Veteran Member Join Date: Sep 2006 Location: Wisconsin USA | Quote: The Complaint of the Democratic Party of Wisconsin,
by Melissa Baldauff,
Complainant,
against
Willard “Mitt” Romney,
Representative Paul Ryan,
Romney for President, Inc.
Respondents
VERIFIED COMPLAINT
On behalf of the Democratic Party of Wisconsin, I, Melissa Baldauff, primarily
based on public records, but also on information and belief, hereby allege as follows:
1. This Complaint is brought against Willard “Mitt” Romney (“Romney”), a
Republican candidate for President of the United States, Representative Paul Ryan
(“Ryan”), representative of and for Wisconsin’s First Congressional District and Romney
for President, Inc. (“RFP”), a campaign committee registered and organized pursuant to
the Federal Campaign Finance Act.
2. I am a citizen, resident, and elector of the State of Wisconsin. I am the
Research Director of the Democratic Party of Wisconsin, 110 King Street, Suite 203,
Madison, Wisconsin 53703, on behalf of which I bring this Complaint.
3. Based on available public records, Respondent Romney maintains a
residence at 585 Commercial Street, Boston, MA 02109. Respondent Ryan maintains
an office address at 20 South Main St., Suite 10, Janesville, WI 53545. Respondent
RFP maintains an address at PO Box 149756, Boston, MA 02114-9756.
4. Respondent Romney is a Republican candidate for the office of President
of the United States of America.
5. The presidential primary in Wisconsin has been scheduled to occur on
April 3, 2012.
6. On or about April 3, 2012, Romney, RFP and Ryan jointly co-hosted a
campaign event billed as an “Election Day Lunch” at Cousin’s Subs, 1700 Pearl Street,
Waukesha, WI.
7. Following his remarks to attendees at the event, Romney stated, “thank
you for voting, if you haven't yet go out there and vote. Take some friends, it's the only
way to vote multiple times legally and if you want another sandwich there are more back
there.” Video of this exchange obtained by the Democratic Party of Wisconsin is
attached hereto and incorporated herein as Exhibit “A.”
8. A reasonable person would understand that Romney’s statement was an
offer of a sandwich for individuals who were going to vote in the Republican primary, or
who had already voted in the Republican primary, and that the sandwiches had been
provided not by Cousins Subs, but by Respondents.
9. Each type of sandwich available for purchase at Cousins Subs exceeds a
purchase price of $1.00, and is therefore is defined by Wis. Stats. Section 12.11(1) as a
thing "of value," which definition includes any amount of money, or any object which has
utility independent of any political message it contains and the value of which exceeds
$1. See Exhibit “B”, Cousins Subs Menu.
10. Wis. Stats. Section 12.11(1m)(a) states, in pertinent part, that any person
who offers, gives, lends or promises to give or lend, or endeavors to procure, anything
of value, or any office or employment or any privilege or immunity to, or for, any elector,
or to or for any other person, in order to induce any elector to:
(1). Go to or refrain from going to the polls;
(2). Vote or refrain from voting;
(3). Vote or refrain from voting for or against a particular person;
(4). Vote or refrain from voting for or against a particular referendum; or on
account of any elector having done any of the above.
Violates Chapter 12, Wisconsin Statutes.
Penalties
11. Violation of Chapter 12, Wisconsin Statutes, constitutes a Class I felony,
as defined by Wis. Stat. Section 12.60(1).
12. A Class I felony carries a penalty of a fine of up to $10,000, or
imprisonment of up to 3-1/2 years, or both; however, for a repeat offender, the term of
imprisonment may increase up to 2 years with prior misdemeanor convictions, and up to
6 years with a prior felony conviction.
13. Section 12.60(2)(a), Wis. Stats., provides, “If a successful candidate for
public office, other than a candidate for the legislature or a candidate for national office,
is adjudged guilty in a criminal action of any violation of this chapter under sub. (1)
(a) committed during his or her candidacy, the court shall after entering judgment enter
a supplemental judgment declaring a forfeiture of the candidate's right to office. The
supplemental judgment shall be transmitted to the officer or agency authorized to issue
the certificate of nomination or election to the office for which the person convicted is a
candidate. If the candidate's term has begun, the office shall become vacant. The office
shall then be filled in the manner provided by law.
14. Section 12.60(2)(b), Wis. Stats., further provides that, “If a successful
candidate for the legislature or U.S. congress is adjudged guilty in a criminal action of
any violation of this chapter under sub. (1) (a) committed during his or her candidacy,
the court shall after entering judgment certify its findings to the presiding officer of the
legislative body to which the candidate was elected.”
15. The public’s faith in electoral activity free from any corrupting influence is
a vital component to the democratic process
Therefore, regardless of whether the Board addresses this matter pursuant to Chapter
11, Wisconsin Statutes, or finds it appropriate to refer the matter to a district attorney for
investigation, the Complainant respectfully submits that the facts warrant the Board’s
attention.
I, Melissa Baldauff, being first duly sworn upon oath, state that I personally read
the above complaint and that the above allegations are true and correct based upon my
personal knowledge and my review of public records and, as to those allegations stated
on my information and belief, I believe them to be true.
Dated this ____ day of April, 2012.
Respectfully submitted,
___________________________
Melissa Baldauff, Research Director
Democratic Between that and this, what a week....... Good Luck, Wisconsin, You?ve Got A Classic Authoritarian Governor: | John Dean | Verdict | Legal Analysis and Commentary from Justia Quote: Hopefully, one or more social scientists or political psychologists in Wisconsin, where there are many, will step forward and tell the people of Wisconsin more about what they have on their hands, with Scott Walker as their governor. In fact, the June 5, 2012 election is a true opportunity to discourage another leader who is a conservative without conscience, for these leaders always have a healthy following. Altemeyer estimates that about twenty-five percent of the population has, in varying degrees, the disposition to follow a double high authoritarian, many blindly or simply because it assuages their fears. And, of course, these are aggressive followers who can attract others who are unaware of the nature of the person they are electing, thus enabling an authoritarian leader like Walker to gain ever-growing control.
Good luck, Wisconsin.
John DeanJohn W. Dean, a Justia columnist, is a former counsel to the president. |