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Queens County Young Democrats President: Costa Constantinides
24-60 28 th Street o
0( l- Executive Vice President: Matt Bishop
Astoria, NY 11102 e. Of'
Vice President of Political Affairs: Ian Rivera
'"C OEMO CI~

September 27,2010

Matthew S. Peterson
Chairman
Federal Election Commission
999 E Street, NW
Washington, DC 20463

Dear Chairman Peterson,

Pursuant to 2 U.s.c. § 437g, please accept this letter as a complaint against Bob Turner and Bob Turner
for Congress for violating the Federal Election Campaign Act and Federal Election Commission
regulations.

Bob Turner is a candidate for Congress in New York's 9th Congressional District. On September 21, 2010
the FEC sent Mr. Turner's campaign a Request for Additional Information, asking him to clarify some
omissions and discrepancies in his 2010 July Quarterly Report. Unfortunately, his very next filing (his
2010 Pre-Primary Report), shows a continued disregard for the law. It is concerning to note that Mr.
Turner has reported spending levels far below clear and apparent expenditures. If done intentionally,
this is misleading activity that violates federal campaign finance laws and regulations. While I
acknowledge such a serious issue requires a rigorous and precise investigation, I wish to share with you
some evidence that suggests Mr. Turner is not submitting accurate information required by federal law.

As you know, and is stated in the Commission's Request for Additional Information, federal campaign
finance laws require the full disclosure of expenditures and funds raised during specified time intervals.
These disclosures are made public in order to ensure the greatest possible level of transparency in our
political system, and to achieve to the greatest extent possible a level playing-field between
multimillionaire candidates such as Mr. Turner and other, less well-financed candidates. Violating these
laws can even be a crime if the violation is knowing and willful.

Under these laws, current Federal Election Commission (FEC) disclosure rules require candidates to file
regular reports that include a full accounting of both receipts and disbursements at the end of each
filing period. Mr. Turner has omitted from his latest FEC filing extensive receipts and disbursements he
has accrued over recent months from his latest FEC filing. If true, this is illegal, misleading, and
deceptive conduct.

In his initial filing, for the second quarter of 2010, Mr. Turner listed the usual receipts and disbursements
associated with a political campaign. But, in his latest filing, for the nearly 2 month period between July
1 and August 25, Mr. Turner has listed a single disbursement: $2,900 for office rent. Beyond the oddity
of not reporting some of the same basic expenditures listed in his first filing, such as utilities and
fundraising expenses, we are aware of several actual receipts and disbursements that did not appear.
These include:

• July 17,2010: Grand opening of the Turner campaign office, an event that included food and
entertainment (documentation attached)
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• July 30, 2010: Half-page print media advertisement on page 3 of the July 30 edition of the
Rocakway Wave (documentation attached)
• August 12, 2010: Fundraiser at a local restaurant - no receipts for this fundraiser were listed
(photos attached)
• August 26-27, 2010: Five print media advertisements in local newspapers
• August 12, 2010: Bob Turner said he raised "about $250,000" to the Queens Chronicle

In addition to these clear examples of campaign receipts and disbursements, we have received
documentation of several other suspect activities during the latest filing period, including:

• Box trucks advertising Mr. Turner's candidacy, yet no disclosed purchase or lease
• Press releases listing a known communications consultant as a contact, yet no disclosed
consulting fee
• Press releases listing a spokesperson as a contact, yet no disclosed salary
• Magnetic bumper signs advertising Mr. Turner's candidacy, yet no disclosed purchase

These clearly visible activities only increase the suspicion aroused by the strange omission in his latest
filing of the basic utility expenses that appeared on his first filing. This would lead one to the bizarre
conclusion that, though Mr. Turner had quite obviously stepped up campaign activities, he had decided
to do so without the use of routine utilities in his campaign office, such as electricity. Cable, electric, and
telephone payments were all separately listed on his July quarterly filing but did not appear on his most
recent filing.

Based on the activity that has been brought to my attention, I am worried that Mr. Turner is not in
compliance with clear, well-understood campaign finance rules. Knowingly and willfully violating these
rules is a crime.

But I believe the spirit and letter of these rules is also essential to ensuring that less well-financed
candidates can compete against multimillionaires like Mr. Turner. Violating these rules jeopardizes the
good functioning of democracy and deprives citizens of important information on which to base their
choice. I encourage you to inquire into these filing inconsistencies in order to guarantee that residents
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of the 9 congressional district enjoy a fair and legal campaign.

Sincerely,

(}fC .
Costa onstantlnl'd es
President
Queens County Young Democrats

J
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JANNA M. l OYOLA-DAVIS
My Commission Expires: ~ !' ~ I' · - ._ .,. Notary Public, State of New York
No. 01 L06128474
Qualified in Queens Count9
Commission expires June 13, 20,
 Photos from Turner's Office Grand Opening

(from Bob Turner for Congress HQ Grand Opening)

http: / /www. facebook.com/ album .php ?aid=16941&id=12 7089667 313198

 Photos from Fundraiser at Local Restaurant

(from Russo's Fundraiser 8/2/10)

http://www.facebook.com/album .php 7aid;18505&id;1270896673B198

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