Sunday, March 23, 2008

1st Dan Pike PDC Investigation (List of Violations as submitted to PDC).

Elisabeth Britt
(Address redacted for privacy)

October 16, 2007

Mr. Phil Stutzman
Director of Compliance
711 Capitol Way #206
PO Box 40908
Olympia, WA 98504

Dear Mr. Stutzman:

In reviewing the PDC filings for Mr. Daniel Pike, candidate for Mayor in Bellingham, Washington, I’ve noted that there are a number of reporting errors, missing expenditures, seriously late filings, missing filings and a serious and deliberate misstatement of fact in his original C-1 filing.

As you can see in the official records posted on the PDC website, the majority of filings during the primary campaign were late. For example, his April filing was late by 10 days and frankly, I find it difficult to track his expenditures and filings given the chaos of his campaign filings. For instance, his Schedule B for June was filed five times beginning with 8/1 (the original late filing date), 8/15, 10/8, 10/12, and 10/15. Repeatedly incorrect and amended filings makes it difficult to determine if he has yet to file other important documents that would provide transparency for this campaign. . Other errors may become evident when all C-3’s are reconciled to Form A and C-4.

His Schedule A for October, dated 10/15/2007, lists a number of expenses, including website development. However, Mr. Pike is claiming an expense of $280.00 for what appears to be a completely redesigned website. This expense seems surprising low, considering the in kind expenses reported for website development during the primary. Photography expenses are also missing, and all the photographs on his website are new.

His Schedule A and B filings, dated 10/15/2007 for September and October, fail to list expenditures for three fundraisers. One, dated September 18, 2007 was held at the Bellwether Hotel and was an open bar fundraiser. I have heard that Peter Roberts, a realtor, paid for it and that the owner of the Bellwether Hotel or Harborside Bistro restaurant may have also paid for it. Truth is, I don’t know who paid for it and his PDC filings do not report in-kind contributions or expenses for the event so it is impossible for me to figure out who paid for it.

A second fundraiser was held on September 29th at the American Museum of Radio. Other than an in-kind contribution for catering from Jere Hawn, I find no other reported expense related to this event. The space was either paid for or donated, yet there is no mention of any other expenses related to this event in his reports. On October 3, a third fundraiser was hosted by developers. From what I can discern, all of the fundraisers were paid by special interests and must be openly disclosed to the public.

Finally, and I believe this to be a significant error, Mr. Pike sent you a letter on January 25, 2007 stating that “the starting point of his campaign was January 21, 2007, when he met with friends and decided to run for office...”.

However, on December 8, 2006, Mr. Pike attended a Christmas event hosted by the Whatcom County Democratic Party and handed out campaign flyers to the 200 guests that were in attendance. A copy of the flyer is attached for your review. It’s likely that this is the flyer for which he filed an expenditure dated 1/10/2007 on his Schedule B dated 10/8/2007. At the December party, he wore an engraved “Dan Pike for Mayor” name badge and told people present that he was a candidate for Mayor of Bellingham. Hence, he should have filed his C-1 on December 22, 2006, rather than on January 25th. His original filing was more than a month late and the letter he attached with his C-1 filing misrepresented his public actions and statements. In other words, his campaign began with a public lie.

Given the continued chaos of Mr. Pike’s campaign filings, the many and continuous errors, missing filings, missing expenditures and his deliberate misstatement of fact in his initial C-1, I ask that you immediately investigate my complaint and require Mr. Pike to bring his filings in compliance with state statutes and levy appropriate fines and penalties for his actions.

Sincerely yours,

Elisabeth Britt
e-mail redacted


Daniel V. Pike Violations of Public Disclosure Requirements

Summary of PDC Violations through October 16, 2007
PDC Form number/ PDC Document number / Dated Filed

1. PDC Form C1 Filed January 25, 2007:
Within two weeks of becoming a candidate. (You become a candidate when you raise or spend money, reserve space, or buy advertising, authorize someone else to take one of these actions for you or you make a public announcement or file your Declaration of Candidacy, which ever occurs first).

Violation: Mr. Pike incorrectly identifies the start date of his campaign as January 21, 2007. In a letter to the PDC dated January 25, 2007, Mr. Pike apologized to the PDC for not including his C1 Form with his F1 Form, which was filed with the PDC on January 9, 2007. Mr. Pike incorrectly identifies January 21, 2007 as his campaign starting point, when he met with friends and decided to run for office. In reality, Mr. Pike publicly announced his campaign for Mayor on December 8, 2006, when he distributed a post card announcing his candidacy for Mayor at a Whatcom Democratic Party function. His C1 and F1 Forms were due on December 22, 2006. Mr. Pike’s C1 Form was filed one month late. Please see attached copies of C1 and letter to PDC dated January 25, 2007.

Violation: Sponsor Identification. Mr. Pike does not provide his address or the address of the campaign committee on the “Pike for Mayor” post card he distributed on December 8, 2006 at the Whatcom Democratic Party holiday celebration. Please see attached copy of post card.

2. PDC Form C3, number 100203088 dated February 13, 2007:
Violation: Filed 1 day late.

3. PDC Form Statement of Miscellaneous Receipts Attachment to Form C3. PDC #100203086 filed February 13, 2007.
Violation: lists personal fund campaign contributions dated 1/10/2007 when C1 states that campaign did not officially begin until January 21, 2007.

4. PDC Form Schedule B to C4. PDC #100203083, filed February 13, 2007.
Violation: lists in-kind contribution dated 1/10/2007 for website development by Marion Beddill for $750.00, when C1 states campaign start date of January 21, 2007.

5. PDC Form Schedule A, #100203083, dated February 13, 2007:
Violation: lists miscellaneous expenses of $19.00 dated January 9, 2007, when C1 lists campaign start date as January 21, 2007.

6. PDC Form C3, # 100203086, dated February 13, 2007:
Violation: lists personal deposit of $62.24 dated January 10, 2007 when C1 lists actual campaign start date as January 21, 2007.

7. PDC Form C3, #100203084, dated February 13, 2007:
Violation: lists personal campaign donation of $100.00 by Mr. Pike dated January 16, 2007.

8. PDC Form C3 #100209228, dated April 20, 2007
Violation: deposit filed 10 days late.

9. PDC Form Schedule L to C3 or C4, #100209227, dated April 20, 2007.
Violation: lists personal loan from Genevieve Cohn dated 3/30/2007 for $180.00 without identifying whether loan is for primary or general election cycle or the details regarding the event held at the park facility.

10. PDC Form C3, #10021103, dated May 10, 2007:
Violation: deposit is 15 days late.

11. PDC Form C4, #100211305, 100211299, 10021110, 10211122, 100211120, 100211117.
Violation: filed out of sequence. C4 and amendments were filed 6 times. Which C4 is accurate?

12. PDC Schedule C3 #100211115 dated May 10, 2007.
Violation: lists contribution by Laura Boynton on 4/25/2007 with an aggregate amount of $1650.00 without previous record of $150.00 contribution.

13. PDC Form C3, # 100211103, dated 5/10/2007.
Violation: late deposit dated 3/22/2007 for a contribution of $75.00.

14. PDC Form C3, #100211105, dated May 10, 2007.
Violation: late deposit dated 3/26/2007 for a contribution of $75.00.

15. PDC Form C3, #100211102, dated May 10, 2007.
Violation: late deposit dated 3/21/2007 for a personal contribution of 150.00 by Dan Pike.
16. PDC Form C3, #100211104, dated May 10, 2007.
Violation: late deposit dated 3/14/2007 for a small contribution listed in section e.

17. PDC Form C3, #100211100, dated May 10, 2007.
Violation: 2 late deposits dated 3/5/2007 for 2 contributions of #37.50 each.

18. PDC Form Schedule A to C4, #100212945, dated June 4, 2007.
Violation: no purpose and expense description listed for expenditure of $25.88 reported on 5/1/2007.

19. PDC Form C4, #10021409, dated June 11, 2007.
Violation: line 8; previous line 8 is $10,676.14 not $14,533.36.

20. PDC Form C3, #100215324, dated June 18, 2007.
Violation: 2 contributions dated 6/1/2007 in the amount of $184.80 each received from Alfred and Winnie Adrian, address listed as 5201 Oakmount Crest, #16, Burnaby B.C. V5H 4S8: Federal election prohibits all candidates and political committees in this country from receiving contributions from foreign nationals (individuals, corporations, associations or other foreign business entities).

21 PDC Form C3, #100218403, dated July 16, 2007.
Violation: contribution dated 7/12/07 for $100.00 is listed as unknown.

22. PDC Form C3, # 100222584, dated August 15, 2007.
Violation: Candidate lists a personal loan of $500.00. This loan is listed twice, once on the form referenced above, and a second time on a C3 #100223225 filed 8/21/07 dated as received on 8/17/2007.

23. PDC Form C3, #100226329, dated September 16, 2007
Violation: Contributor occupation information is not included on C3 for Shirley Zuanich, dated 9/10/07.

24. PDC Form C4, #100230053, dated October 15, 2007.
Violation: line 8 of previous C4 reads $14,521.08

25. PDC Form C4, #100229636, dated October 12, 2007
Violations: previous line 8, May 14, 2007 reads $14,521.08 not $11,221.08.

26. PDC Form C4, #100230054, dated October 15, 2007.
Violations: Amended line 8 = $16,840.41, not $16,470.81.

27. PDC Form C4 Amendment, #100229639, dated October 12, 2007.
Violations: Amended line 8 from August 1, = $19,095.81 not $19,465.41

28. PDC Form Schedule L to C3 or C4 Amendment, #100229639, dated October 12, 2007.
Violation: personal loan from Dan Pike is shown as re-paid, but is represented on Schedule L as not paid.

29. PDC Form C4, #100230062, dated October 15, 2007.
Violation: line 8 of previous C4 $22,010.41, not $21,640.81

30. PDC Form Receipts Continuation Sheet (Attachment to C-3 Form), #100226933, dated 9/21/07.
Violation: contribution for Alice Litton dated 9/19/07 does not include address.

31. PDC Form C3, #100227316, dated September 25, 2007
Violation: late filing for pay pal expenditure of .29 on 1/26/07.

32. PDC Form C3, #100227367, dated September 26, 2007.
Violation: This should have been filed as an amendment. Candidate did not use a proper form. Late filing of deposit of candidate’s own personal funds dated 1/16/07. Not reported until 9/26/07.

33. PDC Form C3, #100227368, dated September 26, 2007.
Violation: This should have been filed as an amendment. Candidate did not use proper form. Late filing of deposit of candidate’s own personal funds dated 5/21/07. Late filing of candidate’s personal funds deposited.

34. PDC Form C3, #100227457, dated September 27, 2007.
Violation: late deposit of campaign contribution dated 4/8/07. 4 months late.

35. PDC Form C3, #100227455, dated September 27, 2007.
Violation: late contribution filing dated 5/21/07.

36. PDC Form C3, #100227456, dated September 27, 2007.
Violation: late contribution received on 4/9/2007. Contribution is 4 months late.

37. PDC Form C3 Amendment, #100228812, dated October 8, 2007.
Violation: late contribution received on 7/26/07. 3 months late.

38. PDC Form C3, #100227526, dated September 28, 2007.
Violation: occupation data is missing for Tom Pratum, along with city and state.

39. PDC Form Schedule L Amendment, 100228808, dated October 8, 2007.
Violation: Campaign loan from Laura Boynton dated 4/25/07 was previously listed as a campaign contribution on C3 #1002111115.

40. PDC Form Schedule A, #100230052, dated October 15, 2007.
Violation: filing reports 9/4/2007 reimbursement to Laura Boynton for child care so she can attend various events. This is not reported as a loan and may qualify as the personal use of contributions that is not directly related to the candidate’s election campaign. Expenditures of a candidate’s campaign funds should be directly related to the campaign.

41. PDC C4 Amendment, #100228817, dated October 8, 2007.
Violation: Report period listed from 1/9/2007 to 1/31/2007, when C1 lists campaign start date as January 21, 2007. Amendment is late.

42. PDC Form C3, #100228158, dated October 4, 2007.
Violation: occupation data for Gerry Wilbour and Kathrine Dalen. Need business name.

43. PDC Schedule A to C4 Amendment, #100228817, dated October 8, 2007.
Violation: miscellaneous expense of $18.90 dated 1/9/2007 is listed without identifying the purpose of expense and/or description. Expense is 9 months late. Expense was incurred before campaign start date of January 21, 2007. Amendment is late.

44. PDC Schedule C3 Amendment, #100228802, dated October 8, 2007.
Violation: lists a late deposit for $25.00 dated 1/27/2007. Amendment is late.

45. PDC Schedule B to C4, Amendment #100228817, dated October 8, 2007.
Violation: lists late in-kind contribution description by candidate. In-kind contributions took place before C1 listed campaign start date of January 21, 2007. Amendment is late.

46. PDC schedule A to C4 Amendment, # 100228819, dated October 8, 2007.
Violations: expense dated 2/1/2007 does not include purpose of expense and/or description. Amendment is late.

47. PDC Schedule L to C3 or C4 Amendment, # 100228819, dated October 8, 2007.
Violations: candidate did not attach Schedule L to original February 21, 2007 report. Amendment is late.

48. PDC Schedule B to C4 Amendment, #100228819, dated October 8, 2007.
Violation: amendment is late.

49. PDC Form Schedule A to C4 Amendment, #100228820, dated October 8, 2007.
Violation: potential late filing of expenditures dated 3/1, 3/3, and 3/9. Amendment is late.

50. PDC Form Schedule A to C4 Amendment, #100228822, dated October 8, 2007.
Violation: lists a miscellaneous expense of $6.00 without a purpose of expense and/or description.

51. PDC Form Schedule A to C4 Amendment, #100228822, dated October 8, 2007.
Violation: 4/1 event does not have a purpose of expense and/or description.

52. PDC Form Schedule A to C4 Amendment, #100228823, dated October 8, 2007.
Violation: 5/1 expenditure does not have a purpose of expense and/or description of expense for $86.50.

53. PDC Form C4 Amendment, #100229637, dated October 12, 2007.
Violation: Line 8 in previous C4 lists $14,521.08. Line 1 reports previous cash total as $11,221.08.

54. PDC Form Schedule A to C4 Amendment, #100229637, dated October 12, 2007.
Violation: The miscellaneous expense dated 6/1/07 does not have a purpose of expense and/or description.

55. PDC Form C4 Amendment, #100230054, dated October 15, 2007.
Violation: Amended line 8 = $16,840.41 not reported amount of $16,470.81

56. PDC Form Schedule L to C3 or C4 Amendment, #100230054, dated October 15, 2007.
Violation: potential late filings of Loans or erroneous filing of loan. Loan of $1,500 from Laura Boynton is reported as a loan, instead of a campaign contribution, as listed in an earlier report dated 4/25/07.

57. PDC Form Schedule L to C3 or C4 Amendment, #100230055, dated 10/15/07.
Violation: late filing of personal loan from Edith Pike, candidate’s mother dated 8/28/07.

58. PDC Form C4 Amendment, #100229639, dated 10/12/07.
Violation: line 8 from August 1, = $19,465.81 not 19,095.81.

59. PDC Form Schedule L to C3 or C4 Amendment, #100229639, dated October 12, 2007.
Violations: Mr. Pike claims to be repaid for loan of $500.00 dated 8/14/07, but is showing it as a debt still owed on this amendment.

60. PDC Form C4 Amendment, #100230062, dated October 15, 2007.
Violation: Line 8 of previous C4 is $22,010.41 not $21,648.81.

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