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NEW JERSEY ELECTION LAW ENFORCEMENT COMMISSION

P.O. Box 185


Trenton, New Jersey 08625-0185
NEW JERSEY ELECTION LAW
ENFORCEMENT COMMISSION,
Complainant,

COMPLAINT AND NOTICE OF


OPPORTUNITY FOR A HEARING FOR LATE
FILING OF CONTRIBUTION AND
EXPENDITURE INFORMATION FOR THE 2009

v.

MUNICIPAL ELECTION
ELIZABETH MASON,
Candidate for Mayor, Hoboken City,
Hudson County,
and
RAUL MORALES,
and
ANTHONY PASQUALE,
and
VINCENT ADDEO,
Candidates for Municipal Office, Hoboken
City, Hudson County,

C-G 0905 05 04-M2009


C-9 0905 15 04-M2009
C-9 0905 17 04-M2009
C-9 0905 08 04-M2009

and
EDWARD M. LOMBARD,
Campaign Treasurer,
and
INES GARCIA-KEIM,
and
RICHARD G. MASON,
de facto Campaign Treasurers,
Respondents.
PLEASE TAKE NOTICE that the New Jersey Election Law Enforcement Commission (hereafter,
the Commission) hereby files a complaint against Elizabeth Mason, Raul Morales, Anthony Pasquale and
Vincent Addeo (hereafter, the Respondent Candidates) and Edward M. Lombard, Ines Garcia-Keim and
Richard G. Mason (hereafter, the Respondent Treasurers) and offers the Respondent Candidates and
Respondent Treasurers an opportunity for a hearing pursuant to the Administrative Procedure Act,
N.J.S.A. 52:14B-1 et seq., to determine whether or not the Respondent Candidates and Respondent

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 2 of 36

Treasurers had the responsibility under the terms of The New Jersey Campaign Contributions and
Expenditures Reporting Act, N.J.S.A. 19:44A-1, et seq. (hereafter, the Act) for the filing of campaign
reports or information required to be filed pursuant to the Act, and to determine whether or not the
Respondent Candidates and Respondent Treasurers failed, neglected or omitted to file any such report or
information at the time and in the manner prescribed by law, or in any other way violated the provisions of
the Act, and are therefore subject to penalties provided by the Act. The hearing will be conducted under the
legal authority and jurisdiction conferred upon the Commission to impose penalties for violations of the Act,
specifically Sections 6(b) and 22.
The Commission, by way of Complaint, alleges:

COUNT ONE
PROPOSED FINDINGS OF FACT:
1.

Elizabeth Mason sought election to the office of Mayor and Raul Morales, Anthony

Pasquale and Vincent Addeo sought election to municipal office in the city of Hoboken, Hudson County,
during the 2009 municipal election, held on May 12, 2009. Hereafter in this Complaint Elizabeth Mason
shall be referred to as the Respondent Candidate Mason, Raul Morales shall be referred to as the
Respondent Candidate Morales, Anthony Pasquale shall be referred to as the Respondent Candidate
Pasquale, and Vincent Addeo shall be referred to as the Respondent Candidate Addeo. The four
candidates shall collectively be referred to as the Respondent Candidates.
2.

The Respondent Candidates filed with the Commission on April 13, 2009, a Joint

Candidates Committee Certificate of Organization and Designation of Campaign Treasurer and


Depository (Form D-2), reporting that the Respondent Candidates established a joint candidates
committee, Mason Team for One Hoboken, to receive contributions and make expenditures for the
Respondent Candidates 2009 municipal election candidacies. The joint candidates committee received
and deposited contributions into and made expenditures from a campaign depository established and

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 3 of 36

maintained at Wachovia Bank, N.A. (hereafter, the 2009 campaign depository account). The Form D-2
designated Edward M. Lombard as the campaign treasurer, and was certified by the Respondent
Candidates. Hereafter in this Complaint Edward M. Lombard shall be referred to as the Respondent
Treasurer Lombard.
3.

The Respondent Treasurer Lombard was a person who acted in the capacity of campaign

treasurer and undertook activity relating to receiving contributions and making expenditures on behalf of
the Respondent Candidates 2009 municipal election candidacies.
4.

During the period of time from April 29, 2009 (the 13 th day preceding the 2009 municipal

election) through May 12, 2009 (the date of the 2009 municipal election), the Respondent Candidates and
Respondent Treasurer Lombard received and deposited into the 2009 campaign depository account, two
contributions totaling $5100.00, as follows:
a. one contribution in the amount of $2500.00, received by check and drawn on the account
of Niall J. Murray, deposited on or around May 7, 2009; and
b. one contribution in the amount of $2600.00, received by check and drawn on the account
of Randall W. Brummette, deposited on or around May 8, 2009.
5.

The Respondent Candidates and the Respondent Treasurer Lombard did not file with the

Commission within forty-eight hours of receipt, or on any date up to and including May 12, 2009, the
date of the 2009 municipal election, any written notice of receipt of the two 48-hour notice reporting
transactions, totaling $5100.00, described in paragraph four (items a and b), above.
PROPOSED CONCLUSIONS OF LAW:
1.

The Respondent Candidate Elizabeth Mason was at all times relevant to this Complaint a

candidate, as the term candidate is defined at N.J.S.A. 19:44A-3c, for the office of Mayor in the City
of Hoboken, Hudson County, in the 2009 municipal election held on May 12, 2009, and therefore was
subject to the requirements of the Act, N.J.S.A. 19:44A-1 to 47, and Commission Regulations, N.J.A.C.
19:25-1 to 21.

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 4 of 36

2.

The Respondent Candidates Raul Morales, Anthony Pasquale and Vincent Addeo, were at

all times relevant to this Complaint candidates, as the term candidate is defined at N.J.S.A. 19:44A3c, for municipal office in the City of Hoboken, Hudson County, in the 2009 municipal election held on
May 12, 2009, and therefore were subject to the requirements of the Act, N.J.S.A. 19:44A-1 to 47, and
Commission Regulations, N.J.A.C. 19:25-1 to 21.
3.

The Respondent Treasurer Edward M. Lombard was at all times relevant to this Count, the

Respondent Candidates campaign treasurer in the 2009 municipal election held on May 12, 2009, and

was therefore subject to the requirements of the Act and Commission Regulations.
4.

The Respondent Candidates and the Respondent Treasurer Lombard were required, pursuant

to N.J.S.A. 19:44A-16i and N.J.A.C. 19:25-8.6, to file with the Commission a written notice within fortyeight hours of receipt of each 48-hour notice reporting transaction. As used in this Complaint, the term,
48-hour notice reporting transaction shall mean the receipt by the Respondent Candidates and the
Respondent Treasurer Lombard of a contribution or aggregate contributions from a single source during
the period of time from April 29, 2009 (the 13th day preceding the 2009 municipal election) through May
12, 2009 (the date of the 2009 municipal election), which contribution was in excess of $1200.00, or
which aggregate contributions from a contributor were in excess of $1200.00. The 48-hour written notice
was required to include for each contribution or aggregate contributions in excess of $1200.00, the name
of the recipient candidate committee, the name and address of the contributor, the contribution amount,
the date of receipt, and if the contributor is an individual, the occupation of said individual contributor
and the name and mailing address of said individual contributors employer.
5.

The Respondent Candidates and the Respondent Treasurer Lombard violated N.J.S.A.

19:44A-16i and N.J.A.C. 19:25-8.6 by failing to file with the Commission either within forty-eight hours
of receipt or on any date up to and including May 12, 2009, the date of the 2009 municipal election, any

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 5 of 36

written notice of receipt of the two 48-hour notice reporting transactions, totaling $5100.00, described in
paragraph four (items a and b) of the Proposed Findings of Fact in this Count, above.
6.

The Respondent Candidates and the Respondent Treasurer Lombard are each subject to

imposition by the Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:2517.1 et seq., which penalties may not be more than $6800.00 for each 48-hour notice reporting
transaction, that is, for each contribution or aggregate contributions from a single source received in an
amount greater than $1200.00 by the Respondent Candidates and Respondent Treasurer Lombard during
the period of time from April 29, 2009 through May 12, 2009, for which a written notice of receipt was
not filed with the Commission within 48-hours of receipt, as required by N.J.S.A. 19:44A-16i and
N.J.A.C. 19:25-8.6.

COUNT TWO
PROPOSED FINDINGS OF FACT:
1. The Proposed Findings of Fact contained in Count One of this Complaint are repeated and
incorporated herein as if set forth in full below.
2. The Respondent Ines Garcia-Keim is a person who acted in the capacity of campaign
treasurer and undertook activities including the certification of reports relevant to the financial activity of
the Respondent Candidates for the time period beginning April 29, 2009 through May 29, 2009
(hereafter, the 20-day postelection reporting period. Hereafter in this Complaint Ines Garcia-Keim shall
be referred to as the Respondent de facto Treasurer Garcia-Keim.
3. The Respondent Candidates and Respondent de facto Treasurer Garcia-Keim certified as
correct and filed with the Commission on September 17, 2009, a Report of Contributions and
Expenditures (Form R-1) as the 20-day postelection report for the 2009 municipal election, disclosing
financial activity relevant to the 2009 municipal election, during the 20-day postelection reporting period.

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 6 of 36

4. The Respondent Candidates, Respondent Treasurer Lombard and Respondent de facto


Treasurer Garcia-Keim reported for the first time on September 17, 2009, on Schedule A, Monetary
Contributions in Excess of $300, of the 20-day postelection report for the 2009 municipal election,
contribution information for the contributors of six contributions totaling $8100.00, received in excess of
$300.00, individually or in the aggregate from one source in the 2009 municipal election, during the 20day postelection reporting period. Contribution information relevant to the six contributions is identified
in Items 1-6, Columns B through F of Exhibit A. Exhibit A is attached hereto and hereby incorporated
into this Complaint.
5. The Respondent Candidates, Respondent Treasurer Lombard and Respondent de facto
Treasurer Garcia-Keim reported for the first time on September 17, 2009, on Schedule B, In-Kind
Contributions in Excess of $300, of the 20-day postelection report for the 2009 municipal election,
contribution information for the contributor of one contribution received in excess of $300.00,
individually or in the aggregate from one source, totaling $2600.00, as an in-kind contribution, during
the 20-day postelection reporting period. Contribution information relevant to the one in-kind
contribution is identified in Item 1, Columns B through G of Exhibit B. Exhibit B is attached hereto and
hereby incorporated into this Complaint.
PROPOSED CONCLUSIONS OF LAW:
1. The Proposed Conclusions of Law contained in Count One of this Complaint are repeated
and incorporated herein as if set forth in full below.
2. The Respondent Treasurer Edward M. Lombard was at all times relevant to this Count, the
Respondent Candidates campaign treasurer in the 2009 municipal election held on May 12, 2009, and

was therefore subject to the requirements of the Act and Commission Regulations.
3. The Respondent de facto Treasurer, Ines Garcia-Keim, was at all times relevant to this Count,
the Respondent Candidates de facto campaign treasurer in the 2009 municipal election held on May 12,
2009, and was therefore subject to the requirements of the Act and Commission Regulations.

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 7 of 36

4. The Respondent Candidates, Respondent Treasurer Lombard and Respondent de facto


Treasurer Garcia-Keim were required, pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.2, to certify
as correct and file with the Commission on June 1, 2009, a Report of Contributions and Expenditures
(Form R-1) as a 20-day postelection report for the 2009 municipal election, to report all contributions
received and expenditures made for the 2009 municipal election, for the period of time beginning April
29, 2009 through May 29, 2009 (hereafter, the 20-day postelection reporting period).
5. The Respondent Candidates, Respondent Treasurer Lombard and Respondent de facto
Treasurer Garcia-Keim were required, pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.2, 19:2510.2 and 19:25-10.4 to certify as correct and report on June 1, 2009, on the 20-day postelection report for
the 2009 municipal election, all contributions received during the 20-day postelection reporting period,
including all moneys, loans, paid personal services, or other things of value, including contributions of
goods and services (in-kind contributions), contributed to the Respondent Candidates during the 20-day
postelection reporting period for the 2009 municipal election.
6. For each contribution in excess of $300.00, individually or when aggregated with prior
contributions from one source, received during the 2009 municipal election through May 29, 2009, the
Respondent Candidates, Respondent Treasurer Lombard and Respondent de facto Treasurer Garcia-Keim
were required, pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-10.2 and 19:25-10.15, to report the
date of receipt and the amount of the contribution, and the name and address of the contributor. Where the
contributor was an individual, the Respondent Candidates, Respondent Treasurer Lombard and
Respondent de facto Treasurer Garcia-Keim were also required, pursuant to N.J.A.C. 19:25-10.2A, to
disclose the individuals occupation, as well as the name and mailing address of the contributors
employer.
7. For each contribution of goods and services, or in-kind contribution, pursuant to N.J.A.C.
19:25-1.7 and 19:25-10.4, received in excess of $300.00, either alone or when aggregated with prior
contributions, from the same contributor during the 2009 municipal election through May 29, 2009, the

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 8 of 36

Respondent Candidates, Respondent Treasurer Lombard and Respondent de facto Treasurer Garcia-Keim
were required to report a description of the contribution, the name and address of the contributor, the date
of receipt of the contribution, and the contribution amount, and where the contributor is an individual, the
occupation of said contributor and the name and address of said contributors employer.
8. The Respondent Candidates, Respondent Treasurer Lombard and Respondent de facto
Treasurer Garcia-Keim violated N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.2 by failing to certify as
correct and file on June 1, 2009, the 20-day postelection report for the 2009 municipal election. The
Respondent Candidates, Respondent Treasurer Lombard and Respondent de facto Treasurer Garcia-Keim
certified as correct and filed with the Commission on September 17, 2009, a Form R-1 as the 20-day
report for the 2009 municipal election, 108 days after the June 1, 2009 due date.
9. The Respondent Candidates, Respondent Treasurer Lombard and Respondent de facto
Treasurer Garcia-Keim violated N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.2, 19:25-10.2, 19:25-10.2A
and 19:25-10.15 by failing to report on June 1, 2009, on the 20-day postelection report for the 2009
municipal election, contribution information for the receipt of six contributions in excess of $300.00,
totaling $8100.00, described in paragraph four of the Proposed Findings of Fact in this Count, above. The
Respondent Candidates, Respondent Treasurer Lombard and Respondent de facto Treasurer Garcia-Keim
reported contribution information relevant to the six contributions totaling $8100.00 on September 17,
2009, 108 days after the June 1, 2009 due date for the 20-day postelection report for the 2009 municipal
election.
10. The Respondent Candidates, Respondent Treasurer Lombard and Respondent de facto
Treasurer Garcia-Keim violated N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.2 and 19:25-10.4 by failing to
report on June 1, 2009, on the 20-day postelection report for the 2009 municipal election, contribution
information for the receipt of one in-kind contribution received in excess of $300.00, individually or in
the aggregate from one source, in the amount of $2600.00, described in paragraph five of the Proposed
Findings of Fact in this Count, above. The Respondent Candidates, Respondent Treasurer Lombard and

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 9 of 36

Respondent de facto Treasurer Garcia-Keim reported contribution information relevant to the one in-kind
contribution in the amount of $2600.00 on September 17, 2009, 108 days after the June 1, 2009 due date
for the 20-day postelection report for the 2009 municipal election.
11. The Respondent Candidates, Respondent Treasurer Lombard and Respondent de facto
Treasurer Garcia-Keim are each subject to imposition by the Commission of the penalties prescribed by
N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which penalties may not be more than $6800.00 for
each reporting transaction, that is for each contribution received which has not been reported in the
manner or in the time prescribed by the Act or Commission regulations.

COUNT THREE
PROPOSED FINDINGS OF FACT:
1. The Proposed Findings of Fact contained in Counts One and Two in this Complaint are
repeated and incorporated herein as if set forth in full below.
2. The Respondent Candidates, Respondent Treasurer Lombard and Respondent de facto
Treasurer Garcia-Keim reported for the first time on September 17, 2009, on Schedule C, Loans
Received, of the 20-day postelection report for the 2009 municipal election, contributor information
relevant to four loans totaling $103,836.59, received during the 20-day postelection reporting period.
Contribution information relevant to the four loans is identified in Items 1-4, Columns B through G of
Exhibit C. Exhibit C is attached hereto and hereby incorporated into this Complaint.
PROPOSED CONCLUSIONS OF LAW:
1. The Proposed Conclusions of Law contained in Counts One and Two in this Complaint are
repeated and incorporated herein as if set forth in full below.
2. The Respondent Treasurer Edward M. Lombard was at all times relevant to this Count, the
Respondent Candidates campaign treasurer in the 2009 municipal election held on May 12, 2009, and

was therefore subject to the requirements of the Act and Commission Regulations.

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 10 of 36

3. The Respondent de facto Treasurer, Ines Garcia-Keim, was at all times relevant to this Count,
the Respondent Candidates de facto campaign treasurer in the 2009 municipal election held on May 12,
2009, and was therefore subject to the requirements of the Act and Commission Regulations.
4. The Respondent Candidates, Respondent Treasurer Lombard and Respondent de facto
Treasurer Garcia-Keim were required, pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.2 and 19:2510.13, to certify as correct and file with the Commission on June 1, 2009, a 20-day postelection report for
the 2009 municipal election, and to report all contribution information, including the date of receipt and
amount of any loans received, and the name and mailing address of the lender. Where the lender was an
individual and for all currency contributions, the Respondent Candidates, Respondent Treasurer Lombard
and Respondent de facto Treasurer Garcia-Keim were also required to disclose the individuals
occupation, as well as the name and mailing address of the lenders employer.
5. The Respondent Candidates, Respondent Treasurer Lombard and Respondent de facto
Treasurer Garcia-Keim violated N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.2 and 19:25-10.13 by failing to
certify as correct and file on June 1, 2009, the 20-day postelection report for the 2009 municipal election,
and to report timely contribution information for the receipt of four loans totaling $103,836.59, described
in paragraph two of the Proposed Findings of Fact in this Count, above. The Respondent Candidates,
Respondent Treasurer Lombard and Respondent de facto Treasurer Garcia-Keim reported contribution
information relevant to the four loans totaling $103,836.59 on September 17, 2009, 108 days after the
June 1, 2009 due date for the 20-day postelection report for the 2009 municipal election.
6. The Respondent Candidates, Respondent Treasurer Lombard and Respondent de facto
Treasurer Garcia-Keim are each subject to imposition by the Commission of the penalties prescribed by
N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which penalties may not be more than $6800.00 for
each reporting transaction, that is for each contribution which has not been reported in the manner or in
the time prescribed by the Act or Commission regulations.

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 11 of 36

COUNT FOUR
PROPOSED FINDINGS OF FACT:
1. The Proposed Findings of Fact contained in Counts One through Three of this Complaint are
repeated and incorporated herein as if set forth in full below.
2. The Respondent Candidates, Respondent Treasurer Lombard and Respondent de facto
Treasurer Garcia-Keim reported for the first time on September 17, 2009, on Line 1 of Table I.
Receipts, of the 20-day postelection report for the 2009 municipal election, receipt of an amount of
$7849.00 from contributors, each of whose contributions to the Respondent Candidates during the 20-day
postelection reporting period for the 2009 municipal election did not exceed $300.00, in the aggregate, as
of May 29, 2009 (hereafter, the sum of contributions of $300.00 or less).

PROPOSED CONCLUSIONS OF LAW:


1. The Proposed Conclusions of Law contained in Counts One through Three of this Complaint
are repeated and incorporated herein as if set forth in full below.
2. The Respondent Treasurer Edward M. Lombard was at all times relevant to this Count, the
Respondent Candidates campaign treasurer in the 2009 municipal election held on May 12, 2009, and

was therefore subject to the requirements of the Act and Commission Regulations.
3. The Respondent de facto Treasurer, Ines Garcia-Keim, was at all times relevant to this Count,
the Respondent Candidates de facto campaign treasurer in the 2009 municipal election held on May 12,
2009, and was therefore subject to the requirements of the Act and Commission Regulations.
4. The Respondent Candidates, Respondent Treasurer Lombard and Respondent de facto
Treasurer Garcia-Keim were required, pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.2 and 19:2510.3, to certify as correct and file with the Commission on June 1, 2009, a 20-day postelection report for
the 2009 municipal election, and to report the sum of contributions of $300.00 or less, received during the
20-day postelection reporting period for the 2009 municipal election.

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 12 of 36

5. The Respondent Candidates, Respondent Treasurer Lombard and Respondent de facto


Treasurer Garcia-Keim violated N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-10.3 by failing to certify as
correct and file on June 1, 2009, the 20-day postelection report for the 2009 municipal election, and to
report timely the amount of $7849.00, received in the sum of contributions of $300.00 or less, in the
aggregate, during the 20-day postelection reporting period. The Respondent Candidates, Respondent
Treasurer Lombard and Respondent de facto Treasurer Keim reported the amount of $7849.00 as the sum
of contributions of $300.00 or less on September 17, 2009, 108 days after the June 1, 2009 due date for
the 20-day preelection report for the 2009 municipal election.
6. The Respondent Candidates, Respondent Treasurer Lombard and Respondent de facto
Treasurer Garcia-Keim are each subject to imposition by the Commission of the penalties prescribed by
N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which penalties may not be more than $6800.00,
that is for each contribution received which has not been reported in the manner or in the time prescribed
by the Act or Commission regulations.

COUNT FIVE
PROPOSED FINDINGS OF FACT:
1. The Proposed Findings of Fact contained in Counts One through Four of this Complaint are
repeated and incorporated herein as if set forth in full below.
2. The Respondent Candidates, Respondent Treasurer Lombard and Respondent de facto
Treasurer Garcia-Keim reported on September 17, 2009, on the 20-day postelection report for the 2009
municipal election, expenditure information for 197 expenditures totaling $355,548.38, as follows:
a. for the first time on Schedule 1(D), Disbursements, 192 expenditures totaling
$151,711.79, made, authorized or incurred during the 20-day postelection reporting period for the
2009 municipal election;

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 13 of 36

b. for the first time on Schedule E, Outstanding Obligations, one expenditure in the
amount of $100,000.00, made, authorized or incurred during the 20-day postelection reporting
period for the 2009 municipal election; and
c. on Schedule E, Outstanding Obligations, four expenditures totaling $103,836.59, made,
authorized or incurred during the 20-day postelection reporting period for the 2009 municipal
election, as described in paragraph two of the Proposed Findings of Fact contained in Count
Three, above.
PROPOSED CONCLUSIONS OF LAW:
1. The Proposed Conclusions of Law contained in Counts One through Four of this Complaint
are repeated and incorporated herein as if set forth in full below.
2. The Respondent Treasurer Edward M. Lombard was at all times relevant to this Count, the
Respondent Candidates campaign treasurer in the 2009 municipal election held on May 12, 2009, and

was therefore subject to the requirements of the Act and Commission Regulations.
3. The Respondent de facto Treasurer, Ines Garcia-Keim, was at all times relevant to this Count,
the Respondent Candidates de facto campaign treasurer in the 2009 municipal election held on May 12,
2009, and was therefore subject to the requirements of the Act and Commission Regulations.
4. The Respondent Candidates, Respondent Treasurer Lombard and Respondent de facto
Treasurer Garcia-Keim were required, pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.2, 19:2510.13 and 19:25-12.2, to certify as correct and file with the Commission on June 1, 2009, on the 20-day
postelection report for the 2009 municipal election, all expenditure information, including the date the
expenditure was made, the full name and address of the payee, the purpose of the expenditure, the amount
of the expenditure, and the number of the check for each expenditure transaction made, incurred or
authorized during the 20-day postelection reporting period for the 2009 municipal election.
5. The Respondent Candidates, Respondent Treasurer Lombard and Respondent de facto
Treasurer Garcia-Keim violated N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.2, 19:25-10.13 and 19:25-12.2

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 14 of 36

by failing to certify as correct and file with the Commission on June 1, 2009, the 20-day postelection
report for the 2009 municipal election, and to report timely expenditure information relevant to 193
expenditures totaling $251,711.79, described in paragraph two (items a and b) of the Proposed Findings
of Fact in this Count, above. The Respondent Candidates, Respondent Treasurer Lombard and
Respondent de facto Treasurer Garcia-Keim reported expenditure information relevant to the 193
expenditures totaling $251,711.79 on September 17, 2009, 108 days after the June 1, 2009 due date for
the 20-day postelection report for the 2009 municipal election.
6. The Respondent Candidates, Respondent Treasurer Lombard and Respondent de facto
Treasurer Garcia-Keim are subject to imposition by the Commission of the penalties prescribed by
N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which penalties may not be more than $6800.00 for
each reporting transaction, that is for each expenditure which has not been reported in the manner or in
the time prescribed by the Act or Commission regulations.

COUNT SIX
PROPOSED FINDINGS OF FACT:
1. The Proposed Findings of Fact contained in Counts One through Five of this Complaint are
repeated and incorporated herein as if set forth in full below.
2. The Respondent de facto Treasurer Garcia-Keim is a person who acted in the capacity of
campaign treasurer and undertook activities including the certification of reports relevant to the financial
activity of the Respondent Candidates for the time period beginning July 1, 2009 through September 30,
2009 (hereafter, the 2009 third quarterly reporting period for the 2009 municipal election), and receiving
and depositing contributions into the campaign depository account.
3. The Respondent Richard G. Mason is a person who acted in the capacity of campaign
treasurer and undertook activities including the certification of reports relevant to the financial activity of
the Respondent Candidates during the 2009 third quarterly reporting period for the 2009 municipal

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 15 of 36

election, and receiving and depositing contributions into the campaign depository account. Hereafter in
this Complaint Richard G. Mason shall be referred to as the Respondent de facto Treasurer Mason.
4. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason certified as correct and filed with the Commission on May 26, 2013, a Receipts

and Expenditures Quarterly Report (Form R-3) as the 2009 third quarterly report for the 2009
municipal election, disclosing for the first time financial activity for the 2009 third quarterly
reporting period for the 2009 municipal election.
5. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason reported for the first time on May 26, 2013, on Schedule A, Monetary
Contributions in Excess of $300, of the 2009 third quarterly report for the 2009 municipal election,
contribution information for the contributor of one contribution in the amount of $4600.00, received in
excess of $300.00, individually or in the aggregate from one source, during the 2009 third quarterly
reporting period for the 2009 municipal election. Contribution information relevant to the one
contribution is identified in Item 1, Columns B through F of Exhibit D. Exhibit D is attached hereto and
hereby incorporated into this Complaint.
PROPOSED CONCLUSIONS OF LAW:
1. The Proposed Conclusions of Law contained in Counts One through Five of this Complaint
are repeated and incorporated herein as if set forth in full below.
2. The Respondent de facto Treasurer, Ines Garcia-Keim, was at all times relevant to this Count,
the Respondent Candidates de facto campaign treasurer in the 2009 municipal election held on May 12,
2009, and was therefore subject to the requirements of the Act and Commission Regulations.
3. The Respondent de facto Treasurer, Richard G. Mason, was at all times relevant to this
Count, the Respondent Candidates de facto campaign treasurer in the 2009 municipal election held on
May 12, 2009, and was therefore subject to the requirements of the Act and Commission Regulations.

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 16 of 36

4. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de


facto Treasurer Mason were required, pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3, to certify
as correct and file with the Commission on October 15, 2009, a Report of Contributions and Expenditures
(Form R-1) as a 2009 third quarterly report for the 2009 municipal election, to report all contributions
received and expenditures made for the 2009 municipal election, for the period of time July 1, 2009
through September 30, 2009 (hereafter, the 2009 third quarterly reporting period for the 2009 municipal
election).
5. For each contribution in excess of $300.00, individually or when aggregated with prior
contributions from one source, received during the 2009 municipal election through October 15, 2009, the
Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de facto Treasurer
Mason were required, pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-10.2 and 19:25-10.15, to report
the date of receipt and the amount of the contribution, and the name and address of the contributor. Where
the contributor was an individual, the Respondent Candidates, Respondent de facto Treasurer GarciaKeim and Respondent de facto Treasurer Mason were also required, pursuant to N.J.A.C. 19:25-10.2A, to
disclose the individuals occupation, as well as the name and mailing address of the contributors
employer.
6. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason violated N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3 by failing to certify as correct
and file on October 15, 2009, the 2009 third quarterly report for the 2009 municipal election. The
Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de facto Treasurer
Mason certified as correct and filed with the Commission on May 26, 2010, a Form R-1 as the 2009 third
quarterly report for the 2009 municipal election, 222 days after the October 15, 2009 due date.
7. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason violated N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3, 19:25-10.2, 19:25-10.2A and
19:25-10.15 by failing to report on October 15, 2009, on the 2009 third quarterly report for the 2009

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 17 of 36

municipal election, contribution information for the receipt of one contribution in excess of $300.00, in
the amount of $4600.00, described in paragraph five of the Proposed Findings of Fact in this Count,
above. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de facto
Treasurer Mason reported contribution information relevant to the one contribution totaling $4600.00 on
May 26, 2010, 222 days after the October 15, 2009 due date for the 2009 third quarterly report for the
2009 municipal election.
8. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason are each subject to imposition by the Commission of the penalties prescribed by
N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which penalties may not be more than $6800.00 for
each reporting transaction, that is for each contribution received which has not been reported in the
manner or in the time prescribed by the Act or Commission regulations.

COUNT SEVEN
PROPOSED FINDINGS OF FACT:
1. The Proposed Findings of Fact contained in Counts One through Six of this Complaint are
repeated and incorporated herein as if set forth in full below.
2. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason reported for the first time on May 26, 2010, on Schedule C, Loans Received, of
the 2009 third quarterly report for the 2009 municipal election, contributor information relevant to three
loans from one contributor, totaling $90,000.00, received during the 2009 third quarterly reporting period
for the 2009 municipal election. Contribution information relevant to the three loans is identified in Items
1-3, Columns B through G of Exhibit E. Exhibit E is attached hereto and hereby incorporated into this
Complaint.

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 18 of 36

PROPOSED CONCLUSIONS OF LAW:


1. The Proposed Conclusions of Law contained in Counts One through Six in this Complaint are
repeated and incorporated herein as if set forth in full below.
2. The Respondent de facto Treasurer, Ines Garcia-Keim, was at all times relevant to this Count,
the Respondent Candidates de facto campaign treasurer in the 2009 municipal election held on May 12,
2009, and was therefore subject to the requirements of the Act and Commission Regulations.
3. The Respondent de facto Treasurer, Richard G. Mason, was at all times relevant to this
Count, the Respondent Candidates de facto campaign treasurer in the 2009 municipal election held on
May 12, 2009, and was therefore subject to the requirements of the Act and Commission Regulations.
4. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason were required, pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3 and 19:2510.13, to certify as correct and file with the Commission on October 15, 2009, a Form R-1 as the 2009
third quarterly report for the 2009 municipal election, and to report all contribution information, including
the date of receipt and amount of any loans received, and the name and mailing address of the lender.
Where the lender was an individual and for all currency contributions, the Respondent Candidates,
Respondent de facto Treasurer Garcia-Keim and Respondent de facto Treasurer Mason were also required
to disclose the individuals occupation, as well as the name and mailing address of the lenders employer.
5. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason violated N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3 and 19:25-10.13 by failing to
certify as correct and file on October 15, 2009, the 2009 third quarterly report for the 2009 municipal
election, and to report timely contribution information for the receipt of three loans from one contributor,
totaling $90,000.00, described in paragraph two of the Proposed Findings of Fact in this Count, above.
The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de facto
Treasurer Mason reported contribution information relevant to the three loans totaling $90,000.00 on May

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 19 of 36

26, 2010, 222 days after the October 15, 2009 due date for the 2009 third quarterly report for the 2009
municipal election.
6. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason are each subject to imposition by the Commission of the penalties prescribed by
N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which penalties may not be more than $6800.00 for
each reporting transaction, that is for each contribution which has not been reported in the manner or in
the time prescribed by the Act or Commission regulations.

COUNT EIGHT
PROPOSED FINDINGS OF FACT:
1. The Proposed Findings of Fact contained in Counts One through Seven of this Complaint are
repeated and incorporated herein as if set forth in full below.
2. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason reported for the first time on May 26, 2010, on Line 1 of Table I. Receipts, of
the 2009 third quarterly report for the 2009 municipal election, receipt of an amount of $450.00 from
contributors, each of whose contributions to the Respondent Candidates during the 2009 third quarterly
reporting period for the 2009 municipal election did not exceed $300.00, in the aggregate, as of October
12, 2009 (hereafter, the sum of contributions of $300.00 or less).
PROPOSED CONCLUSIONS OF LAW:
1. The Proposed Conclusions of Law contained in Counts One through Seven of this Complaint
are repeated and incorporated herein as if set forth in full below.
2. The Respondent de facto Treasurer, Ines Garcia-Keim, was at all times relevant to this Count,
the Respondent Candidates de facto campaign treasurer in the 2009 municipal election held on May 12,
2009, and was therefore subject to the requirements of the Act and Commission Regulations.

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 20 of 36

3. The Respondent de facto Treasurer, Richard G. Mason, was at all times relevant to this
Count, the Respondent Candidates de facto campaign treasurer in the 2009 municipal election held on
May 12, 2009, and was therefore subject to the requirements of the Act and Commission Regulations.
4. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason were required, pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3 and 19:2510.3, to certify as correct and file with the Commission on October 15, 2009, a 2009 third quarterly report
for the 2009 municipal election, and to report the sum of contributions of $300.00 or less, received during
the 2009 third quarterly reporting period for the 2009 municipal election.
5. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason violated N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-10.3 by failing to certify as
correct and file on October 15, 2009, the 2009 third quarterly report for the 2009 municipal election, and
to report timely the amount of $450.00, received in the sum of contributions of $300.00 or less, in the
aggregate, during the 2009 third quarterly reporting period. The Respondent Candidates, Respondent de
facto Treasurer Garcia-Keim and Respondent de facto Treasurer Mason reported the amount of $450.00
as the sum of contributions of $300.00 or less on May 26, 2010, 222 days after the October 15, 2009 due
date for the 2009 third quarterly report for the 2009 municipal election.
6. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason are each subject to imposition by the Commission of the penalties prescribed by
N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which penalties may not be more than $6800.00,
that is for each contribution received which has not been reported in the manner or in the time prescribed
by the Act or Commission regulations.

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 21 of 36

COUNT NINE
PROPOSED FINDINGS OF FACT:
1. The Proposed Findings of Fact contained in Counts One through Eight of this Complaint are
repeated and incorporated herein as if set forth in full below.
2. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason reported on May 26, 2010, on the 2009 third quarterly report for the 2009
municipal election, expenditure information for fifty-one expenditures totaling $399,771.18, as follows:
a. for the first time on Schedule 1(D), Disbursements, forty-four expenditures totaling
$108,571.18, made, authorized or incurred during the 2009 third quarterly reporting period for the
2009 municipal election;
b. on Schedule E, Outstanding Obligations, three expenditures totaling $90,000.00, made,
authorized or incurred during the 2009 third quarterly reporting period for the 2009 municipal
election, as described in paragraph two of the Proposed Findings of Fact contained in Count
Seven, above.
c. on Schedule E, Outstanding Obligations, four expenditures totaling $201,200.00, made,
authorized or incurred during the 2009 20-day postelection reporting period for the 2009
municipal election.
PROPOSED CONCLUSIONS OF LAW:
1. The Proposed Conclusions of Law contained in Counts One through Eight of this Complaint
are repeated and incorporated herein as if set forth in full below.
2. The Respondent de facto Treasurer, Ines Garcia-Keim, was at all times relevant to this Count,
the Respondent Candidates de facto campaign treasurer in the 2009 municipal election held on May 12,
2009, and was therefore subject to the requirements of the Act and Commission Regulations.
3. The Respondent de facto Treasurer, Richard G. Mason, was at all times relevant to this
Count, the Respondent Candidates de facto campaign treasurer in the 2009 municipal election held on

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 22 of 36

May 12, 2009, and was therefore subject to the requirements of the Act and Commission Regulations.
4. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason were required, pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3, 19:2510.13 and 19:25-12.2, to certify as correct and file with the Commission on October 15, 2009, on the
2009 third quarterly report for the 2009 municipal election, all expenditure information, including the
date the expenditure was made, the full name and address of the payee, the purpose of the expenditure,
the amount of the expenditure, and the number of the check for each expenditure transaction made,
incurred or authorized during the 2009 third quarterly reporting period for the 2009 municipal election.
5. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason violated N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3, 19:25-10.13 and 19:25-12.2
by failing to certify as correct and file with the Commission on October 15, 2009, the 2009 third quarterly
report for the 2009 municipal election, and to report timely expenditure information relevant to forty-four
expenditures totaling $108,571.18, described in paragraph two (item a) of the Proposed Findings of Fact
in this Count, above. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and
Respondent de facto Treasurer Mason reported expenditure information relevant to the forty-four
expenditures totaling $108,571.18 on May 26, 2010, 222 days after the October 15, 2009 due date for the
2009 third quarterly report for the 2009 municipal election.
6. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason are each subject to imposition by the Commission of the penalties prescribed by
N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which penalties may not be more than $6800.00 for
each reporting transaction, that is for each expenditure which has not been reported in the manner or in
the time prescribed by the Act or Commission regulations.

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 23 of 36

COUNT TEN
PROPOSED FINDINGS OF FACT:
1. The Proposed Findings of Fact contained in Counts One through Nine of this Complaint are
repeated and incorporated herein as if set forth in full below.
2. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason certified as correct and filed with the Commission on May 18, 2010, a Report of
Contributions and Expenditures (Form R-1) as the 2009 fourth quarterly report for the 2009 municipal
election, disclosing financial activity relevant to the 2009 municipal election, for the period of time
beginning October 1, 2009 though December 31, 2009 (hereafter, the 2009 fourth quarterly reporting
period for the 2009 municipal election).
3. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason reported for the first time on May 18, 2010, on Schedule C, Loans Received, of
the 2009 fourth quarterly report for the 2009 municipal election, contributor information relevant to one
loan in the amount of $20,000.00, received during the 2009 fourth quarterly reporting period for the 2009
municipal election. Contribution information relevant to the one loan is identified in Item 1, Columns B
through G of Exhibit F. Exhibit F is attached hereto and hereby incorporated into this Complaint.
PROPOSED CONCLUSIONS OF LAW:
1. The Proposed Conclusions of Law contained in Counts One through Nine in this Complaint
are repeated and incorporated herein as if set forth in full below.
2. The Respondent de facto Treasurer, Ines Garcia-Keim, was at all times relevant to this Count,
the Respondent Candidates de facto campaign treasurer in the 2009 municipal election held on May 12,
2009, and was therefore subject to the requirements of the Act and Commission Regulations.
3. The Respondent de facto Treasurer, Richard G. Mason, was at all times relevant to this
Count, the Respondent Candidates de facto campaign treasurer in the 2009 municipal election held on
May 12, 2009, and was therefore subject to the requirements of the Act and Commission Regulations.

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 24 of 36

4. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de


facto Treasurer Mason were required, pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3, to certify
as correct and file with the Commission on January 15, 2010, a Report of Contributions and Expenditures
(Form R-1) as a 2009 fourth quarterly report for the 2009 municipal election, to report all contributions
received and expenditures made for the 2009 municipal election, for the period of time beginning October
1, 2009 through December 31, 2009 (hereafter, the 2009 fourth quarterly reporting period for the 2009
municipal election).
5. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason were required, pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3, 19:25-10.2
and 19:25-10.4 to certify as correct and report on January 15, 2010, on the 2009 fourth quarterly report
for the 2009 municipal election, all contributions received during the 2009 fourth quarterly reporting
period, including all moneys, loans, paid personal services, or other things of value, including
contributions of goods and services (in-kind contributions), contributed to the Respondent Candidates
during the 2009 fourth quarterly reporting period for the 2009 municipal election.
6. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason were required, pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3 and 19:2510.13, to certify as correct and file with the Commission on January 15, 2010, a 2009 fourth quarterly
report for the 2009 municipal election, and to report all contribution information, including the date of
receipt and amount of any loans received, and the name and mailing address of the lender. Where the
lender was an individual and for all currency contributions, the Respondent Candidates, Respondent de
facto Treasurer Garcia-Keim and Respondent de facto Treasurer Mason were also required to disclose the
individuals occupation, as well as the name and mailing address of the lenders employer.
7. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason violated N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3 and 19:25-10.13 by failing to
certify as correct and file on January 15, 2010, the 2009 fourth quarterly report for the 2009 municipal

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 25 of 36

election, and to report timely contribution information for the receipt of one loan in the amount of
$20,000.00, described in paragraph three of the Proposed Findings of Fact in this Count, above. The
Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de facto Treasurer
Mason reported contribution information relevant to the one loan in the amount of $20,000.00 on May 18,
2010, 123 days after the January 15, 2010 due date for the 2009 fourth quarterly report for the 2009
municipal election.
8. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason are each subject to imposition by the Commission of the penalties prescribed by
N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which penalties may not be more than $6800.00 for
each reporting transaction, that is for each contribution which has not been reported in the manner or in
the time prescribed by the Act or Commission regulations.

COUNT ELEVEN
PROPOSED FINDINGS OF FACT:
1. The Proposed Findings of Fact contained in Counts One through Ten of this Complaint are
repeated and incorporated herein as if set forth in full below.
2. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason reported on May 18, 2010, on the 2009 fourth quarterly report for the 2009
municipal election, expenditure information for thirteen expenditures totaling $328,712.00, as follows:
a. for the first time on Schedule 1(D), Disbursements, five expenditures totaling
$17,512.00, made, authorized or incurred during the 2009 fourth quarterly reporting period for
the 2009 municipal election;
b. on Schedule E, Outstanding Obligations, one expenditure in the amount of $20,000.00,
made, authorized or incurred during the 2009 fourth quarterly reporting period for the 2009

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 26 of 36

municipal election, as described in paragraph two of the Proposed Findings of Fact contained in
Count Ten, above;
c. on Schedule E, Outstanding Obligations, three expenditures totaling $90,000.00, made,
authorized or incurred during the 2009 third quarterly reporting period for the 2009 municipal
election, as described in paragraph two (item b) of the Proposed Findings of Fact contained in
Count Nine, above; and
d. on Schedule E, Outstanding Obligations, four expenditures totaling $201,200.00, made,
authorized or incurred during the 20-day postelection reporting period for the 2009 municipal
election.
PROPOSED CONCLUSIONS OF LAW:
1. The Proposed Conclusions of Law contained in Counts One through Ten of this Complaint
are repeated and incorporated herein as if set forth in full below.
2. The Respondent de facto Treasurer, Ines Garcia-Keim, was at all times relevant to this Count,
the Respondent Candidates de facto campaign treasurer in the 2009 municipal election held on May 12,
2009, and was therefore subject to the requirements of the Act and Commission Regulations.
3. The Respondent de facto Treasurer, Richard G. Mason, was at all times relevant to this
Count, the Respondent Candidates de facto campaign treasurer in the 2009 municipal election held on
May 12, 2009, and was therefore subject to the requirements of the Act and Commission Regulations.
4. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason were required, pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3, 19:2510.13 and 19:25-12.2, to certify as correct and file with the Commission on January 15, 2010, on the 2009
fourth quarterly report for the 2009 municipal election, all expenditure information, including the date the
expenditure was made, the full name and address of the payee, the purpose of the expenditure, the amount
of the expenditure, and the number of the check for each expenditure transaction made, incurred or
authorized during the 2009 fourth quarterly reporting period for the 2009 municipal election.

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 27 of 36

5. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de


facto Treasurer Mason violated N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3, 19:25-10.13 and 19:25-12.2
by failing to certify as correct and file with the Commission on January 15, 2010, the 2009 fourth
quarterly report for the 2009 municipal election, and to report timely expenditure information relevant to
five expenditures totaling $17,512.00, described in paragraph two (item a) of the Proposed Findings of
Fact in this Count, above. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and
Respondent de facto Treasurer Mason reported expenditure information relevant to the five expenditures
totaling $17,512.00 on May 18, 2010, 123 days after the January 15, 2010 due date for the 2009 fourth
quarterly report for the 2009 municipal election.
6. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason are each subject to imposition by the Commission of the penalties prescribed by
N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which penalties may not be more than $6800.00 for
each reporting transaction, that is for each expenditure which has not been reported in the manner or in
the time prescribed by the Act or Commission regulations.

COUNT TWELVE
PROPOSED FINDINGS OF FACT:
1. The Proposed Findings of Fact contained in Counts One through Eleven of this Complaint are
repeated and incorporated herein as if set forth in full below.
2. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason certified as correct and filed with the Commission on May 26, 2010, a Report of
Contributions and Expenditures (Form R-1) as the 2010 first quarterly report for the 2009 municipal
election, disclosing financial activity relevant to the 2009 municipal election, for the period of time
beginning January 1, 2010 through March 31, 2010 (hereafter, the 2010 first quarterly reporting period
for the 2009 municipal election).

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 28 of 36

3. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de


facto Treasurer Mason reported for the first time on May 26, 2010, on Schedule C, Loans Received, of
the 2010 first quarterly report for the 2009 municipal election, contributor information relevant to one
loan in the amount of $25,500.00, received during the 2010 first quarterly reporting period for the 2009
municipal election. Contribution information relevant to the one loan is identified in Item 1, Columns B
through G of Exhibit G. Exhibit G is attached hereto and hereby incorporated into this Complaint.
PROPOSED CONCLUSIONS OF LAW:
1. The Proposed Conclusions of Law contained in Counts One through Eleven in this Complaint
are repeated and incorporated herein as if set forth in full below.
2. The Respondent de facto Treasurer, Ines Garcia-Keim, was at all times relevant to this Count,
the Respondent Candidates de facto campaign treasurer in the 2009 municipal election held on May 12,
2009, and was therefore subject to the requirements of the Act and Commission Regulations.
3. The Respondent de facto Treasurer, Richard G. Mason, was at all times relevant to this
Count, the Respondent Candidates de facto campaign treasurer in the 2009 municipal election held on
May 12, 2009, and was therefore subject to the requirements of the Act and Commission Regulations
4. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason were required, pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3, to certify
as correct and file with the Commission on April 15, 2010, a Report of Contributions and Expenditures
(Form R-1) as a 2010 first quarterly report for the 2009 municipal election, to report all contributions
received and expenditures made for the 2009 municipal election, for the period of time beginning January
1, 2010 though March 31, 2010 (hereafter, the 2010 first quarterly reporting period for the 2009
municipal election).
5. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason were required, pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3, 19:25-10.2
and 19:25-10.4 to certify as correct and report on April 15, 2010, on the 2010 first quarterly report for the

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 29 of 36

2009 municipal election, all contributions received during the 2010 first quarterly reporting period,
including all moneys, loans, paid personal services, or other things of value, including contributions of
goods and services (in-kind contributions), contributed to the Respondent Candidates during the 2010
first quarterly reporting period for the 2009 municipal election.
6. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason were required, pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3 and 19:2510.13, to certify as correct and file with the Commission on April 15, 2010, a 2010 first quarterly report
for the 2009 municipal election, and to report all contribution information, including the date of receipt
and amount of any loans received, and the name and mailing address of the lender. Where the lender was
an individual and for all currency contributions, the Respondent Candidates, Respondent de facto
Treasurer Garcia-Keim and Respondent de facto Treasurer Mason were also required to disclose the
individuals occupation, as well as the name and mailing address of the lenders employer.
7. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason violated N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3 and 19:25-10.13 by failing to
certify as correct and file on April 15, 2010, the 2010 first quarterly report for the 2009 municipal
election, and to report timely contribution information for the receipt of one loan in the amount of
$25,500.00, described in paragraph three of the Proposed Findings of Fact in this Count, above. The
Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de facto Treasurer
Mason reported contribution information relevant to the one loan in the amount of $25,500.00 on May 26,
2010, forty-one days after the April 15, 2010 due date for the 2010 first quarterly report for the 2009
municipal election.
8. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason are each subject to imposition by the Commission of the penalties prescribed by
N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which penalties may not be more than $6800.00 for

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 30 of 36

each reporting transaction, that is for each contribution which has not been reported in the manner or in
the time prescribed by the Act or Commission regulations.

COUNT THIRTEEN
PROPOSED FINDINGS OF FACT:
1. The Proposed Findings of Fact contained in Counts One through Twelve are repeated and
incorporated herein as if set forth in full below.
2. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason reported on May 26, 2010, on the 2010 first quarterly report for the 2009
municipal election, expenditure information for twenty-two expenditures totaling $366,714.41, as
follows:
a. for the first time on Schedule 1(D), Disbursements, thirteen expenditures totaling
$30,014.41, made, authorized or incurred during the 2010 first quarterly reporting period for the
2009 municipal election;
b. on Schedule E, Outstanding Obligations, one expenditure in the amount of $25,500.00,
made, authorized or incurred during the 2010 first quarterly reporting period for the 2009
municipal election;
c. on Schedule E, Outstanding Obligations, three expenditures totaling $90,000.00, made,
authorized or incurred during the 2009 third quarterly reporting period for the 2009 municipal
election, as described in paragraph two of the Proposed Findings of Fact contained in Count
Seven, above.
d. on Schedule E, Outstanding Obligations, four expenditures totaling $201,200.00, made,
authorized or incurred during the 2009 20-day postelection reporting period for the 2009
municipal election, as described in paragraph two (items b and c) of the Proposed Findings of
Fact contained in Count Five, above.

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 31 of 36

PROPOSED CONCLUSIONS OF LAW:


1. The Proposed Conclusions of Law contained in Counts One through Thirteen of this
Complaint are repeated and incorporated herein as if set forth in full below.
2. The Respondent de facto Treasurer, Ines Garcia-Keim, was at all times relevant to this Count,
the Respondent Candidates de facto campaign treasurer in the 2009 municipal election held on May 12,
2009, and was therefore subject to the requirements of the Act and Commission Regulations.
3. The Respondent de facto Treasurer, Richard G. Mason, was at all times relevant to this
Count, the Respondent Candidates de facto campaign treasurer in the 2009 municipal election held on
May 12, 2009, and was therefore subject to the requirements of the Act and Commission Regulations.
4. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason were required, pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3, 19:2510.13 and 19:25-12.2, to certify as correct and file with the Commission on April 15, 2010, on the 2010
first quarterly report for the 2009 municipal election, all expenditure information, including the date the
expenditure was made, the full name and address of the payee, the purpose of the expenditure, the amount
of the expenditure, and the number of the check for each expenditure transaction made, incurred or
authorized during the 2010 first quarterly reporting period for the 2009 municipal election.
5. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de
facto Treasurer Mason violated N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3, 19:25-10.13 and 19:25-12.2
by failing to certify as correct and file with the Commission on April 15, 2010, the 2010 first quarterly
report for the 2009 municipal election, and to report timely expenditure information relevant to thirteen
expenditures totaling $30,014.41, described in paragraph two (item a) of the Proposed Findings of Fact in
this Count, above. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and
Respondent de facto Treasurer Mason reported expenditure information relevant to the thirteen
expenditures totaling $30,014.41 on May 26, 2010, forty-one days after the April 15, 2010 due date for
the 2010 first quarterly report for the 2009 municipal election.

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 32 of 36

6. The Respondent Candidates, Respondent de facto Treasurer Garcia-Keim and Respondent de


facto Treasurer Mason are each subject to imposition by the Commission of the penalties prescribed by
N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which penalties may not be more than $6800.00 for
each reporting transaction, that is for each expenditure which has not been reported in the manner or in
the time prescribed by the Act or Commission regulations.

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 33 of 36

OPPORTUNITY FOR HEARING:


The Respondents and all parties shall have the opportunity to appear personally or by attorney at a
hearing pursuant to the Administrative Procedure Act, N.J.S.A. 52:14B-1 et seq., and to present evidence
and argument on all relevant issues. All parties shall have the opportunity to examine and cross-examine
witnesses. However, failure of the Respondents to file with the Commission a written answer within twenty
(20) days after service of this Complaint shall constitute a default and thereupon the Commission may enter a
Final Decision, including a penalty.
NEW JERSEY ELECTION LAW
ENFORCEMENT COMMISSION
BY: ________________________
CAROL L. HOEKJE
Legal Director
DATE: February 26, 2014
Elizabeth Mason, Candidate
CERTIFIED MAIL NO. 7009 3410 0001 8443 4862
RETURN RECEIPT REQUESTED
Raul Morales, Candidate
CERTIFIED MAIL NO. 7009 3410 0001 8443 4879
RETURN RECEIPT REQUESTED
Anthony Pasquale, Candidate
CERTIFIED MAIL NO. 7009 3410 0001 8443 4886
RETURN RECEIPT REQUESTED
Vincent Addeo, Candidate
CERTIFIED MAIL NO. 7009 3410 0001 8443 4893
RETURN RECEIPT REQUESTED
Edward M. Lombard, Campaign Treasurer
CERTIFIED MAIL NO. 7009 3410 0001 8443 4909
RETURN RECEIPT REQUESTED
Ines Garcia-Keim, de facto Campaign Treasurer
CERTIFIED MAIL NO. 7009 3410 0001 8443 4916
RETURN RECEIPT REQUESTED
Richard G. Mason, de facto Campaign Treasurer
CERTIFIED MAIL NO. 7009 3410 0001 8443 4923
RETURN RECEIPT REQUESTED

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 34 of 36

Exhibit A
Count Two

(A)
Item No.

(B)
Date

(C)
Contributor
Name

(D)
Contribution
Amount

(E)
Occupation

1.

5-07-09

Niall J. Murray

$2500.00

5-08-09

Matthew
Epstein

$1000.00

2.
3.

5-08-09

Randall W.
Brummette

$2600.00

Analyst

4.

5-08-09

Craig Zaveck

$500.00

SelfEmployed

5.

5-08-09

Edward A.
Zahos

$1000.00

Attorney

6.

5-08-09

Justin M.
Silverman

$500.00

Realtor

TOTAL:

$8100.00

Financial
Advisor

(F)
Employer Name and
Address
Rocabill Advisors
60 E. 42nd St., Suite 1822
New York, NJ 10162

Attorney
Natixis Capital Markets
9 West 57th St.
New York, NY 10019
64 West 11th LLC
333 River St.
Hoboken, NJ 07030
Edward Zahos
1220 Hudson St.
Hoboken, NJ 07030
R. De Ruggiero Real Estate
210 33rd. St.
Union City, NJ 07087

Exhibit B
Count Two
(A)
Item No.
1.

(B)
Date

5-04-09

(C)
Contributor
Name

(D)
Contributio
n Amount

Sara
Stojkovic

$2600.00

TOTAL:

$2600.00

(E)
Description
of In-kind
Contributions
Campaign
Expenses

(F)
Occupation
Mom

(G)
Employer Name
and Address

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 35 of 36

Exhibit C
Count Three
(A)
Item No.

(B)
Date

(C)
Contributor
Name

(D)
Contribution
Amount

(E)
Aggregate
Amount

1.

5-01-09

Elizabeth
Mason

$50,000.00

$150,000.00

Management
Consultant

2.

5-07-09

Elizabeth
Mason

$1200.00

$151,200.00

Management
Consultant

3.

5-11-09

Elizabeth
Mason

$50,000.00

$201,200.00

Management
Consultant

Sara Stojkovic

$2636.59

$2636.59

Mom

TOTAL:

$103,836.59

4.

(F)
Occupation

(G)
Employer Name and
Address
Elizabeth Mason
921 Hudson Street
Hoboken, NJ 07030
Elizabeth Mason
921 Hudson Street
Hoboken, NJ 07030
Elizabeth Mason
921 Hudson Street
Hoboken, NJ 07030

Exhibit D
Count Six
(A)
Item No.

1.

(B)
Date

6/10/2009

(C)
Contributor
Name

(D)
Contribution
Amount

Edwin N.
Ordway

$4600.00

TOTAL:

$4600.00

(E)
Occupation
Financial
Consultant

(F)
Employer Name and Address
Capstone Advisory Group, LLC
Park 80 West PL 1
Saddle Brook, NJ 07663

ELEC v. Elizabeth Mason, Raul Morales, Anthony Pasquale and Vincent Addeo, and Edward M. Lombard,
Campaign Treasurer, and Ines Garcia-Keim and Richard G. Mason, de facto Campaign Treasurers
C-G 0905 05 04-M2009, C-9 0905 15 04-M2009, C-9 0905 17 04-M2009, C-9 0905 08 04-M2009
Page 36 of 36

Exhibit E
Count Seven
(A)
Item No.

(B)
Date

(C)
Contributor
Name

(D)
Contribution
Amount

(E)
Aggregate
Amount

1.

(F)
Occupation

6/09/2009

Elizabeth
Mason

$50,000.00

$336,700.00

Management
Consultant

2.

7/27/2009

Elizabeth
Mason

$20,000.00

$336,700.00

Management
Consultant

3.

9/03/2009

Elizabeth
Mason

$20,000.00

$336,700.00

Management
Consultant

TOTAL:

$90,000.00

(G)
Employer Name and
Address
Elizabeth Mason
921 Hudson Street
Hoboken, NJ 07030
Elizabeth Mason
921 Hudson Street
Hoboken, NJ 07030
Elizabeth Mason
921 Hudson Street
Hoboken, NJ 07030

Exhibit F
Count Ten
(A)
Item No.

(B)
Date

1.

10/26/2009

(C)
Contributor
Name

(D)
Contribution
Amount

(E)
Aggregate
Amount

Elizabeth
Mason

$20,000.00

$336,700.00

TOTAL:

$20,000.00

(F)
Occupation
Management
Consultant

(G)
Employer Name and
Address
Elizabeth Mason
921 Hudson Street
Hoboken, NJ 07030

Exhibit G
Count Twelve
(A)
Item No.

(B)
Date

1.

1/19/2010

(C)
Contributor
Name

(D)
Contribution
Amount

(E)
Aggregate
Amount

Elizabeth
Mason

$20,000.00

$336,700.00

TOTAL:

$20,000.00

(F)
Occupation
Management
Consultant

(G)
Employer Name and
Address
Elizabeth Mason
921 Hudson Street
Hoboken, NJ 07030