13 14 15 16 17 18 19 20 21 22 23 24 25 26 for election or retention or in support of or opposition to an initiative, referendum or recall or any other measure or proposition and that applies for a serial number and circulates petitions and, in the case of a candidate for public office except those exempt pursuant to section 16-903, that receives contributions or makes expenditures in connection therewith, notwithstanding that the association or combination of persons may be part of a larger association, combina of persons or sponsoring organization not primarily organized, conducted or combined for the purpose of influencing the result election in this state or in any county, city, town or precinct in this state. Political committee includes the following types of committees: oppose 2 recall petition or (d) A committee organized to circulate o: to influence the result of a recall elec! Committees which fall within the above definitions are required to register with the Pima County Department of Elections pursuant to ARS 16-902. On or about April 13, 2011, Respondents in concert and cooperation began an effort to stop Complainant’s valid recall efforts by: (1)mischaracterizing Complainant's status as a 527 political organization; (2) falsely claiming that donations and expenditures to Complainant were not being accounted for; (3)falsely claiming that donations to Complainant were “going into someone’s pockets” and not towards the recall efforts; (4)advising donors to initiate refunds based on the unfounded and specious claims of Respondents; and, (5)characterizing Complainant's President as a “crook” and the recall efforts a “scam”, via print publications’, the world- wide web? and in public radio transmissions’. Based on the allegations as set forth above, Respondents were clearly acting as a de facto political committee, within the definitions of ARS 16~ 901(19) (d) in that their combined efforts were designed to oppose and defeat the valid and lawful efforts of Complainant. As a political committee, Complaint-3