The following contains four complaints and two supporting exhibits for the Indiana Election

Division addressed to Mr. King and Mr. Deckard, CoDirectors:

Synopsis
On February 9, 2015, Governor Mike Pence and his campaign committee accepted an in-kind
donation of campaign materials including, but not limited to, political signs with the words
Protect Religious Freedom from the Indiana Coalition to Protect Religious Freedom, a PAC
by definition. The Indiana Coalition to Protect Religious Freedom, led by Monica Boyer, is not
a PAC registered with the Secretary of State of Indiana, but by the definition of a PAC set out
in the Indiana Campaign Finance Manual chapter 4 subsections A and B. Political Action
Committee: An organization located within or outside Indiana that: (1) proposes to influence
the election or defeat of a candidate for statewide, state legislative, local or school board
office or the outcome of a public question that will appear on the ballot in Indiana, and (2)
accepts contributions or makes expenditures during a calendar year that in the aggregate
exceed one hundred dollars ($100). The production of over 200 signs as well as the money
received in donation to produce them, would exceed one hundred dollars ($100). The group
Indiana Coalition to Protect Religious Freedom, has continued to use this sign design lacking
any formal disclaimer at multiple campaign events at the state house, in the days and weeks
following February 9, 2015.
Complaints
Complaint 1: Governor Mike Pence and his campaign committee did knowingly and willingly
accept an in-kind donation of campaign materials, as defined by IC 3-5-2-15, during a budget
session of the General Assembly in violation of Indiana law, pursuant to IC 3-9-2-12.
(Exhibit 1)
Complaint 2: The Indiana Coalition to Protect Religious Freedom, led by Monica Boyer, is
acting in violation of Indiana law, operating as a PAC by rallying against a public question,
endorsing candidates, and making aggregate expenditures in excess of one hundred dollars
($100) without filing the required CFA-2 pursuant to IC 3-9-1-3. (Exhibit 1&2)
Complaint 3: The campaign signs provided to the Governor and his committee by the Indiana
Coalition to Protect Religious Freedom lacked the required campaign finance disclaimer
indicating who paid for those signs pursuant to IC 3-9-3-1. The Indiana Coalition to Protect
Religious Freedom should have been listed. (Exhibit 2)
Complaint 4: The campaign signs provided to the Governor by the Indiana Coalition to Protect
Religious Freedom lacked the required campaign finance disclaimer indicating who approved
of those signs pursuant to IC 3-9-3-1. Governor Mike Pence or his campaign committee
should have been listed. (Exhibit 2)

Exhibit 1

Exhibit 2