FEC Investigation Update: March 4th, 2017

Hello friends!

The day after my last telephone call from the FEC, they sent a letter to Jill Stein For President’s (“JSFP“) committee accountant requesting numerous corrections to their 2016 end-of-year filing, as well as requesting evidence from the campaign in regards to their efforts in maintaining compliance with campaign finance laws regarding recount donations.  The FEC added the letter electronically for public viewing, which can be found here. This letter confirms the substance of my phone call with the FEC where they told me they are continuing with the investigation and JSFP still has not responded to the initial complaint notification from the FEC, and other notices from the FEC regarding their campaign finance disclosure (see letter dated February 6th, 2017 here.)

I’ll be discussing the pertinence of this letter in regards to our complaint.

First, in the process of gathering evidence for our complaint to the FEC that JSFP accepted donations from people or organizations who are not legally permitted to donate to U.S. elections, we discovered the web form JSFP used to collect these donations did not require people to enter accurate identifying information (name, address, zip code, employer, occupation.)

By law, the FEC requires campaigns to collect this information for several purposes. One, to track how much money each individual donor contributes to a campaign to ensure they do not exceed the limit of $2,700 individually.  And two, to ensure each donor is legally allowed to donate to U.S. elections as a U.S. citizen, or a non-citizen legally permitted in the U.S.

Our complaint alleges, with numerous examples as proof, that JSFP recklessly allowed people from all over the world to dump money into the recount fund, and then the campaign quickly used this money to create a near-Constitutional crisis.  They did not take enough steps to ensure only Americans were influencing our election processes.

Excerpt from the letter informing JSFP of their failure in this matter:

3. Commission Regulations require that a committee discloses the identification of all individuals who contribute in excess of $200 in an election cycle. (11 CFR § 104.3(a)(4)(i)) Identification for an individual is defined as the full name (initials for first or last name are not acceptable), complete mailing address, occupation, and name of employer. (11 CFR § 100.12) Your report discloses contributions from individuals for which the identification is not complete.

The FEC is giving JSFP an opportunity to correct this:

You must provide the missing information, or if you are unable to do so, you must demonstrate that “best efforts” have been used to obtain the information. To establish “best efforts,” you must provide the Commission with a detailed description of your procedures for requesting the information. Establishing “best efforts” is a three-fold process. First, your original solicitation must include a clear and conspicuous request for the contributor information and must inform the contributor of the requirements of federal law for the reporting of such information. (11 CFR § 104.7(b)(1)) See 11 CFR § 104.7(b)(1)(B) for examples of acceptable statements regarding the requirements of federal law.

However, there was one important caveat to that:

Second, if the information is not provided, you must make one follow-up, stand alone effort to obtain this information, regardless of whether the contribution(s) was solicited or not. This effort must occur no later than 30 days after receipt of the contribution and may be in the form of a written request or an oral request documented in writing. (11 CFR § 104.7(b)(2)) The requests must:

In other words, JSFP had only 30 days by law to attempt to get correct identifying information for each of those donors.  Since it is now March 4th, (or March 2nd by the date of the letter), this deadline is long past due, as JSFP ceased collecting recount donations on or about December 12th, to the best of my recollection (someone else can double-check this for me.) If, by chance, JSFP did as they were required by law and sent written requests for accurate information to the recount donors – but received no reply – then they are required to submit to the FEC any information that they do have, which would include credit card, debit card, and bank billing info of the donors. As noted in the below excerpt from the FEC’s “Campaign Guide” instructions for treasurers:

If the contributor does not respond to the followup request, but the committee possesses the information in its contributor records, fundraising records or prior reports filed during the same two-year election cycle, then the committee must use that information when disclosing the contribution. 104.7(b)(3).

This means that all those “Anonymous” or “John Doe” donations JSFP solicited electronically through social media mass marketing for the recount campaign will need to be reported to the FEC with credit/debit/bank billing information for the donors.  We believe this will undoubtedly prove they accepted and used illegal donations for the recount.

Secondly, our collection of evidence discovered that JSFP’s web form solicitation did not adequately – or at all – inform donors that they are required by law to give proper, legal personal information with their donation.  In the FEC’s letter, they directly advise JSFP that they must duly inform the donors of this requirement when collecting donor information.

• clearly ask for the missing information, without soliciting a contribution;

• inform the contributor of the requirements of federal law for the reporting of such information, and [underline emphasis mine]

• if the request is written, include a pre-addressed post card or return envelope.

Thirdly, JSFP improperly included the recount donations in the election-year total contributions to the campaign.  This is a big no-no, as a “recount” campaign is separate from an election campaign and all monies collected must be used for and accounted for independent of the election campaign.

When JSFP submitted their post-general and end-of-year reports to the FEC (found here and here, respectively) they tallied all general election donations and recount donations together, and simply just reported to the FEC the recount donations as “unitemized donations” (unitemized simply means they did not individually report each donation with individual donor information).

In the letter, the FEC informed JSFP that these recount donations must be reported separately, as itemized donations:

– Please be advised that contributions to a recount fund should be itemized on Schedule A-P supporting Line 21 of the Detailed Summary Page. They should not be listed on Line 17(a)(i). (FEC Advisory Opinion 2006-24)

And finally, the FEC issued an ultimatum to JSFP that they must comply with the information request and records corrections, and no extensions will be permitted.  Failure to comply may result in the FEC taking enforcement action against JSFP.

Please note you will not receive an additional notice from the Commission on this matter. Adequate responses received on or before this date will be taken into consideration. Requests for extensions of time in which to respond will not be considered. Failure to comply with the provisions of the Act may result in an enforcement action against the committee. Any response submitted by your committee will be placed on the public record and will be considered by the Commission prior to taking enforcement action.

My final thoughts: I’m really interested in seeing if JSFP spends the time and money to go through >$7 million worth of recount donations to gather and correct all the information they should have collected and reported in the first place.  They have until April 6th, 2017 to respond, so we shall see!

  • Phillip

March 1st, 2017 Update…

Hey everyone!  Thanks for sticking with us and checking once in a while for any updates.  I took a brief phone call from the FEC today regarding the current status of our case.  It’s not of huge substance, but is a little revealing – both in how, I believe, disorganized JSFP’s campaign is/was, and the backlog of cases (MURs) is at the FEC…so here goes:

Back when we (Amy and I) first filed the complaint, we were in a huge time crunch, as I’m sure you all can imagine due to how quickly everything developed over the Thanksgiving holiday.  I began researching the data myself after receiving some tips from other websleuths and then started compiling it all over the long holiday weekend.  Once I was convinced I had enough to satisfy an FEC investigation (Monday or Tuesday after Thanksgiving), I put out a request for help via Twitter. I had no experience in writing formal legal complaints, and needed either a paralegal or a J.D. to help me. That’s when Amy stepped up to the plate and really brought it all together and gave me the motivation to see this through.

Between myself, Amy, and other anonymous people (anonymous to the world, but I knew who they were) who worked on it, we were ready to “send it in.”  I called the FEC that Tuesday to make sure we had it all put together properly and ask some questions. The main question was this: would it be ‘okay’ for just me to sign the sworn affidavit and get it notarized, and just add Amy’s information as a complainant via addendum, or would we need to have Amy sign an affidavit, too?  We were in a real time crunch and wanted to get it in the FEC’s hands by Thursday or Friday, and if we needed to have us both do affidavits, that would have caused another 5-day delay in delivery to the FEC.  They assured us it would be okay the way we were proposing to do it.

Fast-forward to today: there was confusion at the FEC from one of the paralegals who had sent a couple letters to Amy telling her she needed to do an affidavit in order for us to proceed.  I knew this is not at all what I was told in December, so I called FEC to get clarification and they called me back today.  It turns out she was just confused and all is good.  JSFP was sent our complaint via the FEC back in December – per standard procedures for proper and sufficient MURs, and the FEC is still waiting on a response from JSFP’s campaign.

In other words: JSFP’s legal team has yet to submit any response to the FEC, and time is quickly running out for them to do so (per FEC complaint procedures, the initial complaint “back and forth” process is given 90 days.  You do the math.) If the Respondent does not respond – or answer the initial complaint – the FEC goes on to the next step in the investigation process, with no answer from the Respondent.

Also interesting of note: I’ve been watching the campaign finance submissions on the FEC website, and JSFP’s campaign has still not submitted a full itemized donors list, as required by law, for all the people who donated to the recount effort.  They did submit an itemized list for the actual campaign, which included donations even as late as December 19th, and expenditures such as “performance bonuses” the last week of December.

I’m guessing it’s taking them quite a long time to go through over $7 million worth of donations and refunding all the illegal ones, before submitting their report to the FEC and a response to our complaint.  Who knows?  Hopefully we’ll have a clear answer on it all very soon, so stay tuned!

-Phillip

Unimportant notification letter

I’m uploading and attaching this very unimportant letter which provides nothing of substance, as a courtesy to our new fan Joe Hepperle. Careful examination of the FEC complaint procedures should tell you that since they did, in fact, assign a MUR # and send us this letter, they did conclude the matter as being sufficient and requires action by the FEC:

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OOPS!

December 12 Update:

Hello friends!

Touching on what I said Friday after telephone conversation with the FEC that day, I now have written notice via mail.  As I am still unable to comment on exactly what the FEC is doing or is not doing, I can say that we may or may not receive further communication from them until the matter is fully resolved.

If you view the complaint procedures on the FEC website, a “fully resolved” complaint can take up to 90 days.

Russians Did Not “Hack” Our Election, the Left is Just in Denial

Today has made me quite nervous for the first time since Clinton conceded, regarding the election. I truly fear for our country. Zero sources are able to be cited in any of this fake news about Russian Interference in the election. The left is getting more and more desperate and calling for Trump’s assassination. They are quite literally, a party full of insane people. Jill Stein’s recount effort has been only one of many totally ridiculous excuses to put off the left’s need to come to terms with their own loss, and it’s obvious it isn’t going as planned. Jill Stein is still trying to raise money though, and she has even removed her donation ticker to show her money totals from her site. They are all in the denial stage of grief over the loss by their corrupt candidate and they simply can’t come to terms with a Trump Presidency.

Despite what some are saying, that there are bigger stories than Pizza Gate, this is one story that I care deeply about and it is literally the deciding factor for a lot of voters. It is hardly fake news. As I pointed out on Twitter earlier, if Wikileaks was fake news, Chelsea Manning would not be in federal prison for leaking intelligence to Wikileaks. Wikileaks has a perfect record, better than anyone else in the world. Nothing they have ever published has come back to be false. Because all of it is leaks.

That being said – I’ve been looking into Pizza Gate and I have not seen one allegation I could point to as being unfounded or false. I’m currently working on a story with my friend Evelyn Pringle about this and it is obvious to me that every excuse the Democrats have come up with is meant to distract everyone from covering Pizza Gate.

The Clinton Foundation has been linked to human trafficking in Haiti, and Hillary is responsible for helping Laura Silsby get off for attempted kidnapping of numerous Haitian children who had families, for her fake orphanage. There are reports that the human trafficking networks encompass several different facets, from entertainment, to organ harvesting. This reaches as near as Planned Parenthood and as far away as China.

Human beings were not put here on this Earth to be exploited, sold and used up for profit. We deserve a government that respects our liberty, and doesn’t treat us as a means to an end or a potential profit. The government is not being run by people who have morals, or respect for life. We need to get rid of as many repeat politicians as we possibly can and drain this political climate of its lifeblood which is the blackmail material being used by those in power to keep politicians from exposing their crimes.

Investigating Pizza Gate will have to be done, even if it is done by The People and not the corrupt CIA or members of the FBI or police. Whistleblower protections are in place and all we need is the right AG or prosecutors who are willing to prosecute these criminals for what they do.

Today I was a victim of censorship and it is obviously not Russians who cut off my phone, and Evelyn Pringle’s phone, while we were discussing the pedophile child trafficking scandal of Pizza Gate on her show on PRN.fm, “Focus on the Facts.” This is the second time “they” have done this to us in the past few weeks on this topic. I’ve been working with Evelyn for several years now, and never experienced this type of censorship until recently. Both of us got cut off at the halfway mark (about 30 minutes in). We both tried to call back in for about 20 minutes but kept on getting a message that the phone could not connect to the number we were dialing. She got cut off from her OWN show. The first time they did this was a couple of weeks ago, at the beginning of her show, for about 5-10 minutes. This was 30 entire minutes of censorship during a one hour show.

Needless to say, they won’t be able to stop the investigation of Pizza Gate no matter how many times, or how many different people they try to censor. We will continue our investigative work and so will millions of other concerned Americans. This issue is never going to go away until all our children are safe.

This is not Communist China. This is the U.S.A. We will not live under a Patriot Act regime of terror on the American children. We will not allow our next generation to be your targets.

#denial, #evelyn-pringle, #focus-on-the-facts, #human-trafficking, #organ-harvesting, #prn-fm

Jill Stein’s Recount Has Zilch to Do With Integrity

Sorry Jill, but war-mongering Hillary Clinton who enjoys taking money from the Saudis in exchange for allowing the murder of our own ambassador, and who wants to ban free speech and journalism unless it’s controlled propaganda from the DNC approval shadow teams, and who wants to go to war with anyone who reads her emails on her super non-secret server… is an unrepentant wannabe dictator. Donald Trump was the President-elect for 5 minutes and suddenly war with Russia is off the table. You said yourself that Hillary Clinton could bring on nuclear war… I guess you’ll say or do anything for enough money, huh?

No, your recount couldn’t possibly be part of a ploy to do the dirty work for Hillary Clinton who is so butt-hurt that she now wants to pass laws banning specific websites and journalists from being allowed to freely conduct business. No, your recount couldn’t possibly have anything to do with protecting the DNC from Wikileaks whistleblower sources. No your recount couldn’t possibly be because you don’t like Donald Trump, it’s obviously all about (imaginary) “Russian Hacking.” Uh huh…

Please tell us Jill, if someone manages to hack into your email account and finds something damning on you, who will be to blame, for the information that is found – you, or the hypothetical hacker?

Integrity is about personal integrity as much as it is about the integrity of the people. You should learn this lesson before you end up exactly like Hillary Clinton.

#benghazi, #election-fraud, #hillary-clinton