2 Attorney General Tom Horne, (“Horne”) and his aide Kathleen Winn, (“Winn”). 2.
Faced with the obvious conflict of interest in reporting this information to Horne or to Chief Deputy Attorney General Rick Bistrow, (“Bistrow”), Plaintiff correctly reported it to an outside law enforcement agency, the FBI. 3.
The FBI undertook an investigation that resulted, on October 2, 2012, in the Maricopa County Attorney’s charging Horne and Winn with a civil penalty for Horne’s receipt of approximately $500,000 in illegal campaign contributions, money raised and handled by Winn through a sham Political Action Committee. 4.
On about January 23, 2012, Horne learned and advised his Chief Deputy Defendant Rick Bistrow, (“Bistrow”), that Plaintiff had been the source of the original information that prompted the FBI investigation. 5.
Beginning about that time Horne, Bistrow and various attorneys and aides employed with the Attorney General’s Office, (“AGO), agreed to and did launch a smear campaign intended to discredit Plaintiff and are currently engaged in attempting to drive her to quit her position and to destroy her law enforcement career. 6.
Horne personally, Bistrow and their co-conspirators have used express and implied threats, slander, libel, spreading salacious rumors, concealment and
Case 2:13-cv-00260-DGC Document 55 Filed 10/28/13 Page 2 of 75