CIRCUIT COURT

STATE OF WISCONSIN

IN THE MATTER OF
JOHN DOE PROCEEDINGS
COLUMBIA Co. Case No.
DANE Co. Case No.
DODGE Co. Case No.
IOWA Co. Case No.
MILWAUKEE Co. Case No.

13JD000011
13JD000009
13JD000006
13JD000001
12JD000023

STATE OF WISCONSIN
CIRCUIT COURT FOR DANE COUNTV

AFFIDAVIT IN SUPPORT OF A REQUEST FOR SUBPOENAS

ROBERT STELTER, being first duly sworn on oath, deposes and says that:
1. I am an Investigator in the Milwaukee County District Attorney's Office. I have 27
years of experience as a law enforcement officer. I have held the rank of Detective and
Lieutenant of Detectives within the City of Milwaukee Police Department. For two years,
I worked at the Milwaukee High Intensity Drug Trafficking Area Task Force, (hereafter
HIDTA), a state/federal task force with law enforcement officers from the City of
Milwaukee Police Department, Federal Bureau of Investigation, Drug Enforcement
Administration, West Allis Police Department, Wisconsin Department of Justice,
Wisconsin State Patrol,

and other jurisdictions.

That experience included the

investigation and supervision of investigations of complex and large scale organized
crime in the Metropolitan Milwaukee, Wisconsin area. Over these last 10 years, I have
overseen multiple investigations and been involved in the supervision of investigations
that involved federal court authorized wiretaps of wire and electronic communications as
defined in

the Federal Code.

I also have participated in investigations involving

individuals and organized group activity related to the distribution of drugs and controlled
substances, and the laundering of drug proceeds and the concealment of assets
purchased with drug proceeds. In the past two years I have been involved with the
investigation of violations of Wisconsin election laws, campaign finance laws, use of
government employees for the purpose of political service, and ethics violations.

The

investigations have resulted in prosecutions for theft, campaign finance violations~ as

 well as political service involving governmental employees. I submit this affidavit in
· support of a request for search warrants and subpoenas for documents related to this
John Doe investigation.
A.

INTRODUCTION
2. On September 5, 2012, Reserve Judge Barbara Kluka authorized the

commencement of a John Doe proceeding in Milwaukee County, Wisconsin, (Case No.
12JD000023) related to violations of Wisconsin Statutes §946.12, 939.30, 939.31, and
939.05; viz. Misconduct in Public Office (PTAC), and Conspiracy and Solicitation to
Commit Misconduct in Public Office, and other violations of
Wisconsin Statutes.

Chapter 11 of the

As a result of evidence developed during the course of the

investigation that identified potential targets residing in several counties throughout
Wisconsin, related John Doe proceedings were commenced in Columbia County (Case
no. 13JD000011 );

Dane County (Case no. 13JD000009); Dodge County (Case no.

13JD000006); and Iowa County

(Case n<?. ·13JD000001). 1

On August 23, 2013,

Attorney Francis Schmitz ·was appointed as a special prosecutor to assist in the
investigation of the subject matter of this John Doe investigation in each county
captioned above.
3. I incorporate by reference the Applications, Affidavits and other papers,
particularly those noted within, that have been submitted to the court in these John Doe
proceedings, including any matters or testimony referenced in the paragraphs that
follow.

I base the foiiowing affidavit upon personai knowiedge; information and beiief

based upon statements and information from law enforcement officers and citizen
witnesses; review of documents, information and records obtained by subpoenas and
search warrants; testimony taken during the course of the John Doe proceedings in
201 OJD000007 2 , and other information as described herein believed to be reliable. In
particular, I incorporate by reference the affidavits and corresponding exhibits dated
December 10, 2012.

1

The pleadings filed in the respective counties describe the reasons for the commencement of
the related John Doe proceedings in those jurisdictions.
2
In an order dated August 10, 2012, the Honorable Neal Nettesheim presiding over the
proceedings in Milwaukee County John Doe case no. 201 OJD000007 authorized the use of all
information obtained in the course of those proceedings in the investigation of the matter that is
the subject of this John Doe.

2

 4. I also incorporate bv reference the Affidavit of Dean Nickel dated September 28,
2013.

5. I use the terms "records" "documents" and/or "information" to include all items of
evidence in whatever form and by whatever means they may have been created or
stored, including any form of computer or electronic storage (such as hard disks, jump
drives, thumb drives, COs, DVDs, external USB drives, 3.5" disks or other media that
can store data); any handmade form (such as writing, drawing, painting); any
mechanical form (such as printing or typing); and any photographic form (such as
microfilm, microfiche, prints, slides, negatives, videotapes, motion pictures,
photocopies), consistent with Wisconsin Statutes §968.13(2).
6. For purposes of this document, I use the term 2011 Senate Recall Elections to
mean any one or more of the following 2011 Senate Recall Elections, including both
the general Recall Elections specified below and any primary elections leading up to the
general Recall Elections as follows:
a. July 19, 2011
i.

District 30- Dave Hansen (Democrat), David Vanderleest
(Republican);

b. August 9:
i.

District 2 - Robert Cowles (Republican) and Nancy J. Nusbaum
(Democrat);

ii. District 8- Alberta Darling (Republican) and Sandy Pasch
(Democrat);
iii.

District 10 Sheila Harsdorf (Republican) and Shelly Moore
(Democrat);

iv. District 14 - Luther Olsen (Republican) and Fred Clark
(Democrat);
v. District 18) -Randy Hopper (Republican) and Jessica King
(Democrat);
vi.

District 32 Dan Kapanke (Republican) and Jennifer Shilling
(Democrat).

c. August 16:

i. District 12 - Kim Simac (Republican) and Jim Halperin (Democrat);

3

 -ii.

District 22 Robert Wirch (Democrat) and Jonathan Steitz
(Republican)

7. For purposes of this document~ i use the term 2012 Senate Recall Elections to
mean any one or more of the following 2012 Senate Recan Elections, including both
the general Recall Elections specified below and any primary elections leading up to the
general Recall Elections as follows:
a. June 5, 2012

i.

District 21 - Van Wanggard (Republican) and John Lehman
(Democrat);

ii.

District 23- Terry Moulton (Republican) and Kristen Dexter
(Democrat);

iii.

District 29 -Jerry Petrowski (Republican) and Donna Seidel
(Democrat);

iv.

District 13- Scott Fitzgerald (Republican) and Lori Compas
(Democrat)

Election to mean the 2012 Gubernatorial Recaii Eiection between Scott \tvaiker
(Republican) and Tom Barrett (Democrat), and the term 2012 Gubernatorial Recall

Election includes any primary election leading up the general Gubernatorial Recall
Election held June 5, 2012:

9. For purposes of this Affidavit, ! use the phrase Recall Related Information and
Records to mean documents relating to the 2011 Senate Recall Elections, the 2012
Senate Recall Elections and/or the 2012 Gubernatorial Recall Election.:
a. All memoranda, email (including archived e-mail), correspondence, and
communications between the person or the entity to be subpoenaed, its
directors, officers, agents or employees, on the one hand, and on the
other hand, the directors, officers, employees or agents of:

i. Coalition Partners, L.L.C.;
ii.

R.J. Johnson and Associates, Inc., its employees, agents, officers
or directors;

iii.

Citizens for a Strong America, Inc.;

4

 iv. William Eisner & Associates, Inc.
v.

Non box, an enterprise operating as a d/b/a of William Eisner &
Associates, Inc. (among others) and which utilizes an Internet
domain identified as www.nonbox.com, including e-mail
addresses ending in "@nonbox.com" and
"@nonboxconsulting.com;"

vi. Ten Capitoline. of Ashburn, Virginia;
vii.

Wisconsin Manufacturers and Commerce, Inc. (WMC);

viii. WMC -Issues Mobilization Council, Inc. (IMC);
ix.

Metropolitan Milwaukee Association of Commerce, Inc.;

x. American Federation for Children, Inc.;
xi.

Doner Fundraising, Inc.;

xii. Americans for Prosperity, Inc.;
xiii. Americans for Prosperity -Wisconsin
xiv. American Crossroads;
xv.

League of American Voters;

xvi.

Republican Governors Association (RGA);

xvii.

Right Direction Wisconsin;

xviii.

Republican State Leadership Committee (RSLC);

xix.

Committee to Elect a Republican Senate (CERS);

xx. Wisconsin Family Action, Inc.;
xxi.

Wisconsin Right to Life, Inc.

xxii.

Wisconsin Recall Action Fund;

xxiii. The Jobs First Coalition, Inc.;
xxiv.

Ending Spending, Inc.;

5

 xxv.

Club for Growth;

xxvi. VVisconsin Club for Grovvth;
xxvii.

Republican Party of Wisconsin;

xxviii.

United Sportsmen of Wisconsin, Inc.; or

xxix.

Friends of Scott Walker.

b. All memoranda, email (including archived e-mail), correspondence, and
communications between the person or the entity to be subpoenaed, its
directors, officers, agents or employees, on the one hand, and on the
other hand:

i. R. J. Johnson;

c.

ii.

Deborah Jordahl;

iii.

Kate Doner; or

iv.

VVi!!iam Eisner.

All memoranda, email (including archived e-mail), correspondence, and
communications between -the person or the entity to be subpoenaed, its
directors, officers, ageiits or employees, on the one hand, and on the
other hand:
i.

The Friends of Scott Walker, the candidate Scott K. Walker, its
Directors, Officers, Employees, and/or Agents;

iL

The candidates, campaign committees, officers, employees and/or
agents associated with the 2011 Senate RecaU Elections.

iii.

The candidates, campaign committees, officers, employees and/or
agents associated with the 2012 Senate Recall Elections.

iv. The candidates, campaign committees, officers, employees and/or
agents associated with the 2012
d.

Gubernatoria~

Recall Election.

Calendars or other records of meetings, phone calls, video conferencing
and/or conference calls on Recall related topics and issues.

6

 e. All contracts, agreements, accords or understandings of any kind into
which the subpoenaed part, entered for performance of services of any
kind related to the 2011 Senate Recall Elections, the 2012 Se1111ate

Recall Elections and/or the 2012 Gubernatorial Recall Election.
f.

All billing, invoices, receipts, financial documents and other records of
expenditures, disbursements or transfers made in connection with the
2011 Senate RecaU E~ections, the 2012 Senate RecaU Elections
and/or the 2012 Gubernatorial RecaU Election.

g. All bank records, credit card bills and other financial records evidencing a
disbursement identified in subparagraph f immediately preceding this
subparagraph;
h. All correspondence, e-mail (including archived e-mail), communications,
memos and/or notes related to the items identified in subparagraphs e
and f above;
i.

All records of advertisements, public service announcements, broadcast
scripts, mailings, flyers and other material published in connection with
the 2011 Senate Recall Elections, the 2012 Senate Recall Elections
and/or the 2012 Gubernatorial Recall Election.

j.

All contracts, agreements and communications related to the items
identified in subparagraph i immediately preceding this subparagraph.

B.
ENTITIES AND RECORDS
WARRANTS AND SUBPOENAS.

SUBJECT

TO

REQUEST

FOR

SEARCH

10. I respectfully submit that good cause exists to believe the documents specified in
the subpoena accompanying this Application are related to the purposes of this John
Doe investigation and will produce information relevant to this criminal inquiry. See In re
Doe Proceeding Commenced by Affidavit Dated July 25, 2001, 2004 WI 149 at ,-r54, 277
Wis.2d 75, 689 N.W.2d 908. 3

3

Rewriting a portion of the original opinion (see 2004 WI 65, 1"{,-r53-54, 272 Wis.2d 208, 680
N.W.2d 792) that suggested a John Doe subpoena required a showing of probable cause, like
that required by §968.135, the supreme court wrote:

7

 1. I respectfully request that the following process issue for the following individuals
and entities:
a. CLUIB FOR GROWTH -I respectfuliy request that the court issue a
subpoena to the Club for Growth, 2001 L St N.W., Suite 600,
Washington D.C. 20036. I request that said subpoena be:
i.

For tlhe timeframe of March 1, 2009 to the present for all
records and information related to the Wisconsin Club for Growth,
including but not limited to:

1. All agreements, memorandum, email (including archived
e-mail), correspondence, and/or communications with:
a. The Wisconsin Club for Growth, its Directors,
Officers, Employees, and/or Agents;
b. The Friends of Scott Walker, the candidate Scott K.

Agents;
c.

The candidates, campaign committees, officers,
employees and/or agents associated with the 2011

Senate Recall Elections.
d. The candidates, campaign committees, officers,
employees and/or agents associated with the 2012
Senate Recall Electuons.

In the case of a John Doe proceeding, the proceeding is lawfully authorized if the judge
determines that the complainant makes a threshold showing sufficient to establish that
the complainant has an objectively reasonable belief that a crime has been committed.
With this iudicial determination, any document requested, in order to be relevant to the
inquiry, must focus on the factual assertions made to the judge at the commencement
of the proceeding. The necessary link between the documents requested and the
suspected criminal activity under investigation is thus shown. affording probable cause
to believe that the documents sought will produce evidence relevant to potentially
criminal activity, as required by Wis. Stat. § 968.135.
2004 WI 149, ,-rs4 (citations omitted)(emphasis added).

8

 e. The candidates, campaign committees, officers,
employees and/or agents associated with the 2012

Gubernatorial RecaH Election.

I respectfully submit that I believe these records will produce information
relevant to this investigation, based upon the information detailed in the
Affidavit of Dean Nickel dated September 28, 2013 and Affidavit of Robert
Stelter dated December 10, 2012.

On March 29, 2009, the national Club

for Growth sent an e-mail requesting that the Wisconsin Club for Growth
(WiCFG) continue to advise the national Club for Growth of it's activities
and the legal propriety of those actions related to activities with FOSW.
(See

Exhibit 15, Affidavit

of December 10,

2012)

In the 2010

gubernatorial election, and in the 2012 gubernatorial recall election,
WiCFG continued to involve itself. in political activity in conjunction with
the gubernatorial campaigns of the Friends of Scott Walker (FOSW), and
other

organizations.

(See

Affidavit

of September 28,

2013,

and

specifically ,-r21-,-r27.) Communications and records between WiCFG and
the national Club for Growth are relevant and may provide evidence of
communications between the national Club for Growth and the WiCFG
related to the potential illegality of that activity by WiCFG.
b. WISCONSIN CLUB FOR GROWTH (WiCFG) AND PERSONS
ASSOCIATED WITH WiCFG I respectfully request that the court issue a
subpoena for documents to the following entities and/or natural persons:
i. Wisconsin Club for Growth (WiCFG) in care of its registered
agent, Godfrey and Kahn, One East Main Street, Suite 500,
Madison, Wisconsin 53703. 4
ii.

Eric O'Keefe - Director; 5

iii.

Eleanore C. Hawley- Treasurer/Secretary/Director; and

iv.

Charles Talbot- President I Director;

4

The registered agent for Wisconsin Club for Growth Godfrey and Kahn, One East Main Street,
Suite 500, Madison, Wisconsin 53703.
5
See ,-r19 and related footnotes, Affidavit of 12/1 0/12.

9

 I request that said subpoena be issued:

i. For the timeframe of March 1, 2009 to the present, for the
production of all records and information of WiCFG in the
possession of the corporation or any of its Employees, Agents,
Officers and/or Directors as follows:
1.

All corporate minutes and resolutions;

2. All communications between corporate directors, officers,
employees and/or agents on the one hand and R.J.
Johnson and/or Deborah Jordahl on the other hand;
3. A!! communications naming R.J. Johnson in the body of
the communication;

4. All communications naming Deborah Jordahl in the body of
the communication;
5. All contracts, agreements, accords or understandings of
any kind which have been entered into with any of the
foliowing:
a. R.J. Johnson & Associates, Inc;
b. Citizens for a Strong Amercia, Inc.;
c.

Coalition Partners, L.L.C.;

d. Doner Fundraising Inc.;
e. Richard "R.J." Johnson;
f.

Deborah Jordahl; or

g. Kate Donor.
. 6. All invoices and payment records relating to any item
identified in the preceding subparagra!Jh;

10

 7. All records of income received, including fundraising
information and the identity of persons contributing to the
corporation;
8. All records of money spent, including expense and other
disbursements data, invoices, payroll records, billing
records and related memoranda; and
9. All Recall Related Information and Records as defined
above in 119.
I respectfully submit that I believe these records will produce information
relevant to this investigat ion based upon the information detailed in the
Affidavit of Dean Nickel dated September 28, 2013 and Affidavit of Robert
Stelter dated December 10, 2012. As described therein, during 201 1 and
2012, R.J. Johnson, Governor Scott Walker, Keith Gilkes, Kate Doner
and ot hers, used WiCFG to coordinate political activity in response to
recall elections against Wisconsin state senators, as well as the recall of
Governor Walker. R.J. Johnson substantially directed the activities of the
WiCFG. Those activities included fundraising to support the activities of
WiCFG and other organization funded directly and indirectly by WiCFG in
coordinat ion with the personal campaign committees of the recall
candidates. (See Affidavit of September 28, 2013, and specifically 11111140.)

Accordingly, WiCFG may have records and materials identified

herein relevant to any illegal campaign coordination.
c . CITIZENS FOR A STRONG AMERICA (CFSA) AND PERSONS
ASSOCIATED WITH CFSA I respectfully request that the court issue a
subpoena for documents to the following entities and/or natural persons:

i. Citizens for a Strong America;6

•

ii . John Connors -President,

6

Wiscons in

The registered agent for Citizens for a Strong America is Godfrey and Kahn, One East Main
Street, Suite 500, Madison, Wisconsin 53703.

11

 iii. Valerie Johnson -Treasurer,
Randolph, Wisconsiniv. Jessika Stauffacher- Director

Westfield,

v. Virginia Marschmann - Director at
Waukesha, WisconsinI request that said subpoena be issued:
ii. For the timeframe of February 16, 2010 to the present, for the
production of all records and information in the possession of the
corporation or any of its Employees, Agents, Officers and/or
Directors, including but not limited to John Connors, Valerie
Johnson, Jessika Stauffacher and Virginia Marschman, as follows:
1.

All corporate minutes and resolutions;

2. All communications between corporate directors, officers,
employees and/or agents on the one hand and R.J.
Johnson and/or Deborah Jordahi on the other hand;
3. All communications naming R.J. Johnson in the body of
the communication ;
4. All communications naming Deborah Jordahl in the body of
the communication;
5. All contracts, agreements, accords or understandings of
any kind which have been entered into with any of the
following:
a. R.J. Johnson and Associates, Inc.;
b. Coalition Partners, L.L.C. ;
c. Doner Fundraising Inc.;
d. Richard "R.J ." Johnson
e. Deborah Jordahl; or

12

 f.

Kate Donor.

6. All invoices and payment records relating to contracts,
agreements, accords or understanding of any kind with
Richard "R.J." Johnson and/or Deborah Jordahl;
7. All records of income received, including fundraising
information and the identity of persons contributing to the
corporation;

8. All records of money spent, including expense and other
disbursements data, invoices, payroll records, billing
records and related memoranda;

9. All contracts, agreements, accords or understanding of any
kind relating to expenditures made in connection with the
2011 Senate Recall Elections, the 2012 Senate Recall
Elections, and/or the 2012 Gubernatorial Recall Election;
and
10. All Recall Related Information and Records as defined
above in 1J9.

I respectfully submit that I believe these records will produce information
relevant to this investigation based upon the information detailed in the
Affidavit of Dean Nickel dated September 28, 2013 and Affidavit of Robert
Stelter dated December 10, 2012.
WiCFG.

CFSA was substantially funded by

CFSA was also controlled by R.J. Johnson and Deb Jordahl,

and was essentially a conduit used to fund other 501 (c)4 organizations
and groups in a coordination with the personal campaign committees in
response to the 2011 to 2012 recall elections. See specifically, Affidavit of
September 27, 2012, 11"16-20, 1111-1115.

For this reason records and

materials described herein are relevant to the investigation of any illegal
campaign coordination.
d.

W~SCONSIN

MANUFACTURERS AND COMMERCE (WMC) AND

PERSONS ASSOCIATED THEREWITH I respectfully request that the

13

 court issue a subpoena for documents to the following entities and/or
natural persons:
i.

WMC, 501 E. Washington Ave., Madison, Wi. 53703; 7

ii.

James Buchen- Former Vice- President of Governmental
Relations at WMC 8

-

10 East Doty St., Suite 500, Madison, Wi.

53703

I request that said-subpoena be:
i. For the timeframe of 2011 ~2012, for all records and information
of WMC in the possession of the corporation or any of its
Employees, Agents, Officers and/or Directors as follows:
1. In connection with the 2011 Senate Recall Elections, the
2012 Senate Recall Elections, and/or the 2012
Gubernatorial Recall Election, all e-mails (including
archived e-mails), memoranda, and correspondence with:
a. The Mih,vaukee Metropolitan i\ssociation of
Commerce; or
b. The United States Chamber of Commerce;
2. All Recan Related lnformatuon and Records as defined
above in 'ff9.
I respectfully submit that I believe these records will produce information
relevant to this investigation based upon the information detailed in the
Affidavit of Dean Nickel dated September 28, 2013 and Affidavit of Robert
Stelter dated December 10, 2012. WMC operated in conjunction with
WMC-IMC.

WMC received $2,500,000 from WiCFG, which it then

passed to WMC-IMC. In turn WMC-IMC sponsored ads supporting
7

The registered agent for WMC and WMC-IMC is Kurt Bauer, 501 E. Washington Ave., Madison,
WI. 53703.
8
James Buchen is presently employed as a lobbyist by WMC. Additionally, per the website of
Hamilton Consulting Group, James Buchen is employed with the group as an affiliated consultant.
Hamilton Consulting Group has an office at 10 E. Doty St., Suite 500, Madison, Wi. 53703. WMC
is also referenced in the Affidavit of 12/10/12, 1{46, f[67-68_

14

 Governor Walker during the 2012 recall campaign as well as ads critical
of potential Democratic opponents. Ten Capitol, an advertising agency,
placed the ads for WMC.

Ten Capitol also paid R.J. Johnson and

Associates $50,000 in June,

2012.

September 28, 2013, 1{41-1{44.

For this reason records and materials

See specifically, Affidavit of

described herein are relevant to the investigation of any illegal campaign
coordination.

e. WMC

~SSUES

MOBILIZATION

COUNC~L,

INC. AND PERSONS

ASSOCIATED THEREWITH I respectfully request that the court issue a
subpoena for documents to the following entities and/or natural persons:
i. WMC Issues Mobilization Councit Inc., 501 E. Washington Ave.,

Madison, Wi. 53703; 9
ii.

James Buchen- Former Vice- President of Governmental
Relations at WMC- 10 East Doty St., Suite 500, Madison, Wi.
53703

I request that said subpoena be:
i. For the timeframe of 2011-2012, for all records and information
of WMC Issues Mobilization Council, Inc. in the possession of the
corporation or any of its Employees, Agents, Officers and/or
Directors as follows:
a. In connection with the 2011 Senate Recall
Elections, the 2012 Senate Recall Elections, and/or
the 2012 Gubernatorial Recall Election, all e-mails
(including archived e-mails), memoranda, and
correspondence with:
i. The Milwaukee Metropolitan Association of

Commerce; or
ii. The United States Chamber of Commerce;
9

The registered agent for WMC and WMC-IMC is Kurt Bauer, 501 E. Washington Ave., Madison,
WI. 53703.

15

 2. All Recall Related

~nformation

arnd Records as defined

above in if9.

I respectfully submit that I believe these records will produce information
relevant to this investigation based upon the information detailed in the
Affidavit of Dean Nickel dated September 28, 2013 and Affidavit of Robert
Stelter dated December 10, 2012. WMC-IMC received $2,500,000 from
WiCFG, and in turn sponsored ads supporting Governor Walker during
the 2012 recall campaign as well as ads critical of potential Democratic
opponents. Ten Capitol, an advertising agency, piaced the ads for WMC.
Ten Capitol also paid R.J. Johnson and Associates $50,000 in June,
2012.

See specificaiiy, Affidavit of September 28, 2013, 1f41-,-r44. For

this reason records and materials described herein are relevant to the
investigation of any illegal campaign coordination.
f.

METROPOLITAN MILWAUKEE ASSOCIATION OF COMMERCE
(MMAC) AND PERSONS ASSOCIATED \1\JITH MMAC - ! respectfully
request that the court issue a subpoena for documents to the foiiowing
entities and/or natural persons:
i. Metropolitan Milwaukee Association of Commerce (MMAC), 756

N. Milwaukee St., Suite 400, Milwaukee, Wisconsin 53202.
I request that said subpoena be:
i.

For the timeframe of 2011-2012, for all records and information
of MMAC in the possession of the corporation or any of its
Employees, Agents, Officers and/or Directors, including but not
limited to Timothy Sheehy, as follows:
1. In connection with the 2011 Senate Recall Elections, the
2012 Senate Recall Elections, and/or the 2012
Gubernatorial Recall Election, all e-mails (including
archived e-mails), correspondence, memoranda, and
correspondence with:
a. The Wisconsin Club for Growth

16

 b. The WMC-Issues Mobilization Council, Inc.; or
c. The United States Chamber of Commerce;
2. All RecaU Related

~nformation

and Records as defined

above in 119.
I respectfully submit that I believe these records will produce information
relevant to this investigation based upon the information detailed in the
Affidavit of Dean Nickel dated September 28, 2013 and Affidavit of Robert
. Stelter dated December 10, 2012. MMAC contributed $579,800 to WiCFG
in 2011 and 2012. WiCFG in turn directly and indirectly sponsored ads
supporting Governor Walker during the 2012 recall campaign as well as
ads critical of potential Democratic opponents. See specifically, Affidavit
of September 28, 2013, 1127.

Records of MMAC are relevant to

contributions to WiCFG, funding the activities of WiCFG that supported
potential illegal coordination with the campaign

committe~s.

g. REPUBLICAN STATE LEADERSHIP COMMITTEE (RSLC) AND
PERSONS ASSOCIATED WITH RSLC

~

I respectfully request that the

court issue a subpoena for documents to the following entities and/or
natural persons:
i. Republican State Leadership Committee (RSLC), 1201 F. St., NW
#675, Washington D.C. 20004;
I request that said subpoena be:

i. For the timeframe of 2011 and 2012, for all records and
information of RSLC in the possession of the corporation or any of
its Employees, Agents, Officers and/or Directors, including but not
limited to Ed Gillespie and Chris Jankowski, as follows:
1. All Recall Related Information and Records as defined
above in 1f9; and
2. All recorded telephone calls, conference calls and/or
videoconferencing sessions which relate to the 2011

17

 Senate Recall Elections, the 2012 Senate Recall Elections,
and/or the 2012 Gubernatorial Recall Election.
I respectfully submit that I believe these records will produce information
relevant to this investigation based upon the information detailed in the
Affidavit of Robert Stelter dated December 10, 2012 and Affidavit of Dean
Nickel dated September 28, 2013. As specifically detailed in the later
affidavit, 1J53-55, RSLC and it's president, Chris Jankowski, were in direct
communication with R.J. Johnson at the onset about the need for
- "coordination." This was evidence by communication between Chris
Jankowski and R.J. Johnson (See the later affidavit, Exhibit 34.)

the 2011-2012 recall elections are relevant to the potential illegal
coordination with the campaign committees.
h. REPUBLICAN GOVERNORS ASSOCIATION AND PERSONS
ASSOCIATED WITH RGA - I respectfully request that the court issue a
subpoena for documents to the following entities and/or natural persons:
i.

Repubiican Governor's Association (RGA) 10 , 1747 Pennsylvania
Ave. N.W., Suite 250, Washington, D.C. 20006;

I request that said subpoena be:
i. For the timeframe of 2011 and 2012, for all records and
information of RGA in the possession of the corporation or any of
its Employees, Agents, Officers and/or Directors as follows:

1. All Recall Related information and Records as defined
above in 1"f9.
2. All recorded telephone calls, conference calls and/or
videoconferencing sessions which relate to the 2011
Senate Recall Elections, the 2012 Senate Recall Elections,
and/or the 2012 Gubernatorial Recall Election.
10

RGA Wisconsin PAC filed a "GAB 6" related to its activities in the State of Wisconsin. See
Exhibit 8.2.

18

 I respectfully submit that I believe these records will produce information
relevant to this investigation based upon the information detailed in the
Affidavit of Robert Stelter dated December 10, 2012 and Affidavit of Dean
Nickel dated September 28, 2013. At the onset in March 2011, Governor
Walker was involved in discussions with the RGA and R.J. Johnson about
the need for "coordination" between the different organizations that
included the RGA. (See the later affidavit, 1{28.) The RGA and FOSW
conducted conference calls and meetings regarding the recall campaign.
Through Right Direction- Wisconsin, the RGA spent over $4,000,000 in
the 2012 gubernatorial recall campaign. (See specifically, Affidavit of
September 27, 2012, 1128-40) Accordingly, records and communications
between the RGA, Right Direction -

Wisconsin and other entities

described here related to the 2011-2012 recall elections are relevant to
the potential illegal coordination with the campaign committees.
i.

RIGHT DIRECTION- WISCONSIN {AIKIA RIGHT DIRECTION
WISCONSIN PAC) 11

-

I respectfully request that the court issue a

subpoena for documents to the following entities and/or natural persons:

i. Right Direction Wisconsin 12 , located at 1747 Pennsylvania Ave.
N.W., Suite 250, Washington, D.C. 20006;
I request that said subpoena be:

ii. For the timeframe of 2011 and 2012, for all records and
information of Right Direction -Wisconsin in the possession of the
corporation or any of its Employees, Agents, Officers and/or
Directors as follows:
1. All Recall Related Information and Records as defined
above in

~9.

11

This entity has modified it's name multiple times; in 2009 it was registered as RGA Wisconsin
2010 PAC; in 2011 an amended registration reflected the name RGA Wisconsin PAC; in 2012 an
amended registration reflected the name Right Direction Wisconsin PAC.
12
Right Direction Wisconsin PAC (affHiated with the RGA) filed a "GAB 6" related to its activities in
the State of Wisconsin. See Exhibit 8.3.

19

 2. All recorded telephone calls, conference calls and/or
videoconferencing sessions \Nhich relate to the 2011
Senate Recall Elections! the 2012 Senate Recall Elections,
and/or the 2012 Gubernatorial Recall Election.

I respectfully submit that I believe these records will produce information
relevant to this investigation based upon the information detailed in the
paragraph above.
j.

UN~TED

SPORTSMEN OF

W~SCONSIN ~NC. ~

I respectfully request that

the court issue a subpoena for documents to the following entities and/or
natural persons:

i.

United Sportsmen of Wisconsin Inc., 13201 Hostak Road, Maribel,
Wisconsin 54227.

I request that said subpoena be:
i. For the timeframe of 2011 and 2012, for all records and
information of United Sportsmen of VVisconsin, inc. in the
possession of the corporation or any of its Employees, Agents,
Officers and/or Directors, including but not limited to Andy
Pantziaff, as follows:
·1 . Aii Recaii Reiated Information and Records as defined
above in

~9.

I respectfully submit that I believe these records will produce information
relevant to this investigation based upon the information detailed in the
Affidavit of Robert Stelter dated December 10, 2012 and Affidavit of Dean
Nickel dated September 28, 2013.

United Sportsmen of Wisconsin

received funding from Citizens for a Strong America. In coordination with
other groups, this organization was involved in absentee ballot application
activity during the recall elections. For this reason, records held by United
Sportsmen of Wisconsin are relevant to any coordination with CFSA (that
in turn was funded by WiCFG) to the benefit of the Wisconsin state
senate personal campaign committees, or FOSW.

20

 k.

WISCONSIN RIGHT .TO UFIE - I respectfully request that the court issue
a subpoena for documents to the following entities and/or natural
persons:
i. Wisconsin Right to Life, located at 9730 W. Bluemound Rd., Suite
200, Milwaukee, Wisconsin 53226 (Milwaukee County)

I request that said subpoena be:
i. For the timeframe of 2011 and 2012, fo.r all records and
information of Wisconsin Right to Life in the possession of the
corporation or any of its Employees, Agents, Officers and/or
Directors, including but not limited to Barbara Lyon, as follows:
1. All Recall Related Information and Records as defined
above in ,-r9.
I respectfully submit that I believe these records will produce information
relevant to this investigation based upon the information detailed in the
Affidavit of Robert Stelter dated December 10, 2012 and Affidavit of Dean
Nickel dated September 28, 2013.

Wisconsin Right to Life (WRTL)

received funding from Citizens for a Strong America.

In coordination with

other groups, this organization was involved in absentee ballot application
activity during the recall elections. For this reason, records held by WRTL
are relevant to any coordination with WiCFG, CFSA .(that in turn was
funded by WiCFG) to the benefit of the Wisconsin state senate personal
campaign committees or FOSW.
I.

WISCONSIN FAMilY ACTION - I respectfully request that the court

issue a subpoena for documents to the following entities and/or natural
persons:
i. Wisconsin Family Action, 222 S. Hamilton Street, Suite 23,

Madison, Wisconsin 53703 (Dane County)
l request that said subpoena be:

21

 i. For the timeframe of 2011 and 2012, for all records and
information of VVisconsin Family Action in the possession of the
corporation or any of its Employees, Agents, Officers and/or
Directors, inciuding but not limited to Director Julaine Appling, as
follows:
1. All Recall Related information and Records as defined

above in ~9.

I respectfully submit that I believe these records will produce information
relevant to this investigation based upon the information detailed in the
Affidavit of Robert Stelter dated December 10, 2012 and Affidavit of Dean
Nickel dated September 28, 2013. In coordination with other groups, this
organization was involved in absentee ballot application activity during the
recall elections. (See the later affidavit, 1f13 and 1}17 .) For this reason,
records held by Wisconsin Family Action are relevant to any coordination

\Nith VVlCFG, CFS,ll, (that in turn vvas funded by VViCFG) to the benefit of
the \/Visconsin state senate personai campaign committees or FOSVV.

m. FRIENDS OF SCOTT WALKER

Q

I respectfully request that the court

issue a subpoena for documents to the following entities andior natural
persons:
i.

Friends of Scott Walker, in care of Attorney Steven Biskupic, 1045
W. Glen Oaks Lane, Suite 106, Mequon, Wisconsin 53092

I request that said subpoena be:
L For the timeframe of 2011 and 2012, for all records and
information of Friends of Scott Walker in the possession of the
campaign committee or any of its Employees, Agents, Officers
and/or Directors as follows:
1. All Recall Related Information and Records as defined
above in

~9.

22

 2. All contracts, agreements, accords or understandings of
any kind between the campaign committee and any of the
following:
a. Richard "R.J." Johnson;

b. Deborah Jordahl;
c.

Kate Doner;

d. Mary Stitt;
e. Dan Morse;
f.

Kelly Rindfleisch;

g. R.J. Johnson & Associates, Inc.;
h. Citizens for a Strong America, Inc.;
i.

Coalition Partners, L.L.C.;

j.

Doner Fundraising;

k. Mary Stitt & Associates, L.L.C.; and

I.

JVS Consulting, L.L.C.

I respectfully submit that I believe these records will produce information
relevant to this investigation based upon the information detailed in the
Affidavit of Robert Stelter dated December 10, 2012 and Affidavit of Dean
Nickel dated September 28, 2013. As described in said affidavits, during
2011 and 2012, R.J. Johnson, Governor Scott Walker, Keith Gilkes, Kate
Doner and others associated with FOSW used WiCFG to coordinate
political activity in response to the 2012 gubernatorial recall election.
FOSW was the personal campaign committee of Governor Scott Walker
during the 2012 gubernatorial recall elections.

R.J. Johnson had

substantial involvement in the decisions of FOSW during the recall
elections; he also directed the activities of WiCFG, and was involved in
the activities of CFSA and other entities. Records maintained by FOSW
will be relevant to any coordination with WiCFG, CFSA and other groups

23

 to the benefit of the Wisconsin state senate

personal campaign

committees or FOSW.
n. REPUBLICAN PARTY OF WISCONSiN- I respectfully request that the
court issue a subpoena for documents to the following entities and/or
natural persons:

i.

Republican Party of Wisconsin, 148 E. Johnson Street, Madison,
Wisconsin 53703 (Dane County);

I request that said subpoena be:
i. For the timeframe of 2011 and 2012, for all records and
information of Republican Party of Wisconsin in the possession of
the corporation or any of its Employees, Agents, Officers and/or
Directors as follows:

1. All Recall Related Information and Records as defined
above in

~9.

2. All contracts, agreements, accords or understandings of
any kind between the campaign committee and any of the
following:
a.

Richard "R.J." Johnson;

b.

Deborah Jordahl;

c.

Kate Doner;

d.

Mary Stitt;

e.

Dan Morse;

f.

Kelly Rindfleisch;

g.

R.J. Johnson & Associates, Inc.;

h.

Citizens for a Strong America, Inc.;

i.

Coalition Partners, L.L.C.;

j.

Doner Fundrarsing;

24

 k.

Mary Stitt & Associates, L.L.C.; and

I.

JVS Consulting, L.L.C.

I respectfully submit that I believe these records will produce information
relevant to this investigation based upon the information detailed in the
Affidavit of Robert Stelter dated December 10, 2012 and Affidavit of Dean
Nickel dated September 28, 2013. RPW was included among the groups
to be involved in a coordinated response to the recall elections in 2011.
(See Affidavit of December 10, 2012, 1124-1{25) As described herein,
during 2011 and 2012, R.J. Johnson, Governor Scott Walker, Keith
Gilkes, Kate Doner and others, used WiCFG to coordinate media and
political activity in response to recall elections against Wisconsin state
senators, as well as Governor Walker.

FOSW was the personal

campaign committee of Governor Scott Walker during the recall elections.
R.J. Johnson had substantial involvement in advising FOSW during the
recall elections and directed the activities of WiCFG. Accordingly, RPW
may have records and materials identified herein relevant to any illegal
campaign coordination.

o. COMMITTEE TO ELECT A REPUBLICAN SENATE (CERS) AND
PERSONS ASSOCIATED WiTH

CERS~

I respectfully request that the

court issue a subpoena for documents to the following entities and/or
natural persons:

i. Committee to Elect a Republican Senate (CERS), P.O. Box 2741,
Madison, Wisconsin 53701.
I request that said subpoena be:
i. For the timeframe of 2011 and 2012, for all records and
information of CERS in the possession of the corporation or any of
its Employees, Agents, Officers and/or Directors, including but not
limited to Scott Fitzgerald, John Hogan and Judi Rhodes, as
follows:

25

 1. All Recall Related Information and Records as defined
above in ~9.

I respectfully submit that I believe these records will produce information
relevant to this investigation based upon the information detailed in the
Affidavit of Robert Stelter dated December 10, 2012 and Affidavit of Dean
Nickel dated September 28, 2013.

CERS was included among the

groups to be involved in a coordinated response to the recall elections in
2011 with other groups. (See Affidavit of December 10, 2012, ,-r26-,-r28)

CERS is in possession of records and materials relating to the activities of
CERS in conjunction with the above described groups, relevant to any
coordination \Nith V\fiCFG, CFSA and the RSLC and to the benefit of the
Wisconsin state senate personal campaign committees. (see Affidavit of
September 28, 2013, 1]"55)
p. WILLIAM EISNER AND ASSOCIATES,

~NC.

D.B.A. NONBOX- I

respectfully request that the court issue a subpoena for documents to the
following entities and/or natural persons:
i.,

V\!illiam Eisner and Associates, Inc. d. b. a. NONBOX, 5307 South
92nd Street., Hales Corners, Wisconsin 53130 (Milwaukee

County).
I request that said subpoena be:

i. For the timeframe of 2011 and 2012, for all records and
information of William Eisner and Associates, Inc. d.b.a. NON BOX
in the possession of the corporation or any of its Employees,
Agents, Officers and/or Directors, including but not limited to
William Eisner, as follows:
1. All Recall Related Information and Records as defined
above in ~9, specifically to include:.
a. All agreements, contracts, correspondence, e-mails
(including archived e-mail), memoranda, invoices,
and other financial records, involving:

26

 i.

Richard "RJ" Johnson;

ii. Deborah Jordahl;
iii. Valerie Johnson;

iv. Wisconsin Club for Growth;
v. R.J. Johnson & Associates, Inc.
vi. Citizens for a Strong America;
vii. Coalition Partners, L.L.C.;
viii. Wisconsin Manufacturers and Commerce;
ix. WMC - Issues Mobilization Council;
x. Wisconsin Family Action, Inc.;
xi. Wisconsin Right to Life, Inc.; or
xii. Wisconsin Federation for Children.
I respectfully submit that I believe these records will produce information
relevant to this investigation based upon the information detailed in the
Affidavit of Robert

Stel~er

dated December 10, 2012 and Affidavit of Dean

Nickel dated September 28, 2013.

Specifically, Nonbox (with the

involvement of managing partner, William Eisner) was involved in the
production of media ads several of the entities that are the subject of this
investigation including Wisconsin Club for Growth, American Federation
of Children, Citizens for a Strong America, Wisconsin Family Action
Committee and Wisconsin Manufacturers and Commerce during the
recall campaigns. R.J. Johnson also worked with Nonbox in the
production of media ads during the 2012 gubernatorial recall campaign
for FOSW. Nonbox also paid entities controlled by R.J. Johnson, such as
R.J. Johnson and Associates and

Coalition Partners.

Nonbox is in

possession of records and materials relating to the activities of Nonbox
with the above described groups, inctuding media ads, relevant to any
coordination with WiCFG, CFSA (that in turn was funded by WiCFG) and

27

 Coalition Partners to the benefit of the VVisconsin state senate personal
campaign committees or FOSW. (See Affidavit of September 28, 2013,
1{12, ~15, 1{17, and 4fl45-~49)
q.

DONER FUNDRAISING,

~NC.

AND PERSONS ASSOCIATED

THEREWITH ~ I respectfully request that the court issue a subpoena for

documents to the following entities and/or natural persons:

i. Doner Fundraising, Inc., 815 Brazos St., Austin, Texas 78701.
I request that said subpoena be:

i. For the timeframe of 2011 and 2012, for all records and
information of Doner Fundraising, Inc. in the possession of the
corporation or any of its Employees, Agents, Officers and/or
Directors, including but not limited to Kate Doner, Jennifer
Bannister and Camille Moughton, as follows:
1. All Recall Related Information and Records as defined
above in ~9.
2. All recorded telephone caiis, conference calls and/or
videoconferencing sessions which relate to the 2011
Senate Recall Elections, the 2012 Senate Recall Elections,
and/or the 2012 Gubernatorial Recall Election.
I respectfully-submit that I believe these records will produce information
relevant to this investigation based upon the information detailed in the
Affidavit of Robert Stelter dated December 10, 2012 and Affidavit of Dean
Nickel

dated September 28,

2013.

As

described therein,

Doner

Fundraising (through the involvement of Kate Doner and her staff) was
directly involved in coordinating activity with FOSW, tNiCFG, the RGA,
and others. (See Affidavit of December 10, 2012, 1141, 1148, 1j52-1f56;
Affidavit of September 28, 2013, 1f30, 1f34, 1[50-1152) Accordingly, records
in possession of Doner Fundraising and it's employees related to any
coordination with WiCFG, FOSW and other groups of entities to the

28

 benefit of the Wisconsin state senate personal campaign committees or
FOSW will be relevant to this investigation.
r.

MARY

ST~TT

AND ASSOCIATES, L.L.C. AND PERSONS

ASSOCIATED THEREWITH

~

I respectfully request that the court issue

a subpoena for documents to the following entities and/or natural
persons:
i.

Mary Stitt and Associates, L.L.C., 1478 Noridge Trail, Port
Washington, Wisconsin 5307 4 (Ozaukee County).

I request that said subpoena be:

i. For the timeframe of 2011 and 2012, for all records and
information of Mary Stitt and Associates, L.L.C. in the possession
of the corporation or any of its Employees, Agents, Officers and/or
Directors as follows:
1. All Recall Related Information and Records as defined
above in

~9,

specifically to include:

a. All agreements, contracts, correspondence, e-mails
(including archived e-mail), memoranda, invoices,
and other financial records involving the Friends of
Scott Walker and/or Wisconsin Club for Growth and
relating to fundraising tasks, including but not
limited to fundraising events, donor meetings,
donor calls, donor conferences and thank you
correspondence.
I respectfully submit that I believe these records will produce information
relevant to this investigation based upon the information detailed in the
Affidavit of Robert Stelter dated December 10, 2012 and Affidavit of Dean
Nickel dated September 28, 2013. As described therein, Mary Stitt and
Kelly Rindfleisch were involved with fundraising on behalf of FOSW and
WiCFG. (See Affidavit of September 27, 2012, 1"f58 and Affidavit of
December 10, 2012, 'if30-1"f35) Records maintained by Mary Stitt will be

29

 relevant to any coordination with VViCFG and FOSW to the benefit of the
Wisconsin state senate personal campaign committees or FOSVV.
s. JED SANIBORN, CPA LlC - f respectfully request that the court issue a
subpoena for documents to the following entities and/or natural persons:
i. Jed Sanborn, CPA, LLC., 8426 Red Granite Rd., Madison,
Wisconsin 53719 (Dane County);
I request that said subpoena be:
i. For tax years 2009, 2010, 2011 and 2012 endong wnth the date
the last return was filed for each year regardless of date, for
a!! records and information of Jed Sanborn, CPA, L.L.C. in the

possession of the corporation or any of its Employees, Agents,
Officers and/or Directors as follows:
1. All tax returns and schedules, together with supporting
notes, records and other documentation, for the following
entities:
a. 'vVisconsin Ciub for Growth; and
b. Citizens for a Strong America.
2. All e-mail (including archived e-mail), letters,
correspondence and memorandum related to the following
entities, ,their directors, officers, employees and/or agents:
a. VVisconsin Club for Growth; and
b. Citizens for a Strong America.
I respectfully submit that I believe these records will produce information
relevant to this investigation based upon the information detailed in the
Affidavit of Robert Stelter dated December 10, 2012 and Affidavit of Dean
Nickel dated September 28, 2013. Specifically, Jed Sanborn CPA L.L.C.,
received payments and is disclosed as preparing periodic tax returns for
CFSA and WiCFG in 2010 and 2011.

Records necessary to the

preparation of said returns maintained by Jed Sanborn CPA LL.C.

30

 related to WiCFG and CFSA, such as information related to income and
expenses, are relevant to the activities of WiCFG in coordination with
CFSA and other entities receiving funding from those entities

(See

Affidavit of September 28, 2013, 1"[18 and 1"[24)
t.

CAROL A. VAlLEY, CPA

S.C.~

I respectfully request that the court

issue a subpoena for documents to the following entities and/or natural
persons:
Carol A. Valley, CPA, S.C., 159 S. Dickason Blvd., Fir 2nd,
Columbus, Wisconsin 53925 (Columbia County);

I request that said subpoena be:
For tax years 2009, 2010, 2011 and 2012 ending with the date
the last return was filed for each year ll'egardless of date, for all
records and information of Carol Valley, CPA, S.C. in the
possession of the corporation or any of its Employees, Agents,
Officers and/or Directors as follows:
All tax returns and schedules, together with supporting notes,
records and other documentation, for the following entities:
Coalition Partners, L.L.C.
All e-mail (including archived e-mail), letters, correspondence
and memorandum related to the following entities, their
directors, officers, employees and/or agents:
Coalition Partners, LL.C.
I respectfully submit that I believe these records will produce information
relevant to this investigation based upon the information detailed in the
Affidavit of Robert Stelter dated December 10, 2012 and Affidavit of Dean
Nickel dated September 28, 2013.

Specifically, Carol Valley CPA

received payments from Coalition Partners, consistent with payments for
the preparation of periodic tax , returns.

Records necessary to the

preparation of said returns maintained by Carol Valley relating to

31

 Coalition Partners, L. L.C., such as information related to income and
expenses, are relevant to the activities of Coalition Partners (i.e.

R.J.

Johnson and Deborah Jordahl) in coordination with WiCFG, CFSA, and
other entities receiving funding from those entities (See Affidavit of
September 28, 2013, 'if15)
u. AMERICANS FOR PROSPERITY- WISCONS~N AND PERSONS

ASSOCIATED THEREWITH

~

I respectfully request that the court issue

a subpoena for documents to the following entities and/or natural
persons:
i. Americans for Prosperity- Wisconsin 10 East Doty Street, Suite
800, Madison, VV!sconsin (Dane County).

I request that said subpoena be:

i. For the timeframe of 2011 and 2012, for all records and
information of Americans for Prosperity - \Nisconsin in the
possession of Americans for Prosperity - VVisconsin or any of its
Empioyees, Agents, Officers andior Directors, inciuding but not

limited to Matt Seaholm, as follovvs:
1. AU Recall Related Information and Records as defined
above in 1J9, specifically to include.
a. All agreements, contracts, correspondence, e-mails
(including archived e-mail), memoranda, invoices,
and other financial records, involving:
i.

ii.

Richard "RJ" Johnson;
Deborah Jordahl;

iii. Valerie Johnson;

iv. Wisconsin Club for Growth;
v.

Citizens for a Strong America;

vi.

Coalition Partners, L.L.C.; and

32

 vii. R.J. Johnson & Associates, Inc.
I respectfully submit that I believe these records will produce information
relevant to this investigation based upon the information detailed in the
Affidavit of Robert Stelter dated December 10, 2012 and Affidavit of Dean
Nickel dated September 28, 2013.

AFP-Wi was included among the

groups to be involved in a coordinated response to the recall elections in
2011 (See Affidavit of December 10, 2012,

~24-~25)

During the 2011

recall elections, AFP-Wi led the 2011 absentee application mailing effort
that also involved other organizations, such as United Sportsmen of
Wisconsin and Wisconsin Family Action.

(Affidavit of September 28,

2013, 1f56,-1f57) Accordingly, records and materials possessed by AFPWi are relevant to coordination with other entities, such as WiCFG, CFSA,
RGA, CERS, RSLC, FOSW, RPW during the 2011-2012 Wisconsin recall
elections.

.30

Dated at Madison, Wisconsin on this

day of September 2013.

Robert Stelter
Investigator
Subscribed and sworn to before me
at Milwaukee, Wisconsin o~:~~~,~~~~;;~;.:\~-~~t~(·
this. ~5rJ f'l--day of Septe~-6~~:~:26~3~~:..-t'.'\
'

)

:::

.,.J,F

.

.

~/

r.

..

::::·

'

',

'·

,\

fl•"•\f!!)

'

y
1c, Mi wat:Jl'cere CoU:f.'lty uis
ate of Wisconsin 't,. '- :.
My commission is perrh:~nint.

33