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Campaign Finance Complaint Form Michigan Department of State This complaint form may be used to file a complaint alleging that someone violated the Michigan Campaign Finance Act (the MCFA, 1976 PA 388, as amended; MCL 169.201 et seq.). All information on the form must be provided along with an original signature and evidence. Please print or type all information. allege that the MCPA was violated as follows: eccone Con eat F Your Nae Wing Rares 215 S. Washington Sq, suite 135 a Lansing See er 2 48933 Name Bill Sehuette pean 525 W. Ottawa St., P.O. Box 30212 oe Lansing Sao Mr Ze 58909 Spettong) or be MCTA vita MCL 169.257 ‘eplaln how thse sections wore ilate Ag detailed in a December 15, 2017 Detroit Free Press story (Exhibit 1) Schuette has used millions of dollars in public resources to pay persons as employees 6r contractors who have worked on his Attorney General campaigns and are working on his gubernatorial campaign, Public resources are being used by Schuette to help pay for his campaign staff. [vidence that supports thou legions tach copie of etnent document deer infomation): | Section 4. certify that to the best of my knowledge, information, and belief, formed after a reasonable inguiry under the circumstances, each factual contention of this complaint is supported by evidence. aC f= St Wel Signa Copan i ction 15(6) of the MCFA (MCL 169.215) requires that the signed certification found in section 4 of this form be included in every complaint. However, if, ater a reasonable inquiry under the circumstances, you are unable to certify that certain factual contentions are supported by evidence, you may also make the following certification: Leertify that to the best of my knowledge, information, or belief, there are grounds to conclude that the following specifically identified factual contentions are likely to be supported by evidence after a reasonable ‘opportunity for further inquiry. Those specific contentions are: x Tiga of Compa Baie Section 15(8) of the MCFA provides that a person who files a complaint with a false certification Is responsible for a civil violation of the MCFA. The person may be required to pay a civil fine of up ‘0 $1,000.00 and some or all of the expenses Incurred by the Michigan Department of State and the alleged violator as a direct result of the filing of the complaint. ‘Mail or deliver the completed complaint form with an original signature and evidence to the following address: ‘Michigan Department of State ‘Bureau of Elections Richard H, Austin Building — 1st Floor 430 West Allegan Street Lansing, Michigan 48918 Revised: 16 COMPLAINT PROCESS ‘Section 15 of the MCFA governs the filing and processing of complaints. If you believe someone has violated the MCFA, you may file a written complaint. The complaint must include all of the following: ‘Your name, address and telephone number. ‘The alleged violator’s name and address, A description in reasonable detail of the alleged violation, including the section or sections of the MCFA you believe were violated, an explanation of how you believe the ‘MCFA was violated, and any other pertinent information. Evidence which supports your allegations. A cettification that: To the best of your knowledge, information, and belief, formed after a reasonable inquiry under the circumstances, each factual contention of the complaint is supported by evidence, If after a reasonable inquiry under the circumstances, you are unable to certify that certain specifically identified factual contentions of the complaint are supported by evidence, you may also certify that: To the best of your knowledge, information, or belief, there are grounds to conclude that those specifically identified factual contentions are likely to be supported by evidence after a reasonable opportunity for further inquiry. ‘Your signature immediately after the certification or certifications. WARNING: Seaton 15(8) of the MCFA (MCL 169.215) provides hal a person who files « complaint with a false certification is responsible for a civil violation ofthe MFA. Under section 15(16) of the MCFA (MCL 169.215), the Secretary of State may requite a porson who files 9 complaint with a false certification to: + Pay the Department some oral ofthe expenses incurred by the Department as a iret result ofthe filing ofthe complain, + Pay the alleged violator some ar all ofthe expenses, inchuding, but not limited to, reasonable attorney fes, incurred by that person as a direct result of the filing ofthe complaint, + Paya civil fine of upto $1,000.00 ‘A compliant may be dismissed if any required information is not included, or if the complaint is determined to be frivolous, illegible, or indefinite. All patties are notified of dismissed complaints ‘When a complaint meets the above requirements, the Department notifies the alleged violator that a complaint has been filed and provides a copy of the complaint, The alleged violator will have an opportunity to file a response. The compliant filer will have an opportunity to file a rebuttal to any response. All parties receive periodic reports concerning the actions taken by the Department on a complaint. If the Department finds no reason to believe that the allegations are true, the complaint will be dismissed, If the Department finds that there may be reason to believe your allegations are true, the Department must attempt to correct the violation or prevent further violations by informal methods such as a conference, conciliation, or persuasion, and may enter into a conciliation agreement with the alleged violator. Ifthe Department is unable to correct the violation or prevent further violations informally, an administrative hearing may be held to determine whether a civil violation of the MCFA has occurred, or the matter may be referred to the Attorney General for the enforcement of criminal penalties. An administrative hearing could result in the assessment of a civil penalty. Such a ‘hearing would be conducted in accordance with the Michigan Administrative Procedures Act. An order issued as a result of such a hearing may be appealed to the appropriate cireuit court, Accepted complaints and all supporting documentation including responses and rebuttal statements are made available on the Department's website as required by the MCFA at the conclusion of the process. Questions? Contact us at: Michigan Department of State Bureau of Elections Richard H. Austin Building ~ 1st Floor 430 West Allegan Street Lansing, Michigan 48918 Phone: 517-373-2540 Email: Disclosure@Michigan gov EXHIBIT 1 Bill Schuette stocks AG staff with GOP operatives as he launches campaign for governor Phu fignn, Detroit Free PressPuished 6:44 4m, BT Dec. 15, 2017) Updated $: IT Dec. 16,2007 LANSING — Michigan Attorney General Bill Schuette has loaded his taxpayer-funded office payroll with Republican campaign activists in the run-up to his 2018 campaign for governor, a Free Press investigation has found. ‘Schuette also has used no-bid state contracts to pay more than $130,000 to two influential Republicans — one of whom has been active in the tea party movement that is important in winning a Republican primary, records show. ‘The state constitution and civil service rules prohibit hiring or firing employees based on partisan considerations, enshrining the idea that a professional state workforce based solely on merit should remain in place, regardless of what party or leader is in power. But this year, in advance of his September announcement that he is running for governor, ‘Schuette hired as civil servants four "constituent relations representatives," also known as “executive office representatives,” who are all Republican activists or experienced GOP campaign operatives, records obtained under Michigan's Freedom of Information Act show. ‘They joined other highly politicized appointees and civil servants on Schuette's executive staff, all paid for by taxpayers. They include Schuette's driver, a political appointee who is paid more than $82,000 a year as a "special assistant" but doubles as Schuette's ‘campaign treasurer, and two others with civil servant posts — a self-described "tea party organizer" and another constituent relations representative who was political director for Schuette's 2014 attomey general campaign and recently took a leave of absence to ‘work fulltime on his campaign for governor. ‘Schuette's executive office representatives are responsible for public outreach, giving speeches to service clubs and community groups, educating people about the department's programs and trouble-shooting issues raised by constituents, according to ‘Schuette spekeswoman Andrea Bitely and department records. ‘Schuette's two predecessors — Republican Attorney General Mike Cox and Democratic Attorney General Jennifer Granholm — did not have these positions, though Cox had a director of constituent relations near the end of his eight years in office, state records show. mi gan Attorney General Bil Schuette of Midland announces his gubernatorial campaign Tuesday, Sept. 12, 2017, at the tidland County Falrgrounds in Midland. (Photo: Katy Kidse, Midland Daily News vie AP) “That's @ Bill Schuette thing ... making sure we have people out there who are listening," Schuette spokeswoman Andrea Bitely said. “Receive rather than broadcast," she said. "These people aren't hired because of their partisan politics. They're hired because they'te the best and brightest." Schuelte's recently hired constituent relations representatives, positioned in attorney general offices around the state, are: «+ Judi Schwalbach: Hired in May as a constituent relations representative at about $50,000 a year, the former Escanaba mayor is an influential Republican in the Upper Peninsula who was a delegate to last year's Republican National Convention and attended President Donald Trump's inauguration. A member of the Republican State Committee, she works ‘out of the attomey general's Marquette office. ‘+ Luke Londo: Also hired in May, Londo, a $82,000-a-year constituent relations representative, was digital director for the 2014 campaign of U.S. Rep. Dan Benishek, R-Crystal Falls, and * a former regional press secretary for the Michigan Republican Party. He works in the attorney general's Detroit office, « Michael Sullivan: Hired in May as a $45,000-2-year constituent relations representative, Sullivan was coordinator of the 2014 state House campaign of Rep. Lee Chatfield, R- Levering, and has worked for a political consulting firm owned by Scott Greenlee, a former ‘Schueite aide and campaign worker. He works in Lansing. + Brandon Sinclair: Hired in March as a $35,000-2-year constituent relations representative, Sinclair is @ former political coordinator for the Kent County Republican Party who ‘managed the 2016 campaign of state Rep. Tommy Brann, R-Wyoming. He works in Grand Rapids. A report fled in October shows Schwalbach, Sullivan and Sinclair were all paid expense reimbursements this year by Bill Schuette for Governor, meaning each has been working on his campaign, ‘Schuette was unapologetic Dec, 6, when a reporter pointed out that his executive office representatives were Republican activists and Schuette supporters. “They better be, or they/re not going to be working for me," he said ‘Schuette, who took office in 201 1, softened his answer when asked whether that wouldn't violate civil service rules. "You don't have to be a Republican, but you'd better have a relationship with Bill Schuette, or | wouldn't hire those people," he said. "I need to trust them, and | do." Bitely said nobody does campaign work on state time, which would violate state law. “I can't speak to what people are doing in their spare time,” Bitely said. Carter Bundy, a former field director for Michigan native Mitt Romney's presidential bid, illustrates the sometimes fluid relationship between Schuette's campaign and his state- funded office. Andrea Bitely Photo: Paul Egan/Detroi Free Press) Bundy served as political director for Schuette's 2014 attorney general campaign — receiving close to $62,000 in wages and expense reimbursements from Schuette's ‘campaign fund — while taking unpaid leave from his then $40,000--year civil service job ‘as a constituent relations representative forthe attomey general's office. Bundy, who returned to his full-time job after the campaign, recently took a leave of absence from his now $74,000-a-year job so he can work full-ime on Schuette's gubernatorial campaign. J. Edward Kellough, a professor of public administration at the University of Georgia and ‘an expert on civil service reform, said the situation in Schuette's office sounds unusual “There has been a trend in recent years to increasingly politicize the civil ser said in an e-mail Thursday. “I find that a very troubling trend that can under Integrity of the civil service.” ." Kellough ine the Bitely said the job openings were posted on the state website and a committee of departmental officials followed civil service rules by not asking candidates about political affiliations during interviews. While the vast majority of attorney general employees are supposed to be hired based solely on merit, without considering their partisan politics, Schuette is allowed up to five appointees who are not subject to civil service rules and serve at his pleasure, Duties of those officials also overlap with Schuette campaigns. Dennis Stamer, Schuette's driver and longtime friend and sounding board, is paid more than $82,000 a year as a “special assistant,” but has another role that is arguably of equal or greater importance. Stamer, a former chairman of the Midland County Republican Party, handles the accounting of millions in campaign donations and expenditures as Schuette's campaign treasurer. “Buy Photo Rusty Hills, oft, senior advisor to Bill Schuette and Michigan Attorney General Bil Schuette during an interview at the Free Press office in Detroit in June 2017. Photo: Juntu Han, Detroit Free Press) Schuette's other appointees include Rusty Hills, and John Seliek. Hills, who eams more than $157,000 a year as Schuette’s director of public affairs, was paid about $93,000 for his work on the 2010 campaign and has received more than $1,300 in campaign expense reimbursements since Schuette took office. Sellek, who is paid more than $153,000 as ‘Schuette's director of public relations, took an unpaid leave during the 2014 campaign and thas received about $95,000 in campaign consulting fees and expense reimbursements since 2013. ‘The four new constituent relations representatives joined civil servants already serving in ‘Schuette's executive office in Lansing, who records show have worked on his attorney general or gubernatorial campaigns, including: + Wendy Anderson: The supervisor of Schuette's constituent relations representatives, ‘Anderson, a frequent donor to Republican candidates and causes who has also listed her ‘occupation as owner of a GOP campaign consulting firm called Election Resources, has worked for Schuette since he took office and is paid about $95,000 a year. ‘+ Sharon Lolli: Pald about $81,000 as Schuette's deputy director of legislative relations, Lollio's Facebook page desoribes her as a “tea party organizer.” She joined Schuette's office in 2011. {n rejecting suggestions that Schuette's work is driven by partisan interests, Bitely noted Schuette has worked closely with Genesee County Prosecutor David Leyton — a Democrat who ran against Schuette in 2010 — in prosecuting alleged crimes arising from the Flint water crisis. ‘Though having four constituent relations representatives in the attomey general's office is unique to Schuette, and the recently hired employees are new, the positions themselves fare not. At least four GOP activists who worked for Schuette during his 2014 campaign for attorney general have since left their constituent relations positions. They are: ‘+ Scott Greenlee: The president of Greenlee Consulting and the Michigan director of Sen. John McCain's 2008 presidential campaign, Greenlee, who left Schuette's office in 2016, was an $89,000-a-year constituent relations representative who received close to $7,400 in consulting fees and expense reimbursements from Schuette’s campaign fund between 2010 and 2015. Greenlee stood out among Schuette insiders as an early supporter of Gov. Rick Snyder, who has frequently been at odds with Schuette and is not expected to endorse him for governor. + Matt Hall: Schuette's former constituent relations representative in Grand Rapids was paid about $77,000 a year when he left in 2016, He is a Republican State Committee member and was 3rd Congressional District chairman of the Trump presidential campaign. Records show he worked on Schuette's 2014 campaign. ‘+ Shannon Price: A former Republican Wayne County commissioner and Plymouth Township supervisor, Price was paid about $87,000 a year as a Schuette constituency relations representative in Lansing and Detroit until he left the office in 2018. He earlier served as a political appointee to both Schuette and his predecessor, Cox, before moving to the civil service late in 2011 + Stanley Grot; Now a Republican candidate for Secretary of State, Grot was an attomey general executive office representative under Schuette until February 2012, when he launched his successful campaign for Shelby Towmship clerk, records show. Grot, a GOP district chair, is a former Sterling Heights city councilman and Macomb County ‘commissioner. Records obtained under FOIA show that since 2011, Schuette has awarded a series of contracts to Glenn Clark, a former president of the Michigan Faith and Freedom Coalition, a former Michigan GOP district chair who was an Oakland County tea party activist. The contracts, each worth between $25,000 and $50,000, are for making presentations related to Schuette's programs on Internet safety, protections for seniors, and the OK2SAY student safety initiative, records show. Bitely said the total amount paid to Clark under the contracts was just under $117,000, Though the contracts weren't awarded through competitive bidding, which Bitely said was Not required, interested vendors had to submit a résumé and/or cover letter and be Interviewed by Schuette's consumer protection team, "We are interested in candidates who are comfortable with technology and speaking In front of an audience,” as well as "diversity in terms of geographic location, race, and gender,” she said, Most of the 36 current contractors are former educators, she said. : Clark, who is supporting Schuette for governor, said Schuette's office felt his experience organizing school fund-raising projects with Nestlé was a benefit in arranging appointments {for presentations in schools, Clark said Wednesday he left the Faith and Freedom Coalition in 2013 and doesn't currently have time for tea party activities because he is caring for his 99-year-old grandmother, ‘Schwalbach, the former Escanaba mayor, received just under $14,000 through si contracts before Schuette hired her as a civil servant this year, Bitely said. : Contact Paul Egan: 517-372-8660 or Follow him on Twitter @paulegand