End Citizens United (ECU) filed four new complaints yesterday with the Federal Election Commission (FEC) and Internal Revenue Service (IRS) to hold third party campaigns and Republican operatives who are attempting to meddle in elections to undermine our democracy accountable. Failing to do so would set a dangerous precedent for future elections.
“MAGA Republicans are doing everything they can to undermine our elections to prop up the Jill Stein and Cornel West campaigns because they know Donald Trump can’t win without illegal meddling,” said End Citizens United President Tiffany Muller. “It’s blatantly illegal to work on their behalf and offer professional services without payment – and yet time and time again these third party campaigns are seeing Republican consultants go far and above what is allowed. Everyone involved in this scheme must be held accountable, otherwise it would set an incredibly dangerous precedent for the future of our democracy.”
The four complaints are: 1) an FEC complaint against Jill Stein and GOP operatives for illegal support and coordination around ballot access in New Hampshire; 2) an FEC complaint against Cornel West and GOP operatives for illegal support and coordination over ballot access across several battleground states, which builds on ECU’s previous complaint against West and GOP operatives; 3) an FEC complaint against RFK Jr’s campaign and attorney Paul Rossi for illegally providing legal services without payment or reporting in-kind contributions; and 4) an IRS complaint against More Voter Choice Fund Inc. for failing to properly disclose a contribution from the pro-RFK Jr. American Values PAC.
Complaint 1: FEC Complaint Against Jill Stein, Jill Stein for President 2024, The Synapse Group, and Impact Advocacy Group LLC
- Under the Federal Election Campaign Act of 1971, candidates must finance their own campaigns for office, and individuals, corporations, and other groups may not provide direct monetary or in-kind assistance to Federal candidates outside the contribution limits and source prohibitions of the Act.
- This Complaint provides conclusive evidence that Republican signature gathering firms—not being paid by the Stein Campaign—illegally colluded with the Stein Campaign and collected the necessary signatures to get her on the ballot in New Hampshire.
- Given the unique and complicated nature of petition gathering for Presidential candidates, it is virtually impossible for these activities to be taking place without direct coordination between the Stein Campaign and the Respondents. Indeed, the Respondents would not know how many signatures the Campaign had or still needed without information from the Stein Campaign.
- Petitioners for ballot access in New Hampshire are required to submit at the municipal level, rather than at the county or state level, meaning that these Republican operatives and the Stein Campaign would have had to know which of the 234 municipalities were going to be covered by the operatives and which of the remaining smaller towns could be covered by the Stein Campaign.
- Documentary evidence to date shows that such coordination with the Stein Campaign has occurred with no attendant reporting of payments for these activities. However, because these are paid petition gathering companies and not charitable entities, someone was paying. It just was not the Stein Campaign.
- Jefferson Thomas, a longtime Republican operative, is the President of The Synapse Group, a company that “partners with individuals, campaigns, and corporations[…]to provide[…]solutions to challenges presented in the government, public affairs, and campaign spaces.” Most notably, Synapse provides petition gathering services to help candidates get on the ballot.
- Impact Advocacy Group LLC (“IAG”), a company dedicated to “develop[ing] and implement[ing] national public engagement campaigns designed to support traditional lobbying efforts,” is led by its Chief Executive Officer Meghan Cox. Samuel F. Wright and Matthew Cohen are employees of IAG. All three have a long history of working as Republican operatives.
- On August 5, 2024, Thomas submitted petitions to the City Clerk’s offices in Rochester, Hudson and in Derry, according to a cover sheet he submitted and signed with the Town Clerks. In Nashua, Thomas signed a cover sheet for petitions that were ultimately delivered to the Nashua City Clerk’s Office by Cohen, according to the nomination papers receipt.
- The following day, Thomas submitted signatures to the town of Merrimack, again leaving a signed cover sheet. This sheet was later signed and dated by Wright, of Impact Advocacy Group, suggesting that Wright picked up the petitions following the town’s certification.
- On August 6, 2024, Wright dropped off nominating petitions for Dr. Stein in Manchester, according to the City Clerk’s receipt of nominating petitions, which Wright signed twice as the “Candidate or Designee,” denoting Wright—and by extension his employer IAG—as an authorized agent of the Stein Campaign.
- In total, the Stein Campaign reported on its website that it had gathered 7,619 petitions by the August 7, 2024 deadline for New Hampshire’s ballot access. Of the 7,619 petitions, at least 4,720 signatures—nearly two-thirds of the total—were submitted by Synapse and IAG employees on behalf of the Stein Campaign.
- The sheer enormity of the amount of petition signatures gathered, organized, and submitted by IAG and Synapse compared to the total number of signatures reported by the Stein Campaign implicates the Stein Campaign’s intentional and inevitable coordination.
- There is no conceivable way IAG and Synapse could have collected, organized, and submitted 4,720 nominating petitions securing the Stein Campaign’s space on the ballot without inside information from the Stein Campaign on (i) how many signatures they still required to gain ballot access, and (ii) which areas the signatures needed to be located in to meet and exceed New Hampshire’s statutory requirements.
- Seeing how the majority were collected in New Hampshire’s 1st Congressional District, the strategy executed in the collection by IAG and Synapse had to have been, at least in part, directed and dictated by the necessities and shortcomings of the Stein Campaign’s own signature collection efforts—making these signature gathering, organizing, and submission services coordinated expenditures and in-kind contributions.
- Legal Analysis of these actions show that:
- A “designee” is the equivalent of an “agent” for a candidate or authorized committee, indicating IAG and Synapse hold actual authority to act on behalf of the Stein Campaign.
- Each of the nominating petitions submitted by Dr. Stein’s agents constituted coordinated expenditures and in-kind contributions required to be included on the Stein Campaign’s FEC reports:
- Impact Advocacy Group and its principals made excessive and illegal in-kind contributions which were accepted by the Stein Campaign.
- Synapse Group and its principals made excessive and illegal in-kind contributions which were accepted by the Stein Campaign.
- The quantity of petitions submitted by these GOP operatives implicates explicit coordination by the Stein Campaign.
- The facts of this complaint show strong reason to believe the Stein Campaign, other Respondents named in this Complaint, and future Respondents yet unknown have grievously violated the Act by making, accepting, and/or facilitating excessive illegal in-kind contributions and excessive illegal coordinated expenditures.
- The Commission must investigate the extent of the FECA violations involved and levy the appropriate penalties on Respondents.
Complaint 2: FEC Complaint Against Cornel West, Cornel West for President, Blair Consulting Group, Blitz Canvassing, LLC, The Synapse Group, Paul Hamrick, People Over Party, and Wells Marketing, LLC
- West’s campaign is financially defunct—it owes over $77,000 in debts while reporting just under $12,000 in cash as of the date of this Complaint.
- This has led West to rely on outside spenders and shady political operatives to finance his ballot qualification efforts. West knowingly accepts this help, stating publicly that he “just want[s] to get on the ballot.”
- West has knowingly accepted outside help in violation of the Federal Election Campaign Act of 1971 reporting requirements and contribution limits.
- West and his Campaign have ties to the Justice For All Party (“JFA”), an organization formed by West and his allies to “secure ballot access” and JFA’s ballot access efforts are intertwined with West and his Campaign.
- In North Carolina, JFA supported West’s ballot access efforts through signature gathering and by taking advantage of state laws requiring fewer signatures for minor party candidates as compared to independent candidates.
- In addition to working with JFA in North Carolina, West works alongside clandestine Republican operatives and right-wing corporate entities to obtain ballot access in key swing states.
- The initial components of this effort were the subject of a complaint by End Citizens United filed with the Commission on August 2, 2024 (“the August Complaint”).
- This Complaint provides new evidence of additional unreported and illegal coordinated expenditures and in-kind contributions, as well as state of mind regarding West’s intentional violations.
- In Arizona, West relied on the help of prominent Republican attorneys to harass and track down potential electors for West after receiving significant Republican help gathering petition signatures.
- Despite relying on Republican help and fraudulent tactics, West still failed to obtain ballot access in Arizona; although, the Republican-supported “third party” candidate has obtained access in Virginia and Maine, among other states, as a result of these efforts.
- Paul Hamrick of People Over Party (“POP”), a purported nonprofit corporation that has been orchestrating efforts to support West on behalf of unknown financiers. Hamrick has a long history of working for and supporting Republicans.
- Desperate to gain ballot access in other states, West and his allies’ shady tactics continued nationwide. In Wisconsin, West coordinated with the Republican-aligned Blair Group Consulting (“Blair”) to gather required signatures.
- In Pennsylvania, most recently, court filings show that Paul Hammick contacted and may still be contacting potential presidential electors for West to attempt to hastily secure necessary affidavits past the deadline.
- Neither Justice for All nor the West Campaign has paid or reimbursed POP for their efforts to track, obtain, cure, and file required affidavits from presidential electors in an effort to place West on state ballots.
- POP and Hamrick, alongside the Republican operatives, worked in at least Arizona, Maine, Minnesota, Pennsylvania, Nebraska, Michigan, Virginia, and North Carolina to put West on the ballot.
- West is clearly aware that his reliance on clandestine Republican operatives and corporate entities to obtain ballot access runs afoul of the law.
- West’s search for free ballot access has caused him to knowingly accept Republican help—help that he otherwise would not be able to pay for. Simply put, West’s journey to obtain ballot access is clearly not financed by West—his financially defunct campaign cannot possibly pay for this effort. Instead, the effort is financed, operated, and managed by a network of Republican interests whose services and help were knowingly and willfully accepted by West.
- West’s acceptance of ballot access services from Republican operatives and conservative corporations in Arizona, Maine, North Carolina, Pennsylvania, Virginia, Wisconsin, and elsewhere created illegal contributions under the Act.
- First, these services are contributions to West because they are coordinated expenditures. Second, these services are in-kind contributions under the Act’s definition of “contribution” and corresponding Commission regulations.
- Under either theory, these services are prohibited contributions to West and his Campaign, and West knowingly and willfully violated the Act by accepting the contributions.
- For the above reasons, the Commission should find reason to believe that the Respondents and other entities currently unknown violated FECA and corresponding commission regulations. Accordingly, the Commission should conduct an immediate investigation. The FEC should pursue all appropriate sanctions and remedies, including increased penalties and potential criminal referrals resulting from knowing and willful violations of the Act.
Complaint 3: FEC Complaint Against Robert F. Kennedy, Jr., Team Kennedy, IMPG Advocates, Inc., and Paul A. Rossi
- Mr. Kennedy’s and the Campaign’s election improprieties arise from Team Kennedy’s relationship with attorney Paul Rossi which started in October of 2023.
- According to Mr. Rossi’s testimony in New York court, his legal engagement is with Team Kennedy specifically—Mr. Rossi expressly denies a relationship with Mr. Kennedy, stating instead that he is “an independent contractor for Team Kennedy.”
- The Federal Election Campaign Act of 1971 (FECA) and Federal Election Commission (“Commission”) regulations prohibit corporations, including those providing independent contractor services to campaigns, from donating to federal candidates by providing no-cost services.
- The Act also places limits on the amount that permissible contributors may contribute to federal candidates, and it imposes reporting requirements for campaigns like Team Kennedy.
- In violation of these laws, IMPG—a Pennsylvania corporation—and Mr. Rossi contributed in-kind contributions in the form of unpaid legal and other services to Team Kennedy.
- Further, Mr. Kennedy and his Campaign have failed to accurately report any contributions—in-kind or otherwise—from IMPG or Mr. Rossi and have failed to report debts owed to the Law Firm or Mr. Rossi.
- More specifically, as this Complaint will demonstrate, IMPG, through Mr. Rossi, continually renders legal and other ballot access services to the Campaign.
- The Campaign has not paid IMPG or Mr. Rossi for these services, and Mr. Rossi has made clear that he does not intend to provide such services in a volunteer capacity.
- Accordingly, these services are contributions to Team Kennedy in excess of the Act’s dollar limits.
- Should the Campaign reimburse Mr. Rossi or IMPG for these costs, such a scenario would create an impermissible corporate loan from IMPG to the Campaign, further violating the Act.
- For these reasons, there is reason to believe that the parties named in this Complaint regularly engage in activities that are in direct violation of FECA and corresponding Commission regulations.
Complaint 4: IRS Complaint Against More Voter Choice Fund Inc.’s Regardings Its Failure to Timely File IRS Form 8872
- More Voter Choice Fund Inc. (MVC), which is registered as a 527 political organization (“527”), is required to file IRS Form 8872 (“Form 8872”) disclosing contributions and expenditures received and made by the organization for each quarter during a regularly scheduled election year.
- MVC received a contribution on June 14, 2024 in the amount of $250,000 from American Values 2024, a pro-Robert F. Kennedy Jr. Political Action Committee.
- As MVC is a registered section 527 political organization and did not claim an exemption to filing Form 8872, and as they have received a contribution totaling over $200, MVC is required to file either quarterly or monthly Form 8872 reports disclosing their contributions and expenditures.
- MVC filed its second quarterly report on August 19, 2024, which is five weeks late from the July 15, 2024 deadline.
- MVC’s failure to file either a quarterly or monthly Form 8872 report on time for the second calendar quarter or July reporting period, respectively, is a direct violation of the IRC reporting requirements for political organizations.
- As such, MVC should receive a penalty equivalent to 21% of the undisclosed American Values 2024 contribution, totaling $52,500, as well as any additional undisclosed contributions or expenditures MVC received or made during the second calendar quarter reporting period.
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