VIA EMAIL
September 14, 2018
Risa S. Sugarman, Esq.
Chief Enforcement Counsel
Division of Election Law Enforcement
NYS Board of Elections
40 North Pearl Street
Albany, NY 12207
Dear Chief Enforcement Counsel Sugarman:
We write to request you investigate the Northeast Brooklyn Democratic Club and State
Senator Martin Dilan for apparent violations of New York State Election Law, ​as
reported by the investigative journalist website ​Sludge1 and corroborated in large
measure by public records.
The Northeast Brooklyn Democratic Club is not registered as a political committee
though Board of Elections records show it has received tens of thousands of dollars in
political contributions dating back to at least 2012. ​This is an apparent violation of
Election Law 14-118 which requires, among other things, that a political committee not
receive, transfer, contribute or make ​any​ expenditure until it has: 1) registered with the
State Board of Elections as a political committee; 2) chosen a treasurer; and 3) set up a
bank account.
The Club’s actions as described by ​Sludge​ also appear to violate Election Law sections
14-102, 14-108 and 14-110, which require periodic statements of campaign activity be
filed with the Board of Elections; section 14-106 regarding submissions of political
communications to the general public; and section 14-122 regarding accounting for and
filing contributions and payments of a political committee by the treasurer or any agent
of the committee.
Sludge​ also raises questions about whether the Club, if effectively an independent
expenditure committee, illegally coordinated its campaign activity with the campaign of
State Senator Martin Dilan. Both the campaign office and political club are​ ​located at 58
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See:
https://readsludge.com/2018/09/12/mysterious-political-group-linked-to-n-y-sen-martin-dilan-is-funded-bybig-real-estate/

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 Vermont Street in Brooklyn. Election Law 14-107(d)(vi) defines coordination as, “the
candidate...shares or rents space for a campaign-related purpose with or from the
independent expenditure committee…”.
If the club is acting as an independent expenditure committee and made expenditures
on behalf of Senator Dilan, it is additionally required to register as such under Election
Law 14-112(3), report contributions and expenditures (Election Law 14-1112(4)) and file
a sworn verified statement by the club’s treasurer that Senator Dilan has not authorized
the Club to aid or take part in his election (Election Law section 14-112).
Political clubs, too often and for far too long, have failed to register as political
committees when conducting campaign activity and the Board’s enforcement has been
inadequate. In 2013, Citizens Union’s ​Hidden from View: The Undisclosed Activity of
Political Clubs​ report used public data to identify 224 political clubs that did not register
while appearing to campaign. In 2018, Reinvent Albany surveyed the Board’s online
filing system to determine if any of the top 50 clubs identified in the 2013 Citizens
Union report as spending and receiving the most money has subsequently registered
with the State Board of Elections. Twenty five clubs who appeared to be active had still
not registered. Four others were inactive, and 21 clubs had registered.
We request you investigate this matter, and, if violations are found, bring civil actions to
assess penalties for willful violations where applicable.
Regards,
John Kaehny
Executive Director
Reinvent Albany
Alex Camarda
Senior Policy Advisor
Reinvent Albany

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