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March 1, 2012 Tom Cave 1618 Emerald St. Broomfield, CO 80020 (720) 849-2462 Attorney for Complainant: Jessica K. Peck, Esq. Open Government Institute of Colorado 700 16th Avenue Denver, Colorado 80203 Ph: 720-628-5756 Email: Jessica@OGIColorado.org Respondent: Anne McGihon 837 Sherman Street Denver, Colorado 80203 On or about February 28, 2012, Dianne Primavera (hereinafter Primavera) distributed an email invitation to an unknown number of recipients soliciting contributions and attendance at a March 11, 2012 fundraiser benefitting her Colorado House of Representatives candidate campaign. The invitation included a Registered Lobbyist as Co-Host for the event in direct violation of Colorado Revised Statute 1-45-1-5.5(1)(a). (March 11th Invitation attached as Exhibit A). SUMMARY OF RELEVANT FACTS As set forth in the invitations introduction, the event is to sponsor a Colorado House candidate campaign: Spring is about to be sprung you can feel it in the air-a Lets help re-elect Dianne Primavera! The Invitation provides contribution amounts which start at $50 for guest, $100 for friend, $175 for co-host and $250 for host. The Invitation includes 13 host committee members, 11 of which are sitting legislators and two of which are former legislators, including Paul Weissmann and Anne McGihon (McGihon). McGihon is a Registered Lobbyist in the State of Colorado (McGihon Registration attached as Exhibit B).

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APPLICABLE LEGAL STANDARDS The Colorado Campaign Reform Act, C.R.S. 1-45-1-5.5(1)(a), prohibits registered lobbyists from soliciting contributions for members of the General Assembly when the General Assembly is in session: No professional lobbyist, volunteer lobbyist, or principal of a professional lobbyist or volunteer lobbyist shall make or promise to make a contribution to, or solicit or promise to solicit a contribution for: (I) A member of the general assembly or candidate for the general assembly, when the general assembly is in regular session. The Colorado General Assembly has been in session from January 11, 2012 to present. STATE LAW VIOLATIONS McGihon violated C.R.S. 1-45-1-5.5(1)(a) by authorizing her name to be used as a co-host to solicit contributions for a Colorado House of Representative candidate campaign during the Colorado legislative session because she is a registered Lobbyist. McGihons illegal conduct may not be limited to this incident. McGihon also co-sponsored a February 23, 2012 fundraiser during the 2012 Colorado legislative session purportedly to benefit the Colorado Democratic Partys House Majority Project. This invitation made clear that the beneficiaries of the political fundraiser were Democratic Colorado House candidates. The invitation read: Colorado's recent redistricting has resulted in an estimated 35 competitive State House districts. Help Take Back the House! According to the HMPs website, the organization is an initiative of the Colorado Democratic Party. The February 23 Invitation opened by identifying 35 competitive State House districts, in need of financial support, and also identified Rep. Daniel Kagan, D-Denver, (who emailed out the invitation) as an attendee at the event (February 23 Invitation Attached as Exhibit C). Multiple news outlets, including The Colorado Statesman, identify Kagans reelection race as one 2012s most competitive legislative races, with the Statesman calling the race a toss up. Other notable attendees listed on the invitation are all Democrats, including House Minority Leader Mark Ferrandino, Rep. Lois Court, Rep. Beth McCann, Sen. Irene Aguilar, Sen. Pat Steadman and Sen. Joyce Foster, all from Denver. (See http://coloradostatesman.com/content/993322-colorado-legislative-races-12-watch-2012).

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ANCILLARY MATTERS While Primavera is not identified as a party to this complaint, her actions demonstrate a serious ethical lapse. Multiple registered lobbyists received the invitation for Primaveras event from Primavera personally, and thus Primavera appears to be purposefully disregarded state laws prohibiting lobbyists from soliciting campaign funds during the legislative session. This prohibition is critical in preventing situations where lobbyists are asked for political contributions at the very same time lobbyists are asking for votes. Colorado has these restrictions in place to avoid Chicago Style Politics and Primaveras decision to disregard these laws is problematic. Through undersigned counsel, Tom Cave (Complainant) submits this Complaint to be referred to the Office of Administrative Courts for a hearing. The Complainant requests an expedited hearing based on the fact that the fundraising event to be hosted by a Lobbyist is less than 15 days away.

Sincerely,

/s/ Thomas E. Cave_______________ Thomas E. Cave Complainant

/s/ Jessica K. Peck. Esq.___________ Jessica K. Peck, Esq. #42199 Attorney For Complainant

**Original signatures appear on cover page accompanying this complaint.

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EXHIBIT A:

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EXHIBIT B:

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EXHIBIT C: