Some highlights from dropbox.com/sh/9lbrytrrb3x…
1.This Complaint alleges an unprecedented, massive, nationwide multi-million dollar conspiracy among the Democratic National Committee (“DNC”);Democratic presidential candidate Hillary Rodham Clinton’s joint fundraising committee (“JFC”),
2.Hillary Victory Fund (“HVF”), Clinton’s presidential candidate committee, Hillary for America (“HFA”), 40 Democratic state parties, and an undetermined number of individual “super donors” to circumvent federal contribution limits
3.and earmarking restrictions by effectively laundering nearly all contributions received by HVF through the state parties to the DNC, which contributed much of those funds to HFA, made coordinated expenditures with HFA,
4.and otherwise granted control of those funds to HFA resulting in a de facto unlawful contribution. As explained below, this scheme allowed the DNC to receive tens of millions of dollars in contributions far exceeding federal limits
5.Based on publicly available FEC records, repeatedly throughout the 2016 presidential campaign, HVF would purportedly transfer funds to its constituent political committees, which included between 34 and 40 state parties.
6.On the very same day each of these transfers supposedly occurred, or occasionally the very next day, every single one of those state parties purportedly contributed all of those funds entirely to the DNC.
7.The uniformity, regularity, magnitude, immediacy, and extent of these reported transfers—every single state party transferring every single disbursement it received from HVF, in its entirety, exclusively to the DNC
8. immediately upon receipt—inexorably leads to the compelling inference, supported by public statements, HVF’s members had an understanding or agreement to automatically funnel funds they received through HVF to the DNC.
9.The DNC, in turn, contributed most of those funds to HFA, made coordinated expenditures with HFA and otherwise transferred control of its money to HFA, as both the DNC’s own public filings and former DNC Chairwoman Donna Brazile’s public confessions make clear.
10, In McCutcheon v. FEC, 134 S. Ct. 1434, 1455(2014), the Supreme Court itself recognized this precise arrangement would flatly violate federal earmarking restrictions, 52 U.S.C. §30116(a)(8); 11 C.F.R. §110.6,
11.though the Court dismissed the possibility of such a flagrantly illegal scheme as “unlikely” to occur.
12. Not even the Supreme Court could anticipate the extent to which the Democratic Party and its elite, wealthy donor class would commit willful felonies in a futile attempt to facilitate Clinton’s election.
13.Because funds state parties received through HVF were apparently “earmarked” to be immediately transferred to the DNC, each contribution to HVF qualifies as a contribution from the original source of the funds to the DNC itself, 11 C.F.R. §110.6(a), (d)(2)
14. causing most such contributions to grossly exceed federal limits of $33,400 per person.52 U.S.C. §30116(a)(1)(B); FEC, Price Index Adjustments for Contribution and Expenditure Limitations and Lobbyist Bundling Disclosure Threshold, 80 FED.REG.5,750, 5,752 (Feb. 3, 2015).
15.Additionally, no contribution to HVF was properly reported to the FEC as a contribution entirely to the DNC. Any contributor to HVF who was expressly or implicitly assured contributions to HVF would be transferred to the DNC, or otherwise
16.used for the benefit and at the direction of Clinton’s presidential campaign, would have been willful participants in the conspiracy to violate federal contribution limits, reporting requirements, and earmarking restrictions, and may be deemed unnamed co-conspirators.
17. On information and belief, it also reasonably appears state parties may have attempted to conceal their conspiracy by fabricating and erroneously reporting pass-through transactions.
18. Even assuming the co-conspirators were wiring their funds across the nation, it appears extraordinarily unlikely that, on hundreds of occasions collectively involving tens of millions of dollars, HVF would have been able to transfer funds to 34-40 different state parties,
19. each of those state parties would have received those funds and immediately transferred them to the DNC, and the DNC would have received those funds, all on the same day.
20. Based on the eerily precise timing of these hundreds of transactions involving dozens of entities over more than a year—and the telling absence of a few such entries—it appears far more plausible HVF did not actually transfer contributions it received to state parties,
21. which in turn contributed them to the DNC (as the FEC filings of both the state parties themselves and the DNC contend occurred).
22. Instead, it appears HVF may have transferred contributions it received directly to the DNC, and the entities involved falsely reported intermediate transfers that never occurred.
23. Even if the transfers did occur as reported, however, the virtually unbroken pattern demonstrates state parties were being used as intermediate pass-through entities to funnel over 80 million dollars in contributions HVF received to the DNC, in violation
24. of federal contribution limits, earmarking restrictions, and reporting requirements-Likewise, assuming such transfers did occur, then at many of the Respondent state parties transferred millions of dollars over dozens of transactions without properly reporting them.
