September 7, 2022

Friends of Joe Blystone

c/o Josh Brown, Esq.
5086 N. High St., Suite A
Columbus, Ohio 43214

Good afternoon Mr. Brown,

Thank you for your Proposition for Resolution regarding the Ohio Elections Commission
(“Commission”) cases against the Friends of Joe Blystone, Joe Blystone, and Jane Blystone, as
Treasurer. While the Complaint from the Secretary of State’s office was not filed at the time of
your original attempt to settle, it appears you are seeking to settle our Complaint 1 under your
original offer of $20,000.

We believe that offer is wholly insufficient given the flagrant and continual disregard for the
basic requirements of campaign finance reporting. Particularly considering the Friends of Joe
Blystone committee, including Joe Blystone himself, contacting our office multiple times when
the committee was first organizing to discuss the particulars of campaign finance reporting,
only to then knowingly disregard the guidance provided.

Your settlement offer’s comparison to the Commission’s case involving the Committee to
Elect Allen Freeman misstates the Commission’s ruling. The Commission did not levy a fine
based on a percentage of the misreported contributions. Instead, the Commission assessed
the maximum fine allowable by law. 2

There are two cases that more similarly align with Mr. Blystone’s blatant neglect for campaign
finance law, although both prior candidates’ actions are likely less egregious than the
disregard for transparency shown here. In State of Ohio v. John A. Clark Jr, 3 the candidate
reported receiving four contributions on a single report that he did not receive. His single
count of election falsification resulted in a jail sentence of 120 days, 250 hours of community
service, and 5 years of probation. In State of Ohio v. Trevor Elkins, 4 the candidate was alleged

1
Friends of Joe Blystone, OEC No. 2022S-002.
2
Committee to Elect Allen Freeman, OEC No. 2020G-019 (Dec. 16, 2021).
3
State of Ohio v. John A Clark Jr, Franklin County C.P. No. 20 CR 005890 (July 18, 2022).
4
State of Ohio v. Trevor Elkins, Cuyahoga County C.P. No CR-22-668764-A (June 21, 2022).
to have failed to track and report campaign funds leading to a jail sentence of 30 days, 200
hours of community services, one year of probation, and a $3,000 fine.

Considering the precedent and the egregious nature of the violations committed in this
matter, our office intends to ask the Commission to refer the evidence for prosecution. As an
alternative to that request for referral, this office would consider an agreement to the
following terms:

• The Friends of Joe Blystone committee must acknowledge in a filing with the
Commission its intentional failing to track and report contributions in violation of Ohio
law;
• The Friends of Joe Blystone committee must pay any outstanding obligations of the
committee as of the date of this correspondence, excluding personal or business loans
or debts owed to Joe Blystone, Jane Blystone, or any business associated with either,
which are instead forgiven;
• The Friends of Joe Blystone committee must pay all remaining funds of the Friends of
Joe Blystone to the Commission;
• The Friends of Joe Blystone committee must request that the Commission terminate
the Friends of Joe Blystone committee; and
• Joe Blystone agrees to not seek public office in the state of Ohio for a period of at least
four years from the date of the signed agreement.

If the Friends of Joe Blystone committee acts in bad faith of this agreement by spending
down their committee balance in the time between this offer and the date of agreement on
any personal expenses of the candidate or treasurer, or in any manner other than described
above, this offer is immediately revoked.

We look forward to reviewing your response no later than the start of the Commission
Preliminary Review Hearing.

Respectfully,

Brian Katz
Director of Campaign Finance & Campaign Finance Counsel

Cc: josh@joshbrownesq.com
philip.richter@elc.state.oh.us
hartmanlawfirm@fuse.net
scott@pullinslaw.com

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