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  • 8/12/2019 SEEC Complaint Coleman

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    AFFIDAVIT OF COMPL INTSTATE ELECTIONS ENFORCEMENT COMMISSIONRevised July 2012

    Page 2 of6

    II. IDENTITY OF RESPONDENT S)RESPONDENT S NAME (Jfknawn; atherwisewrit e unknown )

    First Name E Ml Last Name Suffixr ( [ PMC\{\ i.. RESPONDENT S STREET ADDRESS dJknown)Address ;7 l ~ \ ~JJ . '\\\1 ivCity . . \ 6 j State Zip Codet 6 () r \ \ Ci (J(,J)lRESPONDENT S TELEPHONE NUMBER Ifknown)Home I ork I ellRESPONDENT S EMAIL ADDRESS Ifknown) STATUTE S) VIOLATED Ifknown)

    RESPONDENT S NAME If known, otherwise write unknown )

    First Name MI Last Name Suffix

    RESPONDENT S STREET ADDRESS (Jfknown)Address

    City State Zip Code

    RESPONDENT S TELEPHONE NUMBER Ifknown)Home I ork I ellRESPONDENT S EMAIL ADDRESS If known) STATUTE S) VIOLATED (Jfknown)

    RESPONDENT S NAME Ifknown, otherwise write unknown )

    First Name MI Last Name Suffix

    RESPONDENT S STREET ADDRESS {Ifknown)

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    AFFIDAVIT OF COMPLAINTSTATE ELECTIONS ENFORCEMENT COMMISSIONRevised July 2012

    III. VIOLATION(S) ALLEGEDDATE S) OF ALLEGED VIOLATION(S) If known)

    CONCISE STATEMENT OF FACTS

    Page 3 of6

    Please be s specific s possible with regard to time, place, and the individual(s) taking actions or failing to act, and in de-scribing their actions as well as other witnesses or persons involved. If applicable, please clearly refer to the names of identi-fled respondents, witnesses, and attached evidence (e.g., See Evidentiary Attachment B.). If you have identified more thanone respondent, please identify which respondent is alleged to have committed which action and which specific allegedviolation of the statutes.If you are unable to provide the specific identity of any witnesses in the following Witnesses section, please provide smuch identifying information s possible in the below Concise Statement o Facts.The respondent(s) allegedly violated the law as follows:

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    . AFFiDAVIT OF COMPLAINT Page 4 of6STATE ELECTIONS ENFORCEMENT COMMISSION . ' Revised July 2012 '-.. . ' . ~ ' r.

    IV. WITNESSESWITNESS S NAME ( fknown)

    First Name MI Last Name Suffix

    WITNESS S STREET ADDRESS Ifknown)Address

    City State Zip Code

    WITNESS S TELEPHONE NUMB ER Ifknown)Home Work I ellWITNESS S EMAIL ADDRESS If known)

    WITNESS S NAME Ifknown)First Name MI Last Name Suffix

    WITNESS S STREET ADDRESS (Jfknown)Address

    CityI I tate Zip CodeI IWITNESS S TELEPHONE NUMBER If known)Home Work I ellWITNESS S EMAIL ADDRESS Ifknown)

    WITNESS S NAME Ifknown)First Name MI Last Name Suffix

    WITNESS S STREET ADDRESS (/fknown)

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    FFID VIT OF COMPL INT p"''"'''"'''''"-sTATE ELECTIONS ENFORCEMENT COMMISSIONRevised July 2 12

    DDITION L ST TEMENT OF F CTSPage o

    CONCISE STATEMENT OF FACTS ontinued

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    On July 15th we received from State Senator Eric Coleman a campaign flyer in the mailin the City of Hartford at our homes. One copy of the mailer we both received isenclosed in the complaint as an evidentiary attachment. As it turns out - this piece ofcampaign literature was sent from the Legislative Office Building, Room 2500 and wasproduced by State employees and paid for by State tax-dollars at Senator EricColeman's directive. The mailer is clearly not a "legislative update" that would be apermissible under state statute. The messaging of the flyer is clearly predominantlycampaign related and not related to State work or the work of State Senator EricColeman.Coleman writes in his state funded campaign flyer that "Unfortunately, in-order for thecity to pay for this $60 million stadium deal, Hartford's more pressing needs will not beaddressed." this is simply untrue, and misleading. Not only is this not informational innature, it is a false statement designed to mislead voters in the primary.Coleman also writes that "The proposed stadium instead leaves the city with $60 millionin debt and interest payments that taxpayers will be paying for generations to come."This comment is subject ive and designed to influence the opinion of the recipient. It isnot informational in nature.Coleman writes that "Instead of blindly embracing a $60 million giveaway to out-of-townbusinessmel" to build a sports stadium, I've fought to help local small businesses growjobs[ ]." This too is not informational in nature. This messaging is trying to create acampaign contrast with his opponent. This statement is patently false. There has beenno "blind endorsement of a $60 million giveaway". The City Council has no suchresolution and is currently seeking private investors. The fact that this statement is falseis additional evidence that this mailer was not informational in nature but campaignmessaging paid for by tax dollars. Additionally, any future stadium is a municipal matterand not something that pertains to state government. It has no business being broughtup for "informational purposes" in a legislative update.By creating rhetorical contrast through language such as "instead" and "blindly" and"unfortunately" and "more pressing needs" and "giveaway to out-of-town businessmen",Coleman is attempting to persuade the recipient of a subjective message that he is

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    use public funds to mail r print flyers r other promotional materials intended tbring about his election or reelectionBecause Senator Coleman used public funds for a campaign mailing evidentiaryattachment A) to bring about his re-election n the August 1 Primary which is lessthan 90 days from the date people received the attached direct mailer, we believeSenator Coleman has violated the law, Sec. 9-610 d) 1) and Sec. 2-15a and hasviolated the public trust.

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    AFFIDAVIT OF COMPLAINTSTATE ELECTIONS ENFORCEMENT COMMISSIONRevised July 2012

    ATTACHED DOCUMENTARY OR REAL EVIDENCE

    Page 5 of6

    v. EVIDENCEPlease identify each attachment by number of pages, title, author and date if applicable. Records not identified asattachments shall not be considered a part of the complaint. Please do not provide a website listing as evidence, as thisinformation is subject to change. If you wish to provide Internet or other video or audio communications as evidence,please provide a printed or electronic copy, as appropriate, and list it as an exhibit.Under How Acquired please identify your source for the evidence (e.g., delivery from an individual, Internet website,public flyer location). If the source is an individual, please identify the individual in the witness list. If the source is apublication, such as a newspaper, please identify the publication s name and date of the publication.

    EVIDENTIARY ATTACHMENTTitle { \ - l = v \ . ~ / Number of Pages(_ U\. t'P V , \ff\ A .L v ' " ~ - - . \ \Author

    rj\Ptt,/\ j Date of Publicationl f .(

    H r c q ~ 1 \ ~ ~ ~ , r ~ . ~ \ \ ~ .

    I ) Y, \\ fi :;{Y t\ \ 1 D 7 Y \ : ~ : \lf~ < \ y. \ ~ - Y ~ ~ o 1 ; _ \ d .l. {\f:, I \ .\} .. \ Y ~ \ \ (, < , \ \_) \ \_.EVIDENTIARY ATTACHMENT ., 1

    Title Number of Pages

    Author Date of Publication

    How Acquired Date Acquired

    EVIDENTIARY ATTACHMENTTitle Number of Pages

    Author Date of Publication

    How Acquired Date Acquired

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    AFFiDAVIT OF COMPLAINT .STATE ELECTIONS ENFORCEMENT COMMISSIO N {

    Page 6 of6Revised July 2012

    VI. CERTIFICATION1 Each Complainant must sign a separate page and each signature must be separately certified. Thiscomplaint will not be considered filed without the name, address, and original certified signature of

    at least one Complainant. Mail or hand-deliver this complaint to:State Elections Enforcement Commission20 Trinity Street, Suite 101Hartford, CT 061 06

    2 Once filed, this complaint may not be withdrawn by the Complainant(s) except by a vote of the StateElections Enforcement Commission.3 I am aware that criminal penalties may be imposed upon any Complainant who, under penalty offalse statement, knowingly files a false complaint.4 The State Elections Enforcement Commission s investigation of a complaint is confidential unlessand until the State Elections Enforcement Commission votes to authorize an investigation of acomplaint. Until such a vote, neither the Commission nor its staff will release or confirm anyinformation about the complaint except upon written request of a treasurer, deputy treasurer,

    chairperson or candidate affiliated with a committee that is the subject of the complaint orpreliminary investigation.

    CERTIFICATION

    Guides to the elections laws are available at http://www.ct.gov/seecConnecticut General Statutes are available at http://www.cga.ct.gov

    solemnly swear or affirm) that the above statement is true and accurateto the best of my knowledge and belief.

    /)1/1 1 WI (DATEf mmJAdlyyyy)

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    AFFIDAVIT OF COMPLAINTSTATE ELECTIONS ENFORCEMENT COMMISSIONRevised July 2012

    Page 6 of

    VI. CERTIFICATION1 Each Complainant must sign a separate page and each signature must be separately certified. Thiscomplaint will not be considered filed without the name, address, and original certified signature of

    at least one Complainant. Mail or hand-deliver this complaint to:State Elections Enforcement Commission20 Trinity Street, Suite 101Hartford, CT 061 06

    2) Once filed, this complaint may not be withdrawn by the Complainant(s) except by a vote of the StateElections Enforcement Commission.3) I am aware that criminal penalties may be imposed upon any Complainant who, under penalty offalse statement, knowingly files a false complaint.4 The State Elections Enforcement Commission s investigation of a complaint is confidential unlessand until the State Elections Enforcement Commission votes to authorize an investigation of acomplaint. Until such a vote, neither the Commission nor its staff will release or confirm anyinformation about the complaint except upon written request of a treasurer, deputy treasurer,

    chairperson or candidate affiliated with a committee that is the subject of the complaint orpreliminary investigation.

    CERTIFICATION

    Guides to the elections laws are available at http://www.ct.gov/seecConnecticut General Statutes are available at http://www.cga.ct.gov

    I solemnly swear or affirm) that the above statement s true and accurateto the best o my knowledge and belief.

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    ourSenatort L ~ l ; , r i c _ C _ o l e m a n

    Growing Jobs StrengtheningHartford s Economyhen done with this mailer please share or recycle.

    3*l*************SCH 5-DIGIT 06105THOMPSON GALE HOUSEHOLDOR CURRENT RESIDENT6 CONE ST

    P ~ _ R T O P ~ CT 06105 2501

    l' tmhr . . . u. ,lll'l''l'l n.h l'h .n.tt

    Representing HartfordBloomfield and WindsorLegislative Office Building, Room 2500Hartford, Connecticut 06106-1591860-240-0528www.SenatorColeman.cga.ct.gov

    PRSRTSTDU.S. POSTAGE

    PAIDHARTFORD CT

    PERMIT NO 3937

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    1/.t::.. \ p-....). '. ,I

    Senator Eric Coleman Growing Jobs& t r e n g ~ ~ e q ~ r t ~ ~ r d s EconomyAYOUR STATE SENATOR I ve worked to grow jobs and strengthen oureconomy. The global recession hit us hard-Hartford harder than almostanywhere else. That s why I have worked to create good-paying jobs.

    Instead of blindly embracing a 60 million giveaway to out-of-town businessmento build asports stadium, I ve fought to help -local small businesses grow jobs in---,;;ourneighborhoods with the small Business Express program.And we are developing Hartford s workforce with job-training supports forunemployed individuals and veterans with the STEP:Up program. This .year I worked to help Hartford res-idents get ahead by: Securing 3.5 million to establishJate afternoon and evening programs

    at Hartford s Prince Tech and o t h , e r ~ e c h n i c a l schools to provide youngadults the opportunity to learn a : ~ i ( ) d e in cabinetry, carpentry, masonry,manufacturing and weatherizatioo:

    Raising the minimum wage to illffl.10 in response to President Obama scall in his State of the Union AddressExpanding Youth Summer Employment

    Helping grow the Manufacturing Apprenticeship Program

    Unfortunately, in order for the city to pay forthis 60 million stadium d e ~ l , Hartford s morepressing needs will not be addressed: fixing .crumbling schools; putting more teachers in classrooms; investing in our youth; investing in local economic development

    projectsThe proposed stadium instead leaves the citywith 60 million in debt and interest paymentsthat taxpayers will be paying for generationsto come.

    Resources to Grow Jobs job Expansion Tax Credits for small

    businesses: www.decd.org Small Business Express to get funding for

    your small business:tinyurl.com/SmaiiBizXpress, or contactMichelle Peters at 860-270-8052 [email protected]

    STEP-Up (Subsidized Training fr EmploymentPrograms) provides worker trainingsubsidies for small businesses and smallmanufacturers: www.stepct.com

    Connecticut Reemployment Portal if youhave recently lost a ob and are looking forwork: www1.ctdol.state.ct.us/CTReP

    Job Career ConneCTion for details on joband training programs:www.ctjobandcareer.org .

    ::s.____. -