IN THE MATTER OF )

) March 16, 2023

Benjamin Bergmann )
4201 Cathedral Avenue, NW ) Docket No.: OCF-INV 2022-009
Apt. 123E )
Washington, DC 20016 )
)
and )
)
Patricia (Tricia) Duncan )
5109 Klingle Street, NW )
Washington, DC 20016 )

ORDER

This matter came before the Office of Campaign Finance (OCF) Office of the General
Counsel pursuant to a complaint (Complaint) filed by Chuck Thies (hereinafter Complainant)
which was docketed on September 1, 2022. The Complainant alleged that Patricia (Tricia) Duncan
and Ben Bergmann (hereinafter Respondent Candidates) who were both candidates for Ward 3
Member of the Council in the June 21, 2022, Democratic Primary Election knowingly and
intentionally accepted illegal in kind contributions in violation of D.C. Official Code §§ 1-
1163.32b(a)(4), 1-1163.32f(a)(1) and 3 DCMR § 4205.1(d), and acted based upon the receipt of
the information they obtained unlawfully, to withdraw from the race and endorse Matthew Frumin.
Complainant further alleged that At-Large Council candidate Elissa Silverman, “deliberately and
egregiously”, violated D.C. Official Code § 1-1163.32f (d)(5), through an illegal in-kind
contribution and 3 DCMR § 4209.5(g) by making a contribution to elect Matthew Frumin and
conducting an illegal conspiracy to commit campaign finance fraud.

Specifically, Complainant alleged that Patricia (Tricia) Duncan and Ben Bergmann
violated the $50.00 Fair Elections Program contribution limit set by D.C. Official Code §§ 1-
1163.32b(a)(4), 1-1163.32f(a)(1) and 3DCMR § 4205.1(d), by intentionally accepting illegal in-
kind contributions in the form of results of polls conducted regarding the Ward 3 Democratic
Primary Election, which were in excess of $50.00 and taking action based upon the receipt of the
unlawfully obtained information to alter the operations of their campaigns and withdraw from the
race and endorse Matthew Frumin.

On September 16, 2022, pursuant to docketing the Complaint, the Office of the General
Counsel (OGC) initiated a full investigation into the matter, provided Respondent Candidates
Tricia Duncan and Benjamin Bergmann with copies of the Complaint and advised them of their
right to respond. On November 1, 2022, OCF transmitted questions to the Respondent Candidates.
On October 31, 2022, Respondent Candidate Duncan acknowledged receipt of the Complaint and
submitted responses to the questions through Counsel, Danny Onorato, Esq. On November 10,
2022, Ms. Duncan, through Counsel, denied all allegations in the Complaint and indicated that
even though she became aware of the polls related to the Ward 3 Democratic Primary Election on
or about June 11, 2022, her decision to withdraw as a candidate in the contest was not influenced
by her standing in the polls.
In the Matter of Bergmann and Duncan
OCF-INV 2022-009
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On November 15, 2022, Mr. Bergmann submitted responses to the questions also denying the
allegations in the Complaint, however, he provided detailed responses to the following questions
presented by OCF:

Question 4. Did you or anyone connected to your campaign receive any instruction or
recommendations regarding whether you should continue your campaign for Ward 3
Councilmember after you received the results of the Poll?

Response: Again, while CM Silverman shared some high-level details about polls, she conducted
in Ward 3 (namely that I was going to lose), I was not provided with any polling data, and my
campaign certainly did not receive “instructions” from CM Silverman or any other person. During
the two telephone conversations that we had about the Ward 3 race, one on May 27 and one on
June 11, she was quite open that she (a) believed I was unlikely to win and (b) hoped that one or
more of the progressive candidates (including me) would withdraw to reduce the likelihood of Eric
Goulet winning due to vote splitting. When we discussed vote splitting or put differently, the risk
that I could be a Ralph Nader-like spoiler responsible for someone who I very much opposed
winning public office, it was obvious that CM Silverman believed I could best advance my values
by withdrawing and consolidating behind a more viable progressive candidate. However, this was,
at best, a soft recommendation. Far from cajoling me on the call, CM Silverman acknowledged
that withdrawing at such a late stage was emotionally difficult even for the most clear-eyed of
candidates. Indeed, our conversation felt more like a preemptive condolence call regarding my
impending defeat than a strong-arm effort to orchestrate my exit. Rather than exert some sort of
pressure on me, it seemed like CM Silverman had mainly called out of courtesy, saving me the
discomfort of learning of her decision regarding an endorsement on Twitter. While I was
disappointed with the call, I appreciated the gesture. At some point during the call, CM Silverman
shared that she had also rejected an endorsement request from Tricia Duncan. Aware that Duncan
had actively considered withdrawing in May, I asked if the councilmember thought Duncan would
revisit the idea. Duncan’s surprisingly brief June 10 campaign finance report, filed only the day
before, was fresh on my mind. CM Silverman did not know but indicated that she had shared the
same concerns about vote splitting with Duncan. At no point did CM Silverman explicitly request
that I withdraw, let alone withdraw and endorse Matt Frumin. Towards the end of our call, I recall
her expressing sympathy for how she assumed I was feeling, having run and lost a campaign once
herself. (In the moment, I found this statement to be both kind and infuriating, as I had not yet
lost.) After I expressed pride in what my campaign had accomplished, she encouraged me to see
the big picture and make the decision that best advanced my campaign’s vision and

values. I recall her asking me to think about how it would feel to wake up the day after a narrow
Goulet victory knowing that I could have stopped that outcome if I had suspended and backed a
more viable candidate. At the time, I will admit, I found the entire conversation extremely
frustrating and condescending. As I had told her on May 27, CM Silverman and other progressive
leaders could have, and should have, engaged much earlier, perhaps as early as February. While
progressives waited towards the end of the race to identify the strongest
In the Matter of Bergmann and Duncan
OCF-INV 2022-009
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candidate, the business lobby and other special interest groups engaged much earlier in the process,
icing out potential rivals to their preferred candidate, Eric Goulet, on the moderate/conservative
side of the race. As the call concluded, I acknowledged that I had already been thinking about
withdrawing off and on since, at least, late May. I cited a number of reasons why I was reluctant
to withdraw— the timing, my duty to my volunteers or donors, and so on. All true, at some level,
but also beside the point. I did not want to quit because I did not want to quit. Most candidates that
run for office lose, and I suspect most are fully well-aware that they are destined for defeat well
before Election Day. Very few candidates, however, can successfully put their ego aside long
enough, see the bigger picture, and take action to avoid playing the spoiler that helps elect an
ideological opponent. (See, e.g., Ralph Nader 2000 presidential campaign, Wikipedia; Sahil Kapur
and Allan Smith, “Libertarians and third-party candidates could play spoilers in crucial Senate
races,” (NBC News, Oct. 21, 2022). The idea that I should do so had been put forth to me before
my call with the Councilmember, and my resistance to the idea continued after I spoke with her.
Pride is a hell of a drug. And on June 11, I was still struggling to put my ego aside. Before hanging
up, I told CM Silverman that I had no plans to withdraw. And, as discussed below, I remained
largely committed to this position in the subsequent days.

Question 8. Did Councilmember Silverman encourage you to withdraw from the Ward 3
Council race after discussing the Poll results with you to facilitate a Matthew Frumin
victory?

Response: See answer to question 4. Yes. Discussions regarding the need to coalesce behind a
single progressive candidate was widespread throughout the primary. When we discussed the risk
that vote splitting could play a determinative role in the election, CM Silverman encouraged me
to see the bigger picture, for Ward 3 and the entire District, and choose the path that was most
likely to result in a candidate aligned with my values winning the primary—and that is exactly
what I did. As noted above, although I largely agreed with her, I indicated in my June 11 call with
CM Silverman that I was unlikely to withdraw. The next day, in a public reply to one of my tweets,
CM Silverman wondered aloud whether candidates (like me) would put their ego aside, coalesce,
and fight back against the special interests working to reverse recent progressive gains on the
Council.

In conjunction with the responses provided by Bergmann and the denial of the allegations in the
Complaint, by Duncan, through counsel, a through legal analysis of the facts presented in the
Complaint, which is before the Office of Campaign Finance, with respect to illegal in-kind
campaign contributions and conspiracy to commit election fraud, has been conducted using
applicable statutes and regulations governing campaigns and elections in the District of Columbia.

The following statutes and regulations define the parameters of contributions, as they relate to the
Fair Election Program. The selected provisions consist of statutes and regulations, around the
definitions, limitations, requirements, and expenditures in connection with contributions and
In the Matter of Bergmann and Duncan
OCF-INV 2022-009
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conspiracy to commit fraud. Categorically, the law and statutes cite provisions for the definition
of contribution, contribution limitations and requirements, limitations on contributions and
expenditures, limitations on the use of campaign funds, limitations on Fair Elections Program
funds and expenditures, definitions of in-kind contribution and conspiracy to commit fraud.

As a general legal principle, D.C. Official Code Section 1-1161.01 (10A) provides that:

(10)(A) “Contribution” means:

(i) A gift, subscription (including any assessment, fee, or membership dues), loan (except a loan
made in the regular course of business by a business engaged in the business of making loans),
advance, or deposit of money or anything of value (including contributions in cash or in kind),
made for the purpose of financing, directly or indirectly:

(I) The election of a candidate;

(II) Any operations of a political committee, political action committee, or independent

expenditure committee; or

(III) The campaign to obtain signatures on any initiative, referendum, or recall measure, or to
bring about the ratification or defeat of any initiative, referendum, or recall measure;

(ii) A transfer of funds between

(I) Political committees;

(II) Political action committees;

(III) A political committee and a political action committee; or

(IV) Candidates;

(iii) The payment, by any person other than a candidate, a political committee, political action
committee, or independent expenditure committee of compensation for the personal services of
another person that are rendered to such candidate or committee without charge or for less than
reasonable value, or the furnishing of goods, advertising, or services to a candidate's campaign
without charge or at a rate which is less than the rate normally charged for such services; and

[(iv)] An expenditure that is coordinated with a public official, a political committee affiliated
with a public official, or an agent of any person described in this sub-subparagraph.

(B) Notwithstanding subparagraph (A) of this paragraph, the term “contribution” does not
include:
In the Matter of Bergmann and Duncan
OCF-INV 2022-009
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(i) Personal or other services provided without compensation by a person (including an

accountant or an attorney) volunteering a portion or all of the person's time to or on behalf of a
candidate, political committee, political action committee, or independent expenditure
committee;

(ii) Communications by an organization other than a political party solely to its members and
their families on any subject;

(iii) Communications (including advertisements) to any person on any subject by any

organization that is organized solely as an issue-oriented organization, which communications
neither support nor oppose any candidate for office.

(iv) Normal billing credit for a period not exceeding 30 days.

(v) Services of an informational or polling nature, designed to seek the opinion of voters
concerning the possible candidacy of a qualified elector for public office, before such qualified
elector becomes a candidate;

(vi) The use of real or personal property, and the costs of invitations, food, and beverages
voluntarily provided by a person to a candidate in rendering voluntary personal services on the
person's residential premises for related activities; provided, that expenses do not exceed $500
with respect to the candidate's election; and

(vii) The sale of any food or beverage by a vendor for use in a candidate's campaign at a charge
less than the normal comparable charge, if the charge for use in a candidate's campaign is at least
equal to the cost of such food or beverage to the vendor; provided, that expenses do not exceed
$500 with respect to the candidate's election.

(10B)(A)(ii) In cooperation, consultation, or concert with, or with other material involvement of

a public official, a political committee affiliated with a public official, or an agent of a public
official or a political committee affiliated with a public official.

(B) There shall be a rebuttable presumption that a contribution or an expenditure is coordinated

with a public official, a political committee affiliated with a public official, or an agent of a
public official or a political committee affiliated with a public official, if:

(i) The contribution or expenditure is made based on information that the public official, political
committee affiliated with the public official, or an agent of a public official or a political
committee affiliated with a public official, provided to the particular person making the
contribution or expenditure about its needs or plans, including information about campaign
messaging or planned expenditures;
In the Matter of Bergmann and Duncan
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(ii) The person making the contribution or expenditure retains the professional services of a
person who also provides the public official, political committee affiliated with the public
official, or an agent of a public official or a political committee affiliated with a public official,
with professional services related to campaign or fundraising strategy;

(iii) The person making the contribution or expenditure is a political committee, political action
committee, or independent expenditure committee that was established or is or was staffed in a
leadership role by an individual who:

(I) Works or previously worked in a senior position or in an advisory capacity on the

public official's staff or on the public official's principal campaign committee; or
(II) Who is a member of the public official's immediate family; or

(iv) The contribution or expenditure is made for the purpose of financing, directly or indirectly,
the election of a candidate or a political committee affiliated with that candidate, and that
candidate has fundraised for the person making the expenditure.

Pursuant to the law governing contributions under the Fair Elections Program, D.C. Official Code
§ 1–1163.32b expressly provides:

Fair Elections Program contribution limitations and requirements.

(a) Neither a candidate seeking certification, nor a participating candidate may accept a qualified
small-dollar contribution or a contribution from a non-District resident individual, that, when
aggregated with all other qualified small-dollar contributions received from that small-dollar
contributor or contributions received from that non-District resident individual, exceeds, per
election cycle:

(1) In the case of a qualified small-dollar contribution or contribution from a non-District

resident individual in support of a candidate for Mayor, $200;
(2) In the case of a qualified small-dollar contribution or contribution from a non-District
resident individual in support of a candidate for Chairman of the Council or Attorney
General, $200;
(3) In the case of a qualified small-dollar contribution or contribution from a non-District
resident individual in support of a candidate for member of the Council elected at-
large, $100;
(4) In the case of a qualified small-dollar contribution or contribution from a non-District
resident individual in support of a candidate for member of the Council elected from a
ward or for member of the State Board of Education elected at-large, $50; and
(5) In the case of a qualified small-dollar contribution or contribution from a non-District
resident individual in support of a candidate for member of the State Board of
Education elected from a ward, $20.
In the Matter of Bergmann and Duncan
OCF-INV 2022-009
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(b) Each qualified small-dollar contribution and contribution from a non-District resident
individual shall be acknowledged by a physical or digital receipt to the contributor, with a copy
to be retained by the candidate. The receipt shall include:

(1) The contributor's digital or physical signature, printed name, home address, telephone
number, occupation and principal place of business, if any, and the name of the candidate to
whom the contribution is made; and

(2) A written and signed oath or affirmation declaring that the contributor:

(A) Is making the contribution in the contributor's own name and from the contributor's own
funds;

(B) Is making the contribution voluntarily and has not received anything of value in return for
the contribution;

(C) In the case of a small-dollar contributor, is a District resident;

(D) In the case of a contribution from a non-District resident individual, is a non-District resident
individual; and

(E) Understands that a false statement is a violation of law.

(b-1) Notwithstanding subsection (b)(2) of this section:

(1) If a contributor agrees to make contributions to a candidate that recur automatically on a

periodic basis, the contributor's initial indication made pursuant to subsection (b)(2) of this
section or paragraph (2) of this subsection is sufficient to indicate continuous assent, and the
contributor need not provide an indication pursuant to subsection (b)(2) of this section or
paragraph (2) of this subsection for each recurring contribution.

(2) If a contributor makes a contribution to a candidate over the phone, the indication required by
subsection (b)(2) of this section may be provided by the contributor orally.

(c) A candidate seeking certification and a participating candidate may accept qualified small-
dollar contributions and contributions from non-District resident individuals made by means of
personal check, credit card, cash, or electronic payment account: provided, that contributions in
the form of cash cannot, in the aggregate, exceed $100 per small-dollar contributor or non-
District resident individual per candidate per election cycle.
In the Matter of Bergmann and Duncan
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The law governing the Fair Elections Program, pursuant to, D.C. Official Code § 1–1163.32f also
provides:

Limitations on contributions and expenditures

(a) Except as provided in subsection (d)(2) of this section, a candidate seeking certification and a
participating candidate shall not receive or expend any contribution in that election cycle other
than:
(1) Qualified small-dollar contributions;
(2) Contributions from non-District resident individuals that comply with the limitations
in section 1-1163.32b(a);
(3) Contributions from Fair Elections Committees that do not exceed $1,500 per Fair
Elections Committee per election cycle; provided, that Fair Elections Committees
established, financed, maintained, or controlled by substantially the same group of
individuals shall be treated as a single Fair Elections Committee and their contributions
aggregated;
(4) Base amount payments under section 1-1163.32d;
(5) Matching payments under section 1-1163.32e; and
(6) Personal funds of the candidate or the candidate's immediate family in the form of a
contribution or loan that does not exceed, in the aggregate:
(A) For a candidate for Mayor, $5,000; or
(B) For a candidate for Attorney General, Chairman of the Council, member of the
Council elected at-large or by ward, or member of the State Board of Education elected
at-large or by ward, $2,500.

(b) The amounts described in subsection (a)(6) of this section shall be adjusted by the Director of
Campaign Finance each election cycle by the percentage increase in the Consumer Price Index
for the Washington-Baltimore Metropolitan Statistical Area for All Urban Consumers published
by the Bureau of Labor Statistics of the Department of Labor, or any successor index, for the
prior calendar year.

(c)(1) A candidate seeking certification who accepted a contribution from sources other than
those described in subsection (a) of this section before the date the candidate is certified may not
participate in the Fair Elections Program, unless within 10 days after certification, the
participating candidate:
(A) Returns the unexpended contribution to the contributor;
(B) Remits the unexpended contribution to the Fair Elections Fund; or
(C) If the contribution has been expended, and:
(i) The election is a contested election, subtracts the total amount of the expended
contributions from the base amount to which the candidate would be eligible
under section 1-1163.32d; or
In the Matter of Bergmann and Duncan
OCF-INV 2022-009
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(ii) The election is an uncontested election, subtracts the total amount of the
expended contributions from the matching payments to which the candidate
would be eligible under section 1-1163.32e.

(2) If the candidate expended contributions from sources other than those described in subsection
(a) of this section in excess of the base amount to which the candidate would be eligible
under section 1-1163.32d, the candidate may not participate in the Fair Elections Program.

(d) A participating candidate shall not make expenditures for the following:
(1) Legal expenses not directly related to acts taken under this act or the Elections Code;
(2) Payment of any penalty or fine imposed pursuant to federal or District law;

(3) Compensation to the participating candidate or a member of the participating candidate's

immediate family, except for reimbursement of out-of-pocket expenses incurred for campaign
purposes;

(4) Clothing and other items or services related to the participating candidate's personal
appearance;

(5) Contributions, loans, or transfers to another candidate's political committee or a political

action committee;

(6) Gifts, which, for the purposes of this paragraph, shall not include printed campaign materials
such as signs, brochures, buttons, or clothing; and

(7) Any other purpose that the Elections Board establishes through rules issued pursuant
to section 1-1163.32l.

As a general principle, the limitations on the use of campaign funds, is governed by 3 DCMR
Section 3013, which provides, in part, that:

3013.1 Campaign funds shall be used solely for the purpose of financing, directly or
indirectly, the election campaign of a candidate.

The law governing the limitations on the use of Fair Election Program funds and expenditures,
pursuant to, 3 DCMR Section 4209.5, expressly provides that:

4209.5 A participating candidate shall not make expenditures for the following:

(a) Legal expenses not directly related to acts taken under this act or the
Elections Code;
In the Matter of Bergmann and Duncan
OCF-INV 2022-009
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(b) Payment of any penalty or fine imposed pursuant to Federal or District

law;

(c) Compensation to the participating candidate or a member of the

participating candidate’s immediate family, except for reimbursement of
out-of-pocket expenses incurred for campaign purposes;

(d) Clothing and other items or services related to the participating

candidate’s personal appearance;

(e) Contributions, loans, or transfers to another candidate’s political

committee or a political action committee;

(f) Gifts, which, for the purposes of this paragraph, shall not include printed
campaign materials such as signs, brochures, buttons, or clothing; and

(g) Any other purpose that does not support the nomination of election to
office of the participating candidate as delineated in § 3013 of this title.

3 DCMR Section 9900.1 establishes the definition of in-kind contributions, as follows:

In-kind contribution - a contribution of goods, services, or property by the contributor to a

campaign finance committee, candidate, constituent-service program, or Statehood Fund.

The legal definition under the law for a political committee is set forth in D.C. Official Code § 1–
1161.01(44), as follows:

(44) “Political committee” means a committee, club, association, organization, or other group of
individuals that is:

(A) Organized for the purpose of promoting or opposing:

(i)) The election of a person to public office;

(ii) A political party; or

(iii) Any initiative, referendum, or recall; or

(B) An inaugural, transition, or legal defense committee; and

(C) Controlled by or coordinated with any public official or agent of a public official.
In the Matter of Bergmann and Duncan
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The Code of the District of Columbia Section 22-1805a governs Conspiracy to commit a crime.
Conspiracy under DC law is defined as an agreement between two or more people. The elements
of a conspiracy are that a person was a part of an agreement to commit a crime, and at least one
person in the agreement committed an act to further the conspiracy, or an overt act.

Section 22-1805(a)(1) provides that: “if 2 or more persons conspire either to commit a criminal
offense or to defraud the District of Columbia or any court or agency thereof in any manner or
for any purpose, each shall be fined not more than the amount set forth in Section 22-3571.01 or
imprisoned not more than 5 years, or both, except that if the object of the conspiracy is a criminal
offense punishable by less than 5 years, the maximum penalty for the conspiracy shall not exceed
the maximum penalty for that offense.”

Section 22-1805(b) establishes that “No person may be convicted of conspiracy unless an overt
act is alleged and proved to have been committed by 1 of the conspirators pursuant to the
conspiracy and to effect its purpose.”

In addition, the legal definition of conspiracy, referenced in Black’s Law Dictionary, is as follows:

” A combination, or an agreement between two or more persons, for accomplishing an unlawful

end or a lawful end by unlawful means.”

The allegations set forth in the Complaint submitted by the Complainant are primarily based on
the fact that the Respondent Candidates and their committees engaged in discussions regarding the
results of polls to determine the likelihood of the success of the candidates who were competing
in the Ward 3 Democratic Primary Election for Member of the Council. While it is apparent that
the results of the polls did play a role in the decisions both Respondent Candidates and their
committees made to discontinue their campaigns prior to the June 21, Democratic Primary
Election, the record, however, fails to demonstrate and it has not been clearly established,
substantiated, or corroborated that their knowledge of the polls and subsequent withdrawals equate
to illegal in-kind contributions, as defined under the law, to their Principal Campaign Committees
or the Principal Campaign Committee of candidate, Matthew Frumin. Further, the record does not
provide evidence sufficient to satisfy the elements of a charge of conspiracy to commit campaign
finance fraud. Expressly, there has been no evidence averred, proffered, or advanced in this record,
to establish that there was an overt “agreement” between Silverman, Bergmann and Duncan. Nor
was there any confirmation that the knowledge of the polls and withdrawal from the race
constituted a conspiracy to commit fraud.

While the activity of the Respondent Candidates and their committees may not comport with the
principles of the Fair Elections Program, the activity does not rise to the level of conspiracy to
commit fraud or receipt of an illegal in-kind contribution.
In the Matter of Bergmann and Duncan
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Moreover, the record does not indicate or demonstrate that the polls provided any benefit to either
Respondent Candidate. Even though decisions to withdraw from the Primary Election campaign
by the Respondent Candidates were made despite the fact that the Fair Elections Program public
financing program had made significant investments in both committees, that fact does not
substantiate the allegations in the Complaint. While it may be clearly asserted that the timing of
the withdrawals may reflect poor judgement, nonetheless, poor judgement does not establish that
an illegal act occurred.

Therefore, absent any evidence that the Respondent Candidates and committees engaged in any
activity that is prohibited by applicable statutes or regulations, the Complaint cannot be sustained
and must be dismissed.

RECOMMENDATION

In view of the foregoing and the information included in the record, I HEREBY
RECOMMEND that the Director dismiss the Complaint in this matter, its entirety.

03/16/2023
William O. SanFord
Date William O. SanFord
General Counsel

ORDER OF THE DIRECTOR

IT IS ORDERED that the Complaint in this matter is hereby Dismissed.

03/16/2023 William O. SanFord for Cecily E. Collier-Montgomery

Date Cecily E. Collier-Montgomery
Director
In the Matter of Bergmann and Duncan
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CERTIFICATE OF SERVICE

THIS IS TO CERTIFY that a true copy of the ORDER has been served to Danny Onorato, Esq.
via electronic mail at donorato@schertlerlaw.com, Ben Bergmann via electronic mail at
ben@benbergmann.com and Chuck Thies (the complainant) at chuckthies@gmail.com on
this 16th day of March 2023.

Natasha Alexander

Notice

Any party adversely affected by an Order of the Director may: (1) file a Motion for
Reconsideration (Motion) with the OCF within five (5) days after receipt of an Order, provided
that, relevant evidence was omitted from consideration at the hearing (3 DCMR §3709.13); or (2)
obtain review of the Order by filing a request for a hearing de novo with the Board of Elections
within fifteen (15) days from the date of issuance of an Order. Any fine imposed by the Director,
pursuant to §3711.2 shall become effective on the sixteenth (16th) day following the issuance of a
decision or Order; provided that, the Respondent does not request a hearing de novo with the
Board of Elections. Fines imposed shall be paid within ten (10) days of the effective date of the
issued Order of the Director. Make payment by check or money order, payable to: District of
Columbia Treasurer. Send payment to the Office of Campaign Finance, 1015 Half Street SE, Suite
775, Washington, DC 20003.