STATE OF NORTH CAROLINA

COUNTY OF WAKE

DEAN C. DEBNAM, ) )

Complainant, ) )

~ ) )

KEEP RALEIGHVIBRANT,ZACHARY T. ) MEDFORD, TIPPETT ENTERPRISES, ) LLC (D/B/A TARGETED PERSUASION), ) JEFFERY T. TIPPETT, DUSTIN M. ) INGALLS, AND DOUGLAS F. JACKSON, )

) )

Respondents. ) )

BEFORE THE NORTH CAROLINA STATE BOARD OF ELECTIONS AND WAKE

COUNTY BOARD OF ELECTIONS

[gj~(G~~\W~IT1J

WAKEC~CB:AR:OF2~~ VERIFIED COMPLAINT

RECE\VED OCT 05 2015

STATE BOARD OF ELECTIONS

Complainant, Dean C. Debnam ("Complainant") files this complaint with the Wake

County Board of Elections (the "Wake BOE") and North Carolina State Board of Elections

("SBOE") under North Carolina General Statutes ("G.S.") § 163-271 et seq. (Chapter 163,

Subchapter VIII Regulation of Election Campaigns, "Campaign Finance Law") against Jeff

Tippett Enterprises, LLC (d/b/a Targeted Persuasion), Jeffery T. Tippett, Dustin M. Ingalls,

Douglas F. Jackson, (collectively, the "Persuasion Respondents"), Keep Raleigh Vibrant, and

Zachary (Zack) T. Medford (collectively, the "Vibrant Respondents"), and all respondent parties

(collectively, "Respondents") for numerous statutory violations of North Carolina Campaign

Finance Law.

Based on recent press reports,- public record filings, internet po stings and public

admissions, Respondents appear to be illegally coordinating through ongoing expenditures,

collection of contributions and in-kind contributions, the support for the election of one or more

clearly identified candidates, made in concert or cooperation with, or at the request of agent(s) of

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the candidate or agent(s) of candidate committees with corporations and individuals resulting in

prohibited contributions and expenditures to candidates in Raleigh City Council elections.

Further, such alleged coordinated communications, contributions and expenditures appear

to not have been properly reported by Vibrant Respondents or the Candidates.

If such allegations are accurate, they represent potential violations of G.S. §§ 163-278.6 –

Definitions; 163-278.12 – Special reporting of contributions and independent expenditures; 163-

278.13 – Limitation on contributions; 163-278.14 – No contributions in names of others; no

anonymous contributions; contributions in excess of fifty dollars; no contribution without specific

designation of contributor; 163-278.15 – No acceptance of contributions made by corporations,

foreign and domestic, or other prohibited sources; 163-278.19 – Violations by corporations,

business entities, labor unions, professional associations and insurance companies; and 163-

278.40C–H – Municipal Campaign Reporting.

Parties

1. Complainant, Dean C. Debnam is a resident, voter and citizen of Wake County, North

Carolina.

2. Respondent Keep Raleigh Vibrant is a North Carolina non-profit corporation incorporated

on September 2, 2015, with its principal office located at 414 Fayetteville Street, Suite 100,

Raleigh, North Carolina 27601.

3. Respondent Keep Raleigh Vibrant is registered with the North Carolina Secretary of State

as a nonprofit corporation, claiming to operate under I.R.C. Sec. 501 (c)(4).

4. Respondent Jeff Tippett Enterprises, LLC is a North Carolina limited liability company

incorporated on July 3, 2014, with its principal office located at 906 Oakwood Avenue,

Raleigh, North Carolina 27601.

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5. On July 14, 2014, Jeff Tippett Enterprises, LLC filed a Certificate of Assumed Name to

conduct business under the assumed name of Targeted Persuasion.

6. Respondent Jeffery T. Tippett is a citizen, voter and resident of Wake County.

7. Respondent Dustin M. Ingalls is a citizen, voter and resident of Wake County and a

Consultant with Targeted Persuasion since July 2015.

8. Respondent Douglas F. Jackson is a citizen, voter and resident of Wake County and a

Consultant with Targeted Persuasion since January 2015.

9. Respondent Zachary (Zack) T. Medford is a citizen, voter and resident of Wake County.

BACKGROUND

10. Upon information and belief, Persuasion Respondents and Vibrant Respondents acted in

concert or cooperation with each other, or at the request or suggestion of one another, in

matters and actions concerning the Raleigh City Council election (hereinafter,

“communicating and coordinating”).

11. Persuasion Respondents were hired and currently work for 2015 Raleigh City Council

candidates Ashton Mae Smith (paid at least $5,000 on August 31, 2015), Matt Tomasulo

(paid at least $4,000 on September 17, 2015), Bonner Gaylord (paid at least $16,080.40 on

September 3, 2015 and apparently $52,552.69 in total to date), J. B. Buxton (paid at least

$10,879 on September 9, 2015 and apparently $19,182.68 in total to date) and Eugene

Weeks (paid at least $4,000 on September 14, 2015). [Exhibit A]

12. Collectively, these enumerated Raleigh City Council candidates are candidates under G.S.

§ 163-278.6 (“Candidates”) for the purposes of this Complaint.

13. Mary-Ann Baldwin is a 2015 Raleigh City Council candidate, but upon information and

belief, did not hire Persuasion Respondents.

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14. Upon information and belief, reflected in public online postings, Vibrant Respondents and

Persuasion Respondents engaged in communicating and coordinating with one another to

create and maintain various websites, Twitter and Facebook pages with a common theme

or message.

15. On various online websites, Twitter and Facebook pages, and upon information and belief,

by emails and other electronic form such as “banner ads,” various communications

identifying the Candidates, communications to support or oppose the nomination or

election of one or more clearly identified Candidates, events, fundraising appeals,

volunteer recruitment, and calls to action are posted or transmitted (“Communication(s)”).

16. Upon information and belief, reflected in public online postings, Vibrant Respondents and

Persuasion Respondents engaged in communicating and coordinating with one another to

create and post or transmit such Communications. Upon information and belief, Vibrant

Respondents discussed Candidate and/or Respondent Keep Raleigh Vibrant campaign

plans, fundraising plans, campaign messages, campaign spending, volunteer recruitment

and scheduling, GOTV efforts, and Communications with Persuasion Respondents.

17. Upon information and belief, and as reflected in public campaign finance filings, the

Candidates hired and paid Persuasion Respondents to create and post or transmit such

Communications. Upon information and belief, irrespective of payment, Persuasion

Respondents discussed Candidate and/or Respondent Keep Raleigh Vibrant campaign

plans, campaign message, campaign spending, volunteer recruitment and scheduling,

GOTV efforts, and Communications with Vibrant Respondents.

5

18. Vibrant Respondents maintain a Facebook page with endorsements in its profile section:

[https://www.facebook.com/keepraleighvibrant]

19. On September 17, 2015, Vibrant Respondents updated the page with a Communication:

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20. On September 24, 2015, Vibrant Respondents updated their Facebook page with a

Communication:

Keep Raleigh Vibrant updated their profl~ p~lure Se~14at324!lrn .,.

... S","re ~ 8l1ffe •

7

21. On September 29, 2015, Vibrant Respondents updated their Facebook page with a

Communication:

Keep Raleigh Vibrant s .... mII ... 29.1 7:01pm .,.

• We need your ~p- we need your vote. If you've been prolJd to see how

much Raleigh has grown in the last 6 years, and you think that's a great thing then vote Vllith us to keep Raleigh ~itJr.,"1 Polls are open all week until 5pm. Vole a1337 S Salisbury Street

The Keep Raleigh Vibrant candidates:

'" Mary-Ann Baldwin <& Ashton Mae Smilll

':1 J.b. Buxton

'" Bonner Gaylord 'if Matt TOITlaSlJIo

0' Eugene Weeks

'" John OOOm

,. like • Comrnnt

8tpeo.., l ke 1!1 '"

23 shares

... Shue ~ Buffer

~ostRec""t-

8

22. On September 29, 2015, Vibrant Respondents posted two photos and “We have teams

covering the city this afternoon, spreading the word about Keep Raleigh Vibrant and

encouraging folks to hit the polls!”

23. Upon information and belief, reflected in public postings, Vibrant Respondents and

Persuasion Respondents engaged in communicating and coordinating with one another to

maintain Facebook pages and create Communications for posting.

24. Upon information and belief, prior to October 3, 2015, no expenditure, contribution or in-

kind contributions (e.g. printing production costs) have been reported to the SBOE or the

Wake BOE by Respondent Keep Raleigh Vibrant as an independent expenditure, nor as

contributions, or in-kind contributions to the Candidates.

25. Upon information and belief, to date, no contribution or in-kind contributions from

Respondent Keep Raleigh Vibrant have been reported to the Wake BOE by any Candidate.

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26. Vibrant Respondents maintain a webpage: [http://keepraleighvibrant.nationbuilder.com]

PosWd by K""p fta l ~'9h Vibrant Sept~mber 20 2015 n:20 PM Add your reaction

Vote to Keep Raleigh Vibrant

Read more

10

27. On July 3, 2015, Respondent Vibrant posted on its website:

Posted by Keep RaleIgh Vibrant July 03, 2015 tk31 PM

How Can We Keep Raleigh Vibrant

Raleigh is run by the mayor, and seven city council members. These members vote on everything from zoning to

property taxes. The city council decides the direction we want to take our city. As citizens of Raleigh, we elect our

city council every two years in a non-partisan race.

We must elect strong leaders to our council, but these days that takes more than just great ideas. Money speaks

volumes in these local elections, and a little goes a long way. lfwe can raise our goal of $20, 000 to support strong

local leaders, we can have a significant impact on this election and on the course of our city.

Candidates need support in four ways.

1. Money - Like it or not, money is a major part of politics. Money buys direct mail campaigns, pays for

advertising, and enables a candidate to get their message in front of as many people as possible. The more money

we can raise for to Keep Raleigh Vibrant, the more influence we will be able to have. We can use that influence to

elect leaders w ho will protect the sources of vibrancy that have grown Raleigh great these last ten years.

2. Time - Candidates time is valuable. The less time they have to spend fundraising, the more time they'll have to

actually connect with voters and spread their message.

3. Volunteer. - Candidates can only do so much by themselves. Volunteers are essential to a campaign.

Volunteers can staffpbone banks, knock on doors, pass out flyers, and staff polling locations. Our supporters can

offer a candidate help in the fonn of volunteering. Just like money, it doesn't take a lot to make a real impact. All

we need is 25 volunteers to help sway this election and define the direction our city is going to take.

4. Endorsements: - The average voter in municipal elections b as a hard time determining wbo will best represent

their interests. Endorsements from groups like Keep Raleigh Vibrant can belp those voters know who is really

looking out for them.

lfwe do our job, then our hard-work, time, and money will traru;late directly into votes to support candidates and

ideas we believe in. Election day is coming soon, and most of these elections are decided by a few hundred votes.

We truly can make a difference.

Do you like this post?

G·'

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28. In the July 3, 2015 posting Vibrant Respondents made an explicit appeal to raise money,

“Money speaks volumes in these local elections, and a little goes a long way. If we can

raise our goal of $20,000 to support strong local leaders, we can have a significant impact

on this election and on the course of our city. … Money buys direct mail campaigns, pays

for advertising, and enables a candidate to get their message in front of as many people as

possible.”

29. In the July 3, 2015 posting Vibrant Respondents made explicit appeal to recruit and

organize volunteers for Candidates, “Volunteers - Candidates can only do so much by

themselves. Volunteers are essential to a campaign. Volunteers can staff phone banks,

knock on doors, pass out flyers, and staff polling locations. Our supporters can offer a

candidate help in the form of volunteering.”

30. Upon information and belief, reflected in public online postings, Vibrant Respondents was

successful in recruiting and organizing volunteers, utilizing those volunteers to staff phone

banks, knock on doors, pass out flyers, and staff polling locations.

31. Upon information and belief, reflected in public online postings, Respondent Persuasion

and Vibrant Respondents engaged in communicating and coordinating with one another to

organize volunteers, utilize those volunteers to staff phone banks, knock on doors, pass out

flyers, and staff polling locations to support the nomination or election of one or more

clearly identified Candidates.

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32. On September 12, 2015, Respondent Vibrant posted looking for volunteers to work a poll:

33. As evidenced by the Vibrant Respondents’ September 29, 2015 Facebook post, the effort

to recruit volunteers was successful as, “[w]e have teams covering the city this afternoon”

that disseminated printed Communications, supporting the election of one or more clearly

identified Candidates.

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34. On September 20, 2015, Respondent Vibrant Respondents posted a Communication to

their website:

Vote to Keep Raleigh Vibrant

These six leaders are the future of a vibrant Raleigh, and they need your support:

Di.trict A: JB Buxton

JB Buxton believes we should work with our city" s entrepreneills, not against them.

District C: Eugene Weeka

Eugene Weeks aims to improve quality of life through jobs, healthcare and affordable housing.

District D: Ashton smith

Ashton Smith pledges to make Raleigh a vibrant, world-class city everyone can call home.

Di.trict E: Bonner Gaylord

Bonner Gaylord believes in a collaborative approach to finding innovative solutions to the challenges racing

Raleigh.

At-LaJ:ge (City Wide): Matt Tomaaulo

Matt Tomasulo wants Raleigh to be a world-wide leader in innovatioIL He"s the driving force behind Walk IYour

Cityl.

At-Large (City Wide): Mary-Ann Baldwin

Mary-Ann Baldwin"s vision is for Raleigh to become one afthe top five centers for innovation and

entrepreneurship.

00 you like this post?

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35. Upon information and belief, reflected in public online postings, at least one Candidate

was hosted by various downtown bars and restaurants, such as Common 414

Incorporated (Respondent Zack Medford, President), Cornerstone Tavern, Deep South,

Tobacco Road, Oak City Meatball Shoppe, and Café de los Muertos.

Ashton for Raleigh· District D added 4 new phobs ­w~h Ashton Mae Smith ana 3 other.;. at Corrmon 414

Sel'tember 15 at 2. 16llm EOiIoo '"

Common 4 14 and oak City Me<JI:tJall Shoppe pul~d out all ~ the slops lor last nights Meet and Greet We had a wonderlul group olengaged and

passionate guests Ihal were treated to lop nctch lood, drink and live music w tile we discussed the lutuJe 01 Fayeneovil~ SIJeel and Downlown Ra~igh .

Thank you lor all ollhe supportlrom these amazing local tJusinesses and

residents.

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Ashton for Raleigh - District D adde:l 4 new phokls Se"""""'16atr37pm .,.

Thanks 10 Brian Oschwakl and Ihe lolks at West at Ncrth lor hosting lonighfs meel and greel, and 10 Tobacco Road lorcalering. G.eal crowd

and a tJeaumul view al SlIlset.

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36. Various online posting by Respondent Zack Medford clearly indicate some level of

cooperation with Respondent Dustin Ingalls:

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37. Vibrant Respondents posting endorsements and a Candidate fundraiser:

Tell Raleigh City Council: Don't Take Away Our Patios! byZackMedford B,784supportefS

PETITION UPDATE

Keep Raleigh Vibrant Endorsements

Zack Medford Raleigh, NC

Sep 14, 2015 - Patios are just the tip of Ihe iceberg Decisions are being

made on council that affecl evef)' aspecl of our Ihriving downtown_

If we want to Keep Raleigh Vibranl then we need visionaf)' leadership

Evef)' seat on the Raleigh City Council is up for election starting

September 24th. Raleigh residents are allowed to vote for mayor, two

ai-large city councillors, and a district represenlative. We strongly endorse

the following candidates who have demonstraled thallhey wanllo move

Raleigh into the future

District A: JB Buxton

JB Buxton believes we should be working with businesses instead of

against them to improve vibrancy, predic tability for business investment,

and improve quality of life in our city.

District C: Eugene Weeks

Eugene Weeks voted againstlhe patio curfew and has been a strong

supporter of Downtown's vibrancy, as well as the service industry-

District D: Ashton Smith

Ashton Smith pledges to make Raleigh a vibrant, workl-elass city

everyone can call home and has been a vocal opponent of the patio curfew_

District E Bonner GaylOfd

Bonner Gaylord says he voted against the patio curfew because we shouldn', stifle Ihe entrepreneurs who took a risk on our reemerging

downtown

At Large_ Maf)'-Ann Baldwin

Maf)'-Ann Baldwin voted against the patio curfew and has worked

tirelessly to fight the patio curfew since it was passed

At Large_ Matt Tomasulo

Matt Tomasulo was the driving force behind Walk [Your City] and the Wander Box Beer Garden_ He wants Raleigh to truly be a world-wide

leader in innovation

TONIGHT (MONDAY, 9(14)

Join us tonight as we spend an evening helping raise money for City

Council Candidate Ashton Smith

Ashton Mae Smith moved to Raleigh at Ihe age of four, graduated from

Broughton High School at 16, and from North Carolina Stale's College of Design althe age of twenty She's lived in District D for the pasl 12 years

She's a strong leader who believes that Raleigh should become a

world-class city that's inclusive and accessible 10 all types of residents

Help us support Ashton by spending an evening at Common 414. We'll

have catering from Oak City Meatball Shoppe Special musical guesls

Todd Monlgornef)' and DJ Nixxed will be providing Ihe background music

for our evening, and the expert mixologists from Common 414 will be

serving up their incredible cocktails

Your licket gels you food , two drink tickets, and an incredible evening at Downtown Raleigh's favorite cocktail parlor all in the name of a great ,a~

httn l lfnendsofashtonsmlth.natlonbuilder comfcommon 414 even!

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38. Vibrant Respondents posting endorsements:

change.org ~ Start it petition . ~ Orowse P Search

Tell Raleigh City Council: Don't Take Away OUf PaiJOs! by ZaE:k Medford 8 ,784 supporters

PETITION UPDATE

#Drunktown? ,('b. Zack Medford .• Raleigh, NC

Oct 2 , 2015 - By now YOtive probably seen the #Drunktown ads in

response 10 our #SavethePatios movement

An anonymously funded group called 'Wake Citizens for Good

Government" is pouring $70,000 into the negative ads thai paint Raleigh

as #Drunktown Do you think Raleigh can do better than the politics of fear

and intimidation? Does having a vibrant city matter to you?

The only way to fix it is to VOTE and show the "Wake Citizesn for Good

Government" thai fear and intimidation have no place in our city

Early Yoting runs Friday October 2nd from 8:30am-Spm, and Saturday

October 3rd from 10am-lpm To vole during early voting, visit the Wake

County Board of Elections at by 337 S_ Salisbury Street and cast your

ballot You can register to vote at the same lime as filling out your ballot

during early YOUng.

Election day is October 6th_ On election day. vote at your specific precinct

You can find out where that is using this linle httoltwww wakOOQvcom

feloctionmters/Pageslyoterinfo . aspx

You may vote for one district representaUve, two at-large candidates, and

ooe mayor_ The n ames oolow am the candidates who support a vibrant

Raleigh.

Vote for the Keep Raleigh V ibrant candidates:

<::? Mary-Ann Baldwin

<::? Ash ton Mae Smith

<::? J.b. Buxton

<::? Bonner Gaylord

<::? Mati Tomasulo

<::? Eugene Weeks

<::? John Odom

I ~ Em"jl

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39. To the extent any Candidate was hosted by a bar or restaurant, upon information and belief,

to date, no expenditure, contribution or in-kind contributions (e.g. food or drink) has been

reported to the SBOE or the Wake BOE by that bar or restaurant as an independent

expenditure, nor as contributions, or in-kind contributions to the Candidate.

LEGAL DISCUSSION

40. Persuasion Respondents were hired and paid by the Candidates and are therefore defined

as agents of the Candidates under G.S. § 163-278.6.

41. Under G.S. § 163-278.14A, evidence that communications are “to support or oppose the

nomination or election of one or more clearly identified candidates” are outlined: “the

following shall be means of proving that an individual or other entity acted “to support or

oppose the nomination or election of one or more clearly identified candidates”: presenting

evidence of financial sponsorship of communications to the general public that use phrases

such as “vote for”, “reelect”, “support”, “cast your ballot for”, “(name of candidate) for

(name of office)”, “(name of candidate) in (year)”, “vote against”, “defeat”, “reject”, “vote

pro-(policy position)” or “vote anti-(policy position)” accompanied by a list of candidates

clearly labeled “pro-(policy position)” or “anti-(policy position)”…”

This Complaint provides numerous Communications that meet this definition.

42. There are numerous instances when it appears that Respondents Jeff Tippett, Dustin Ingalls

and Doug Jackson were either posting or being the first to like the work of Keep Raleigh

Vibrant. This strongly suggest that Persuasion Respondents had a large a role in the work

of Vibrant Respondents.

43. Public facts presented within this Complaint clearly indicate some measure of acting in

concert or cooperation by and among the Respondents. G.S. § 163-278.6 (6h) states the

term “coordination” means in concert or cooperation with, or at the request or suggestion

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of. The very nature of Respondents’ business and actions together required the

Respondents’ to act in concert or cooperation.

44. By the public facts presented, Vibrant Respondents and Persuasion Respondents appear to

have engaged in illegal coordination through ongoing Communications, expenditures,

collection of contributions, supporting the election of one or more clearly identified

Candidates, made in concert or cooperation with, or at the request of agents – Persuasion

Respondents, of the Candidate with corporations and individuals resulting in prohibited

contributions and expenditures to Candidates in Raleigh City Council elections.

45. G.S. §§ 163-278.15 and 163-278.19, prohibit corporations from making contributions, and

Candidates from accepting them, in connection with any North Carolina election. If

corporate funds of Respondent Keep Raleigh Vibrant were utilized to pay for Candidate

campaign and communication expenditures, Vibrant Respondents, knowingly and

willingly violated these statutes. To the extent other bars and restaurants contributed (even

in-kind), they may have violated these statutes and Campaign Finance Law as well.

46. Upon information and belief, Vibrant Respondents engaged in communicating and

coordinating with Persuasion Respondents, and through agency, or possibly directly, the

Candidates. By operation of this arrangement, it impossible for Vibrant Respondents and

Persuasion Respondents not to be in violation of the coordination and contribution statutes.

47. Under G.S. § 163-278.6(6), “contribution” means any advance, conveyance, deposit,

distribution, transfer of funds, loan, payment, gift, pledge or subscription of money or

anything of value whatsoever, made to, or in coordination with, a candidate to support or

oppose the nomination or election of one or more clearly identified candidates.

48. The statute goes further, “[a]n expenditure forgiven by a person or entity to whom it is

owed shall be reported as a contribution from that person or entity. These terms include,

without limitation, such contributions as labor or personal services, postage, publication of

21

campaign literature or materials, in-kind transfers, loans or use of any supplies, office

machinery, vehicles, aircraft, office space, or similar or related services, goods, or personal

or real property. These terms also include, without limitation, the proceeds of sale of

services, campaign literature and materials, wearing apparel, tickets or admission prices to

campaign events such as rallies or dinners, and the proceeds of sale of any campaign-

related services or goods.” [Emphasis added]

49. Under G.S. § 163-278.6 (9), “expenditure” mean any purchase, advance, conveyance,

deposit, distribution, transfer of funds, loan, payment, gift, pledge or subscription of money

or anything of value whatsoever, whether or not made in an election year, and any contract,

agreement, or other obligation to make an expenditure, to support or oppose the

nomination, election, or passage of one or more clearly identified candidates, or ballot

measure. An expenditure forgiven by a person or entity to whom it is owed shall be reported

as a contribution from that person or entity.

50. To the extent any Candidate was hosted by a bar or restaurant, upon information and belief,

to date, no expenditure, contribution or in-kind contributions (e.g. food or drink) has been

reported to the SBOE or the Wake BOE by that bar or restaurant as an independent

expenditure, nor as contributions, or in-kind contributions to the Candidate.

51. Vibrant Respondents’ actions and contributions, along with potential other bar or restaurant

contributions and expenditures appear to violate G.S. §§ 163-278.13 – Limitation on

contributions; 163-278.14 – No contributions in names of others; no anonymous

contributions; contributions in excess of fifty dollars; no contribution without specific

designation of contributor; 163-278.15 – No acceptance of contributions made by

corporations, foreign and domestic, or other prohibited sources; and 163-278.19 –

Violations by corporations, business entities, labor unions, professional associations and

insurance companies.

22

52. Independent expenditures are defined in G.S. § 163-278.6 (9a), as an expenditure to support

or oppose the nomination or election of one or more clearly identified candidates that is

not a coordinated expenditure. Supporting or opposing the election of clearly identified

candidates includes supporting or opposing the candidates of a clearly identified political

party. A contribution is not an independent expenditure. Vibrant Respondents’

contributions and coordination render this category of expenditure unavailable to

Respondents.

53. The failure of Respondents, Candidates and any bar or restaurant making expenditures or

contributions to file campaign finance reports violates G.S. § 163-278.40C through H –

Municipal Campaign Reporting and other provisions of Campaign Finance Law.

23

RELIEF

54. Complainant respectfully requests the Wake BOE (or in lieu, the SBOE) to conduct an

immediate investigation into these violations; and any additional coordination between the

Candidates, Persuasion Respondents, Vibrant Respondents and other individuals or

“independent” groups who may have also been involved in this scheme; declare the

Respondents to have violated North Carolina Campaign Finance Law; impose monetary

sanctions appropriate to these violations; and take such further action as may be

appropriate, including referring this case to the Wake County District Attorney for criminal

prosecution of any violations.

VERIFICATION

Dean C. Debnam, being duly sworn, deposes and says:

That the contents ofthe foregoing Complaint are true to his own knowledge, except

as to matters stated on information and belief, and as to those matters, he believes them to

be true.

[Signature]

Sworn to and subscribed before me, this 5 day of October, 2015

~.!)< W~ Notary Public Signature

S y s c:::t t) D . W 0.. r n e I Printed Name of Notary Public

My commission expires: ---=B=--+-)_:2._q-+-/--,--,---,,~,,------__ I

24

Exhibit A

Amendment Disclosure Report Cover 1:1 Ye s IlIJ No Use lhis fonn for general report and committee infonnation, mus t be s igned and submitted along wilh o lher detailed forms . Do h' , d' , no t use t IS onn to Up( ate m onnatlon.

1. Committee Informalion a. Full Name c. ID Number

COMMITTEE TO ELECT I.B . BUXTON

rRllE' "" rr= n" n r;= fM\ b. Mailing Address (Indude City, State and Zip ode) t.nllS~t£;U VJ 1£l!dJ d. Date flied

PO BOX 27592 RALEIGH , NC 276 11 SEP 28 2015 09/2512015

e. Phone Number

WAKE CO. BOARD OF ELECTIONS (9 19) 987- 1355

2. Re .... tYear 3. Period Start Date (mm/ddlyy) 4. PeriodFlld Date (mmldd/yy) S. 'I'reaourer FUll Name

20 15 0812612015 09/2 1/20 15 LANGLEY BORNEMAN

6. Type oI'CommIttee (Check One) 9. Type 01' RePJrt (check only one type otreport from one Calel/ory) IX] Candidate Campaign D Pany Municipal State/County Rererendum

D Joint Foodraiser D PAC 18 Organizatio nal 10 Organizationa l Ig Organizat ional

D Referendum D Legal Expense Fund Thirt y·five day Quarterly D Pre- referendum

7. Type 01' Fund (if applicabl~, check one) D Pre-primary D First [] Final

g "Booster Food" IXI Pre-election D Second [] &Jpp lemental Final

D Building Fund D Pre- rWlorr D Third [J Ann ual

D Presidential Election Year Candidates Fund Semi-annual D Fourth D Special

D NC Public Campaign Financing Fund D Mid Year Semi-an nual

0 Year End 0 Mid Year 10. SuecIaI Reuort Name D Othe" D Final 0 Year End

8. Number or Fundralsers this Report 0 Spec ial D Final

2 o Special

3. Accountlnfonnation 3. Accoont Information a. FInancial Institution Full Name a. Flnanaallnstitution FUll Name

WELLS FARGO

b. Purpose c. Account Code b. Purpose c. Account Code

CAMPAIGN ACCOUNT A

d. Period Begin Balance d. Period Begin Balance

$ 44,864.00 $

CERTIFlCA nON I certify thallhe Conunillce or Fund is in compliance wilh aU applicable provis ions of Artic le 22A, 228 & 22D-22M of Chapler 163 oflhe NC G!nera l Stalules and thai no funds are commingled wilh prohibited or other non-disc1osed fu nds. I further certify that this report is comp lete. true and correct and that I have been trained by the NC State Board

Prin ted Name of Signer Signature or Appointed Treasurer Date

roROFllCELSEONLY

Date Received: q V2.-8-(S fnl>loyee: q \'Yic. DeliveQ; Method D Normal Mail

Date Postrnuked: fnl>loyee: D Registered Mail D Hand Delivered

Date Scanned: Q-'Z.8 -IS fnl>loyee: O,rvlC- jZ! ElectronicaUy Filed

Date Data !'ntered: fnl>loyee: o Signer has not received

mandatory training

Please Note: This fonncannot be used to arrend committee information such as the comrrittee address , treas urer, assistant treasurer. custodian of books infonnation, or account infonnation.

You must aJr£nd lh e SlaleJr£nl ofOreanizalion (CRO-2100A-E) to make conunillee changes . CRO-J OOO NC State Board or Elect Ions December 2007

Amendment

Disbursements Pg _3_ of _4_ DYes IliI No

Use this fonn to report expenditures from the committee for operating expenses, contributions to candidate/political and 1 Dartv A"'~

I. ' ,FollName 12.

COMMITTEE TO ELECT J.B. BUXTON

iTYiIOoc ~ itO( .{'~ I farm. far pnrh tvn. af ~ -rr .[ I Party

~ D Add D

la. Full ~::: ... t •• &. ';0' : & Phone Ib. IC • Name It!. C

NEOMONDE CATERING 3817 BERYL I (Specify)

RALEIGH, NC 27609 IB ~:al B County: , Ie. I Sum to Date

$ 1,058.73

tCode I •• Form of lb. , Code • Date Ij· Ik.

A Check C 09/09/2015 1$ 1,058.73 CATERING

1$

I4.Pavee D Add D

la. Fun ~:':::~ .. o, :&Phone Ib.c I ( , Name It!.

ITARGETED PERSUASION 1206 NEW BERN PLACE

IDFedefal g Comty: IOHmrm NC 27601 lei State Ie. I Sum to-Date

$ 19,182.68

iCOcie ~ lb. , Code Ii. Date IJ~n .. nt Ik.

A Check ICl 09110/2015 [$- 10,879.00 CONSULTING

1$

~ l:JAdd D [a.l'tlll Narre;U;;= & Phone

, cltv. state. 8. ziol Ii' ,Name It!.

lWUUV CREATIVE [C:Level 1211 WEST HORNE STREET

ICLAYTON, NC 27520 rg ~e::al g CoIIIHy

'Ie. I Sum to Date

$ 750.00

iCOcie ~ Ih. ..-code u:D.rle Ik.

A Check 10 V,t " [$ 750.()() 11'tiU 1 u ~tiUU 1

1$

~ , $ 12,687.73

16. Total or AIL CR0-1310 Pages (This line goes in line 13a of Detailed Summary Page CRO-1100 ijOperating Expenses)

$ 18,293.54 (This line goes in line 13h of Detailed Summary Page CRO-1100 ijContrib to Candidates/Political Comm)

(This line "'''' in line 13c , Pa;e CRO·l1 00 I Party

17. (list e code in (h.) above)

1A*.Me<ia B* • Printing C*· Fundraising D . To Another Candidate IE. Salaries F* • FAPJDlent G· Political Party H* • Hohing PuWc Office &pense.

- Postage J - Penalties K* • omce &pense. Q* • Donation to Legal EXpense Fund

I~~:r .in -.. CRO-1310 NC State Board of ' 200~

Amendmen l Disclosure Report Cover 0 Ves ~ No

Use th is fo nn for genera l report and committee info nmtio n, mus t be signed and s ubmitted a lo ng with o the r detailed fonns . Do I ' r. d' r. not use t liS onn to Up( ate III onUl.t lo n.

]. Committee Information 3. Fu ll Name c. ID Number

F~ENDSOFBONNERGAYLORD

r. ~ ~ 17'" f£ n \\/11 :I n~ b. Mailing Address (include City, State and Zip ode) ~=u v = "=,, d. Date Fil ed

4441 SIX FORKS ROAD SUITE 106-2 12 SEP 3 0 lO15 09128/20 15 RALEIGH, NC 27609

e . Phone Number WAKE CO. BOARD OF ELECTIONS (919) 427-5040

2. Report Year 3. PeriodStart Date (mm /d,Vyy) 4. Period Elld Date (mm/ddlyy) 5. Treas urer Full Name

201 5 08126120 15 09121/20 15 DA VID W JOYNE R III

6. Type of Committee (Check One) 9. Type of Report (check ollly olle type o!reportji-otn Oll e category) (XI Candidate Campaign o Party Municipa l Sla te/County Referendum

o Joint FWldraiser o PAC 0 Organiza tiona l 0 Organiz31 iooal 0 Organ iz3t io nal

o Referendum o Legal Expense Fund 0 T hirty· fi ve day Quarterly 0 Pre· rcfcrcndwn

7. Type of Fund (if applicable, check olle) 0 Pre-primary 0 First 0 Final

0 "Booster FWld" ~ Pre-election 0 Second 0 Supp lementa l Final

0 Building Fund 0 Pre-runo ff 0 Thi rd 0 An nual

0 Presidential Election Year Candidates F1Uld Semi -an nual 0 Founh 0 Special

0 NC Public Campaign Financing FWld 0 Mid Year Sem i-annual

0 Year End 0 Mid Yea r 10. Special Report Name

0 Other: 0 Final 0 Yea r End

8. Number ofFulldraisers this Report 0 Special 0 Final

2 0 Special

3. Account Information 3 . Account Information a. Financia l lnsli lution Ful l Nam e a. Financial institution Full Name

F~ENDSOFBONNERGAYLORD NORTH STATE BANK

b. Pu rpose c. Account C ode b. Purpose c. Account Code

CAMPAIGN ACCOUNT A CONTRIBUTIONS

CAMPAIGN ACCOUNT ACCOUNT B

d. Period Begin Balan ce d. Pe riod Begin Balance

$ $

CI!lUIF1CA TION I certify that the Co ll.nittee or Fund is in compliance with a ll applicable provisions of Article 22A, 22B & 22D-22M of 01apte r 163 o f the NCGenera i Statutes and that no fund s are COIrulling ied with prohibited or o ther n o n-disclosed

fund s. I further cel1ify that this report is comp lete, true and correct and that I have been trained by the NC State Board

- ~~..4 ~ DMIt/) Woa..TH "SO'f .... ~ I fly S2l ijn c-- 09128120 15 Printed Name of Signer Signature of AJ)f'fo inled Treasurer Da te

FOR OFFICEUSEONLY

Date Rece ived: Q '-2D-/S Enl' loyee: ome Delivery Method o NonmlMail

Date Pos t'mrked: q - ZE - lS Employee: orne B Regis tered Mail o Hand Delivered

Date Scanned: Q- 30- lS Emp loyee: OtYlC o Electronically Filed

Date Data Entered: Enl' loyee: o Sig ner has not rece ived

nmndatory training

Please Note: This fonncannot b e used to amend committee infoffik3.tion s uch as the committee address, treas urer,

assistant treas urer, cus todian o f books infonnation. or account info n113tion.

You mus t amend th e Staten1Cnt of Organization (CRO-2100A-E) to n-ake co mmittee ch anges.

CRO- / OOO , NC State Board ofEieclions December 2007

: Amendment

Disbursements Pg 4 of _4_ 0 Yes !XI No

Use this fOlm to report expenditures from the conunittee for operating expenses, contributions to candidate/political comnuttees an d d' d d' coor mate l party expen ltures

1. CQmmitteeFulI N;une (andF'l.lltdifapPIiCable) . . ' ... .'. '. .....•.... kIDNumber .• '.' '< •

FmENDSOFBONNERGAYLORD

31:rYPe ofDisbursement ' /PleDsfJ'use',sei!.arale'CRO-1310 lornls tir each tru.e"i/lDisbursenieiJt.i ................. IIXI Operating Expenses _ ~.l Contributions to CandidatesfPolitical Committees o Coordinated Party Expenditures

4.paye~ .!qforllll\tl{)n·<·<.>· < .> D Add.O· lkIIJi)v'e,: :, ' ..... > . ."

a. Full Nam:, Mailing Address & Phone b. Coordinated Committee Name d. Comments

(include city, state, & zip)

TARGETED PERSUASION 206 NEW BERN PLACE c. Level Registered (Specify)

RALEIGH, NC 27601 ~ Federal I."J County.

(919) 819-2138 o State o Municipality: e. Election Sum to Date

$ 52,552.69

f. Account Code g. Form of Payment h. Purpose Code i. Date (mm/dd/yyyy) j. Amount k. Required Remarks

ACCOUNTB Check C 09/0312015 $ 8,200.20 FUNDRAISING

ACCOUNTB Check 0 09/0312015 $ 8,200.20 L~

4; Payee Information . .

. .. '. o Add 0 Remove .. . ".

. .. a. Full Natre, Mailing Address & Phone b. Coordinated Committee Name d. Comments

(include city, state, & zip)

USPS 7800 FALLS OF NEUSE ROAD c. Level Registered (Specify)

RALEIGH, NC 27615 ~ Federal U County. o State o Municipality: e. Election Sum to Date

$ 392.00

f. Account Code g. Form of Payment h. Purpose Code i. Date (mm/dd/yyyy) j. Amount k. Required Remarks

ACCOUNTB Debit Card I 08/26/2015 $ 49.00

ACCOUNTB Debit Card I 09/0112015 $ 49.00

4. Payee Information ••••• ••

......... .... DAMD .. RerriOve ...•.. . .' ..'. a. Full Name, Mailing Address & Phone b. Coordinated Committee Name d. Comments

(include city, state, & zip)

USPS 7800 FALLS OF NEUSE ROAD c. Level Registered (Specify)

RALEIGH, NC 27615 ID Federal o County; o State o Municipality: e. Election Sum to Date

$ 392.00

f. Account Code g. Form of Payment h. Purpose Code i. Date (mm/ddJyyyy) j. Amount k. Required Remarks

ACCOUNTB Debit Card I 09/01/2015 $ 98.00

$

5. Total only this Page ; ; . . . .. ..... .. "'; .' $ 16,596.40

6. Total of ALL CRO-1310 Pages . .' ... . .

(T/tis line goes in line 130 of Detailed Summary Page CRO-lJ 00 ijOperating Expenses) $ 28,765.94 (This line goes in line 13b of Detailed Summary Page CRO-I 1 00 ijContrih to Candidates/Polifical Comm)

(This line goes in line J 3c of Detailed Summary Page eRO-iI 00 ijCoordinated Party R"\:penditures)

7. Purpose Codes (Listdetailed expenditure code in (h.)above) ;" .

A* -Media B* - Printing C* - Fundraising D - To Another Candidate E- Salaries F* - Equipment G - Political Party H* - Holding Public Office E<penses I - Postage J - Penalties K* - Office Expenses Q* - Donation to Legal E<pense Fund 0* Other .. Codes requiredetailedeXJianation in required remarks field(k) .

CRO-13JO NC State Board of ElectIOns December 2009

Amendm e nt Disclosure Report Cover 0 v" III N. Use Ih is form for gencm l report and cormillee in folm:lIion, ITl.ISI be s igned and s ub rrin ed along ..... ilh other de tailed fonT'l" .

Do no t u se this formto urxla te in fonnll ion .

1. c..i.tte ... _ 11-. Fu ll Na .• t c. ID Nu.btr

FRiENDS OF ASHTON SMITH 1Rl~~~1Mm ~t.1II111 Acldr'fu (iadu. Cit,. . S It .. d ZlpCode) do. o.lt fl lt d

123 FENNER LANE OCT 0 I 1015 10101120 15 RA LEIG H . NC 27603

t . .... o.t Nu.bt r WAKE CO SOARD Of ELECTIONS

V_ 3. PaildSIart IWt (a , 4 ...... Gd __ (........"." S. -rre...-er filii N.R

20lS 08126/2015 0911112015 HENRY WARD

~1)0< cl ~_ (<l>ccl< Ooc) •• cl (declc DIll ••• ."" n '" OfIe CD.U 0

Candioote Campaign ~ Parly Muaid .. 1 StatelCou . ly Rdtrudu.

D .loml FUlI(hlscr D PAC 8 OrpnlLlllOnai o Orgalli1.a1 iOll ol IS! Orpnl/.al ion~1

o RtJercnlbn 0 upl E.\pen~ Fund Ttmly· live day Qwmrly o Pre· rderendum

. 1)po cl'" (,yplicUk. d.d:_J D Pre.pnmary D RM D final

~ "Bomiler F~d" 1X1 Pre·ele<:llon 0 Second D ~pkmental Final

o Building F~d 0 Prc·rmof( 0 T hird o Ann ..... l

D PreSIdential Elect ion Year CandiwlC5 Fund S:m..:mnual D Fo",' D Sp«lltl D NC Publ,C CampaIgn Fin&n <:mg r.,.,d D Mid Year Seml· :tJ1n ..... l

0 Year End 0 MId Year 1' .S -D Oher. 0 Rnal [J Ye:u- End

1" ( r ", ....... IIIIben 1Ws~ . 0 Special D Fin",l

I [J Speml

~ ........ 3. Acca.IIt .... MIIica • A ... dal "sUhniN Full N •• t •. A ... dal la. lltuUOII FUll Naat

WELLS FARGO

........ c. A('(OUII I Code b.. ". fllO$t c. Atteull t C ock

CAMPA IGN C HEC KING CH

Ii. Period Refi ll Bal .... ('t II.. PuiMllkcl. BaJ .. ce

S 36,746 -41 S

~::'f~~~ COll'anllee o r Fund L~ U1 c0Tl1'liance with all applicable provisions of Aniclc 22A. 228 & 220 ·22M o f

Otapler 163 of the NC Q:nerdl Statutes and tha t no fun ds arc cOllninglcd with prohibited or o ther non--disclosed

funds. I funhcrcen ify tha t Ihis repon is COlT{llcle.lrue and correct and thaI I ha ve been tm ined by the NC Slate Board

Pnnted Name of Signer Signatur~ of APPolll ltd Trea.~ef Dat e

RlROn lCEUiEONLY

Date Received : /O-I-I S El1-1>Joyec:: we [)eijvery Method [j Normtl M llil

Dale Postmu'b::d : fn1>lo yec: o ~gis lered Mai i3: Hand Delivered

Date Scanned : 10 - /-I)S frl1>loycc.: o.rne ~EleclrQnical1y Filed

Dale Data &lu:red : fn'1>loyec: o Signer has not received

I1lUldalol)' training

Please Note: Th is formcan no l b e used to atrend conmtlce informat ion such as the connittce address, t reas urer.

assis tant treasurer. c us todian of books info rmat ion. or accoun t in fomntion .

You f1lJ SI arrend the Staten..:nt of Ort!ani13tion {CR0-2100A ·E) to n'Oke conrnllec c hanl!cs.

e RO-I OOO NC :hlt Board of EJectIOns ,

Ame ndmrn t

Disbursements I', .2.. (Jf --i... 0 Yrs II No

Usc this fonn to rcpon c"Pcnditurcs from the co rrmittec for opera t ing expenses, contributions to candid:lIe/polit ical ; ,.d . j pony ,

;OF~

~. FuU , Ad~ss & Pho ne

. A d.)

Arv ENGINE 12 125 14th SI NW IWASHI NGTON, DC 20009

CH Draft c Cll Draft C

~ ... ~ ~ ...... ".;; ,1 . 1 ' & "'0",

'" ",u PRINTI NG li803 ·lndustrial Dr 1","'".H""rG uH. NC 27609

e .... : ... ~.r CH Check

14."-p. Fun Na"". Mailing .&.,., I' AKC,O I W PERSUASION 1206 New Bern PI IR,'L101GH. NC 2760 1

Ie ... CH Ched

CH Check

,ooIydlia .....

& Fliooe

c C

•• _ fill AlLCRO-lJJI ~eI

, 15 A~ :g:

I~

I~ I .. "" lei Slale

'c .... I. "."

09/09/201 5

09/1612015

[ 'dd 0

", .. ~I

19 r ... "oJ 10 Slale

09/0312015

[ I Add 0

Ie. Lr~1 i

,c ... . Do"

08/3 112015

08/3 112015

I

IS IS

I This liM guu i" li"t' I JQ of IHtaihd Sum mQry " QIft CHO-IIOO ifOpf'ruliflg UPf'luu)

I This liM gun in liM I Jb of IHtaihd SummGry PGIft CHO_ II OO ijColllrib to .

(ais liM gut'S in lillt' I 1.- . • • t PGrty

(Lio' H' · ... . ... - E'lPlBEnt .I - Penalties

, (b.)obov.)

CO· G - Political Pany K" - omc::e EXpenses

~

~ , ,

I , Na.,

~ U>~'" Cl M.., icipalilY : I" ,,«,; ••

S 1.225.02

l'c I

90.34 I PROCESSING FEE

167. 13 PROCESSING FEE

~

o U>~'Y i ... Da"

S 246.59

246.59 REM IT ENVELOPES

i ~

4,IXX),OO

1.IXX).OO

I~

. B,dl ••

$ 5,000.00

I

U,=""",-FEES

~FEES

S

$ 9, 174 .39

~.- T~ AnolhcrCandidatc:: fP - RoIdng Publi c:: Of'Iitt F.Xpemes Q • • Donation to l..egaJ EXpense Fund

, 21)09

Ame ndm ent Disclosure Report Cover I:l Yes !XI No

Use this fonn for genera l report and corrunittee in format ion, must be signed and submitted along with other detailed foIlTlS. Do not use this form to update informatio n.

1. ConwnIttee InCOrmaliOll a. Full Name c.IDNumMr

COMMITTEE TO ELECT MATT TOMAS pLU ~ fEre fE n~I§:rDl

b. Mailing Address (I nclude Cily, S late and Zi Code) d. Date Flied

706 MOUNTFORD AVE ScI' 28 2015 09/27120 15 RALEIGH, NC 27603

WAKE CO. BOARD OF ELECTIONS e. Phone Number

2, Report Year 3. Period Start Date (mm/ddlyy) 4. PerlodlhdDate (mmldd/yy) S. Treasurer Full Name

20 15 0812612015 09/2 1120 15 DOMlNlQUE BISCHOF

6. 1YPe of ConwnIttee (Cleck One) 9. 1YPe of Report (check only one type of rep or/from one category) I!J Candidale Campaign D Party Municipal State/County ReFerendum

D Jo int Fundraiser D PAC IB Organizational ID Organ izat iona l ,g Organ izat ional

D Referendwn o Legal Expense Fund Thirty-five day Quarterly D Pre-referendwn

7. 1YPe of Fund (if applicable. check one) D Pre- primary CI First CJ Fi nal

g "Booster Food" Ill! Pre-election CI Second [] &ipp lemenlal Final

D Bui ldi ng Ftmd D Pre-runoff D Third D Annual

D President ial Election Year Candidates Fund Semi-annua l CI Fourth CI Special

D NC Public Campaign Financing Fund D Mid Year Semi-annual

0 Year End 0 Mid Year 10. Special HePll't Name D Oth." D Fina l D Year End

8. Nmmer of F'IlJd'aIsers this RePll'l D Special CI Final

2 D Special

3. Ace"""t InCOI1IIltim 3. Account InrOl1llltim a . Flnancial Institution Full Name a. Flnanda. Institution Full Name

WELLS FARGO BANK, N.A. WELLS FARGO BANK, N.A.

b. Purpose c. Account Code b. Purpose c. Account Code

CONTRIBUTIONS AND A SAVINGS B EXPENSES

d Period Begin Balance d. Period Begin Balance

$ 16,889.22 $ 50.00

ORTIFlCA nON I certify that the Committee or Fund is in compliance with all app~cable provisions o f Article 22A, 228 & 22D-22M of Olapter 163 of the NC Genera l Statutes and that no funds are commingled with prohibited or othernon-disclosed

funds. I further certify that this report is complete, true and correct and that r have been trained by the NC State Board

Printed Name of Signer Signature of Appointed Treasurer Date

FOR OFFICElSEONLY

Date Received : q-U-I$ ~Ioyee: CtfY'-C Delivery Method D Nonnal Mail

Date Postrrnrked: ~Ioyee: D Registered Mail D Hand Delivered

Date Scanned: q - U" -/S ~Ioyee : O¥V1C J2I.- Electronically Filed

Date Data Entered : ~Ioyee: o Signer has not received

rmndatory mining

Please Note: This form canno t be used to arrend committee information such as the conmillee address, treasurer,

assis tant treasurer, cus todian of books infonmtion, or account infonnation .

You trust arrend the Staten~nt ofOrRanization (CRO-2100A-E) to make corrrrnin ee changes. CRO·/OOO NC Sate Board of Elect Ions December 2007

Amendment

Dis bursements Pg _2_ of -1... D Yes !XI No

Use this form to report expenditures from the committee for operating expenses, contributions to candidate/political corrnnittees and coordinated party

,Full ~ ,2.

COMMITTEE TO ELECT MATT TOMASULO

3. TypeN'1 -Ef'a.e fL.e. 110 farm.. Itvn~ 1131 ( ;10 I Parly

14. Payee. D Add D la. Full Nalre, Mailing I & Phone b.' , Name d.

, city, state, & zip)

IAI ENGINE 12125 14TH ST NW g ;e::al ~ ColD1ly: . WASHINGTON, DC 20009

Ie. I Sum to Date

$ 967.04

II. I Code Ig. Form ofl •• lb. , Code Ii. Date U· Ik.

A Draft IC 09116/2015 1$ 92.55 IPAllv"'I" PROCESISNG

A Draft Ic 08/2612015 1$ 314.69 I riHmu,,,

'UK UUI'AllUI'~ 4. Payee Jnfcrmati ... D Add D Rennve a. Full Nalre, Mailing Address & Phone b. Coordinated Committee Name d. Comments

(include city, state, & zip)

NATIONBUILDER 520 S. GRAND AVE c. Level Registered (Specify)

2ND FLOOR ,g Federal o Counly:

LOS ANGELES, CA 90071 o State C] MWlicipality: e. Election Sum to Date

$ 198.00

f. Account Code g. Form of Payment b. Purpose Code i. Date (mm/ddlyyyy) j. Amount k. Required Remarks

A Debit Card C 09/0812015 $ 99.00 WEBSITE

$

~. Payee Jnfcrmati ... D Add D ReDDve a. Full Nalre, Mailing Address & Phone b. Coordinated Committee Name d. Comments

(include city, state, & zip)

TARGETED PERSUASION 206 NEW BERN PLACE c. Level Registered (Specify)

RALEIGH, NC 2760\ ~ Federal

o State !::! County: [] MlUlicipality: e. Dection Sum to Date

$ 4,000.00

f. Acc:ount Code g. Form of Payment h. Purpose Code I. Date (mmlddlyyyy) j.Amount k. Required Remarks

A Check 0 09/1712015 $ 4,000.00 CAMP AlGN CONSULTING

$

5. Total ooIy Ibis Page $ 4,506.24

6. Total of ALL CR()"1310 Pages (This line goes in line 13a of Detailed Summary Page CRO-llOO if Operating Expenses)

(This line goes in line 13b ofDetaikd Summary Page CRO-IIOO ifContrib to Candidates/Political Comm) $ 7,387.43

(This line goes in line 13e of Detailed Summary Page CRO-IIOO if Coordinated Parly Expenditures)

7.Pmpose Codes (list detailed expenditure code in (h.) above)

A'·Media B* • Printing CO . Fundraising D - To Another Candidate E - Salaries F* - FJPpnent G - Political Party H* • Iil\ding PuUic Office &.penses I· Postage J - Penalties K* - Office &.penses Q* • Donation to Legal &.pense Fund 0* Other * Codes relJlire detailedeXJianation in relJlired remarks field (k) CR()'1310 NC State Board of ElectIOns December 2009

t\ mrndnu,nl Disclosure Report Cover 0 Y" IJI,-,N",._ Usc this n.-port and colTlliUcc infonmtion, ITllst be si~ned and s ubmttted along with olherdetaikxl fOrm>. Do nOI

•. full N. m. o. to

~~~~~C~ITI~Z~E~~.~SC~TO,,~y,~ .. EL,~~EI~~ •• rn~Wd~EEK~S~Li~===i~ ~~~~~~~=3~~~~====~ 2059 FOXGATE DR.

IRA I "1"1 NC 27610 SEP »B !Ol~ 09/28/201 S

WIrJ<ECO BOARDClFELEC'nONS

!;:!!i2;;0!!IS~ij!;!;!!!!~!!0!!812]612i!!!0j!I;;S~~ ~i;]~~09~/2~I~/2~0~IS;~~~~B]RA~D;K~ENN~r~"ED~~;;;;;;::::::~

~~I~~~~i'~"~~~'i~~i~~~~ ~~,g~~~Io¥a~~i~~~~,g~ .. ~,~~ 10 0 I.,cS-1 Expaue Fmd I;: ThIrty-live day Quarter ly Ig Plt-refercnlbn

19 11IIr~d" I~ ~:::::~ Ig ::d I~ :~kmlcntaIFma l 10 9.lilding Fmd 0 Pre-runoff 0 Third Ig Annual

19 PrcSld..'Iltial E\e(:llon Year Candidrolet; Fmd St:mi-anm.1 0 FOIr,h 10 Spttial

10 NC I'wlic Campll8J1 Finlllcin g Fund 0 Mid YCII' Semi·annual

10 O<h~ . C Year End C Mid Year IlL

"!!~i!.!i!!]i!!!:!!i!!L=~ DO Finll 0 Year End ~ .... ....... Specill 0 FiAiI

10 ~ecilol , Full N.m, , "'It N.m,

I WELLS

.. c ... I" A

c P,",. 8,.1, s s

I certify that the ColTITittee o r Fund i!'l in eOl1l'liance with all applicabk! provisIOns o f Art ick! llA. 2213 & 22.1)·22M of Chaph:r 163 of the NC CA!neml SUllutcs and that no funds are conTnmglcd \\'llil prohibited or other no n-discklscd funds . I furthcr ecrtuy lilal thIS repon IS col1l'k!tc , true and Cj;1 and that I ha\le been ,mined by the NC Stale Board

W;ll:c.tM R,. ~{, I .. "V{, '// ~,~~~ 09~~0 I S

Dale Received : 9 -1..& ~1S &q>loyce: 9,rY\c.. 1&1il::s:rr: M~!.b2S1 o Normal Mail

Dete Postrnarb:d: &q>loyee: o Registered Mail J;iX,..Hand Delivered

Dote Scanned: q-U-1S En'ployee: (XIV'C o flccuorucolly Filed

Date Data Entered: &q>loyce: o Signer has no t received

Please Note: Thi'i fonncannot be used to anx:nd conmittcc infonmtion s uch as the eormiucc address , treasurer, assistant treasurer, c usto<lian of books information , or account information.

fu"~" I" ~~'~~"'~'A'~'.~'~~~ ~>~~· ~~~~~~~wt ;;;, ~u, , 20"

Amt n dm~ nt

Disbursements )'" 2 of _ 2_ 0 "ts lSI /'10'0

USC Ii'lL" ronn 10 report expenditures rrom Ihe comutltt ror opcmllng expenses, conlnbuhon, 10 cBndtdllleipolilltal " nd ,

CONCERNED CITIZENS TO ELECf WEEKS

I!:. ~ ~ ~ , [.i.P_ ' L Add 10 ~Nom. I" Full Nome, ' ,& Phone I ~ '

, " d p) k" 150 Fa)~;lC"i1 1c SI

IHI IO II::! ",.1m' ~ COm'y'

RALEIG H. NC 2760 1 10 !il: .tc o , , Sum '0 "" . S 127.15

' C .... h . • Cook .",,, I' · A Debtl Card 0 09117120 15 , 127.15 FOOD FOR VOLUNTEERS ,

i4.P_ ' - [] A<id 0 I" Fun No"", i , & Phone I ~ ' , Nom.

, .. d p)

M U O' ':" PERSU ASION I' . Low' , 1206 NEW BERN PLACE

RALEIGH. NC 2760 1 I!:! ""'nl ~ COm ' y' 1(9 19) 819-2138 10 !il:1Ic:

S 4,000.00

, C.d • ... ~ , h . .,,- I" A Ch<£' 0 09/1 4120 15 ,S 4.000,00 CONSULTING

$

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la. Fun ':'d':: "".: .. d p) • & Phone

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