August 25, 2009

Via Facsimile and First Class Mail

Peri Horowitz, Director

Special Compliance & Policy Assurance
New York City Campaign Finance Board
40 Rector Street, 7th Floor
New York, NY 10006

Dear Ms. Horowitz:

In light of recent news media coverage about the connections between candidates endorsed by the Working
Families Party (hereafter “WFP”) and the for-profit arm of the party, Data and Field Services (hereafter “DFS”), I
hereby file a formal complaint with the New York City Campaign Finance Board (hereafter “CFB”) based on the
actions of the campaign of candidate James G. Van Bramer and request an investigation into the collaboration
between these parties in advance of the September 15 Democratic Primary.

Through the actions taken by the campaign of Mr. Van Bramer, the WFP, and DFS, it appears spending by a third
party, namely WFP and DFS, which is not independent of the Van Bramer campaign, but benefits that campaign,
is occurring. Additionally, I believe goods or services are being donated to Mr. Van Bramer’s campaign by WFP
and DFS and are not being reported or are being reported incorrectly.

Allegations of spending by a third party that is not independent of a campaign but benefits that campaign and
the donation of goods or services donated to a campaign are not being reported or are being reported
incorrectly:

Numerous news outlets have recently covered the relationship between candidates endorsed by the WFP and
services provided by DFS. It appears the campaign of Mr. Van Bramer and spending by the WFP is not
independent of the campaign for the benefit of said campaign in violation of New York City Campaign Finance
Laws and that the WFP and DFS have donated goods or services to the campaign that are not being reported or
are being reported incorrectly, including a $4,700 expense recorded on state campaign finance records to WFP
that is reported on CFB filings as an expense for the same amount to DFS. The news reports include:

• The New York Times, “Questions for Data and Field” published August 22, 2009, in which the editorial
board has “serious questions about the activities of a private corporation set up by the Working Families
Party to assist candidates the party has endorsed” and continues “If candidates are not paying market
 rates, the company and perhaps the party and its donors could be unfairly subsidizing candidates who
have agreed to abide by the strict donor limits and spending caps required by the public financing
system.”
• City Hall News, “Six Council Campaigns, de Blasio Campaign, Discovered Using Working Families Staff,
Resources In Test of City Finance Limits” published August 9, 2009, in which Mr. Van Bramer’s campaign
staff acknowledges the WFP is assisting the campaign, saying, “They’re involved in the campaign,
definitely…They’re helping with our canvas right now.” Additionally, Mr. Van Bramer’s campaign staff
further notes using WFP for data management, saying: “They’re also doing our data management. We
have their VAN [Voter Activation Network] service as well.” CFB public disclosure filings record no
payment for the Voter Activation Network or for data services by either the WFP or DFS. Two payments
to DFS are recorded as “canvass” and “paid canvass.”

Additionally, the City Hall News report notes that “the WFP’s state Board of Elections campaign finance
disclosure shows a check for $4,700—the precise amount of the DFS contract—cashed and logged on
July 7. Since Van Bramer shows a $4,700 expenditure to DFS, and WFP shows a payment from Van
Bramer for $4,700, it appears that Van Bramer wrote a check to DFS that the WFP cashed.” New York
State Board of Election records show an expenditure of $4,700 by the account of Friends for Jimmy Van
Bramer, in what appears to be an incorrect reporting of a campaign expenditure to a political party.

These accounts seem to show collaboration between the campaign of Mr. Van Bramer and the WFP that violates
rules barring third-party spending that is not independent of a campaign yet benefits a campaign.

In the interest of transparency and to ensure that New York City’s campaign finance laws are being followed
both in spirit and to the letter, I request an investigation into the relationship between the campaign of Mr. Van
Bramer, the WFP, and DFS. It is a concern to the voters of the 26th Council District that particular candidates may
have an advantage over others due to a possible evasion of New York City and New York State campaign finance
laws.

I may be contacted through my campaign manager, Edward Kiernan, by telephone at 718-784-2193, or at 45-23
47th Street, Woodside, New York, 11377.

I affirm the truthfulness of the contents of this letter.

Sincerely,

Deirdre Feerick