10 1 12 13 14 15 16 a7 18 1s 20 2. 22 23 24 25 26 Complainant is informed and believes and therefore alleges that Respondent The Tucson Tea Party (hereinafter TTP) is an is an exempt organization pursuant to IRS section 501(c) (4), headquartered in Tucson, Arizona. Complainant is further informed and believes and therefore alleges ‘that Respondent Trent Humphries (hereinafter “Humphries”) is the Presids TTP and was at all times material herein acting in the course and scope of his official capacity as President of the TTP. Complainant is informed and believes and therefore alleges that Humphries maintains and publishes an online print publication entitled the “TTPdaily”. Complainant is informed and believes and therefore alleges that Respondent Alexandrea Merrell (hereinafter “Merrell”) is now and was at 2. times material herein, a resident of Magnolia, Arkansas. Complainant is further informed and believes and therefore alleges that Merrell, in concert and cooperation with the other Respondents, operates a site on the world wide entitled “Conning Conservatives”, as well as a radio show entitled “The Alexandrea Merrell Show” which are both utilized by Respondents as a vehicle to deliver election information to the general public, within and without Pima County, Arizona. Respondents John and Jane Does I-K are persons whose identities are unknown to Complainant at this time, but through the course of further proceedings in this matter, their identities will become known. IT. Allegations Count 1-Violation of ARS 16-902, (Operation of an unregistered political committee) ARS 16-901(19) defines a political committee a 19, "Political committee" means a candidate or any association or combination of persons that is organized, conducted or combined for the purpose of influencing the result of any election or to determine whether an individual will become a candidate for election in this state or in any county, city, town, district or precinct in this state, that engages in political activity in behalf of or against a candidate Complaint-2