S TA T E OF CA L IF OR NI A

FAIR POLITICAL PRACTICES COMMISSION

1102 Q Street • Suite 3000 • Sacramento, CA 95811

October 21, 2019

Andrew Liebich

Re: Complaint No. COM-09142019-01799; Austin Bennett, PanRecall2.org

Dear Mr. Liebich,

This letter is in response to the sworn complaint you submitted to the Enforcement Division of the
Fair Political Practices Commission regarding the above-named individual and entity.

Under the Political Reform Act, a person or group of persons who raise or spend $2,000 or more for
a recall attempt qualifies as a recipient committee under Section 82013 when the target officer is
served with a notice of intent to recall1. Based on a review of the complaint, the documentation you
provided, and information provided by Mr. Bennett, the Enforcement Division found insufficient
evidence that the $2,000 committee qualification threshold has been met. Once the group reaches
the $2,000 threshold, it will incur filing obligations2.

At present, we have found insufficient evidence of a violation of the Political Reform Act, and we
will not pursue an enforcement action in this matter. If you have any questions, please contact
Ginny Lambing at 916-322-8064 or glambing@fppc.ca.gov.

Sincerely,
GWest
Galena West
Chief, Enforcement Division

GW:gal

Cc: Austin Bennett

Karen Klinger

1
Regulation 18531.5(c)(3)
2
Section 82013(a)