FEDERAL ELECTION COMMISSION

In the matter of:

The Arizona Sports Foundation (db a "the Fiesta Bowl")

John H. Junker

Susan Junker

Natalie Aguilar Wisneski Richard Wisneski Anthony Aguilar

Jay Fields

Jamie Fields

Shawn Schoeffler

Peggy Eyanson

Lee Eyanson

Mary McGlynn

Monica Simental

Scot Asher

MURNo.

COMPLAINT

1. Citizens for Responsibility and Ethics in Washington ("CREW") and Melanie

Sloan bring this complaint before the Federal Election Commission ("FEC") seeking an

immediate investigation and enforcement action against the Arizona Sports Foundation (dba "the

Fiesta Bowl"), John H. Junker, Susan Junker, Natalie Aguilar Wisneski, Richard Wisneski,

Anthony Aguilar, Jay Fields, Jamie Fields, Shawn Schoeffler, Peggy Eyanson, Lee Eyanson,

Mary McGlynn, Monica Simental and Scot Asher for direct and serious violations of the Federal

Election Campaign Act ("FECA").

Complainants

2. Complainant CREW is a non-profit corporation, organized under section

501(c)(3) of the Internal Revenue Code. CREW is committed to protecting the right of citizens

to be informed about the activities of government officials and to ensuring the integrity of

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government officials. CREW is dedicated to empowering citizens to have an influential voice in government decisions and in the governmental decision-making process. CREW uses a combination of research, litigation, and advocacy to advance its mission.

3. In furtherance of its mission, CREW seeks to expose unethical and illegal conduct

of those involved in government. One way CREW does this is by educating citizens regarding the integrity of the electoral process and our system of government. Toward this end, CREW monitors the campaign finance activities of those who run for federal office and publicizes those who violate federal campaign finance laws. Through its website, press releases and other methods of distribution, CREW also files complaints with the FEC when it discovers violations of the FECA. Publicizing campaign finance violators and filing complaints with the FEC serves CREW's mission of keeping the public informed about individuals and entities that violate campaign finance laws and deterring future violations of campaign finance law.

4. In order to assess whether an individual, candidate, political committee or other

regulated entity is complying with federal campaign finance law, CREW needs the information contained in receipts and disbursements reports that political committees must file pursuant to the FECA, 2 U.S.C. § 434(a)(2); 11 C.F.R. § 104.1. CREW is hindered in its programmatic activity when an individual, candidate, political committee or other regulated entity fails to disclose campaign finance information in reports of receipts and disbursements required by the

FECA.

5.

CREW relies on the FEC's proper administration of the FECA's reporting

requirements because the FECA-mandated reports of receipts and disbursements are the only source of information CREW can use to determine if a candidate, political committee or other regulated entity is complying with the FECA. The proper administration of the FECA's

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reporting requirements includes mandating that all reports of receipts and disbursements required by the FECA are properly and timely filed with the FEC. CREW is hindered in its programmatic activity when the FEC fails to properly administer the FECA's reporting requirements.

6. Complainant Melanie Sloan is the executive director of Citizens for

Responsibility and Ethics in Washington, a citizen of the United States and a registered voter and resident of the District of Columbia. As a registered voter, Ms. Sloan is entitled to receive information contained in reports of receipts and disbursements required by the FECA, 2 U.S.C. § 434(a)(2); 11 C.F.R. § 104.1. Ms. Sloan is harmed when a candidate, political committee or other regulated entity fails to report campaign finance activity as required by the FECA. See FEC v. Akins, 524 U.S. 11, 19 (1998), quoting Buckley v. Valeo, 424 U.S. 1, 66-67 (1976) (political committees must disclose contributors and disbursements to help voters understand who

provides which candidates with financial support). Ms. Sloan is further harmed when the FEC fails to properly administer the FECA's reporting requirements, limiting her ability to review campaign finance information.

Respondents

7. The Arizona Sports Foundation (dba "the Fiesta Bowl") is a 501(c)(3)

organization with its principal place of business in Arizona.

8. John H. Junker is the former President and Chief Executive Officer of the Fiesta

Bowl. Susan Junker is the spouse of John H. Junker.

9. Natalie Aguilar Wisneski is the former Chief Operating Officer of the Fiesta

Bowl. Richard Wisneski is the spouse of Natalie Aguilar Wisneski. Anthony Aguilar is the former Director of Community and Corporate Relations for the Fiesta Bowl and the brother of Natalie Aguilar Wisneski.

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10. Jay Fields is the former Senior Vice President of Marketing for the Fiesta Bowl.

Jamie Fields is the spouse of Jay Fields.

11. Shawn Schoeffler is the former Vice President of Media Relations for the Fiesta

Bowl.

12. Peggy Eyanson is the former Director of Business Operations for the Fiesta

Bowl. Lee Eyanson is the spouse of Peggy Eyanson.

13. Mary McGlynn is the former Director of Ticket Operations for the Fiesta Bowl.

14. Monica Simental is the former Executive Assistant to Natalie Aguilar Wisneski.

15. Scot Asher was a former volunteer at the Fiesta Bowl.

Factual Allegations

16. On October 8, 2010, the Board of Directors of the Fiesta Bowl authorized a

Special Committee of the Board of Directors to conduct an investigation of allegations that the Fiesta Bowl had reimbursed employees for campaign contributions made to Arizona politicians. The Special Committee retained the firm of Robins, Kaplan, Miller & Ciresi LLP to conduct the investigation. On March 21,2011, after a comprehensive investigation, Robins, Kaplan Miller & Ciresi LLP released its Final Report to the Special Committee of the Board of Directors of the Fiesta Bowl (attached as Exhibit A). The Final Report concluded that, under the direction of President and Chief Executive Officer John H. Junker, the Fiesta Bowl had used corporate funds to reimburse twenty-one individuals for at least $46,539 in campaign contributions to Arizona politicians since 2000. See Exhibit A at 25-67.

17. The Final Report demonstrated that a majority of these contributions ($28,500)

had been made to federal candidates and committees since January 1,2006. Specifically, the Final Report found evidence that the Fiesta Bowl, under the direction of President and Chief

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Executive Officer John H. Junker, had used corporate funds to reimburse thirteen individuals for
the following campaign contributions to federal candidates and committee since January 1,2006:
Name Date Amount Recipient

John H. Junker 4/28/06 $1,000 Straight Talk America
John H. Junker 3/8/07 $2,100 John McCain
John H. Junker 6/30/09 $1,000 John McCain
Susan Junker 6116/06 $500 Jon Kyl
Susan Junker 10/18/06 $1,500 J.D. Hayworth
Susan Junker 3/8/07 $2,100 John McCain
Natalie Aguilar Wisneski 4/28/06 $1,000 Straight Talk America
Natalie Aguilar Wisneski 3/8/07 $2,100 John McCain
Natalie Aguilar Wisneski 6/30/09 $1,000 John McCain
Richard Wisneski 3/8/07 $2,100 John McCain
Anthony Aguilar 2/23/06 $500 Jon Kyl
Anthony Aguilar 5/3/06 $250 John Shadegg
Jay Fields 10/18/06 $600 J.D. Hayworth
Jay Fields 3/28/08 $1,000 John McCain
Jamie Fields 4/28/06 $1,000 Straight Talk America
Shawn Schoeffler 10118/06 $600 J.D. Hayworth
Shawn Schoeffler 3/28/08 $1,000 John McCain
Shawn Schoeffler 6/30/09 $1,000 John McCain
Peggy Eyanson 6/16/06 $1,500 Jon Kyl
Peggy Eyanson 10118/06 $1,250 J.D. Hayworth GENBUS1797504.1

Lee Eyanson 5/6/06 $500 John Shadegg
Lee Eyanson 3/28/08 $1,000 John McCain
May McGlynn 4/28/06 $1,000 Straight Talk America
Monica Simental 10/18/06 $300 J.D. Hayworth
Monica Simental 3/8/07 $2,100 John McCain
Scot Asher 2/23/06 $500 Jon Kyl
Id. 18. The Final Report also found that the Fiesta Bowl used corporate resources and

facilities to host fundraising events for federal candidates and committees. Specifically, the Final Report found that Fiesta Bowl employees organized fundraising events for federal candidates and committees at the Fiesta Bowl Museum, coordinated invitation lists, set up the Museum, attended and helped out during the events, and provided contributions that were later reimbursed by the Fiesta Bowl. See Exhibit A at 183-186.

19. The Final Report found that the Fiesta Bowl used corporate resources and

facilities to host a fundraising event for Rep. J.D. Hayworth (R-AZ) on or about October 18, 2006. See Exhibit A at 185-186. On information and belief, the Fiesta Bowl also used corporate resources to organize a fundraising events for Straight Talk America on or about April 28, 2006 and two fundraising events for Senator John McCain (R-AZ) on or about March 8, 2007 and March 28,2008. See Exhibit A at 185, n. 974.

COUNT I

20. FECA and FEC regulations prohibit the making of a contribution in the name of a

person other than the true source of the contribution. 2 U.S.C. § 441f; 11 C.F.R. § 110.4(b)(1)(i).

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21. By reimbursing employees for contributions made to federal candidates and

committees, the respondents violated 2 U.S.C. § 44lf and 11 C.F.R. § 110.4(b)(I)(i).

COUNT II

22. FECA and FEC regulations prohibit corporations from making contributions in

connection with any federal election. 2 U.S.C. § 441b(a) and 11 C.F.R. § 114.2(a). FEC

regulations also specifically prohibit the use of corporate resources or facilities to engage in

fundraising activities for federal candidates and committees. 11 C.F.R. § 114.2(£).

23. By reimbursing employees and others with corporate funds for contributions

made to federal candidates and committees and by using corporate resources and facilities to

raise funds for federal candidates and committees, the respondents violated 2 U.S.C. § 441b(a),

11 C.F.R. § 114.2(a) and 11 C.F.R. § 114.2(£).

CONCLUSION

WHEREFORE, Citizens for Responsibility and Ethics in Washington and Melanie Sloan

request that the Federal Election Commission conduct an investigation into these allegations,

declare the respondents to have violated the Federal Election Campaign Act and applicable FEC

regulations, and impose sanctions appropriate to these violations and take such further action as

may be appropriate, including referring this case to the Justice Department for criminal prosecution of any violations of2 U.S.C. §§ 441 b(a) ~

MdSkall

Executive Director

Citizens for Responsibility and Ethics

in Washington

1400 Eye Street, N.W. Suite 450

Washington, DC 20005 (202) 408-5565 (phone) (202) 588-5020 (fax)

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Verification

Citizens for Responsibility and Ethics in Washington and Melanie Sloan hereby verify

that the statements made in the attached Complaint are, upon information and belief, true.

01.

Melanie Sloan

Sworn to and subscribed before me this 5th day of April, 2011.

LIsa Drew

District of Columbia, Notary Publie My Commission Expires July 31. 2014

N0t8X1" Public

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