FEDERAL ELECTION COMMISSION In the matter of: Mike Crapo for US. Senate Freedom Fund Idaho Conservative Growth Fund MUR 223 Street, LLC Vicki Hart as Governor of 223 Street, LLC COMPLAINT 1. Campaign for Accountability and Daniel E. Stevens bring this complaint before the Federal Election Commission (?Commission? or seeking an immediate investigation and enforcement action against Mike Crapo for US. Senate, Freedom Fund, Idaho Conservative Growth Fund, 223 Street, LLC and Vicki Hart, as Governor of 223 Street, LLC, for direct and serious violations of the Federal Election Campaign Act and Commission regulations. Complainants 2. Complainant is a Section 501(c)(3) organization dedicated to ensuring accountability of public officials and compliance with federal laws. Toward this end, seeks to protect and advance the right of citizens to be informed about the activities of government officials and to ensure the integrity of government officials and the government decision-making process by exposing unethical and illegal conduct of those involved in government. uses research, litigation, and communications to advance its mission. 3. In furtherance of its mission, also monitors campaign finance activities of those who finance federal elections and publicizes information regarding those who violate federal campaign finance laws. In order to assess whether an individual or entity is complying with 44921888;1 federal campaign finance law, needs the information contained in disclosure reports political committees must file pursuant to the FECA, 52 U.S.C. 11 CPR. 104.1, 104.3. is hindered in its programmatic activity when an individual or entity fails to disclose campaign finance information in reports required by the FECA. 4. relies on the proper administration of the reporting requirements because the FECA-mandated disclosure reports are the only source of information can use to determine if an individual or entity is complying with the FECA. The proper administration of the reporting requirements includes mandating that all disclosure reports required by the FECA are pr0perly and timely filed with the FEC. is hindered in its programmatic activity when the FEC fails to properly administer the reporting requirements. 5. Complainant Daniel E. Stevens is the executive director of Campaign for Accountability, a citizen of the United States, and a registered voter and resident of the District of Columbia. As a registered voter, Mr. Stevens is entitled to receive information contained in disclosure reports required by the FECA, 52 U.S.C. 30104; 11 CPR. 104.1, 104.3. Mr. Stevens is harmed when an individual, candidate, political committee, or other entity fails to report campaign finance activity as required by the FECA. See FECA v. Akins, 524 US. 11, 19 (1998), quoting Buckley v. Valeo, 424 US. 1, 66-67 (1976)(political committees must disclose contributors and disbursements to help voters understand who provides which candidates with financial support). Mr. Stevens is further harmed when the FEC fails to properly administer the reporting requirements, limiting his ability to review campaign finance information. Respondents 6. Mike Crapo for US. Senate, FEC Identification Number C00330886, is the principal campaign committee for Senator Mike Crapo 44921888;1 7. Freedom Fund, FEC Identification Number C00390674, is a nonconnected committee and leadership PAC. Senator Mike Crapo is the leadership sponsor. 8. Idaho Conservative Growth Fund, FEC Identification Number C00544270, is a nonconnected committee and leadership PAC. Senator Mike Crapo is the leadership sponsor. Freedom Fund and Idaho Conservative Growth Fund are affiliated committees. 9. 223 Street, LLC is a District of Columbia limited liability company that owns a condominium located at 223 Street, NE, Washington, DC, 20002 for the purpose of generating rental income. See 223 Street, LLC, Articles of Organization for Domestic Limited Liability Company (June 15, 2012)(attached as Exhibit A). 10. Vicki Hart was the organizer of 223 Street, LLC and has been the governor of 223 Street, LLC since its inception. Exhibit see also 223 Street, LLC, Two?Year Report for Domestic Foreign Filing Entity (February 26, 2017)(attached as Exhibit B). Factual Allegations 11. Throughout 2017, Mike Crapo for US. Senate, Freedom Fund and Idaho Conservative Growth Fund (hereinafter referred to as ?the Crapo committees?) held a series of fundraising events at the 223 Street, NE. condominium owned by the 223 Street, LLC. See Lachlan Markay and Sam Stein, EPA Administrator Scott Pruitt?s Lobbvist?Owned Pad Was GOP Fundraising Hub, The Daily Beast (April 2, 2018)(attached as Exhibit C). Speci?cally, the Crapo committees held fundraising events at the 223 Street, NE. condominium on May 24, 2017, June 28, 2017, July 27, 2017, September 27, 2017, October 25, 2017 and November 30, 2017. See NRSC, Upcoming Events Memo Changes and Additions Mav 4, 2017 available at (attached as Exhibit D). 44921888;l 12. Despite the fact that at least six fundraising events were held by the Crapo committees at the 223 Street, NE. condominium during 2017, none of the Crapo committees reported any disbursements to 223 Street, LLC for rent for the use of the condominium on any of the reports the Crapo committees filed with Commission. In addition, none of the Crapo committees reported receiving an in-kind contribution of the use of the condominium from 223 Street, LLC or Vicki Hart as the Governor of 223 Street, LLC. See Mike Crapo for U.S. Senate, Form 3X, April 15th Quarterlv Report (April 14, 2017); Mike Crapo for U.S. Senate, FEC Form 3X, July 15th Quarterlv Report (July 14, 2017); Mike Crapo for U.S. Senate, FEC Form 3X October 15th Quarterlv Report (October 13, 2017); Mike Crapo for U.S. Senate, FEC Form 3X Year?End Report (January 31, 2018); Freedom Fund, FEC Form 3X, Pre-Special Report Amended (August 2, 2017); Freedom Fund, FEC Form 3X, Mid-Year Report (July 24, 2017); Freedom Fund, FEC Form 3X, Year-End Report (January 31, 2018); Idaho Conservative Growth Fund, FEC Form 3X, Mid?Year Report (July 21, 2017) and Idaho Conservative Growth Fund, FEC Form 3X, Year?End Report (January 10, 2018). COUNT I 13. FECA and FEC regulations require that all political committees, including a federal candidate?s principal campaign committee and any leadership PACs sponsored by a federal candidate, disclose any contribution or expenditure with an aggregate value in excess of $200. 52 U.S.C. 30104(b)(3)(A) 11 C.F.R. 44921888;l 14. Because Mike Crapo for US. Senate, Freedom Fund and Idaho Conservatives Fund failed to report any in?kind contributions from, or disbursements to, 223 Street, LLC or Vicki Hart, as Governor of 223 Street, LLC, for rent for the use of the 223 Street, NE. condominium for the six fundraising events that were held there in 2017, Mike Crapo for US. Senate, Freedom Fund and Idaho Conservative Fund may have violated 52 U.S.C. 30104(b)(3)(A) or and 11 C.F.R. or or (vii). COUNT II 15. FECA and FEC regulations prohibit corporations from making contributions in connection with any federal election and prohibit any officer or director of any corporation from consenting to any contribution by the corporation in connection with any federal election. 52 U.S.C. 30118(a); 11 CPR. FEC regulations require that limited liability companies like 223 Street, LLC maybe treated as corporations in certain circumstances and, accordingly, are prohibited from making contributions in connection with any federal election. ?An LLC that elects to be treated as a corporation by the Internal Revenue Service, pursuant to 26 CFR 301?7701?3 . . . shall be considered a corporation pursuant to 11 CFR Part 114.? 11 C.F.R. 16. Therefore, if 223 Street, LLC has elected to be treated as a corporation by the Internal Revenue Service, 223 Street, LLC and Vicki Hart, as Governor of 223 Street, LLC, may have violated 52 U.S.C. 30118(a) and 11 CPR. by making the 223 Street, NE. condominium available to the Crapo committees without charge to be used for multiple fundraising events in 2017. 44921888;1 Conclusion WHEREFORE, Campaign for Accountability and Daniel E. Stevens request that the Commission investigate whether respondents have violated the FECA and Commission regulations, declare the respondents to have violated the FECA and applicable Commission regulations, impose sanctions for these violations and take such further action as may be appropriate. %f - Daniel E. Stevens Executive Director Campaign for Accountability 611 Avenue, SE. Suite 337 Washington, DC. 20003 (202) 780-5750 (phone) 44921888;1 Veri?cation Campaign for Accountability and Daniel Stevens hereby verify that the statements made in the attached Complaint are, upon information and belief, true. Sworn to pursuant to 18 U.S.C. 1001. District of Columbia: SS SUBSCRIBED AND SWORN to before me this '1 day of April, 2018. Not lic My Commission Expires: Aw?ug? 2027. \\I Ill[?19/4 ?1 449218883 EXHIBIT A (P1961 of 3) 4 9? ?r Initial File GOVERNMENT DISTRICT OF COLUMBIA DEPARTMENT OF CONSUMER AND REGULATORY AFFAIRS CORPORATIONS DIVISION CERTIFICATE THIS IS TO CERTIFY that all applicable provisions of the District of Columbia Business Organizations Code have been complied with and accordingly, this CERTIFICATE OF ORGANIZA TION is hereby issued to: 223 STREET, LLC Effective Date: 6/26/2012 IN WITNESS WHEREOF I have hereunto set my hand and caused the seal of this of?ce to be af?xed as of 6/2612012 3: 38 PM Business and Professional Licensing Administration ?ee/f PATRICIA E. GRAYS Superintendent of Corporations Corporations Division Vincent C. Gray . Mayor Tracking #1 (Page 3 of 3) . District of Columbia Government Department of Consumer and Regulatory Affairs Corporation Division 1100 4th Street, SW Washington, DC 20024 Billing Voucher Charge To: 223 STREET, LLC OFFICE OF FINANCE 9H0 TREASURY Date: 6/26/2012 3:53 PM Office: DCRA Tare: Butch: 16294 Butch Date 6/26/2012 Cashier: OFTUQ Trans 112 DORA Rent: 010395 34 Comment/Document: 223 street 11c Payment Total: $270.00 Payment Distribution: 2152 CRO (3235 l?exn 09980 $50.00 2115 (F0 (3222) $220.00 CK Tendered: $50.00. CV. Tendered: ?220.00 Of?ce Use Only "52725?? . . ow :3 Day Expedite Services 1 $50 00' LLC initial Domestic 1 $220.00 iDate: 6/26/20l2 PAY THIS AMOUNT PAYABLE TO THE D. C. TREASURER $270 00 W1) i --. .Y Government of the District of Columbia- Of?ce of the Chief Financial Of?cer Returned Check Fee $65.00 - DCMR 1~108 All checks returned are subject toelectronic representment along with a $65.00 fee. (Page 2 of 3) osmarmem or consume a. naeuuroav AFFAIRS District of Columbia Government Corporations Division One or more persons acting as the organizers under the provisions of the Title 29 oi D. Code (Business Organizations Act) adopt the following Articles of Organization: Company name. 223 STREET, LLC 24 The street address of the initial principal oitice. 3823 Fordham Street NW, Washington DC 200% 8. Registered agent?s name and address in the District oi Goiumbla. Corporation System. iOlS 15th Street. N.W., Suite 1000 Washington, DC. 20005 4 The company will have one or more series that is treated as a separate entity which limits the debts obligations. and other liabtiities to the assets of a particular series as provided in the operating agreement as authorized by 29-802 06. No Yes Answer 4A 48 it onslvored 'Yes 4A. The limited liability company has at least one member. 48 The data onwhidi a person orparsons became the company?s initial memborormembers. 1mg, 2012 Effective date. Date ofeoccptancc of Articles of Organization 6. Miscellaneous provisions. may attach the statement) teatime? 333% 25 28i2 BY: it you sign this form you agree that anyone who makes a false statement . an be punished oy criminal . . of a line up to 51000 imprisonment up to 180' days or izoth under 22 2405 7 Organizers Name Address Vicki Hart Mail ail and required payment to: Dopenmeni oi Consortia! and Regulatory Aliairs lesmn 3 F0 80% 92960 . Washing Hon DC fit/?090 Phone: (202). 442 4400 Pieese check octane gov to view organizations required to register to search business names. to get step?brstep guidelines to registsten organization. to search registered organizations and to download terms and domenis Just dick on Corporate Registrations! EXHIBIT GOVERNMENT OF THE DISTRICT OF COLUMBIA DEPARTMENT OF CONSUMER AND REGULATORY AFFAIRS CORPORATIONS DIVISION CERTIFICATE THIS IS TO CERTIFY that the attached is a true and correct copy Ofthc documents for this entity as shown by the records of this of?ce. 223 STREET, LLC IN TESTIMONY WHEREOF I have hereunto set my hand and caused the seal of this of?ce to be af?xed as of 4/5/2018 1:30 PM Business and Professional Licensing Administration 9%??ng f?w? PATRICIA GRAYS Superintendent of Corporations Corporations Division Muriel Bowscr Mayor Tracking Scanned by CamScanner .J an HI ll. my DEPARTMENT or CONSUMER REGULATORY AFFAIRS District of Columbia Government Corporations Division Two-Year Report for Domestic Foreign Filing Entity Year of Filing: 2017 File Number: L00004580855 Date of Filing: 2/26/2017 7:11 AM Filing Fee: $300.00 First: Entity Name: 223 STREET, LLC Second: Organized under the laws of which state or country: District of Columbia Third: Address of principal of?ce: 3823 FORDHAM STREET NW WASHINGTON, District of Columbia 20016 Fourth: Name of Registered Agent and address of registered of?ce in DC: CORPORATION SYSTEM 101515th St NW Suite 1000 Washington, District of Columbia 20005 Fifth: Brief statement of business affairs conducted in DC: Other Rental Sixth: List all entity governors (attach list if needed): 4' uAddress? VICRI Columbia 20016 Seventh: is foreign ?ling entity in good standing in state country where it is organized? Eighth: Name of the Governor or Authorized Person: No information provided. If you sign this form you agree that anyone who makes a false statement can be punished by criminal penalties of a ?ne up to $1000, imprisonment up to 180 days, or both, under DCOC 22-2405; E-Signcd Scanned by CamScanner GOVERNMENT OF THE DISTRICT OF COLUMBIA DEPARTMENT OF CONSUMER AND REGULATORY AFFAIRS CORPORATIONS DIVISION CERTIFICATE THIS IS TO CERTIFY that the attached is a true and correct copy of the documents for this entity as shown by the records of this of?ce. 223 STREET, LLC IN TESTIMONY WHEREOF I have hereunto set my hand and caused the seal of this Of?ce to be af?xed as of 4/5/2018 1:30 PM Business and Professional Licensing Administration gait, 5% PATRICIA E. GRAYS Superintendent of Corporations Corporations Division Muriel Bowser?_ ?Mayer .22: Y6 Scanned by CamScanner DEPARTMENT OF CONSUMER REGULATORY District of Columbia Government Corporations Division Two-Year Report for Domestic Foreign Filing Entity Year of Filing: 2015 File Number: Date of Filing: 10/17/2016 3:15 PM Filing Fee: $400.00 First: Entity Name: 223 STREET, LLC Second: Organized under the laws of which state or country: District of Columbia Third: Address of principal of?ce: 3823 FORDHAM STREET NW WASHINGTON, District of Columbia 20016 Fourth: Name of Registered Agent and address of registered of?ce in DC: CORPORATION SYSTEM 101515th St NW Suite 1000 Washington, District of Columbia 20005 Fifth: Brief statement of business affairs conducted in DC: Other Rental Sixth: List all entity gchmors (attach list if needed): Address iv 3823 FORDHAMS My; District of {Columbia 20016 Seventh: Is foreign ?ling entity in good standing in state country where it is organized? Eighth: Name of the Governor or Authorized Person: No information provided. If you sign this form you agree that anyone who makes a false statement can be punished by criminal penalties of a line up to $1000, imprisonment up to 180 days, or both, under DCOC 22-2405; Scanned by CamScanner GOVERNMENT OF THE DISTRICT OF COLUMBIA DEPARTMENT OF CONSUMER AND REGULATORY AFFAIRS CORPORATIONS DIVISION CERTIFICATE THIS IS TO CERTIFY that the attached is a true and correct copy of the documents for this entity as shown by the records of this of?ce. 223 STREET, LLC IN TESTIMONY WHEREOF I have hereunto set my hand and caused the seal of this of?ce to be af?xed as of 4/5/2018 1:30 PM Business and Professional Licensing Administration 7% Mia PATRICIA E. GRAYS Superintendent of Corporations Corporations Division Muriel Bowser Mayor Tracking Scanned by CamScanner DEPARTMENT or CONSUMER REGULATORY AFFAIRS District of Columbia Government Corporations Division Two-Year Report for Domestic Foreign Filing Entity Year of Filing: 2013 File Number: L00004580855 Date of Filing: 10/17/2016 3:08 PM Filing Fee: $400.00 First: Entity Name: 223 STREET, LLC Second: Organized under the laws of which state or country: District of Columbia Third: Address of principal of?ce: 3823 FORDHAM STREET NW WASHINGTON, District of Columbia 20016 Fourth: Name of Registered Agent and address of registered of?ce in DC: CORPORATION SYSTEM 1015 15th St NW Suite 1000 Washington, District ofColumbia 20005 Fifth: Brief statement of business affairs conducted in DC: Other Rental Sixth: List all entity governors (attach list ifneeded): Mme . .. . Columbia 20016 Seventh: Is foreign ?ling entity in good standing in state country where it is organized? Eighth: Name of the Governor or Authorized Person: No information provided. If you sign this form you agree that anyone who makes a false statement can be punished by criminal penalties of a ?ne up to $1000, imprisonment up to 180 days, or both, under DCOC 22-2405; F-9ionnd Scanned by CamScanner EXHIBIT 4/11/2018 EPA Administrator Scott Pruitt's Lobbyist?Owned Pad Was GOP Fundraising Hub ELLUSTRATION BY THE QAELY DOWNSTAIRS EPA Administrator Scott Pruitt?s Lobbyist-Owned Pad Was GOP Fundraising Hub Republican yaised money dawngtaim} White the EPA asziminigtmizin? lived upstairs in his rented tabbyigt-ane? Ezewnhouse. 511%?th 84.62.18 82% PM ET 1/5 4/11/2018 EPA Administrator Scott Pruitt?s Lobbyist-Owned Pad Was GOP Fundraising Hub (HOMEPAGE ?g $38011} BY THE BASLY The lobbyist?owned townhouse that EPA Administrator Scott Pruitt rented for relatively small sums also served as a hub for Republican lawmakers hoping to raise money for their congressional campaigns. A review of fundraising invitations reveals that at least three members of Congress had fundraisers at the now?controversial Capital Hill brownstone during the same period of time that Pruitt was living there. Several of those fundraisers took place on dates when Pruitt was in Washington, DC, according to a cross?reference of the invitations and Pruitt?s schedule. ADVERTISEMENT The EPA said that Pruitt wasn?t invited to and didn?t attend any of the events. And even if he were to have attended, ethics laws do not prohibit a cabinet secretary from going to a political event in his or her personal time. 2/5 4/11/2018 EPA Administrator Scott Pruitt's Lobbyist?Owned Pad Was GOP Fundraising Hub is: (HOMEPAGE over how the EPA chief conducted himself upon arriving in Washington. ?Nothing says ?the swamp? like corporate lobbyists holding high?dollar fundraisers in a luxury Capitol Hill condo,? said Brendan Fischer, the director of federal reform programs at the Campaign Legal Center, a nonpro?t ethics group. ?The fact that a senior member of the administration is staying in a lobbyist?s fundraiser den when he isn?t ?ying ?rst class on the taxpayer dime might say something about President Trump?s commitment to his ?Drain the Swamp? pledge.? The townhouse at 223 Street, NE, is owned by Vicki Hart and her husband J. Steven Hart, who chairs one of major lobbying ?rms and represents, among other clients, major energy companies. According to ABC News, Pruitt lived at the address during the spring and early summer of 2017, paying a rate of $50?a?night?well below a standard fare for someone renting out prime real estate on the Hill. The EPA says the relationship was entirely above board. A spokesperson for the agency provided a memo from its chief ethics attorney, who reviewed the arrangement retroactively and found that it fully complied with relevant laws and regulations. But the White House said on Monday that it was conducting its own review of the practice to ensure it was above board, according to a Wall Street Journal rep_o_rt. RELATED IN POLITICS Third GOP Member of Is the Scott Pruitt Pruitt Hangs On, and Congress Calls for Pruitt?s Too Crooked, to Fail? Hopes Kelly Overplayed Resignation His Hand During those months that Pruitt stayed in the house?from March through July, according to records mported by Bloomberg?political action committees associated with several members of Congress held fundraisers at 223 Street, NE as well. They include Sen. Mike Crapo who hosted, what appears to be, luncheons. A request for comment made to Crapo?s Freedom Fund was not returned. Rep. Bill Huizenga held a breakfast fundraiser at the townhouse on March 9, 2017. A treasurer for ?Huizenga for Congress? did not return a request for comment. And Save America PAC, the political action committee for Sen. Jim Risch also held an event at the house in mid?July, 3/5 4/11/2018 A (HOMEPAGE if? A request for comment made to Steven Hart?s office was not returned. EPA Administrator Scott Pruitt's Lobbyist?Owned Pad Was GOP Fundraising Hub <12 Pruitt was in Washington, DC, on the same day of at least three of the Crapo fundraisers (he was in Oklahoma for a fourth). He was in Little Rock, Arkansas, on the date of the Risch fundraiser and in Houston during the Huizenga event (his publicly released schedule does not go back that far). Though the events took place at his residence, most of them were in the middle of the day which would have made it dif?cult for Pruitt to have attended. Pruitt was out of town for some of the events, and might not have even known they were taking place. But Fischer insists that that?s almost beside the point. ?Even if that is true,? he said, ?the fact that fundraisers were a common occurrence is a reminder that Pruitt was getting a sweet deal on a luxury condo from a couple whose job is in?uence?peddling.? Sponsored Stories Recommended by Early Signs of Ulcerative Colitis. See about Treatments SEARCH xx . Enter Any Name, Wait 7 Seconds, Brace Yourself PEOPLEWHIZ These Wallet-Friendly, Walkable Heels Keep Flying Out of Stock ?5?1 Cash in on these "Bonus Checks" While They Last 4/5 4/1'1/2018 EPA Administrator Scott Pruitt?s Lobbyist?Owned Pad Was GOP Fundraising Hub (HOMEPAGE i; is? .13. >7 .. Size Matters! Tips for A Chef's Honest How Senior ln-Home Have You Tried A Keeping Your Breasts Review Of HelloFresh Care Can Help Restore Sleepgram? Healthy SOUTHERN PLATE Your One's SLEEPGRAM HEALTH CENTRAL Active Lifestyle VISITINGANGELS 5/5 EXHIBIT Upcoming Events Memo -Changes and Additions- May 4, 2017 Please send all changes and additions by 12:00 PM on Friday: May 5th, 2017 2017 Senator Events Wednesday, May 24. 2017 MIKE RAW) (1911)) Lunth: Location: 2:23 Street NE: Unit 8 Cost: $2,500 Individual RSVP: Amy Mmh'w or 703?5bbu826'7 \?v'bdnfiday, June 28. 2,0 17* MIKE (12.41)} Lunch: mutation: 2:23 Street NE: Unit Cost: $2,500 lndividml RSVP: Amv Mathis at 01' Thursday, July 2m? MIKE (R-ID) Lunch: mum-Moumn Lewntinn: 2213(5 Strum MEL: Unit 1! Cost: $2.500 individual RSV Amy Mathis at amvli?hrs?locum or 303-566-8267 Wednesday. Scpteml?wr 2m 3' SENATOR CRAPC) (ll-ll?) Lunch: suzooqsoopm location: 223 Street NE: Unit Cost: $2.500 Individual RSVP: Amv Mathis at nr 7113-5hfh8267 Wednmday, {)ctulwr 23, 2:01? MIKE. CRAPO (R413) Lunch: mien-1200px): Location: 223 C. Street NE: {?rm Cost: $2.500 lndividtml RSVP: Mm Mathis? at m? rug-sbbesmjr ?l?humdash NIWE?ll?lf?f :30, 2017 sure-tron CRAPG Location: 2'13 C. Sin-ct mm (Just: $2500 PAC [$1.000 lmlividml RSVP: Mathis at amuiz?hrs-demm or 7og-5b6-82?? Source: Political Party Time