...Since the filing of this complaint, additional facts have been brought to light which further confirm the need for immediate action by your office. Those additional facts are as follows:

Additional Facts Evidencing the Misuse of Funds Beyond the $387,561.00 in Supposed Petty Cash Disbursements

....The New Haven Register reported today that “[Tomas] Reyes [of Oxford] and another man, Daryl Brooks of New Haven, who ran a consultant service, said they each got one check from the campaign for their services, but they are listed in the third quarter campaign finance report as getting two checks, for a total of twice what the men said they received.” M. E. O’Leary, Register Topics Editor, New Haven Register (Nov. 2, 2006). “The report lists Reyes as getting two checks for $8,250, one on Aug. 4 and one on Aug. 15. Brooks received $12,200 on Aug. 11 and another check for the same amount on Aug. 15, according to the Lieberman report. Both men said this was inaccurate.” Id. Thus, the amount of unaccounted for expenditures from the Lieberman campaign is now at least $408,011.00.

Additional Facts Further Evidencing the Failure to Itemize Supposed Disbursements in Excess of $200.00

...The New Haven Register’s report establishes that “[s]everal young men, who were paid $60 a day out of [the supposed] petty cash [fund] to canvass in Bridgeport, said they were paid in cash for aggregate earnings over $200.” M. E. O’Leary, Register Topics Editor, New Haven Register (Nov. 2, 2006).

Specifically, “Rob Dhanda, 18, of Stratford, said he earned $480 in cash over several weeks, while Walter Ruilova, 18, also of Stratford, said his total was an estimated $360 in cash. Id. Moreover, “Ruilova estimated there were about 30 teenagers working out of the Bridgeport office, each earning $60 a day in cash, over a few weeks.” Id.

one of these disbursements are itemized in any of the Lieberman Committee’s reports and we therefore submit that the foregoing constitutes a patent violation of federal law.

Additional Facts Further Evidencing the Failure to Maintain a Written Journal

Title 11 C.F.R. §102.11 (2 U.S.C. 432(h)(2)) (Petty Cash Fund) provides that “[i]f a petty cash fund is maintained, it shall be the duty of the treasurer of the political committee to keep and maintain a written journal of all disbursements. This written journal shall include the name and address of every person to whom any disbursement is made, as well as the date, amount, and purpose of such disbursement.”

As further chronicled in today’s Register, Tomas Reyes “said he has yet to be asked by the campaign to turn over material for the journal, which would justify expenditures of $8,250.”

It is simply not possible to comply with the foregoing regulation if the Lieberman campaign has not even made an effort to collect the information that may (or may not) exist to maintain the journal.

The committee filed incorrect reports. Petty cash is not supposed to be disclosed until it is distributed. Until such time it is part of a committee’s cash on hand. Thus, by reporting the creation of petty cash instead of the actual disbursement of the petty cash, this may have artificially deflated their disclosure of cash on hand.

Conclusion

The Lieberman campaign’s flagrant disregard for these laws and regulations calls for the immediate investigation of this matter by your office to ensure that the voters of Connecticut can be fairly informed about the conduct of their elected officials.

I would appreciate you contacting me confirm receipt of this amended complaint.

I thank you in advance for your attention to this pressing matter.

Sincerely Yours,

Tom Swan

posted by tparty at 8:33 PM