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March 21, 2023

Molly Woon
Elections Director
Oregon Secretary of State
Public Service Building Suite 126
255 Capitol St. NE
Salem OR 97310

Dear Ms. Woon:

As Clatsop County residents and voters, we submit the following complaint against Marie Gwydir-Moore
and Everyone for the North Oregon Coast (EFTNOC). This commercial vacation rental industry group was
formed expressly to oppose Measure 4-221, a Clatsop County citizen referendum on the ballot on May
16 and is breaking multiple Oregon campaign finance laws.

1. EFTNOC has failed to file a statement of organization for their political action committee.

According to the Secretary of State’s campaign finance manual, “A political action committee is a
combination of two or more individuals, or a person other than an individual, that receives a
contribution or makes an expenditure for the purpose of supporting or opposing a candidate, measure,
or political party. Each political action committee must establish a campaign account and file a
Statement of Organization…The treasurer of a political action committee must file a Statement of
Organization not later than three business days after first receiving a contribution or making an
expenditure.”

As you can see in Images 1-3 in the appendix, EFTNOC began fundraising to oppose Measure 4-221, as is
explicitly stated on their Go Fund Me page, and through a PayPal account linked from the group’s web
site. From the GoFundMe page alone, it is clear that EFTNOC has received more than 2 contributions
and those contributions were longer than 3 days ago (see Images 4 and 5.)

2. EFTNOC has failed to report transactions in a timely manner in accordance with campaign
finance reporting laws.

According to the Secretary of State’s campaign finance manual, a committee must file each transaction
with OreStar no more than 30 days after the transaction. The campaign has broken this rule by creating
a Go Fund Me page that explicitly opposes Measure 4-221 and receiving contributions as far back as six
months ago, and yet no contributions have been reported.

3. EFTNOC has accepted anonymous contributions to their effort to oppose Measure 4-221, in
clear violation of Oregon election law.

The Oregon Campaign Finance manual further states “If an individual or organization collects
contributions on behalf of a candidate or committee, the contributions must be reported as being
received from the person giving the contribution, not the collecting individual or organization that
forwards the contributions.” Page 28 of the manual explicitly states that anonymous contributions are
prohibited: “Warning: No committee or person associated with a committee shall accept anonymous
contributions. This includes “passing a hat,” a “collection plate,” or setting out a “jar” to collect
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contributions.” However, according to GoFundMe, EFTNOC has accepted multiple anonymous

contributions in large sums, amounting to nearly $2000 of anonymous contributions to their electoral
effort (see images 4 and 5).

Finally, earlier this month, EFTNOC filed a lawsuit in Clatsop County circuit court, challenging the
legitimacy of the referendum in an attempt to prevent the election from moving forward. The group is
represented by the Portland law firm Tonkon Torp. We believe this may be a further example of failure
to report campaign transactions, since EFTNOC is an explicit opponent of Measure 4-221 and may have
used campaign funds to pay their legal fees. In addition to legal representation, Tonkon Torp, through its
sister corporation, “TT Administrative Services, LLC,” acts as the groups registered agent, according to
filings with the Oregon Secretary of State’s Corporations Division.

Regardless of how we may choose to vote on this issue in May, we think it is important everyone plays
by the rules as codified in Oregon campaign finance laws. We respectfully ask the Elections Division to
investigate this matter fully and quickly.

Sincerely,

Cheryl T. Conway Beatrice Michel

Astoria Gearhart

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APPENDIX OF PHOTOS

Photo 1:

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Photo 2:

Photo 3:

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Photo 4:

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Photo 5: