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DENNIS J. HERRERA, State Bar #139669
City Attorney
YVONNE R. MERE, State Bar #173594
Chief of Complex & Affirmative Litigation
SARA J. EISENBERG, State Bar #269303
Deputy City Attorney
1390 Market Street, 6th Floor
San Francisco, California 94102-5408
Telephone: (415) 554-3800
Facsimile: (415) 437-4644
E-Mail: yvonne.meré @sfgov.org
E-Mail: sara.eisenberg @sfgov.org
Attorneys for Defendant
CITY AND COUNTY OF SAN FRANCISCO
ELECTRONICALLY
FILED
Superior Court of California,
County of San Francisco
07/29/2016
Clerk of the Court
BY-EDNALEEN ALEGRE
Deputy Clerk
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
UNLIMITED JURISDICTION
MARK FARRELL FOR DISTRICT 2
SUPERVISOR 2010 and MARK FARRELL,
Petitioners and. Plaintiffs,
vs.
CITY AND COUNTY OF SAN
FRANCISCO; SAN FRANCISCO ETHICS
COMMISSION; CITY AND COUNTY OF
Case No. CGC-16-551745
DECLARATION OF ANDREW SHEN IN
SUPPORT OF THE CITY AND COUNTY OF
SAN FRANCISCO’S OPPOSITION TO
CROSS-DEFENDANT MARK FARRELL’S
SPECIAL MOTION TO STRIKE THE CITY
AND COUNTY OF SAN FRANCISCO’S
CROSS-COMPLAINT
SAN FRANCISCO TREASURER AND TAX | Judge: Hon. Harold E. Kahn
COLLECTOR; and DOES 1 to 100, inclusive, | Date: August 11, 2016
Time: 9:30am
Respondents and Defendants. Dep’t: 302
Date Action Filed: April 29, 2016
Trial Date: Not set
CITY AND COUNTY OF SAN FRANCISCO,
Cross-complainant,
vs.
MARK FARRELL, an individual; and ROES 1
to 25, inclusive,
Cross-defendants. _
Shen Decl. ISO Opp. to Special Motion to Strike; Case No. CGC-16-551745 cattchmnt\pldg opp to anti-
slapp_shen decl.docxaI Dn WwW
L Andrew Shen, declare as follows:
1. Tam an attorney admitted to practice law in the State of California. I am employed by
the City and County of San Francisco as a Deputy City Attorney. I have personal knowledge of the
facts stated in this declaration. If called as a witness, I could and would competently testify to the
facts set forth below.
2. Attached hereto as Exhibit A is a true and correct copy of the signed stipulation
between the Fair Political Practices Commission (“FPPC”), Chris Lee, and “Common Sense Voters,
SF 2010; Vote for Mark Farrell for District 2 Supervisor.” I obtained this document via a Public
Records Act Request to the FPPC.
3. Attached hereto as Exhibit B are true and correct copies of Common Sense Voters’
campaign finance reports (FPPC Form 460s) for 2010 and 2011, which I obtained from the San
Francisco Ethics Commission (“SFEC”). Page numbers have been added to aid in citation to the
documents.
4. Attached hereto as Exhibit C is a true and correct copy of the meeting minutes of the
SFEC’s March 23, 2015 meeting, which were printed from the SFEC website at
http://www.sfethics.org/ethics/2015/04/minutes-march-23-2015.html on July 27, 2016.
5. Attached hereto as Exhibit D is a true and correct copy of the meeting minutes of the
SFEC’s June 5, 2015 meeting, which were printed from the SFEC website at
http://www.sfethics.org/ethics/2015/06/minutes-june-5-2015 html on July 27, 2016.
6. Attached hereto as Exhibit E is a true and correct copy of the meeting minutes of the
SFEC’s March 24, 2008 meeting, which were printed from the SFEC website at
http://sfgov3.org/ftp/ethics_archive/sfarchive.org/index3dcb.html ?dept=268 1 &sub=&dtype=279 1 &ye
ar= on July 28, 2016.
I declare under penalty of perjury under the laws of the State of California that the foregoing is
true and correct. Executed this 28th day of July, 2016, in San Francisco, California.
ANDREW SHEN
1
Shen Decl. ISO Opp. to Special Motion to Strike; Case No. CGC-16-551745 c’\attchmntipldg opp to anti-
slapp_shen decl.docxEXHIBIT ACO wm AY ADH RB wH =
GARY S. WINUK
Chief of Enforcement
GALENA WEST
Commission Counsel TV
FAIR POLITICAL PRACTICES COMMISSION
428 J Street, Suite 620
Sacramento, CA 95814
Telephone: (916) 322-5660
Attorneys for Complainant
BEFORE THE FAIR POLITICAL PRACTICES COMMISSION
STATE OF CALIFORNIA
Tn the Matter of FPPC No. 10/973
)
) STIPULATION, DECISION and
COMMON SENSE VOTERS, SF 2010; VOTE ) ORDER
FOR MARK FARRELL FOR DISTRICT2 +)
SUPERVISOR AND CHRIS LEE )
)
)
)
Respondents.
Complainant Fair Political Practices Commission and Respondents Common Sense Voters, SF
2010; Vote for Mark Farrell for District 2 Supervisor committee and Chris Lee agree that this
Stipulation will be submitted for consideration by the Fair Political Practices Commission at its next
regularly scheduled meeting.
The parties agree to enter into this Stipulation to resolve all factual and legal issues raised in this
matter and to reach a final disposition without the necessity of holding an administrative hearing to
determine the liability of Respondents, pursuant to Section 83116 of the Government Code. ~
Respondents understand, and hereby knowingly and voluntarily waive, any and all procedural
rights set forth in Sections 83115.5, 11503 and 11523 of the Government Code, and in Sections 18361.1
through 18361.9 of Title 2 of the California Code of Regulations. This includes, but is not limited to,
the right to personally appear at any administrative hearing held in this matter, to be represented by an
STIPULATION, DECISION AND ORDER
FPPC NO. 10/973Cm IY AH BR WBN
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attorney at Respondents’ own expense, to confront and cross-examine all witnesses testifying at the
hearing, to subpoena witnesses to testify at the hearing, to have an impartial administrative law judge
preside over the hearing as a hearing officer, and to have the matter judicially reviewed.
It is further stipulated and agreed that Respondents Common Sense Voters, SF 2010; Vote for
Mark Farrell for District 2 Supervisor committee and Chris Lee violated the Political Reform Act by
failing to file an amended statement of organization within 10 days to disclose that Respondent
Committee was controlled by a candidate, in violation of Sections 84102, subdivisions (e) and (g), and
84103, subdivision (a), of the Government Code (1 count) and failing to use proper sender identification
on mass mailers sent in support of Mark Farrell for District-2 Supervisor and against his opponent, Janet
Reilly, which failed to display the name of the candidate controlling the committee, in violation of
Section 84305 (4 counts). All counts are described in Exhibit 1, which is attached hereto and
incorporated by reference as though fully set forth herein. Exhibit 1 is a true and accurate summary of
the facts in this matter.
Respondents agree to the issuance of the Decision and Order, which is attached hereto.
Respondents also agree to the Commission imposing upon them an administrative penalty in the amount
of Fourteen Thousand Five Hundred Dollars ($14,500). A cashier’s check from Respondents in said
amount, made payable to the “General Fund of the State of California,” is submitted with this
Stipulation as full payment of the administrative penalty, to be held by the State of California until the
Commission issues its decision and order regarding this matter. The parties agree that in the event the
Commission refuses to accept this Stipulation, it shall become null and void, and within fifteen (15)
business days after the Commission meeting at which the Stipulation is rejected, all payments tendered
by Respondents in connection with this Stipulation shall be reimbursed to Respondents. Respondents
further stipulate and agree that in the event the Commission rejects the Stipulation, and a full evidentiary)
hearing before the Commission becomes necessary, neither any member of the Commission, nor the
Executive Director, shall be disqualified because of prior consideration of this Stipulation.
2
STIPULATION, DECISION AND ORDER,
FPPC NO. 10/973Dated: HL Wit
/ Gary Winuk, Enforcement Chief,
on behalf of the
olitical Practices Commission
Ue
ris Lee, Respondent
Individually and on beKalf of Common Sense Voters,
ark
SF 2010; Vote for Farrell for District 2 Supervisor
DECISION AND ORDER
The foregoing Stipulation of the parties “In the Matter of Respondents Common Sense Voters,
SF 2010: Vote for Mark Farrell for District 2 Supervisor and Chris Lee,” FPPC No. 10/973, including all
attached exhibits, is hereby accepted as the final decision and order of the Fair Political Practices
Commission, effective upon execution below by the Chairman.
IT IS SO ORDERED.
Dated: // [nfo One Kan be
Joafin Remke, Chair /
Ffir Political Practices Commission
3
STIPULATION, DECISION AND ORDER
FPPC NO. 10/973EXHIBIT 1
INTRODUCTION
In November 2010, the City and County of San Francisco held a ranked-choice voting
election to elect the representative for District 2 of the Board of Supervisors. Respondent
Common Sense Voters, SF 2010; Vote for Mark Farrell for District 2 Supervisor (“Respondent
CSV”) qualified as a primarily formed committee on October 1, 2010, and registered on October
13, 2010. At all relevant times, Respondent Stacy Owens (“Respondent Owens”) was the
treasurer of the Respondent CSV and Henry C. Levy, was assistant treasurer. The principal
officer for Respondent CSV was Jack Helfand (“Principal Officer Helfand”).
In August 2009, Mark Farrell created a campaign committee for the November 2010
Supervisor race named the Mark Farrell for District 2 Supervisor 2010 committee (“Farrell
Committee”). At all relevant times, Respondent Owens was the treasurer of the Respondent.
CSV and Henry C. Levy, was assistant treasurer. Respondent CSV’s Principal Officer, Principal
Officer Helfand, was a member of the fundraising subcommittee for the Farrell Committee for
the November 2010 election campaign before leaving to form Respondent CSV. During this
campaign, the Farrell Committee retained Chris Lee of Townsquare Consulting (“Respondent
Lee”), as its campaign consultant.
In September 2010, incumbent Supervisor Michela Alioto-Pier was informed by the
California courts that she was unable to run for reelection for her District 2 Supervisor seat. She
then chose Mark Farrell, a candidate for District 2 Supervisor, to endorse as her replacement.
She and her staff worked with Mark Farrell and his campaign consultant, Respondent Lee, during
the course of the campaign to offer her endorsement and appear at events in support of Mark
Farrell. In addition to this interaction with Mark Farrell and his staff, Supervisor Alioto-Pier was
also in charge of the fundraising activities for Respondent CSV. Supervisor Alioto-Pier raised
86% of the contributions received by Respondent CSV.
While Respondent Lee was a campaign consultant for the Farrell Committee, he also
coordinated with Respondent CSV, Principal Officer Helfand and the campaign consultant for
Respondent CSV, MSHC Partners, regarding the setup, fundraising, and initial campaign
planning of Respondent CSV. Respondent Lee reached out to Principal Officer Helfand, who
had previously volunteered for the Farrell Committee, to assist Principal Officer Helfand with the
formation of Respondent CSV. In addition, Respondent Lee also had contacts with another mail
house used by Respondent CSV to produce a door hanger. The door hanger was being produced
as a Farrell support piece containing an endorsement letter written by Supervisor Alioto-Pier.
Respondent Lee’s interactions with Respondent CSV and its staff caused Respondent CSV to
become a controlled committee of Mark Farrell, instead of a committee primarily formed for his
election, The evidence supports the finding that Mark Farrell did not authorize Respondent Lee,
as an agent of the Farrell Committee, to coordinate with Respondent CSV.
1
EXHIBIT | IN SUPPORT OF STIPULATION, DECISION AND ORDER
FPPC NO. 10/973Under the Political Reform Act! (the “Act”), any person who violates any provision of
this title, who purposely or negligently causes any other person to violate any provision of this
title, or who aids and abets any other person in the violation of any provision of this title, shall be
liable under the provisions of this chapter. As a result, Respondents were required to amend the
statement of organization to reflect being a controlled committee and have all mailers identify the
Farrell Committee as the sender of the mailer.
For the purposes of this Stipulation, Respondents’ violations of the Act are stated as
follows:
COUNT 1:
COUNT 2:
COUNT 3:
Respondents Common Sense Voters, SF 2010; Vote for Mark Farrell for District
2 Supervisor failed to file an amended statement of organization within 10 days to
disclose that Respondent Committee was a controlled committee and failed to add
the name of the controlling candidate to the committee name. Respondent Chris
Lee purposely or negligently caused this violation (within the meaning of Section
83116.5) through his role of campaign consultant for the Farrell Committee and
his coordination with Respondent CSV, Principal Officer Helfand and the
campaign consultant for Respondent CSV, MSHC Partners, regarding CSV’s
setup, fundraising, and initial campaign planning. In this way, Respondents
Common Sense Voters, SF 2010; Vote for Mark Farrell for District 2 Supervisor
and Chris Lee violated Government Code Sections 84102, subdivisions (e) and
(g), and 84103, subdivision (a).
Respondents Common Sense Voters, SF 2010; Vote for Mark Farrell for District
2 Supervisor failed to use proper sender identification on a mass mailer sent on or
about October 17, 2010, sent in support of Mark Farrell for District 2 Supervisor
and against his opponent, Janet Reilly, which failed to display the name of the
candidate controlling the committee. Respondent Chris Lee purposely or
negligently caused this violation (within the meaning of Section 83116.5) through
his role of campaign consultant for the Farrell Committee and his coordination
with Respondent CSV, Principal Officer Helfand and the campaign consultant for
Respondent CSV, MSHC Partners, regarding CSV’s setup, fundraising, and initial
campaign planning. In this way, Respondents Common Sense Voters, SF 2010;
Vote for Mark Farrell for District 2 Supervisor and Chris Lee violated
Government Code Section 84305.
Respondents Common Sense Voters, SF 2010; Vote for Mark Farrell for District :
2 Supervisor failed to use proper sender identification on a mass mailer sent on or
about October 19, 2010, sent in support of Mark Farrell for District 2 Supervisor
and against his opponent, Janet Reilly, which failed to display the name of the
"The Political Reform Act is contained in Government Code Sections 81000 through 91014. All statutory
references are to the Government Code as it was in effect at the time of the violations, unless otherwise indicated.
The regulations of the Fair Political Practices Commission are contained in Sections 18110 through 18997 of Title 2
of the California Code of Regulations. All regulatory references are to Title 2, Division 6 of the California Code of
Regulations as in effect at the time of the violations, unless otherwise indicated.
2
EXHIBIT | IN SUPPORT OF STIPULATION, DECISION AND ORDER
FPPC NO. 10/973COUNT 4:
COUNT 5:
candidate controlling the committee. Respondent Chris Lee purposely or
negligently caused this violation (within the meaning of Section 83116.5) through
his role of campaign consultant for the Farrell Committee and his coordination
with Respondent CSV, Principal Officer Helfand and the campaign consultant for
Respondent CSV, MSHC Partners, regarding CSV’s setup, fundraising, and initial
campaign planning. In this way, Respondents Common Sense Voters, SF 2010;
Vote for Mark Farrell for District 2 Supervisor and Chris Lee violated
Government Code Section 84305.
Respondents Common Sense Voters, SF 2010; Vote for Mark Farrell for District
2 Supervisor failed to use proper sender identification on two mass mailers sent
on or about October 20, 2010, sent in support of Mark Farrell for District 2
Supervisor and against his opponent, Janet Reilly, which failed to display the
name of the candidate controlling the committee. Respondent Chris Lee
purposely or negligently caused this violation (within the meaning of Section
83116.5) through his role of campaign consultant for the Farrell Committee and
his coordination with Respondent CSV, Principal Officer Helfand and the
campaign consultant for Respondent CSV, MSHC Partners, regarding CSV’s
setup, fundraising, and initial campaign planning. In this way, Respondents
Common Sense Voters, SF 2010; Vote for Mark Farrell for District 2 Supervisor
and Chris Lee violated Government Code Section 84305.
Respondents Common Sense Voters, SF 2010; Vote for Mark Farrell for District
2 Supervisor failed to use proper sender identification on a mass mailer sent on or
about October 25, 2010, sent in support of Mark Farrell for District 2 Supervisor
and against his opponent, Janet Reilly, which failed to display the name of the
candidate controlling the committee. Respondent Chris Lee purposely or
negligently caused this violation (within the meaning of Section 83116.5) through
his role of campaign consultant for the Farrell Committee and his coordination
"with Respondent CSV, Principal Officer Helfand and the campaign consultant for
Respondent CSV, MSHC Partners, regarding CSV’s setup, fundraising, and initial
campaign planning. In this way, Respondents Common Sense Voters, SF 2010;
Vote for Mark Farrell for District 2 Supervisor and Chris Lee violated
Government Code Section 84305.
SUMMARY OF THE LAW
When the Political Reform Act was enacted, the people of the state of California found
and declared that previous laws regulating political practices suffered from inadequate
enforcement by state and local authorities. (Section 81001, subd. (h).) To that end, Section 81003
requires that the Act be liberally construed to achieve its purposes.
A committee includes any person or combination of persons who receive contributions
totaling $1,000 or more in a calendar year. (Section 82013, subd. (a).) This type of committee
commonly is referred to as a recipient committee. Section 82047.5 defines a primarily formed
3
EXHIBIT | IN SUPPORT OF STIPULATION, DECISION AND ORDER
FPPC NO. 10/973committee, in relevant part, as a committee which is formed or exists primarily to support or
Oppose a single candidate, a single measure, a group of specific candidates being voted upon in
the same city, county, or multicounty election, or two or more measures being voted upon in the
same city, county, multicounty, or state election. By contrast, a controlled committee is one that
is controlled directly or indirectly by a candidate or that acts jointly with a candidate in
connection with the making of expenditures. (Section 82016.) A candidate controls a committee
if the candidate, the candidate's agent, or any other committee-controlled by the candidate has a
significant influence on the actions or decisions of the committee. Section 84102, subdivision
(g), requires any other information shall be required by Commission regulations that are
consistent with the purposes and provisions of this chapter.
To further the well-established state interest in the integrity of its election processes, the
Act imposes certain restrictions on candidates for elective offices, chiefly in the form of
contribution limits and disclosure requirements. To insure that candidates and their supporters do
not evade the Act’s contribution limits and disclosure requirements, these restrictions are
extended to include the activities of persons who coordinate campaign spending with the
candidates themselves, or with the candidates’ committees and agents.
Duty to Amend Statement of Organization
Section 84101 requires every recipient committee to file a statement of organization with
the Secretary of State. Section 84102, subdivision (a), states that the statement of | organization
shall include the committee’s name, street address and telephone number, if any. The statement
of organization shall also include the full name, street address and telephone number, if any, of
the treasurer and other principal officers of the committee. (Section 84102, subd. (c).)
Section 84102, subdivision (e), states that the statement of organization shall include a
statement of whether the committee is independent or controlled, and if controlled, the name of
each candidate or state measure proponent by which it is controlled, or the name of any
controlled committee with which it acts jointly. Regulation 18402, subdivision (c), requires that
whenever identification of a committee is required by law, the identification shall include the full
name of the committee as required in the statement of organization including the last name of
each candidate that controls the committee.
Section 84103, subdivision (a), requires that whenever there is a change in any of the
information contained in a statement of organization, an amendment shall be filed within 10 days
to reflect the change.
Duty to Disclose Proper Sender Identification
Section 84305, subdivision (a), requires candidates and committees to properly identify
themselves when sending a mass mailing. Specifically, the statute provides that no candidate or
committee shall send a mass mailing unless the name, street address, and city of the candidate or
committee are shown on the outside of each piece of mail in the mass mailing. If the sender of
the mass mailing is a controlled committee, Section 84305, subdivision (c), requires that the
4
EXHIBIT 1 IN SUPPORT OF STIPULATION, DECISION AND ORDER
FPPC NO. 10/973name of the candidate, as well as the name of the committee, be included on the mass mailing.
Section 82041.5 defines a “mass mailing” as over two hundred substantially similar
pieces of mail, but does not include a form letter or other mail which is sent in response to an
unsolicited request, letter or other inquiry. Regulation 18435, subdivision (a), clarifies this
section, and further defines a mass mailing as over two hundred substantially similar pieces of
mail sent in a calendar month.
Joint and Several Liability for Causing Another to Violate the Act
Recognizing that the law should hold accountable not only those persons who directly
commit violations, but also those persons who encourage or assist in the commission of
violations, the Act extends liability for a violation to include anyone who causes, either
intentionally or negligently, or aids and abets in the violation of the Act. Section 83116.5
imposes liability for violating the Act on those who: (i) violate the Act; (ii) purposely or
negligently cause another to violate the Act; or (iii) aid and abet another in violating the Act.
When two or more persons are responsible for a violation of the Act, they are jointly and
severally liable. (Section 91006.)
SUMMARY OF THE FACTS
In November 2010, the City and County of San Francisco held a ranked-choice voting
election to elect the representative for District 2 of the Board of Supervisors. Respondent CSV
qualified as a primarily formed committee on October 1, 2010, and registered on October 13,
2010. As discussed above, while Respondent Lee was a campaign consultant for the Farrell
Committee, he also coordinated with Respondent CSV, Principal Officer Helfand and the
campaign consultant for Respondent CSV, MSHC Partners, regarding the setup, fundraising and
initial campaign planning of Respondent CSV. Respondent Lee’s interactions with Respondent
’ CSV and its staff caused Respondent CSV to become a controlled committee of Mark Farrell,
instead of a committee primarily formed for his election. As such, under the Act, Respondents
were required to amend the statement of organization to reflect being a controlled committee and
have all mailers identify the Farrell Committee as the sender of the mailer.
COUNT1
Failure to Amend Statement of Organization
Respondent CSV qualified as a primarily formed committee on October 1, 2010, and
filed a statement of organization reflected that information on October 13, 2010. Respondent
CSV disclosed that it was formed to support candidate Mark Farrell for County Supervisor of the
City and County of San Francisco for District 2. As mentioned above, Mark Farrell had a
campaign committee for this election, the Farrell Committee. While Respondent Lee was a
campaign consultant for the Farrell Committee, he coordinated with Respondent CSV, Principal
Officer Helfand and the campaign consultant for Respondent CSV, MSHC Partners, regarding its
setup, fundraising and initial campaign planning. In addition, Respondent Lee also had contacts
with another mail house used by Respondent CSV to produce a door hanger. The door hanger
5
EXHIBIT | IN SUPPORT OF STIPULATION, DECISION AND ORDER
FPPC NO. 10/973was being produced as a Farrell support piece containing an endorsement letter written by
Supervisor Alioto-Pier. Through these interactions, Respondent Lee, an agent of the Farrell
Committee, thereby had significant influence on the Respondent CSV and thus caused
Respondent CSV to become a controlled committee of Mark Farrell.
As a candidate controlled committee, Respondents were required to include in the name
of the candidate controlling the committee in the name of Respondent Committee. Respondents
failed to provide this required information in the name of Respondent CSV and failed to amend
the statement of organization.
Thus, Respondent CSV failed to file an amended statement of organization within 10
days to disclose that Respondent Committee was a controlled committee and failed to add the
name of the controlling candidate to the committee name. Respondent Chris Lee caused this
violation (within the meaning of Section 83116.5) through his role of campaign consultant for
the Farrell Committee and his coordination with Respondent CSV, Principal Officer Helfand and
the campaign consultant for Respondent CSV, MSHC Partners, regarding its setup, fundraising
and initial campaign planning. In this way, Respondents CSV and Chris Lee violated
Government Code Sections 84102, subdivisions (e) and (g), and 84103, subdivision (a).
COUNTS 2-5
Failure to Disclose the Controlling Candidate in Mass Mailings
Section 82041.5 and Regulation 18435 define a “mass mailing” as over 200 substantially
similar pieces of mail sent in a calendar month, which are not sent in response to an unsolicited
request. Section 84305, subdivision (a), requires candidates and committees to properly identify
themselves when sending a mass mailing. Pursuant to Section 84305, subdivision (b), ifa
candidate or committee sends a mass mailing, the name, street address, and city of the candidate
or committee must be shown on the outside of each piece of mail sent as part of the mass
mailing, in no less than 6-point type, which shall be in a color or print which contrasts with the
background, so as to easily legible. Furthermore, if the sender of a mass mailing is a controlled
committee, the name of the person controlling the committee must also be included in each piece
of mail. (Section 84305, subd. (c).)
Respondents Common Sense Voters, SF 2010; Vote for Mark Farrell for District 2
Supervisor failed to use proper sender identification on mass mailers sent on or about October
17, 2010, through October 25, 2010, sent in support of Mark Farrell for District 2 Supervisor and
against his opponent, Janet Reilly, which failed to display the name of the candidate controlling
the committee. Respondent Chris Lee caused this violation (within the meaning of Section
83116.5) through his role of campaign consultant for the Farrell Committee and his coordination
with Respondent CSV, Principal Officer Helfand and the campaign consultant for Respondent
CSV, MSHC Partners, regarding its setup, fundraising and initial campaign planning. The
mailers are detailed below:
6
EXHIBIT | IN SUPPORT OF STIPULATION, DECISION AND ORDER
FPPC NO. 10/973Mailer Title Date Quantity (approx.)
The Man Behind the Curtain 10/17/10 12,248
Captain Mysterious Mail Piece 10/19/10 20,239
CMV1003: Proposition H 10/20/10 40,478
Negative/CMV 1005: Comparative
11757 Farrell Doorhanger 03 10/25/10 25,000
Thus, Respondents Common Sense Voters, SF 2010; Vote for Mark Farrell for District 2
Supervisor and Chris Lee violated Government Code Section 84305 four times.
CONCLUSION
This matter consists of five counts of violating the Act, which carries a maximum
administrative penalty of five thousand dollars ($5,000) per count.
In determining the appropriate penalty for a particular violation of the Act, the
Enforcement Division considers the typical treatment of a violation in the overall statutory
scheme of the Act, with an emphasis on serving the purposes and intent of the Act. The
Enforcement Division also considers the facts and circumstances of the violation in context of
the factors set forth in Regulation 18361.5, subdivision (d)(1)-(6), which include: the seriousness
of the violations; the presence or lack of intent to deceive the voting public; whether the violation
was deliberate, negligent, or inadvertent; whether the Respondent demonstrated good faith in
consulting with Commission staff; whether there was a pattern of violations; and whether upon
learning of the violation the Respondent voluntarily filed amendment to provide full disclosure.
Additionally, liability under the Act is governed in significant part by the provisions of Section
91001, subdivision (c), which requires the Commission to consider whether or not a violation is
inadvertent, negligent or deliberate, and the presence or absence of good faith, in applying
remedies and sanctions,
Statement of Organization: Respondents had a duty to file an amendment to the
statement of organization to disclose it was no longer a primarily formed committee but a
controlled committee after the actions of Respondent Lee caused this status change. The
amendment was needed to include in the name of the candidate controlling the committee in the
name of Respondent CSV. Respondents failed to provide this required information in the name
of Respondent CSV and failed to amend the statement of organization.
The failure to amend the statement of organization concealed from the public the true
nature of the Respondent CSV’s activity. In aggravation, these actions coordinating the
committees gave an unlawful advantage to one side in an election which was decided by only the
slimmest of margins. In mitigation, Respondents filed other campaign information correctly and
the name of the committee disclosed its support of Mark Farrell.
Other cases regarding the failure to amend a statement of organization recently approved
by the Commission include:
7
EXHIBIT | IN SUPPORT OF STIPULATION, DECISION AND ORDER
FPPC NO. 10/973In the Matter of Put California Back to Work, Sponsored by the Civil Justice Association
of California and J. Richard Eichman, FPPC No. 10/504. Respondents formed as a state general
purpose committee and failed to amend the statement of organization when the committee
became primarily formed. The committee was aware of the requirement, having been told by the
treasurer, and chose not to timely amend the statement. A $3,500 stipulated settlement was
approved for this violation by the Commission on March 15, 2012.
In the Matter of Californians for SAFE Food, a coalition of public health and food safety
experts, labor unions, consumers, family farmers, and veterinarians. No on Proposition 2, FPPC
No. 08/515. This case involved one count of failing to name a sponsor on the statement of
organization and one count of failing to amend the statement of organization to include a
sponsor. A $2,500 penalty for the each count was approved by the Commission on April 8,
2010.
In this matter, Respondent CSV’s actions were serious as Respondent CSV coordinated
with the candidate’s campaign consultant. However, in mitigation, Principal Officer Helfand had
little campaign experience and neither of the Respondents have a history of violating the Act.
Therefore, imposition of an administrative penalty in the amount of two thousand five hundred
dollars ($2,500) is recommended.
Sender Identification: As a candidate controlled committee, Respondents had a duty to
display on the mass mailing the name of the controlling candidate. The failure to provide proper
disclosure in a mass mailing deprives the public of important information by making them
believe that the mailing is independent of a candidate. In aggravation, Respondent CSV was able
to send out hit pieces on opponents without disclosing its association with the candidate. Also,
without the statement of organization’s amendment, the public would not have been able to trace
the association back to the candidate. Further, Respondent CSV was involved in multiple
advertisements, all of which failed to provide proper disclosure. In mitigation, the name of
Respondent CSV clearly presented its support of candidate Mark Farrell and Respondents have
cooperated with the investigation and assert that the contacts and coordination were the actions
of only one individual who believed that he was acting within the law.
Other similar cases regarding failing to properly include the required disclosure
statements on mailers recently approved by the Commission include:
In the Matter of Alan Frank, Alan Frank for City Council 2012, and Jeff Buchanan,
FPPC No. 12/890. Staff: Commission Counsel Zachary Norton and Special Investigator Paul
Rasey. Respondent, Alan Frank, was an unsuccessful candidate for Placentia City Council in the
November 6, 2012 election. Alan Frank for City Council 2012 was Respondent Frank’s
candidate controlled committee, and Respondent Jeff Buchanan was the Treasurer of the
committee. Prior to the election, Respondents paid for and caused to be sent two mass mailers
which failed to identify Respondents as the senders of the mailers in violation of Government
Code Section 84305, subdivision (a) (1 count). A stipulated settlement of $2,500 was approved
by the Commission on September 19, 2013.
8
EXHIBIT 1 IN SUPPORT OF STIPULATION, DECISION AND ORDER
FPPC NO. 10/973In the Matter of Protect Burlingame and Kevin Osborne, FPPC No. 09/804. This case
involved two mailers in a local election campaign, each sent to approximately 7,000 households,
which lacked sender identification. Respondent in this matter did not have an Enforcement
history. A $2,500 penalty was approved by the Commission on April 11, 2011.
In this matter, Respondents failed to provide proper disclosure statements as a result of
failing to properly file as a candidate controlled committee and concealing the connection
between the candidate-controlled committee and the committee which was supposed to be
independent of it. Taking into consideration the factors above, imposition of an administrative
penalty of three thousand dollars ($3,000) is recommended for each of the four counts.
PROPOSED PENALTY
After consideration of the factors of Regulation 18361.5, as well as consideration of
penalties in prior enforcement actions, the imposition of a penalty of Fourteen Thousand Five
Hundred Dollars ($14,500) is recommended.
9
EXHIBIT 1 IN SUPPORT OF STIPULATION, DECISION AND ORDER.
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