April 12, 2017

Risa S. Sugarman, Esq.

Chief Enforcement Counsel
Division of Election Enforcement
NYS Board of Elections
40 North Pearl Street
Albany, New York 12207

Re: Warren For A Strong Rochester PAC (Filer #A21061), Friends of Lovely
Warren, (Filer #C21714)

Dear Ms. Sugarman:

Please permit this letter to serve as a formal complaint regarding what are
believed to be improper campaign and political action committee financial disclosure
filings on behalf of the committees named above. It is respectfully requested that your
office conduct an investigation pursuant to your powers under the Public Trust Act and
corresponding Election Law provisions into the financial activities of these entities.

Certain conduct of these entities reported to have taken place warrants

immediate inquiry. The issue discussed below is illustrative of various Election Law
violations but is not intended to be exhaustive. These entities are registered with the
State as Rochester Mayoral candidate Lovely Warrens Authorized Committee
(#C21714) hereinafter Friends of Lovely Warren and a Political Action Committee
(#A21061) hereinafter Warren PAC. Respectfully, it is requested that the following
information warrants investigation:

Upon information and belief, the two organizations maintain common operational
control with the same individuals exercising actual and strategic control over the day to
day activities of both organizations. Both of the organizations are authorized by the
same candidate operating in the same election cycle. It is fair to assume that the two
entities are, therefore, created with the intended purpose of ensuring Lovely Warrens
efforts to become re-elected as Mayor of the City of Rochester.
Risa S. Sugarman, Esq.
April 12, 2017
Page 2

It is believed that the Friends of Lovely Warren has received from the Warren
PAC goods, services and funds well in excess of what is permissible. Since her first
election as Mayor, Warren has authorized an annual event known as The Mayors
Ball. The event raises many thousands of dollars each year. It is routinely held in the
month of February, and forms the basis for this complaint.

In 2015, the event was believed to have been organized and funded by Friends
of Lovely Warren. The contributions from the event were, as well, received by Friends
and retained by it.

In 2016, however, the Warren PAC conducted The Mayors Ball, funded it and
received the revenue from it. Schedule F to the PAC financial disclosure for 2016
reveals expenditures to various event vendors including the Rochester Riverside
Convention Center, Accelerated Mailing Services and Panther Graphics.
Correspondingly, the attendees contributions were retained by the Warren PAC in
2016.

The following year, on February 25, 2017, the event was once again held, but at
that time, the expenditures and proceeds were processed by Friends of Lovely Warren.
The amounts attributable to the event were again in the many tens of thousands of
dollars.

It is indisputable that The Mayors Ball is and has been an event designed to
raise money for Ms. Warrens re-election campaign. The 2016 event website states:

A Note From Mayor Lovely Warren -

The Mayors Ball is my annual fundraising event. As we celebrate

Rochesters accomplishments, this gathering raises money to support
my vision for Rochester and my re-election campaign (see attached).

The 2017 Mayors Ball website language is similar, stating contributions will be
used in connection with an election. The event announcement solicits not only
monetary contributions but campaign volunteers, rides to the election polls and lawn
sign locations.

It is apparent, therefore, that Ms. Warren is permitting the two committees to act
interchangeably as vehicles to conduct campaign activity in violation of the NYS
Election Law. The value of funds, goods and services received by Friends of Lovely
Warren from the Warren PAC from the event well-exceeds the amount permissible
under controlling law.
Risa S. Sugarman, Esq.
April 12, 2017
Page 3

Time is of the essence and it is respectfully requested that your office perform a
prompt investigation, with the awareness that any impermissible conduct is ongoing and
may have significant consequences in the September 2017 primary election.
Accordingly, it is requested that a directive be issued by the Board of Elections requiring
immediate disgorgement of funds and cessation of further prohibited transactions.

Thank you for your attention to this matter.

Very truly yours,

James A. Sheppard