Information of the other party, such copies shall also constitute Confidential Information and any and all confidential markings on such documents shall be maintained

Political Consulting Agreement Page 4 of7 EXHllSlT / 0 (J LJ-;ef- I'\) Agreed to: Consultant__ _ Candidate --- \.

b Maintenance of Confidentiality. Each party shall take reasonable measures to protect the secrecy of and avoid disclosure and unauthorized use of the Confidential Information of the other party. Without limiting the foregoing, each party shall take at least those measures that it takes to protect its own most highly confidential information, and shall promptly notify the disclosing party of any misuse or misappropriation of Confidential Information of which it becomes aware c No WaHanty. ALL CONFIDENTIAL INFORMATION IS PROVIDED "AS IS " NEITHER PAR TY MAKES ANY WARRANTIES, EXPRESS, IMPLIED OR OTHERWISE, REGARDING ITS ACCURACY, COMPLETENESS OR PERFORMANCE.

d Return of Materials. All documents and other tangible o]Jjects containing 01 representing Confidential Information which have been disclosed by either party to the other party, and all copies thereof which are in the possession of the other party, shall be and remain the property of the disclosing party and shall be promptly returned to the disclosing party upon the disclosing party's written request e.. No License .. Nothing in this Agreement is intended to grant any rights to either party under any patent, mask WOik right 01 copyright of the other party, nor shall this Agreement grant any party any rights in or to the Confidential Information of the other party except as expressly set forth herein .. f Term .. The obligations of each receiving party hereunder shall survive for a period often years after the disclosure of the Confidential Information or until such time as all Confidential Information of the other party disclosed hereunder becomes publicly known and made generally available through no action or inaction of the receiving party, whichever is earlier g Remedies Each party agrees that any violation or threatened violation of this Agreement may cause iITeparable injury to the other party, entitling the other party to seek injunctive relief in addition to all legal remedies .. h Miscellaneous Neither party may assign its rights or obligations under this Agreement without the prior written consent of the other party

9. ENTIRE AGREEMENT. This Agreement contains the entire agreement of the parties and there are no other promises or conditions in any other agreement whether oral 01 written This Agreement supersedes any priOI written 01 oral agreements between the parties ..

10,. AMENDMENT. This Agreement may be modified or amended if the amendment is made in writing and is signed by both parties ..

11. SEVERABILITY. If any prnvision of this Agreement shall be held to be invalid or unenforceable for any reason, the remaining provisions shall continue to be valid and enforceable .. If a court finds that any provision of this Agreement is invalid or

Political Consulting Agreement Page 5 of7 Candidate ___ FX:t··llBlT I 5 Os of- ri) Agreed to: Consultant__ _ r"' I 1.

unenforceable, but that by limiting such provision it would become valid and enforceable, then such provision shall be deemed to be written, construed, and enforced as so limited.

12. WAIVER OF CONTRACTUAL RIGHT. The failure of either party to enforce any provision of this Agreement shall not be construed as a waiver or limitation of that party's right to subsequently enforce and compel strict compliance with every provision of this Agreement.

13. APPLICABLE LAW. This Agreement shall be governed by the laws of the State of Florida

14. ARBITRATION. Any controversies or disputes arising out of or relating to this Agreement shall be resolved by binding arbitration in accordance with the then current Commercial Arbitration Rules of the American Arbitration Association .. The parties shall select a mutually acceptable arbitrator knowledgeable about issues relating to the subject matter of this Agreement. In the event the parties are unable to agree to such a selection, each party will select an arbitrator and the two arbitrators in turn shall select a third arbitrator, all three of whom shall preside jointly over the matter. The arbitration shall take place at a location that is reasonably centrally located between the parties, or otherwise mutually agreed upon by the parties .. All documents, materials, and information in the possession of each party that are in any way relevant to the dispute shall be made available to the other party for review and copying no later than 30 days after the notice of arbitration is served The arbitrator(s) shall not have the authority to modify any provision of this Agreement or to award punitive damages .. The arbitrntor(s) shall have the power to issue mandatory orders and restraint orders in connection with the arbitration The decision rendered by the arbitrator(s) shall be final and binding on the parties, and judgment may be entered in conformity with the decision in any coUit having jurisdiction.. The agreement to arbitration shall be specifically enforceable under the prevailing arbitration law. During the continuance of any arbitration proceeding, the parties shall continue to perform their respective obligations under this Agreement

15. SIGNATORIES. This Agreement shall be signed on behalf of Candidate by Dr. Michael Dreikom, Candidate, and on behalf of South Eastern Strategies by Matthew J HUiley, Managing Partner and effective as of the date first written above

Candidate:

By: Michael Dreikom Candidate

Political Consulting Agreement Page 6 of7 Agreed to: Consultant'--- Candidate ___ -···"~'"' /")(/(_ o-f- 1 "rl (

Consultant:

By: Matthew J Hurley Managing Pa1tne1

Political Consulting Agteement Page 7 of7 Agreed to: Consultant.__ _ Candidate --- Statutes & Constitution :Vier"',mtutes: Online Sunshine Page 1 of3

Select Year: !2014 vi~

The 2014 Florida Statutes

Title IX Chapter 106 View Entire Chapter ELECTORS AND ELECTIONS CAMPAIGN FINANCING 106.143 Political advertisements circulated prior to election; requirements .. - (1 )(a) Any political advertisement that is paid for by a candidate, except a write·in candidate, and that is published, displayed, or circulated before, or on the day of, any election must prominently state: 1 "Political advertisement paid for and approved by (name of candidate! , !party affiliation! , for !office sought) "; or 2. "Paid by (name of candidate) , (party affiliation) , for (office sought) . " (b) Any political advertisement that is paid for by a write·in candidate and that is published, displayed, or circulated before, or on the day of, any election must prominently state: 1 "Political advertisement paid for and approved by

(a) Editorial endorsement by any newspaper, radio or television station, or other recognized news medium. (b) Publication by a party committee advocating the candidacy of its nominees .. (5)(a) Any political advertisement not paid for by a candidate, including those paid for by a political party or affiliated party committee, other than an independent expenditure, offered on behalf of a candidate must be approved in advance by the candidate. Such political advertisement must expressly state that the content of the advertisement was approved by the candidate, unless the political advertisement is published, displayed, or circulated in compliance with subparagraph (1 )(a)2., and must state who paid for the advertisement The candidate shall provide a written statement of authorization to the newspaper, radio station, television station, or other medium for each such advertisement submitted for publication, display, broadcast, or other distribution. (b) Any person who makes an independent expenditure for a political advertisement shall provide a written statement that no candidate has approved the advertisement to the newspaper, radio station, television station, or other medium for each such advertisement submitted for publication, display, broadcast, or other distribution The advertisement must also contain a statement that no candidate has approved the advertisement. (6) No political advertisement of a candidate who is not an incumbent of the office for which the candidate is running shall use the word "re-elect.." Additionally, such advertisement must include the word "for" between the candidate's name and the office for which the candidate is running, in order that incumbency is not implied. This subsection does not apply to bumper stickers or items designed to be worn by a person (7) Political advertisements paid for by a political party or an affiliated party committee may use names and abbreviations as registered under s 103.081 in the disclaimer (8) This section does not apply to novelty items having a retail value of $10 or less which support, but do not oppose, a candidate or issue .. (9) Any political advertisement which is published, displayed, or produced in a language other than English may provide the information required by this section in the language used in the advertisement.. (10) This section does not apply to any campaign message or political advertisement used by a candidate and the candidate's supporters or by a political committee if the message or advertisement is: (a) Designed to be worn by a person .. (b) Placed as a paid link on an Internet website, provided the message or advertisement is no more than 200 characters in length and the link directs the user to another Internet website that complies with subsection (1 ) .. (c) Placed as a graphic or picture link where compliance with the requirements of this section is not reasonably practical due to the size of the graphic or picture link and the link directs the user to another Internet website that complies with subsection (1) (d) Placed at no cost on an Internet website for which there is no cost to post content for public users .. (e) Placed or distributed on an unpaid profile or account which is available to the public without charge or on a social networking Internet website, as long as the source of the message or advertisement is patently clear from the content or format of the message or advertisement. A candidate or political committee may prominently display a statement indicating that the website or account is an official website or account of the candidate or political committee and is approved by the

EXHIBIT ff. (2of3) -~·-"'---~-· ,...... 1?/17/?014 Statutes & Constitution :Viey-"'tatutes : Online Sunshine Page 3 of3

candidate or political committee A website or account may not be marked as official without prior approval by the candidate or political committee. (f) Distributed as a text message or other message via Short Message Service, provided the message is no more than 200 characters in length or requires the recipient to sign up or opt in to receive it. (g) Connected with or included in any software application or accompanying function, provided that the user signs up, opts in, downloads, or otherwise accesses the application from or through a website that complies with subsection (1 ) .. (h) Sent by a third-party user from or through a campaign or committee's website, provided the website complies with subsection (1 ) .. (i) Contained in or distributed through any other technology-related item, service, or device for which compliance with subsection (1) is not reasonably practical due to the size or nature of such item, service, or device as available, or the means of displaying the message or advertisement makes compliance with subsection (1) impracticable .. (11) Any person who willfully violates any provision of this section is subject to the civil penalties prescribed ins 106.265 .. History .. -s .. 8, ch .. 26870, 1951; s. 1, ch 61-145; s.. 21, ch 65·379; s 57, ch 71·136; s 30, ch. 73-128; s 52, ch 77·175; s. 30, ch. 81-304; s .. 16, ch. 89·256; s. 35, ch 90-315; s. 16, ch .. 91·107; s 646, ch 95··147; s. 17, ch. 97·13; s.. 18, ch .. 99·318; s 5, ch 2004··252; s 46, ch 2007·30; s. 18, ch 2010·167; ss 17, 30, ch. 2011·6; s 66, ch. 201HO; HJR 7105, 2011 Regular Session; s 9, ch 2012-5 Note -Formers 104 37

EXH!BlT___ {c; (3 oF 3)

l'J/17/?fllA. Fretn: Dr.,Mlchael Drelkom dr~ikomC.':llhei~.grcup.con1 ,/ Su!)l<"ll.; URGENT .. Donation Tab Update and Paid fOr disclaimer o.11o: May 30, 2014 al 3:11 PM To: Collin OSborne ([email protected]) coc-Oorne<;i~iroh1'jjh<µ;o com Cc: Matt Hurley ([email protected]) hurt.oy®!:irchlishtpro. r.om

1) We need to change the Donation page settings to direct the transactions to my bank

API Login ID and Transaction Key

·--··------··-·"·-·· -·-·---·----·-····--~.·--·--~----·-·-. -~· ..- .. ·-o--"'·-·~·----- .. --·····-· ·---·-··-·-·-····--· -----~---,·-··- Your API Login ID and Transaction Key have been suecessfulty created. Current API L.ogin ID: 5d45Ju47Cm Current 'Transaction Key: 2qPVP34bEx354v78

2) We also need to attach .a downloadable pdf for those who wish to main in their donation. On the same donation page we should place an obvious statement, "If youwould rather mail a check directly to the campaign, please complete the attached form and make a check out to: Oreikorn for Senate, and mail to: POB 654, Bokeelia, Fl. 33922."

3) We need to modify the disclaimer on all of the webpages. Florida election law requires the exact following on every page: "Political advertisement paid for and approved by Or.. Michael J.. Dreikorn, Republican for State Senate, District 30.~'

4) The video that is attached to the Bio page needs to have the following statement applied either at the beginning or end of the film: "Political advertisement paid for and approved by Or Michael J. Oreikorn, Republican for State Senate, District 30 .." I am thinking, simply overlay It to the video at the end, last S seconds or so ..

5) On the landing page, the events scroll down into the white space when I have more posted. Also, the posted date of the event may be far in advance of the event date and the posted date shows up rather large on the landing page, can we eliminate the posted date?

Regards, Michael

MichaelJ .. Dreikorn, Ed.D Candidate for SW Florida's Senate District 30 ~.o. Box654 Bokeelia, Fl 33922 l: 239 .. 283 .. 2197 Email: [email protected] Website: www.MjchaelDrejkorn.com Facebook: hftps:Uwww.facebook.com/dr.mjchael.drejkorn Twitter: @MlchaelDrelkorn Michael J .. Dreikorn, Ed .. D

MICHAEL P 0 Box 654 tel.: 239.283 2197 DREIKORN Bokeelia, FL 33922 [email protected] FOR FLORIDA SENATE

Florida Elections Commission ,.,...... , ,.- = Attn: Ms. Helen Hinson rrlU'> :;;; ;m c-i-1 107 W. Gains Street -\)"',> --1 ~ rn Suite 224 Collins Building 5?....,, en 0 Tallahassee, FL 32399-1050 (i)O I pa C?-ri""" -· ~r- - July 29, 2014 :.;o 'J;> < _... ;o rn :> ()"I ~-::2 ()"I .ct .. Dear Ms. Hinson:

In response to a letter from your office, date June 26, 2014, I am offering the following information to further your investigation .. The subject letter outlines four alleged violations to various Florida statutes, though the complainant only made one compliant (e .. g .. , "Charge #1) deny the allegations outlined in your letter and as made by the complainant

Alleged violation No.1: It is alleged that I violated Section 106.021(1)(a) by soliciting campaign contributions or making campaign expenditures before appointing a treasurer or designating a campaign depository. On May 12, 2014, I notified, by appropriate form application, the Florida Division of Elections of my candidacy for the 30th State Senate district My campaign treasurer was appointed on this same day and the campaign depository identified On May 19, 2014, the Florida Division of Elections formally accepted my campaign application. As certified in my initial campaign finance report (May 2014), no expenditures were made and contributions solicited or accepted, prior to May 19, 2014

In reference to Section 99, there are no specific statutory provisions for the method of delivering the relevant documents identified above to the Division of Elections. As the Division of Elections provides for electronic submission of documents, this method was chosen. Delivery receipt of email submission was obtained on May 13th, from a second email submission to the Division of Elections. No notification was ever made by the Division of Elections to me that the method of submission was improper. On May 14•h, I contacted the Division of Elections and inquired as to required method submission of my documents and was instructed that they needed to be provided as paper original copies. Upon said instruction, I immediately removed the subject "YouTube" video from my campaign website and re-submitted the documents via USPS overnight service.

No contributions or expenditures were made prior the Division of Elections acceptance of my application documents.

Alleged violation No .. 2: It is alleged that I violated Section 106.11 (4), in that I incurred expenses without sufficient funds on deposit in the primary deposit account. As stated above, there were no expenditures in the time in question. There is no evidence that I violated the stated statute

Page 1 of2 Alleged violation No .. 3: It is alleged that I violated Section 106143(1), in that I failed to provide a statutory required disclaimer on a political advertisement. As provided by the complainant, it is alleged that I commissioned the development of a "television advertisement". made no such commission, and he is making an inaccurate characterization of the video that is referenced .. The video is a "YouTube" video that was created by a local consulting firm that was soliciting me as a potential client. On their own accord, as a promotional demonstration piece, the local consulting firm, created at their own expense a video and posted it on a no-fee internet site. The "YouTube" video has never been provided from any location other than from the free "You Tube" internet service .. As provided in Section 106 143(1 O)(d), content "[p]laced at no cost on an Internet website for which there is no cost to post content for public users" does not require political disclaimers.. The subject internet based video is not subject to the requirements of Section 106.143(1) and does not require the noted disclaimer. However, voluntarily, the subject video was modified prior to being reposted on "YouTube" as if had had been subject to the statutory required disclaimer language of relevant political advertising.

Alleged violation No .. 4: It is alleged that I violated Section 106.19(1)(d), in that I made or authorized one or more expenditures prohibited by Chapter 106. As described above. there were no expenditures made in the time of question. There was no violation to the stated statute.

As provided in my previous correspondence with your office, there were no violations, as alleged by the complainant

Please feel free to contact me with questions or comments at any time

Best Regards, ->?-<~

Michael Dreikorn, Ed D Veteran, Businessman and Candidate for Florida State Senate District 30

FOR AN OATH OR AFFIRMA T/ON;· STATE OF FLORIDA COUNTY OF LEE

Sworn to (or affirmed) and subscribed before me this 29•h day of July, 2014, by Michael J. Dreikorn

....~~~~z;,, DARLENE M. SOLER s~m~i\ Notary Public .. State of Florida ~· ! E My Comm Expires Sep 11, 2015 ,; - '''·rHFf129310 ';.;"~.>•,,, ",~-" ,~13,,.,.~ Darlene M Soler

(NOTARY SEAL)

Personally Known \./ OR Produced Identification ___ Type of ldentificati~uced ______

Page 2 of 2 Jul 29 14 09:52p The IPL Grouo,. LLC '?39-283-2197 p 1 1. I

~ Michael J .. Dreikorn, Ed .. D -;.,~';"'

\UCHAEL P 0 .. Box654 tel.: 239 283 219'7 DREIKC)RN Bokeelia, FL 33922 M D@Michael Dreikorn .. com FOR ILORID'\ SE:'>J '\TE

_-., Florida Elections Commission ~ ,- = Attn: Ms. Helen Hinson r·1v.1 = ;;::i 107 W. Gains Street :~ s~;,: <-- .c;;.~ r-c:: r·~'1 Suite 224 Collins Building (") Tallahassee, FL 32399-1050 ('. ~' ) w -·- q : .. ~ --r1 0 rn -·- .. r July 29, 2014 . ~ "') - ::-,J u < z'" ", .;:5 rn ~ Ref: Case No. FEC 14-138 ,_,..,.-·--., t:::J 0 : co Dear Ms .. Hinson:

In response to a letter from your office, date June 26, 2014, I am offering the following information to further your investigation The subject letter outlines four alleged violations to various Florida statutes, though the complainant only made one compliant (e g , "Charge #1). deny the allegations outlined in your letter and as made by the complainant

Alleged violation No.. 1: It is alleged that I violated Section 106 021 (1)(a} by soliciting campaign contributions or making campaign expenditures before appointing a treasurer or designating a campaign depository. On May 12, 2014, I notified, by apfropriate form application, the Florida Division of Elections of my candidacy for the 30 State Senate district My campaign treasurer was appointed on this same day and the campaign depository identified On May 19, 2014, the Florida Division of Elections formally accepted my campaign application As certified in my initial campaign finance report (May 2014), no expenditures were made and contributions solicited or accepted, prior to May 19, 2014

In reference to Section 99, there are no specific statutory provisions for the method of delivering the relevant documents identified above to the Division of Elections. As the Division of Elections provides for electronic submission of documents, this method was chosen. Delivery 1 receipt of email submission was obtained on May 13 h, from a second email submission to the Division of Elections. No notification was ever made by the Division of Elections to me that the method of submission was improper On May 14"', I contacted the Division of Elections and inquired as to required method submission of my documents and was instructed that they needed to be provided as paper original copies Upon said instruction, I immediately removed the subject "YouTube" video from my campaign website and re-submitted the documents via USPS overnight service

No contributions or expenditures were made prior the Division of Elections acceptance of my application documents

Alleged violation No. 2; It is alleged that I violated Section 106.11(4), in that I incurred expenses without sufficient funds on deposit in the primary deposit account. As stated above, there were no expenditures in the time in question. There is no evidence that I violated the stated statute.

Page 1 of 2 Jul 29 14 09:53p The IPL Grouo LLC ,. . ?c~9-283-2197 p2

Alleged violation No.. 3: It is alleged that I violated Section 106.. 143(1) in that I failed to provide a statutory required disclaimer on a political advertisement As provided by the complainant, it is alleged that I commissioned the development of a "television advertisement'. made no such commission, and he is making an inaccurate characterization of the video that is referenced The video is a 'YouTube" video that was created by a local consulting firm that was soliciting me as a potential client On their own accord, as a promotional demonstration piece, the local consulting finm, created at their own expense a video and posted it on a no-fee internet site .. The "YouTube" video has never been provided from any location other than from the free 'YouTube" internet service. As provided in Section 106.143(10)(d), content "[p]laced at no cost on an Internet website for which there is no cost to post content for public users" does not require political disclaimers The subject internet based video is not subject to the requirements of Section 106 143(1) and does not require the noted disclaimer. However, voluntarily, the subject video was modified prior to being reposted on "You Tube' as if had had been subject to the statutory required disclaimer language of relevant political advertising

Alleged violation No. 4: It is alleged that I violated Section 106. 19(1)(d), in that I made or authorized one or more expenditures prohibited by Chapter 106.. As described above, there were no expenditures made in the time of question There was no violation to the stated statute

As provided in my previous correspondence with your office, there were no violations, as alleged by the complainant..

Please feel free to contact me with questions or comments at any time. :::t R~:-__: If. .d-:-- ---

Michael1 Dreikom, Ed D Veteran, Businessman and Candidate for Florida State Senate District 30

FOR AN OATH OR AFFIRMATION: ST A TE OF FLORIDA COUNTY OF LEE

Sworn to (or affirmed) and subscribed before me this 29'" day of July, 2.014, by Michael J Dreikorn

~~'"~~;:,,,, OARLfNE M SOLER ,s..:;P ~~~ Ncrary Puotic .. State of florida ; .. • • .. ;My Comm Expires Sep 11, 2015 ":.~;-";. !' i II i:-r 12931 Q '•. ,,

(NOT ARY SEAL)

Personally Known V OR Produced Identification-·---- Type of ldentificati~uced ______-----

Page 2 of 2 FLORIDA ELECTIONS COMMISSION 107 W, Gaines Street, Suite 224 Collins Building Tallahassee, Florida 32399-1050 Telephone: (850) 922-4539 Fax: (850) 921-0783

June 26, 2014

Michael J Dreikom 5697 Bay Point Road Bokeelia, FL 33922

RE: Case No.: FEC 14-138; Respondent: Michael J. Dr·eikom

Dear Mr Dreikom: On May 28, 2014, the Florida Elections Commission received a complaint alleging that you violated Florida's election laws I have reviewed the complaint and find that it contains one or m01e legally sufficient allegations The Commission staff will investigate the following alleged violations: Section 106.021(1)(a), Florida Statutes: Michael J Dreikom, candidate for Florida Senate, District 30, in the November 2014 election, solicited campaign contributions and made campaign expenditme;; before appointing a treasurer or designating a campaign depository, as alleged in the complaint.

Section 106.11( 4), Florida Statutes: Michael J Dreikom, candidate for Florida Senate, District 30, in the November 2014 election, incurred one or more expenses for the purchase of goods or services, without sufficient funds on deposit in the primary depository account, as alleged in the complaint

Section 106 ..143(1), Florida Statutes: Michael J Dreikom, candidate for Florida Senate, District 30, in the November 2014 election, failed to include the statut01ily required disclaimer on a political advertisement, as alleged in the complaint

Section 106.19(l)(d), Florida Statutes: Michael J Dreikom, candidate for Florida Senate, District 30, in the November 2014 election, made OJ authoiized one or more expenditures prohibited by Chapter 106, Florida Statutes, as alleged in the complaint

ComOl I (10/07) You may Jespond to the allegations above by filing a notarized statement providing any information Jegarding the facts and circumstances sunounding the allegations Your Jesponse will be included as an attachment to the investigator's repoJt When we conclude the investigation, a copy of the Repo1t oflnvestigation will be mailed to you at the above address You may file a response to the repoit within 14 days from the date the repo1t is mailed to you.. Based on the Jesuits of the investigation, legal staff will make a written recommendation to the Commission on whetheJ there is probable cause to believe you have violated ChapteJ 104 OJ 106, Floiida Statutes.. A copy of the Staff Recommendation will be mailed to you and you may file a response within 14 days from the date the recommendation is mailed to you. Your timely filed Jesponse(s) will be consideied by the Commission when deteJmining prnbable cause The Commission will then hold a heruing to determine whether there is prnbable cause to believe you have violated ChapteJs 104 01 106, FloJida Statutes. You and the complainant will receive a notice of heaiing at least 14 days before the heaiing The notice of healing will indicate the location, date, and time of yom heruing You will have the oppoJtunity to make a bJief oral statement to the Commission, but you will not be pe1mitted to testify or call others to testify, 01 introduce any documentaiy OJ otheJ evidence. At any time before a probable cause finding, you may notify us in wiiting that you want to enteJ into negotiations diJected towaids Jeaching a settlement via consent agieement The Report of Investigation, Staff Recommendation, and Notice of Hearing will be mailed to the above address as this letter .. Therefore, if your address changes, you must notify this office of your new address. Otherwise, you may not receive these important documents. Failure to receive the documents will not delay the probable cause hearing .. UndeJ section 10625, FloJida Statutes, complaints, Commission investigations, investigative Jeports, and other documents relating to an alleged violation of ChapteJs 104 and 106, Flo1ida Statutes, aie confidential until the Commission finds prnbable cause OJ no pJobable cause. The confidentiality provision does not apply to the peJson filing the complaint However, it does apply to you unless you waive confidentiality in writing The confidentiality provision does not pJeclude you from seeking legal counsel Howeve1, if you retain counsel, yom attorney must file a notice of appeaiance with the Commission before any member of the Commission staff can discuss this case with him OJ he1 If you have any questions OJ need additional information, please contact Helen Hinson, the investigator assigned to this case

Sinc,eiely, /-) II ( / '-,~\}J~Ll''-f\~' \)} .·· .. ___ , __ _ Amy McKe ver T Jinan . \. . Executrve·.. nector

AMI/em

Como 11 (8/08) Page 1of1 (

Case No FEC 14-138 Dr Michael Dreikom to: ' [email protected] 06/13/2014 12:18 AM Cc: Darlene Soler Show Details

2 Attachments

imageOOl .jpg Dreikorn Response Case No FEC 14-138.pdf

The attached document is my response to the compliant in Case No FEC 14-138 Please do not hesitate to contact me if you should have further questions.

Regards, Michael

Michael J Dreikorn, Ed .D Candidate for SW Florida's Senate District 30 PO Box 654 Bokeelia, FL 33922 T 239 283 2197 Email: [email protected] Website: www.MichaelDreikorn.com Facebook: https:Uwww.facebook.com/dr.michael.dreikorn Twitter: @MichaelDreikorn

~IICI-IAEL DREIKORN FC)R. FLORIDA. SENATE

Paid for by Dr. Michael Dreikorn, Republican, For State Senate, District 30

file:///C:/U sers/Malphursd/AppData/1ocal/Iemp/notesFCBCEE/-web1396 htrn 6/13/2014 I I

Michael J. Dreikorn, Ed ..D ~--- -"' MICHAEL P 0 Box654 tel.: 239 283 2197 --···--- -··· ---... ·---~------.. --. -- DRE IKORN Bokeelia. FL 33922 MD@MichaelDreikorn com FOR FLORIDA SEN\TE

Florida Elections Commission 107 W. Gains Street Suite 224 Collins Building Tallahassee, FL 32399-1050

June 12, 2014

Ref: Case No. FEC 14-138

Dear Florida Elections Commission:

I am writing in response to your letter dated May 30, 2014, for a complaint that was filed against me by a Mr. Fidel Balan, alleging a campaign violation. In his written complaint, Mr.. Balan alleges that I "violated FL Statute 106 .. 021(1)(a) barring preemptory campaign solicitations, expenditures, or contributions " I deny the allegation

Assumedly, the language within 106 021(1)(a) that Mr. Balan is referring to is "[a] person may not accept any contribution or make any expenditure with a view to bringing about his or her nomination, election, or retention in public office, or authorize another to accept such contributions or make such expenditure on the person's behalf, unless such person has appointed a campaign treasurer and designated a primary campaign depository .. "

Per Chapter 11 of the Florida Division of Elections, Candidate and Campaign Treasurer Handbook, "[a]n expenditure is a purchase, payment, distribution, loan, advance, transfer of funds by a campaign treasurer or deputy campaign treasurer between a primary depository and a separate interest-bearing account or certificate of deposit, or gift of money or anything of value made for the purpose of influencing the results of an election or making an electioneering Communication "

On May 12, 2014, I notified, by appropriate form application, the Florida Division of Elections of my candidacy for the 30th State Senate district My campaign treasurer was appointed on this same day .. On May 19, 2014, the Florida Division of Elections formally accepted my campaign application .. As certified in my recent campaign finance report (May 2014), no expenditures were made, or contributions accepted, prior to May 19, 2014.

Please feel free to contact me with questions or comments at any time ..

Best Regards,

Michael Dreikorn, Ed.D. Veteran, Businessman and Candidate for Florida State Senate District 30 106,,021 Campaign treasurers; deputies; primary and secondary depositories .. - (1)(a) Each candidate for nomination or election to office and each political committee shall appoint a campaign treasurer Each person who seeks to qualify for nomination or election to, or retention in, office shall appoint a campaign treasurer and designate a primary campaign depository before qualifying for office Any person who seeks to qualify for election or nomination to any office by means of the petitioning process shall appoint a treasurer and designate a primary depository on or before the date he or she obtains the petitions. At the same time a candidate designates a campaign depository and appoints a treasurer, the candidate shall also designate the office for which he or she is a candidate. If the candidate is running for an office that will be grouped on the ballot with two or more similar offices to be filled at the same election, the candidate must indicate for which group or district office he or she is running. This subsection does not prohibit a candidate, at a later date, from changing the designation of the office for which he or she is a candidate .. However, if a candidate changes the designated office for which he or she is a candidate, the candidate must notify all contributors in writing of the intent to seek a different office and offer to return pro rata, upon their request, those contributions given in support of the original office sought This notification shall be given within 15 days after the filing of the change of designation and shall include a standard form developed by the Division of Elections for requesting the return of contributions .. The notice requirement does not apply to any change in a numerical designation resulting solely from redistricting. If, within 30 days after being notified by the candidate of the intent to seek a different office, the contributor notifies the candidate in writing that the contributor wishes his or her contribution to be returned, the candidate shall return the contribution, on a pro rata basis, calculated as of the date the change of designation is filed. Up to a maximum of the contribution limits specified in s. 106.08, a candidate who runs for an office other than the office originally designated may use any contribution that a donor does not request be returned within the 30-day period for the newly designated office, provided the candidate disposes of any amount exceeding the contribution limit pursuant to the options in s. 106.11(5)(b) and (c) ors. 106.141(4)(a)1 , 2 , or 4.; notwithstanding, the full amount of the contribution for the original office shall count toward the contribution limits specified in s. 106.08 for the newly designated office. A person may not accept any contribution or make any expenditure with a view to bringing about his or her nomination, election, or retention in public office, or authorize another to accept such contributions or make such expenditure on the person's behalf, unless such person has appointed a campaign treasurer and designated a primary campaign depository. A candidate for an office voted upon statewide may appoint not more than 15 deputy campaign treasurers, and any other candidate or political committee may appoint not more than 3 deputy campaign treasurers. The names and addresses of the campaign treasurer and deputy campaign treasurers so appointed shall be filed with the officer before whom such candidate is required to qualify or with whom such political committee is required to register pursuant to s. 106.03 STATE OF FLORIDA FLORIDA ELECTIONS COMMISSION 107 West Gaines Street, Suite 224, Tallahassee, Florida 32399-1050 Telephone Number: (850) 922-4539 www fee.state.fl.us CONFIDENTIAL COMPLAINT FORM The Commission's r·ecords and proceedings in a case ar·e confidential until the Commission ruteJ..l'Jpi'.·~~tCO ~~~JlfJA cause.. A copy of the complaint will be provided to the person against whom the complaint is brought. "•ISSll!/N

1. PERSON BRINGING COMPLAINT:

Name: [:"; Z> £. L- BAL/:1-,.j Work Phone: L_)___ _

Address: g3oo .StLveR... J3>11ec+1 W4'f Home Phone: (2~9 ). 2q2-q~7z. City: Le/.ltG/.I Aues County: Lee. State: FL_ Zip Code: 339'7 / 2. PERSON AGAINST WHOM COMPLAINT IS BROUGHT: A person can be an individual, political committee, committee of continuous existence, political party, electioneeting communication organization, club, corporation, partnership, company, association, 01 any other type of organization. (If you intend to name more than one individual or entity, please file multiple complaints )

Name of individual or entity: -~/fl~1_c_t-1-_11_e_1-__D_12..._E_1_!(_0_-'?.._rJ ______Address: 60 C/7 BAf f?oiN' I /(]> - Phone:~ 558-8525 City: BoKEELr tJ County: LcE State: FL Zip Code: ·33q ..z. ·i.. If individual is a candidate, list the office or position sought: __,A_Lo __ R._1_P_/J __ 5_e_AJ._'A-"TC ___ _ Have you filed this complaint with the State Attorney's Office? (check one) D Yes Ill No 3. ALLEGED VIOLATION(S): Please list the provisions of The Florida Election Code that you believe the person named above may have violated. The Commission has jmisdiction only to investigation the following provisions: Chapter 104, Chapter· 106, and Section 105 .. 071, Florida Statutes .. Also, please include:

./ The facts and actions that you believe support the violations you allege, ./ The names and telephone numbers of persons you believe may be witnesses to the facts, ./ A copy or pictme of the political advertisements you mention in yow statement, ./ A copy of the documents you mention in yow statement, and ./ Other evidence that supports your allegations ..

FEC 002 (Rev 05-05-14) --··------

Additional mateiials attached (check one)? llYes DNo

4. OATH STATE OF FLORIDA COUNTY OF LEE

I swear or affirm, that the above information is true and conect to the best of my knowledge.

_p .:.~- ""' &:if) Complaint D '""'-'1 a~tr> Ori~-e~inging Ci?.~ uJ -a. 6"-,:.:.. Jo '/> "-u Sworn to and subscribed before me this J "3 f d. day of -- c:JJ 'GliV> w N ~AC! L 20_\~ (.) ,_.;§ ?d. i-:·- uJ "'>'.>-;--u ---_,,,,.

(Pri , e, or Stamp Comm~oncd Name of Notary Public) Personally known Vor Produced Identification__ _ Iype ofldentification Produced_j2t. 0 I - r I

Any person who files a complaint while knowing that the allegations are false or without merit commits a misdemeanor of the first degree, punishable as provided in Sections 775 .082 and 775. 083, Florida Statutes

FEC 002 (Rev OS·OS-14) 8300 Silver Birch Way Lehigh Acres, FL 33971

State of Florida Elections Commission 107 West Gaines Street Collins Building, Suite 224 Tallahassee, FL 32399-1050

May21, 2014

Re: Elections Violation against Senate District 30 candidate Michael Dreikorn

Dear Sir or Madam:

Please accept this letter as my formal complaint against candidate Michael Dreikorn for possible violations of the State of Florida Elections law..

Charge #1: I allege that Mr .. Dreikorn violated FL Statute 106..021(1)(a) barring pre emptory campaign solicitations, expenditures, or contributions ..

In support, I offer the following for your consideration:

1.. Michael Dreikorn purposefully commissioned the creation of a television advertisement specifically supporting his candidacy for the Florida Senate .. The Television ad can be found at: https://www.youtube.com/watch?v=B2BiRUW!7Sg 2 Michael Dreikorn specifically asserts that he "approved" this message .. At 0:01 the advertisement bears a voice-over approval statement by Mr .. Dreikorn.. Additionally, the advertisement at 0:01 bears an approval disclaimer that reads "APPROVED AND PAID FOR BY MICHAEL DREIKORN FOR STATE SENATE.." 3.. Mr Dreikorn's advertisement was posted on May 13, 2014 at approximately 11:41a.m. 4.. The Creation of a professional advertising video such as Mr .. Dreikorn's requires pre-planning, and the expenditure of numerous man-hours .. This inherently indicates that the creation of this video occurred prior to its posting on May 13, 2014. 5.. The creation of a professional advertising video such as Mr. Dreikorn's requires the employment of professional media specialists and in turn ' l l

requires the expenditure of funds or conversely the receipt of an in-kind campaign contribution 6. In a May 13, 2014 newspaper article Mr .. Dreikhorn stated that he has solicited donations and has obtained promises of campaign contributions. "Dreikorn now says he has gained thousands of supporters and has promises of more donations." (News-Pres.s, 5/13/14) 7.. Mr.. Dreikorn made statements to the news media that he was going to pay for his commercial (and seemingly other campaign expenses such as logo design) "as donations come in" and stated in his defense that he hadn't yet paid anyone for the work they had done, a distinction that is irrelevant under the law, as he had obligated funds to be expended. 8.. FL Statute 106.021(1)(a) states that "A person may not accept any contribution or make any expenditure with a view to bringing about his or her nomination, election, or retention in public office, or authorize another to accept such contributions or make such expenditure on the person's behalf, unless such person has appointed a campaign treasurer and designated a primary campaign depository.. " 9 .. As of 11:41 a.. m .. on May 13, 2014, Mr .. Dreikorn had not filed any paperwork with the Florida Secretary of State's Division of Election for any of the following purposes A) Declaring his candidacy for Florida Senate District 30 B) Appointing a campaign treasurer C) Designating a primary campaign depository.. Mr Dreikorn did not file such paperwork with The Division until May 19, 2014 .. 10.. I allege that Michael Dreikorn has violated Florida Statute 106 .. 021, by expending money for the creation of a campaign advertising video prior to his filing the requisite paperwork with the Florida Division of Election lL I allege that prior to his declaration of candidacy, and appointment of Campaign Treasurer, Mr .. Dreikorn actively solicited campaign contributions, per his statement affirming such actions, and obligated fonds to be expended in view of bringing about his nomination or election. This solicitation is a violation of FL Statute 106. .21..

Charge #2: I allege that Mr .. Dreikorn violated FL Statute 106. .143(1)(a) relating to political advertisement disclaimers ..

In support of this allegation, I offer the following for your consideration:

L Michael Dreikorn purposefolly commissioned the creation of a television advertisement specifically supporting his candidacy for the Florida Senate.. The Television ad can be found at: https://www.youtube.com/watch?v=B2BiRUWJ7Sg 2. Michael Dreikorn specifically asserts that he "approved" this message.. At 0:01 the video bears an approval disclaimer that reads "APPROVED AND PAID FOR BY MICHAEL DREIKORN FOR STATE SENATE" See Exhibit A: for a screen shot of Mr .. Dreikorn's video disclaimer.. 3.. FL Statute 106. .143(1)(a) states that "Any political advertisement that is paid for by a candidate, except a write·· in candidate, and that is published, displayed, or circulated before, or on the day of, any election must prominently state: L "Political advertisement paid for and approved by (name of candidate), (party affiliation), for (office sought) ";QI 2 .. "Paid by (name of candidate), (party affiliation), for (office sought}." 4.. I allege that Michael Dreikorn's current political advertisement contains a deficient disclaimer .. The advertisement's disclaimer fails to follow the specific disclaimer terminology guidance of Florida Statute 106.143(1)(a)..

Therefore, I ask the Florida Elections Commission to fully investigate this serious matter, and apply the applicable sanctions for these violations of the law .. Exhibit A

https.://www.youtube.. com/watch?v=B2BiRUW]7Sg From: Fidal Bah1n Ship Cate.: 23MAY14 l'lctWgt: 0.2 LS 8300 SILVER SIRCH 1-/l'IY CAO: 69909?7/SSFO!SOI

LEHIGH ACRES, FL_ 339'71 <29f!) ?92-9Q?? -

FL Elections Commlssio~,

107 W GAl,NES ST TA!.U\H~~SEE, FL 32di9 W1 ..0Q0"<1 •P2C>10ae>.. 107 W GAINES ST ffiJ 32399

961 201944 793171 0027032

' . (9612019) 4479317 10027032 GND Prepaid