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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

Lonnie

Scott

Mailing Address

215 South Washington Square #100

City

Lansing

State

MI

Daytime Telephone Number

(517) 999-3646

Zip

48933

Section 2. Alleged Violator

Name

Governor Rick Snyder

Mailing Address

111 South Capitol Avenue

City

Lansing

State

MI

Zip

48933

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

circumstances, each factual contention of this complaint is supported by evidence. X 3/11/16 Signature of Complainant
circumstances, each factual contention of this complaint is supported by evidence. X 3/11/16 Signature of Complainant
circumstances, each factual contention of this complaint is supported by evidence. X 3/11/16 Signature of Complainant

3/11/16

Signature of Complainant

Date