r- -fi f.Tn WALTON LAW FIRM, LLC rT? -irtM 2320 Chambers Rd. /i 'ON St. Louis, MO 63136 • - ^ N Telephone; 314-388-3400 EibertA. Walton, Jr. Fax:314-388-1325 201^ AUG "9 PH I-* 0 I Attorneys at Law

August 9,2016

Federal Election Commission CELA Office of Complaints Examination and Legal Administration . Attn: Mary Beth deBeau, Paralegal 999 E. Street, NW Washington, DC 20436

Also sent by email to [email protected]: iioidan@rec:gov

Re:MUR7108

Dear Ms. deBeau:

We are in receipt of your letters dated July 25, 2016, directed to (a) Angela Moslcy, Treasurer of the Citizens to Elect Gray, (b) Angela Mosley, Treasurer of Citizens to Elect , and (c) Linda Weaver, in her individual capacity, respectively, along with a copy of the Complaint and attachments. We have been retained to respond to said three letters and complaint. We enclose the Statements of Designation of Counsel executed by Ms. Mosley as Treasurer of said two committees and by Ms. Weaver, respectively. We submit this joint response to said letters by Angela Mosley in her official capacity as Treasurer of said two committees and Linda Weaver in her individual capacity.

The Complainant alleges:

"On or about Sunday, June 19,2016, somebody lelA the enclosed flyer at my front door the flyer contained not only candidates for offices in St Louis County and State Representative but also Congressional Candidate Maria Chappellc Nadal. *** My research found that Maria Chapelle Nadal is using money from her State Senate Campaign fund to provide money to Jay Mosely and Rochelle Walton Gray whose campaigns paid for the enclosed flyer. This appears to be a violation of federal election law." (Emphasis mine)

The facts appear to be as follows. The enclosed Amended Statement of Committee Organization for the "Citizens for Maria Chappelle Nadal," dated 2/7/2009 (Exhibit A), filed with the Missouri Ethics Committee that regulates the campaign finance laws for the state of Missouri, indicates that the committee was organized to support Maria Chappelle Nadal as a Democrat for election to the Missouri House of Representatives. It was later amended, as enclosed (Exhibit B), on 2/25/2010, to state that its purpose was to elect Maria Chappelle Nadal as a Democrat to the Missouri State Senate. It was finally amended on 1/28/2015 (Exhibit C) to state that its purpose was to elect Maria Chappelle Nadal as a Democrat to a Statewide Missouri Office in the Democratic primary election scheduled for 8/20/2020. We presume that Maria Chappelle Nadal also established a separate campaign committee to run for the US Congress, named "Chappelle- Nadal for Congress" in the Democratic primary election held on 8/2/2016 and filed a stafement of committee organization with the Federal Election Commission.

The enclosed Amended Statement of Committee Organization of the "Citizens to Elect Gray" (Exhibit D), fijcd with the Missouri Ethics Commission, states that said committee was organized to support Rochelle Walton Gray as a Democrat for the St. Louis, Missouri County Council in the primary election of 8/2/2016. The enclosed Statement of Committee Organization of the "Citizens to Elect Jay Mosley, LLC" (Exhibit E), states that said committee was organized to support Jay Mosley as a Democrat in the primary election scheduled for 8/2/2016 for the office of State Representative, 68"* District.

Documentation attached to the complaint indicates that on 3/17/16, the Missouri statewide candidate campaign committee, "Citizens for Maria Chappelle Nadal," made a campaign contribution to the "Citizens to Elect Gray" in the sum of $25,000.00. The documentation also indicates that on S/23/2016, said committee, "Citizens for Maria Chappelle Nadal" made a campaign contribution to "Citizens to Elect Jay Mosley, LLC" in the sum of $15,000.00.

Also attached to the complaint was a copy of a door hanger, that indicated that it was paid for by both the "Citizens to Elect Gray" and the "Citizens to Elect Jay Mosley." Although it was the intent to have both campaigns pay for said door hangers, campaign records indicates that only the Citizens to Elect Gray paid for said door hangers in the sum of $356.56. (Exhibit F) Said door hangers rcferences.the election of Tuesday, August 2"^. It contains a caption, "Vote Democratic & Elect" and lists five candidates and offices on the door hanger, (1) Rochelle Walton Gray, County Councilwoman, (2) Jay Mosley, State Representative, (3) Maria Chappelle Nadal, Congresswoman, (4) Tony Weaver, Committeeman, and (5) Linda Weaver, Committeewoman. The Weavers were seeking election to the County Central Committee of the Democratic party.

The complaint seems to be that it was allegedly a violation of the Federal Election Campaign laws for "Maria Chappelle Nadal, Congresswoman," to be included among the candidates for state, county and political party office, in the democratic primary, listed on the door hanger, solely because she is a candidate for federal office, while the other candidates were seeking state, county and political party offices and/or due to the fact that her statewide campaign committee had made campaign contributions to the two candidate committees that the door hanger indicated had paid for the door hangers.

It is common practice for state, local and party campaign and candidate committees to include both federal, state, county and political party candidates that are being endorsed by the committee on campaign materials when elections are conducted. It does not cost a candidate for election to a particular office anything additional to print a campaign piece that includes not only the candidate paying for the campaign piece, but other candidates for different federal, state, county and political party office that the candidate, printing the campaign piece, determines to endorse and support for nomination or election to federal, state, county or political party office, on the same election date in which the candidate paying for the campaign piece stands for election or nomination to office. This practice has gone on for over a hundred (100) years. I am enclosing copies of four different campaign pieces that were paid for and distributed by four different candidates or campaign committees, other than the Citizens to Elect Gray and the Citizens to Elect Jay Mosley, during the August 2,2016, democratic primary election held in St Louis County, Missouri, that supported federal, state, county and political party candidates on the campaign materials. (Exhibits G, H, I & J)

The price charged by the printer for a door hanger order was not based on the number of candidates listed on the door hanger but was based on the number of door hangers being ordered. Thus, the Citizens to Elect Gray did not incur any increase in the cost of the door hanger to include not only Maria Chappelle Nadal, Congresswoman, on the door hanger, but the other candidates who were listed thereon, i.e., Jay Mosley, State Representative, Tony Weaver, Committeeman, and Linda Weaver, Committeewoman, along with Rochelle Walton Gray, county councilwoman. Basically, there was no separate, distinct and direct cost incurred by the Citizens to Elect Gray, in the printing of said door hanger, that may be identified as a separate, distinct or direct cost or expenditure in support of Maria Chappelle Nadal as a candidate for Congresswoman. The Citizens to Elect Gray would have paid $356.56, in the printing of said door hanger, if the only candidate on the door hanger was Rochelle Walton Gray or if she included on the door hanger. Jay Mosley, Tony Weaver, Linda Weaver and Maria Chappelle Nadal. Thus, there could not be nor was there any violation of the Federal Campaign Finance Laws by neither Chappelle Nadal For Congress, Citizens for Maria Chappelle Nadal, Citizens to Elect Gray nor Citizens to Elect Jay Mosley in that there was no direct, separate or distinct expenditure of funds in support of Maria Chappelle Nadal for the Democratic nomination for Congress.

Moreover, there was no coordination, agreement or direction given to Rochelle Walton Gray nor Jay Mosley nor to their campaign committees by Maria Chappelle Nadal that they were to include her congressional candidacy on said dour hanger or on any other campaign materials in exchange for the campaign contributions from her statewide campaign committee to their respective campaign committees. Moreover, she did not supply the photo, but instead the photo was downloaded from the internet without any communication to or from her whatsoever. The political organization of which Gray, Mosley and the Weavers are members determined to support Chappell Nadal based on dissatisfaction with the incumbent congressman and it was at the request of said organization's leadership that Chappelle Nadal's candidacy for congress was included on said door hanger along with those of Gray, Mosley and the Weavers.

Moreover, we believe that as a matter of free speech, a state campaign committee can support a candidate for federal office without violation of the federal election laws, especially where there is no direct or increased costs or expense associated with that support.

We trust that the aforesaid adequately responds to said complaint. If you are in need of additional information, please feel free to contact me.

Sincerely,

Elbert A. Walton, Jr. l"i:DF,KAt. l-LGCrtON COMMISSfON yjo I-; Slrccl, NW WashinijUm; DC 2()'163

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to. ' DEiPUTYI^ASURiERS ADDRESS It. TaEPHONE NUMBER ADDRESS; HOME; CITY/STATE zap; WWRK: IdiA 12. OTHER COMMITTEE OFFICERS OF ANY) IS IFCAM}IOATEHASOTNERCOMMrnEES.IS A. NAME B. C. TITLE THIS COMMITTEE DE8IGNATE0 AS THE AOOREGATING COMMITTEE? I a. •YES PNO 14.- OFFICIAL FUND DEPOSITORY: CHECKINO ACCOUNT FIRST. THEN ANY 8AVIN0S ACCCUNT(S) A. NAMES AOORE8S OF BANK. SAVINO SLOAN. OR CREDITUNION \ B. ACCOUNT NAME

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10. BALLOT MEASURE(S} SUPPORTED OR OPPOSE I • CHECKONE ANAME(S)0FMEASURE(S) IR ELECTION DATE | C SUBJECT ANDPOLITICAL SUSOMSON |E SUnoir F. WMM \ kuUMMIIIbE TREASURER'S SIQNATURE 21. CANDIDATES SKNATT LSF I CERTIFY THAT THIS STATEMENT IS COMPLETE. TRUE AND I CERTIFY TIMT THIS 8TA' ACCURATE. /ACCURATE.

MO 900.1308(IROS) C0.1S2 OFFICE USE QNLV MISSOURI ETHICS COMMISSION STATEMENT OF COMMITTEE ORGANIZATION MECID#. STATEMENT DA' TYPE OP STATEMENT (CHECKJPNE) IF AMENDED. USTfTEMS (LINE NUMBERS) I I NEW r^^ENDED FULL NAME OF COMM)TTEE

4. coMMnnrEE MAIUNG A(}PRESS 5. TELEPHONE NUMBER ADDRESS: 7/55 CITY/STATEDZIP: f.'L ./HO 62/30 (^) 1Si^~7:L8d e. TREASURER'S NAME /beob. Tia/»r 7. TREASURER'S MAILING ADDRESS 0 a. TELEPHONE NUMBER ADDRESS: l/^D ,UriaL HOME: (%><) CITY/STATE/ZIP: /I'/tf • ^0 (o 3/5^ WORK: Sgl?>-O^OT 9. DEPUTY TREASURER'S NAME CHECK IF NO DEPUTY TREASURER liSSOURI ETHICS COIIIIiyilSSlOW 10. DEPUTY TREASURER'S ADDRESS 11. TELEPHONE NUMBER ADDRESS: FEB 25 2010 HOME: CITY/STATE/ZIP: WORKj 12. OTHER COMMITTEE OFFICERS (IF ANY) 13. IF CANODATE HAS OTHER COMMITTEES. IS A. NAME B. ADDRESS THIS COMMITTEE DESIGNATED AS THE AGGREGATINQ COMMITTEE? I • YES pNO 14- OFFICIAL FUNO DEPOSITORY: CHECKING ACCOUNT FIRST. THEN /WY SAVINGS ACC0UNT(8) A. NAME S ADDRESS OF BANK. SAVING B LOAN. OR CREDIT UNION B. ACCOUNT NAME j C. ACCOUNT NO.

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17. CONNECTED ORGANIZATION (IF ANY) (CONTINUING COMMITTEES ONLY) A. NAME I 8. ADDRESS

IB. CANDIDATES SUPPORTED OR OPPOSED CHECK ONE I I I A. NAME(S) OF CANOIOATE(S) ;B. ELECTION OAT& C. OFFICE SOUGHT •D. POLITICAL SUBDIVISION •£. SUPFORT F. OFFOGE j e/s^° j sU'S^^ | ^•"^1! [2r\ • 19. BALLOT MEASURE(S) SUPPORTED OR OPPOSED T | CHECK ONE A. NAME(S)OFMEASURE(S) js. ELECTION DATE j C. SUBJECT AND POLITICAL SUBDIVISION |E. SUPFORT F. OFFOSE I • I I 20. COMMITTEE TREASURER'S SIGNATURE Ml iTE COMMITTEES ONLY) I CERTIFY THAT THIS STATEMENT IS COMPLETE. TRUE AND I CERTIFY THAT THIS STATEMENT IS COMPLET ACCURATE. ACCURATE.

TREASURERS SIGNA MO 300-1308 (10-06) CO-IB 2 Missouri Ethics Commission (MEG) Office Use •!' PO Box 1370. Jefferson City MO 55102, (800) 392-8660, www.mec.mo.gov Statement of Committee Organization

1.

2.

NamrolCoinnliKt ^g.fW •XaA%'\ IL»»rf,,4J^ m0CAI3O i3/^ I 4^-3^g7 CnmniiiM Nubni Mtfieu.M.C«v.Sute.&Zip Ctv.Suia. & 2Ip ' ~ ~ V Telephone Nufnber

^deik or Ueatdoi election CnmmtisiMiKri ' {/ Committee Type: ^Campaign ^ Candidate ^Continuing (PAC) PI Debt Service ^Exploratory (^Political Party

3. Treasurer/Deputy Treasufer Information Ahm- T^/oi^ lieawier'i Namcirvsltuul Ireaiuref's Emad Aldieis lepiioitai) P.n. 'iocsii ( )_ Ifcaiuieri Miirlni Aidfcu. liir. Suit, t Zip TfcatufeCs rtome Telephone Numbei WeriL Tclephune Numbei

Deputy Treasiuei's Name (il one appointed) Deputy Ti«a%uiei's lino'il Aooretk ioptSsnal) ( ). ( ) Oepuiv Ireakurei's MailingAddretk. City. Slate, & Zip . .Dep. Trcaswrr'k HonteTelei cr oep.Treaftirer*sWoik1elrphflnelihimbif

4. Additional Committee information

Additional Commtitee Oiiicef^k Meiiii^ Addiesi, Cny.Siaie, & Zip

Connected Orgonijatlon's Name (il any) COMiected Orgaruiation'a MaUing Addreaa, Gly. Stale, & I

CANDIDATES: Do you have more than one candidate committee?D Yes (refer to instructions on backl H] No 5. Official Bank Account Information (required by ail committees)

Nimt & Milling APdiHs. Oly. SIPIe. & Zip of fiiuncul Inililulion Accpuni Himc Accouni Nufflpei

Candidate Supported or Opposed (candidate committees must include self. If candidate) (^/^) {.{ ) Jkehtc a MiUnp Ajidicn. Cllv, SI«V|lVip sT CanPiMW Telephone Numbc (Candidiie Cemmftieea Only)

7. Ballot Measure Supported or Opposed (campaign committees must complete tfiis section)

Name el Bailoi Mtaiure Elcaion one A Poiiikal SvPiiviiion Suppoii or Cppoie

Signature(s) Cfieck certificatlon(s) & sign (required by all committees)

Bl'afrirm and attest untJu penalty of perjui^^that Information and facts in this report are iftrue, and acc^te. I fur^tberaikh^wl^gQ thi^am^reth^jpiy false statement or deciaration ' blgm(^Q(^75 ftSMo.

MO 300-1308 Form mus,^pe completed in full & contain original signature(s), fafi^illngs are not accepted. Page I of 3 Packet (Rev. 11/J014) Missouri ElMnA Commission FEB26 2015 Missouri Ethics Commission (MEG) PO Box 1370, Jefferson City MO 65102, (800) 392-8660, www.mec.mo.gov Statement of Committee Organization

1. icm Intorinntion Date: 2I^I26^6___ Type:n New 171 Amended (If amending, enter MEC ID C081082 & section changed ^3 & ^

2. Committee intoi CItlZENS TO ELECT GRAY Nam orCoinMlin ( )_ Cmniiilcue Mil«i«A4drau.aty,Sula.aBp

OmcUIComnWIaitiMlMNm CouinvOanierBoardar tiocI'Mfi CamnltsiMian Committee Type: PICampaign [71Candidate ^Continuing (PAC) Q Debt Sen/Ice QExpioratory ^Political Party

Trc.'jsurcr/Tre;isurer Informntior

Tnasurai'i Nam|Flnl S us) Tnasuroi't Emal Addrasf (ai I ) Traaswrars MNIIng Addnn, OW.State, a lip Trauirtf's NofrnTntanli^ work Tatepaona Number Rochelle Gray Deputy Treasurer'i Nuna pf ana appebita^ nf iiauiHtr«cinBNMor«wiepiHiniii| 11845 Rollingsford Black Jack Mo 63033 ,314,477-0841 ,314,355-6789 Daputy Tcaaiumr'a MNFJII Adifiau, Oly. Suw.S Hp Dap. Treaiunr'aHome TalephoM Nunbar oap. Tteiiurari Wort TaiaplionaNumbar

4. Committee Information

AOdMonal COmailtlaa OMcara Nam A THIa Tif any) Mdltlanal Comialtlaa OWcai't 0 Clly.jlala.a2lp Amenrimet^4 Cannanad Orianliallan'iHam (It any) COananedaitanltMloirtMaBiisAddiau, Cllv,Suia,azip

CANDIDATES: Do you have more than one candidate committee? Bves (refer to instructions on back) DNo S. Bank AccniuiH Inlormaiion (rtrqun

support iuppaRarOppaac

' Supf)orte(j or Opposed (c I (.onif)iL'tc Ihi

NamaofSallatlMaaiuia BactlanDBte&PalltlealSuMMilan SuppeitorOppaia

8. Cliecii ceitification('>) S iiyi El I affirm and attest under penalty of perjury that Information and facts in this report are complete, true, and accurate, i further acknowledge that I am aware that any false statement or declai^tlbt made h^elnif etyrishabl^ditder Ch. S75 ftSMo. MISSOUWBTHIM

MO 300-1308 Form must be completefUbpilltEcaniDi original si^ature(s), fax filings are not accepted.^ Page i of 3 Packet (Rev, 11/2014) ' ^ Missouri Ethics Commission (MEG) Office PC Box 1370, Jefferson City MO 65102, (800) 392-8660, www.mec.mo.BOV , "1^ Statement of Committee Organiizatlon

1. Statement Information Date: 3gi/2oi6 /i/t;,/n Type: ^ New- PP Amended (If amending, enter MEG ID cJU'' 8i section changed.

2. Committee Information Citizens to Elect Jay Mosley LLC MamolCoiiiiiiliifa 195 Waterford, Fiorissant, MO 63033 (314 i 974-8207 UiUlfi* SlMf. aUp TclaphoniNumbn St Louis County Board of Election Commissioners umcai wOmmiiMO ttnaimimaM CoiimyankerBoiiaoKlfctionCaminiiiioiMri Committee Type: QCampaign [^ Candidate-^Continuing (PAC)Q Debt Service 1^1 Exploratory [^Political Party 3. TreasuiL*r/D0puty Treasurer Information Angela D Mosley Trusurai'i Niim (Flni aUit) 195 Waterford, Fiorissant, MO 63033 (314,974-8208 ( ) Tieuum'i Malllni Address, Ciiv. Suit, & Bp Tiuiunri Heme lelapligntNumber ' Tient-ietti Wett Tckpbene Numbs Jermond L Mosley Deputy Trcnuni'i Name |X one ippoMtd) 195 Waterford, Florissant, MO 63033 (314,974-8208 ( , •rs MHIIniM^n, Oiy, sate. S Np Dep. Tfeiiurei'f Heme Tetepiwne Number Dep. Tteuurefi wort felepl

4. Additional Committee Information

Bl ConmHKU OllkWiNime t Tine |lf any) AMiilonil Cemmnue Oltui-,Malllns Mdre>»,Oiy, Stele,B Zip None CemeaedOitanliulcn-i KimePI eay) Amendment Connencb DrganiiMlon'iMalllnt AMicti, Oiy, siMe,k Zip CANDIDATES: Do you have more than one candidate committee?D Yes (refer to Instructions on back)D No 5. Official Bank Account fnformation (required by ail committees)

Candidate Supported or Opposed (candidate committees must Include self, if candidate) Jermond L Mosley, IBS Waterford, Florissant, Md63033 (314,974-8208 ( J. mne a MaUni Addmi. Clly. Sine a Up of CneMile Toliphuro*NumbtP (CendUati CAfflmlRN*Onlv)" 8/2/2018 State Rep, District 68 Democrat Support eiai^bim Mice SouslRa Millcil SubdMilon PolUciltany •-Oppe

7. Ballot Measure Supported or Opposed (campaign committees must complete this section) None NemeolSpllMMenuie election D»ie 8 Poiiticsi SubdMilon Support or Oppoie

Signature(s) Check certification(5) & sign (required by all committees) 131 affirm and attest under penalty of perjury that information and facts in this report are complete, true, and accurate. I r acknowledge that I am aware that any false statementj>r declaration made herein Is punishable under Ch. 575 RSMo.

MO 300-1308 Form must^b completed in full ft contain original slgnature(s), fax filings are not accepted. Page i of 3 Ppckct (Rev. 11/2014) BMnt Commlsston APR1820K EXHIBIT F

Order Confirmation

Order Number: 124873 WALT Email Address: Phone Number: 314.388.3400

Shipping Information Ship To: Elbert Walton Walton Law Firm LLC 2320 Chambers Rd St Louis. MO 63136 Phone: 314.388.3400

Shipping Method: Fedex Ground Estimated Shipping Date: Monday, May 16 2016 Arrival: Thursday, May 19 2016 Weight: 401bs in 2 boxes Shipping Cost: $61.00

Job Information: Item: Door Hanger 4.25x11 on 12pt card stock Quantity: 2000 Price: $271.16 Rush; $24.40

Files: Door_Hanger_Jay_Spanish_Lake.pdf Art Instructions: Turn time: Express 3

Payment Information: Total: $356.56 Card Type: Visa Authorization Code: 095083

Billing Address: Citizens To Elect Gray 2320 Chambers Rd St Louis. MO 63136 Phone: 314.388.3400

Thank-you for your order! Lady Printing 877-885-5239 EXHIBIT H EXHIBIT G FLORISSANT TOWNSHIP OPEN OFFICIAL SAMPLE BALLOT DEMOCRATIC CLUB AND SPANISH LAKE TOWNSHIP DEMOCRATIC CLUB LEWIS & CLARK DEMOCRATIC CLUB OWEN REED, COMMITTEEWOMAN ORLANDO SMITH, PRESIDENT OFFICIAL SAMPLE BALLOT

U.S. SENATE JASON KANDER US Senator - Jason Kander U.S. REPRESENTATIVE 1ST DISTRICT LACY CLAY

US Representative District 1 - Lacy Clay GOVERNOR CHRIS KOSTER

MO State Governor - Chris Koster LT GOVERNOR RUSS CARNAHAN

MO State Lt. Governor - Tommie Pierson Sr. SECRETARY OF STATE ROBIN SMITi^

MO Secretary of State - Robin Smith TREASURER PAT CONTRERAS

ATTORNEY GENERAL JAKE ZIMMERMAN MO State Treasurer - Pat Contreras

STATE SENATOR 13TH GINA WALSH MO Attorney General - Jake Zimmerman STATE REPRESENTATIVE 67TH ALAN GREEN MO State Senator District 13 - Gina Walsh STATE REPRESENTATIVE 6BTH BERT ATKINS MO State Representative District 67 - Aian Green STATE REPRESENTATIVE 69TH

MO State Representative District 66 - Tommie Pierson Jr. STATE REPRESENTATIVE 74TH

St. Louis County Council District 4- Mike O'Mara STATE REPRESENTATIVE 75TH TEONA McGHAW-BOURE'

Spanish Lake TcNvnshts ConmAeewamah -Gwendolyn (GMen) ST LOUIS COUNTY COUNCIL 2ND DISTRICT SAM PAGE

Spanish Lake Township Committeeman - Orlando Smith ST LOUIS COUNTY COUNCIL 4TH DISTRICT MIKE O'MARA

LEWIS & CLARK COMMITTEEMAN

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Wm. Lacy Clay 1st District, Unites States Congress

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