March 6, 2018 To: Delaware State Elections Commissioner Elaine Manlove 905 $ Governors Way Suite #170 Dover, Delaware 19904 Re: Campaign Finance Official Complaint Dear Ms. Manlove, Pursuant to Delaware Campaign Finance Law Title 15 Chapter 80 (§ 8010 Contribution limits for candidates) it is my belief that a violation of the law has accrued and request your department complete a full audit and forward findings to the Delaware Department of Justice. Background: In 2016, | Patrick Jones, loaned then candidate for New Castle County President Karen Hartley-Nagle approximately $5000.00 per month to be used for living expenses. The: were loans to be repaid upon her obtaining employment, as she was unemployed, During this, period Ms. Hartley-Nagle did not seek employment and worked full-time on her campaign for NCC Council President. At no time were any part of the funds loaned to her to be used for her campaign expenses, Email communications substantiate that these were loans. I have attached them along with copies of the cancelled checks I wrote to her during this period. Under Delaware Campaign Contributions: (a) No person (other than a political party) shall make, and no candidate, treasurer or anyone acting on behalf of any candidate or candidate committee shall accept, any contribution which will cause the total amount of such person's contributions to or in support of such candidate to exceed, with respect to a statewide election, $1,200 during an election period, or with respect to any election that is not statewide, $600 during an election period Upon viewing Ms. Hartley-Nagle filed campaign finance reports, she loaned her campaign funds periodically during the same period she was receiving funds from me. This brings up the question of how did Ms. Hartley-Nagle obtain the funds to loan herself while unemployed? Review of Delaware Law and the penalties for such violations of campaign contributions shows: § 8043 Violations; penalties; jurisdiction in Superior Court. (a) Except as set forth in § 8044 of this title, any person who knowingly violates any provision of § 8003, § 8004 or § 8008 of ths title shall be guilty of a class B misdemeanor. (b) Any person who knowingly accepts or knowingly makes an unlawful contribution or ‘expenditure in violation of any provision of subchapter II or Ill of this chapter shall be guilty of class A misdemeanor.(©) Any reporting party who knowingly files any report required under this chapter that is false in any material respect, oF fails to file any such report, shall be guilty of a class A misdemeanor. For purposes of this subchapter, "reporting party" means any candidate, treasurer or other person required to file reports under this chapter. (a) Any person who knowingly violates any provision of § 8006 of ths title shall be guilty of a class G felony. (e) A reporting party who reasonably relies upon information provided by another person which is inaccurate, false or misleading and who has no reason to know that such information was inaccurate, false or misleading, shall not be liable for any report filed by such reporting party which is inaccurate, false or misleading as a result of such information, if such reporting party, within 30 days after learning that such information was inaccurate, false or misleading, files an amended report with the Commissioner that corrects the inaccurate, false or misleading aspects of the report. Where a reporting party files an amended report later than 30 days after learning that such information was inaccurate, false or misleading, the reporting party shall not be liable if the reporting party shows good cause for filing the amended report beyond the 30-day period Clearly , if Ms. Hartley-Nagle did use any of my loaned funds for her campaign, this would be a violation of the law. My request: © Acomplete audit of Ms. Hartley-Naglé’s bank accounts, both personal and campaign account, be performed to verify that none of the funds | loaned to her where used for her campaign for political office. © Astatement from your office, clearing me of any violations of the Delaware Campaign Finance Law based on the findings of such an audit. ‘© Acomplete report on the findings to be forwarded to the Department of Justice Public. Integrity Division. © If Ms. Hartley-Nagle did, in fact, use my funds in excess of the contribution limits, that those funds be returned to me in accordance with the law. In conclusion, I, as a law abiding citizen of the United States and a resident of the State of Delaware believe that I have the sole right to be cleared of any wrong-doing, especially in this case where another persons actions may have caused a violation of the law. The civil matter ofthe loan repayment has nothing to do with the possible criminal implications in this matter per the duties of your position as commissioner: § 302A Investigatory authority. (@) In connection with his or her authority pursuant to § 302 (14) of this title hereunder to investigate possible violations of Chapter 80 of this title, the State Election Commissioner: (1) May appoint 1 or more investigators, having such experience and qualifications as. shall be established by the Board of Elections, to investigate information coming to the attention of the Commissioner that, if true, would constitute a violation of Chapter 80 of this title. The activities of any investigator appointed hereunder shall be directed solely by the Commissioner, and such investigator shall not be deemed to be an employee of, or otherwise answerable to, the Board of Elections; (2) Shall have the authority to subpoena witnesses, compel their attendance and testimony, administer oaths and affirmations, take evidence and require by subpoena the production of books, papers, records or other evidence needed for the performance of the Commissioner's duties or exercise of his or her powers pursuant to this section; and (3) May refer any possible violation to the Attorney General or the United States Attorney for investigation and prosecution, either directly or following an investigation or preliminary investigation by the Commissioner hereunder. This complaint carries serious implications as to the integrity of your office and Delaware Campaign Finance rules and laws. No candidate should be able to filter money into a campaign from personal loans from another party. This behavior, if left un-checked will set a precedent to enable future candidates to fund campaigns by filtering money outside lawful contribution limits. | trust you will investigate my case efficiently and accurately without any outside political influence, | believe | have a civil right to due process under the law. Due Process Violation. Under both the Fifth and Fourteenth Amendments to the U.S. Constitution, neither the federal government nor state governments may deprive any person “of life, liberty, or property without due process of law.” | request to be cleared in this matter.Sincerely, Patrick Jones 911 Cloister Road, Apt. A Wilmington, DE 19809 (703) 479-0170 Cc: The News Journal WDEL Governor John Carney New Castle County Democratic Party Leadership An Erik Raser-Schram, State Democratic Party Leadership