COMPLAINT FOR VIOLATION OF MICHIGAN LEGAL DEFENSE FUND ACT

I allege that the Michigan Legal Defense Fund Act (MLDFA) was violated as follows:
Section 1. Complaint
Your Name

Daytime Telephone Number

Lonnie Scott

(517) 999-3646

Mailing Address

215 South Washington Square #100

City

State

Zip

Lansing

MI

48933

City

State

Zip

Lansing

MI

48933

Section 2. Alleged Violator

Name

Governor Rick Snyder

Mailing Address

111 South Capitol Avenue

Section 3. Alleged Violations (Use additional sheet if more space is needed.)

Section(s) of MLDFA violated:

The Michigan Legal Defense Fund Act (MLDFA), MCL 15.521 et seq., requires that a legal
defense fund (LDF) be established whenever any funds are expended for:
the purpose of defending an elected official in a criminal, civil or administrative action
that arises directly out of the conduct of the elected officials governmental duties.
MCL 15.523(3)(a).
Explain how those sections were violated:

Governor Rick Snyder has violated the MLDFA by failing to establish a LDF to pay the costs of
two (2) contracts to provide legal defense for him personally, not the State of Michigan, in
connection with the Flint water crisis.
The first contract with Warner Norcross and Judd is addressed to Snyder and is signed by him. It
states:
You have retained us to provide you with legal advice and representation related
to any criminal investigations and prosecutions and related claims arising from the Flint
water supply matter, including, but not limited to, investigations conducted by the United

States Government or its agencies, Michigan Attorney General Bill Schuettes Special
Counsel, and Genesee County
The scope of our engagement does not include representation of any other
individual or any governmental entity.
At 1 (emphasis added) (copy attached).
The second contract is allegedly between the Department of Attorney General and several
attorneys of Barris, Sott, Denn & Driker, each described as SAAGs, but the legal services are
personal to Snyder:
The Department and each SAAG agree that the SAAGs will provide legal advice
and representation to the Governor, related to any civil litigation or civil investigations of
Flint Water legal matters. The SAAGs will also represent the Governor in such related
matters where the Department of Attorney General has determined it cannot provide
representation, or the parties otherwise agree there is a conflict.
Paragraph 1.2 (emphasis added) (copy attached).
Evidence that supports those allegations (attach copies of pertinent documents and other information):

See the attached contracts.________________________________________________________

______________________________________________________________________________
Section 4. Certification (Required)
I certify that to the best of my knowledge, information, and belief, formed after a reasonable
inquiry under the circumstances, each factual contention of this complaint is supported by
evidence.
X __________________________________
Signature of Complainant

3/11/16
_______________________________
Date