AFFIDAVIT OF COMPLAINT

STATE ELECTIONS ENFORCEMENT COMMISSION

Revised July 2012
Please complete this form to the fullest extent possible.
The following sections are required and must be completed in full:
Page 1 of6
I. Identity ofComplainant(s)-page 1 I III. Violation(s) Alleged-page 3 I VI. Certification-page 6
I. IDENTITY OF COMPLAINANT(S)
COMPLAINANT'S NAME
First Name MI Last Name
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COMPLAINANT'S STREET ADDRESS
Address
City
COMPLAINANT'S TELEPHONE NUMBER
I Cell
COMPLAINANT'S EMAIL ADDRESS
COMPLAINANT'S NAME
First Name
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Last Name D
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COMPLAINANT'S STREET ADDRESS
Address

COMPLAINANT'S TELEPHONE NUMBER
Home
I Work
COMPLAINANT'S EMAIL ADDRESS
COMPLAINANT'S NAME
First Name MI Last Name
COMPLAINANT'S STREET ADDRESS
Address
City
COMPLAINANT'S TELEPHONE NUMBER
Home
I Work I Cell
COMPLAINANT'S EMAIL ADDRESS
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Suffix
Zip Code
06\0S"
Suffix
State Zip Code
CT 00112.
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Suffix
State Zip Code
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AFFIDAVIT OF COMPLAINT
STATE ELECTIONS ENFORCEMENT COMMISSION
Revised July 2012
Page 2 of6
II. IDENTITY OF RESPONDENT(S)
RESPONDENT'S NAME (Jfknawn; atherwisewrite "unknown")
First Name E
Ml Last Name/ Suffix
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RESPONDENT'S STREET ADDRESS dJknown)
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RESPONDENT'S TELEPHONE NUMBER (If known)
Home
I Work
I Cell
RESPONDENT'S EMAIL ADDRESS (If known) STATUTE(S) VIOLATED (If known)

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 (If known)
Home
I Work I Cell
RESPONDENT'S EMAIL ADDRESS (If known) STATUTE(S) VIOLATED (Jfknown)

RESPONDENT'S NAME (If known, otherwise write "unknown")
First Name MI Last Name Suffix
RESPONDENT'S STREET ADDRESS {If known)
Address
City State Zip Code
RESPONDENT'S TELEPHONE NUMBER (Ifknown)
Home
I Work JCell
RESPONDENT'S EMAIL ADDRESS (If known) STATUTE(S) VIOLATED (If known)

Copy and attach page(s) for additional respondents if necessary.
Please check "See attached Additional Respondent List" and list the number of pages.
'
D See attached Additional Respondent List pages
Number of Pages
'
AFFIDAVIT OF COMPLAINT
STATE ELECTIONS ENFORCEMENT COMMISSION
Revised July 2012
III. VIOLATION(S) ALLEGED
DATE(S) OF ALLEGED VIOLATION(S) (If known)
CONCISE STATEMENT OF FACTS
Page 3 of6
Please be as specific as 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 than
one respondent, please identify which respondent is alleged to have committed which action and which specific alleged
violation of the statutes.
If you are unable to provide the specific identity of any witnesses in the following "Witnesses" section, please provide as
much identifying information as possible in the below "Concise Statement of Facts."
The respondent(s) allegedly violated the law as follows:
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Use attached page (s) for additional statement of facts if necessary.
Please check "See attached Additional Statement of Facts" and list the number of pages.
~ h e d 2- Additional Statement of Facts pages
Number or Pages
. AFFiDAVIT OF COMPLAINT
Page 4 of6
STATE ELECTIONS ENFORCEMENT COMMISSION . "'
Revised July 2012
111
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IV. WITNESSES
WITNESS'S NAME (!fknown)
First Name MI Last Name Suffix
WITNESS'S STREET ADDRESS (If known)
Address
City State Zip Code
WITNESS'S TELEPHONE NUMBER (If known)
Home
'Work I Cell
WITNESS'S EMAIL ADDRESS (If known)
WITNESS'S NAME (If known)
First Name MI Last Name Suffix
WITNESS'S STREET ADDRESS (Jfknown)
Address
City I I State
Zip Code
I I D
WITNESS'S TELEPHONE NUMBER (If known)
Home
'Work I Cell
WITNESS'S EMAIL ADDRESS (If known)
WITNESS'S NAME (If known)
First Name MI Last Name Suffix
WITNESS'S STREET ADDRESS (/fknown)
Address
City State Zip Code
WITNESS'S TELEPHONE NUMBER (If known)
Home
I Work I Cell
WITNESS'S EMAIL ADDRESS (If known)
Copy and attach page(s) for additional witnesses if necessary.
Please check "See attached Additional Witness List" and list the number of pages.
D See attached Additional Witness List pages
Number of Pages
AFFIDAVIT OF COMPLAINT p"''"'''"'''''"-
sTATE ELECTIONS ENFORCEMENT COMMISSION !
Revised July 2012
ADDITIONAL STATEMENT OF FACTS
Page __ of __
CONCISE STATEMENT OF FACTS continued
On July 15th we received from State Senator Eric Coleman a campaign flyer in the mail
in the City of Hartford at our homes. One copy of the mailer we both received is
enclosed in the complaint as an evidentiary attachment. As it turns out - this piece of
campaign literature was sent from the Legislative Office Building, Room 2500 and was
produced by State employees and paid for by State tax-dollars at Senator Eric
Coleman's directive. The mailer is clearly not a "legislative update" that would be a
permissible under state statute. The messaging of the flyer is clearly predominantly
campaign related and not related to State work or the work of State Senator Eric
Coleman.
Coleman writes in his state funded campaign flyer that "Unfortunately, in-order for the
city to pay for this $60 million stadium deal, Hartford's more pressing needs will not be
addressed." this is simply untrue, and misleading. Not only is this not informational in
nature, 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 million
in debt and interest payments that taxpayers will be paying for generations to come."
This comment is subjective and designed to influence the opinion of the recipient. It is
not informational in nature.
Coleman writes that "Instead of blindly embracing a $60 million giveaway to out-of-town
businessmel"! to build a sports stadium, I've fought to help local small businesses grow
jobs[ ... ]." This too is not informational in nature. This messaging is trying to create a
campaign contrast with his opponent. This statement is patently false. There has been
no "blind endorsement of a $60 million giveaway". The City Council has no such
resolution and is currently seeking private investors. The fact that this statement is false
is additional evidence that this mailer was not informational in nature but campaign
messaging paid for by tax dollars. Additionally, any future stadium is a municipal matter
and not something that pertains to state government. It has no business being brought
up 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
currently using in his campaign. This is a direct violation of Sec. 2-15a of State Statute.
Here is the state statute that has been violated by Senator Coleman:
Sec. 2-15a. Annual informational mailing by General Assembly members. (a)
Each member of the General Assembly shall be entitled to send an annual mailing
to each household in such member's district, for informational purposes. The
mailing shall be conducted under the supervision of the Joint Committee on
Legislative Management and in accordance with rules adopted by the committee.
The flyer also specifically violates the following Connecticut General Statute - Sec. 9-
610 (d) (1} No incumbent holding office shall, during the three months preceding
an election in which he is a candidate for reelection or election to another office,
use public funds to mail or print flyers or other promotional materials intended to
bring about his election or reelection.
Because Senator Coleman used public funds for a campaign mailing (evidentiary
attachment A) to bring about his re-election in the August 1 ih Primary which is less
than 90 days from the date people received the attached direct mailer, we believe
Senator Coleman has violated the law, Sec. 9-610 (d) (1) and Sec. 2-15a and has
violated the public trust.
AFFIDAVIT OF COMPLAINT
STATE ELECTIONS ENFORCEMENT COMMISSION
Revised July 2012
ATTACHED DOCUMENTARY OR REAL EVIDENCE
Page 5 of6
v. EVIDENCE
Please identify each attachment by number of pages, title, author and date if applicable. Records not identified as
attachments shall not be considered a part of the complaint. Please do not provide a website listing as evidence, as this
information 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 a
publication, such as a newspaper, please identify the publication's name and date of the publication.
EVIDENTIARY ATTACHMENT
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Title Number of Pages
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How Acquired Date Acquired
EVIDENTIARY ATTACHMENT
Title Number of Pages
Author Date of Publication
How Acquired Date Acquired
EVIDENTIARY ATTACHMENT
Title Number of Pages
Author Date of Publication
How Acquired Date Acquired
Copy and attach page(s) for additional evidence if necessary.
Please check Addf,ional Evidence List" and list the number of pages.
See attached )_ . Additional Evidence List pages
Number of Pages
AFFiDAVIT OF COMPLAINT .,,,,,
STATE ELECTIONS ENFORCEMENT COMMISSION {
Page 6 of6
Revised July 2012
VI. CERTIFICATION
1) Each Complainant must sign a separate page and each signature must be separately certified. This
complaint 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 Commission
20 Trinity Street, Suite 101
Hartford, CT 061 06
2) Once filed, this complaint may not be withdrawn by the Complainant(s) except by a vote of the State
Elections Enforcement Commission.
3) I am aware that criminal penalties may be imposed upon any Complainant who, under penalty of
false statement, knowingly files a false complaint.
4) The State Elections Enforcement Commission's investigation of a complaint is confidential unless
and until the State Elections Enforcement Commission votes to authorize an investigation of a
complaint. Until such a vote, neither the Commission nor its staff will release or confirm any
information 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 or
preliminary investigation.
CERTIFICATION
Guides to the elections laws are available at http://www.ct.gov/seec
Connecticut General Statutes are available at http://www.cga.ct.gov
I solemnly swear (or affirm) that the above statement is true and accurate
to the best of my knowledge and belief.
/)1/1"1 I WI"(
DA TEf(mmJAdlyyyy)
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Sworn and subscribed before me on this day

Seal
SIGNA TU/I.E OF PERs/)N ADMINISTERING THE OATH
TITLE OF PERS ADMINISTERING THE OATH
NAME OF PERSON ADMINISTERING THE OATH (Pleasei'rint)
JENNIFER A. DOLS
NOTARY PUBLIC
MY COMMISSION EXPIRES NOV. 30,2017
Note: This oath may be administered by anyone authorized by Section 1-24 of the Connecticut General Statutes, which includes: notaries public; justices of the peace;
town clerks and assistant town clerks; judges and clerks of any court; and attorneys who are Commissioners of the Superior Court of Connecticut.
AFFIDAVIT OF COMPLAINT
STATE ELECTIONS ENFORCEMENT COMMISSION
Revised July 2012
Page 6 of6
VI. CERTIFICATION
1) Each Complainant must sign a separate page and each signature must be separately certified. This
complaint 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 Commission
20 Trinity Street, Suite 1 01
Hartford, CT 061 06
2) Once filed, this complaint may not be withdrawn by the Complainant(s) except by a vote of the State
Elections Enforcement Commission.
3) I am aware that criminal penalties may be imposed upon any Complainant who, under penalty of
false statement, knowingly files a false complaint.
4) The State Elections Enforcement Commission's investigation of a complaint is confidential unless
and until the State Elections Enforcement Commission votes to authorize an investigation of a
complaint. Until such a vote, neither the Commission nor its staff will release or confirm any
information 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 or
preliminary investigation.
CERTIFICATION
Guides to the elections laws are available at http://www.ct.gov/seec
Connecticut General Statutes are available at http://www.cga.ct.gov
I solemnly swear (or affirm) that the above statement is true and accurate
to the best of my knowledge and belief.
,204
-
Seal
Note: This oath may be administered by anyone authorized by Section 1-24 of the Connecticut General Statutes, which includes: notaries public; justices of the peace;
town clerks and assistant town clerks; judges and clerks of any court; and attorneys who are Commissioners of the Superior Court of Connecticut.

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Your Senator

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Growing Jobs &
Strengthening
Hartford's Economy
When done with this mailer, please share or recycle.
3*l*************SCH 5-DIGIT 06105
THOMPSON GALE HOUSEHOLD
OR CURRENT RESIDENT
6 CONE ST
CT 06105-2501
l'"tmhr ,,,,.,.,,.,u., . ,lll'l''l'l! n. h l'h f' .n.tt
Representing Hartford/
Bloomfield and Windsor
Legislative Office Building, Room 2500
Hartford, Connecticut 06106-1591
860-240-0528
www.SenatorColeman.cga.ct.gov
PRSRTSTD
U.S. POSTAGE
PAID
HARTFORD CT
PERMIT NO. 3937
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Senator Eric Coleman: Growing Jobs
& Economy
A
S YOUR STATE SENATOR I've worked to grow jobs and strengthen our
economy. The global recession hit us hard-Hartford harder than almost
anywhere else. That's why I have worked to create good-paying jobs.
Instead of blindly embracing a $60 million giveaway to out-of-town businessmen
to build a sports 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 for
unemployed 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 schools to provide young
adults the opportunity to learn in cabinetry, carpentry, masonry,
manufacturing and weatherizatioo:
Raising the minimum wage to $illffl.10 in response to President Obama's
call in his State of the Union Address
'Expanding Youth Summer Employment
Helping grow the Manufacturing Apprenticeship Program
Unfortunately, in order for the city to pay for
this $60 million stadium Hartford's more
pressing needs will not be addressed:
fixing .crumbling schools;
putting more teachers in classrooms;
investing in our youth;
investing in local economic development
projects
The proposed stadium instead leaves the city
with $60 million in debt and interest payments
that taxpayers will be paying for generations
to 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 contact
Michelle Peters at 860-270-8052 or
Michelle.Peters@ct.gov
STEP-Up (Subsidized Training fr Employment
Programs) provides worker training
subsidies for small businesses and small
manufacturers: www.stepct.com
Connecticut Reemployment Portal if you
have recently lost a job and are looking for
work: www1.ctdol.state.ct.us/CTReP
Job & Career ConneCTion for details on job
and training programs:
www.ctjobandcareer.org .
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