MONT REPUBLICANS P.O. Box 70 * Montpelier, VT 05601 October 19, 2016 Hon. Attorney General William Sorrell Office of the Vermont Attorney General 109 State Street Montpelier, VT 05609-1001 RE: Complaint for Violation of Vermont Campaign Finance Law by Planned Parenthood Vermont Action Fund IE PAC Dear Attorney General Sorrell, Please consider this a formal complaint against the Planned Parenthood Vermont Action Fund IE PAC. (On September 1, 2016 the Planned Parenthood Vermont Action Fund IE PAC registered as an Independent-Expenditures only PAC. PP Vermont Action Fund IE Pac does not meet the definition of an Independent-Expenditures only PAC under Vermont law because it does not conduct its activities entirely independent of candidates. (On September 2, 2016 Planned Parenthood Vermont Action Fund IE PAC distributed a questionnaire to Vermont candidates, a copy of which is located here: https://www.surveymonkey.com/r/FKKY2QL Question #6 expressly asks candidates if they would like an endorsement from the organization: In addition, PP Vermont Action Fund IE PAC offers a quid-pro-quo at the conclusion of the survey, stating they expect endorsed candidates to vote 100% of the time in support of PP Vermont Action Fund IE PAC's position if elected A political committee that expressly asks candidates if they want an endorsement from the PAC is not ‘conducting its activities entirely independent of candidates, and therefore does not qualify as an IE only PAC under Vermont law. (On October 15, 2016 PP Vermont Action Fund IE PAC reported they had received a $10,000 contribution from Jake and Donna Carpenter. This contribution, which would be legal for an IE only PAC, violates Vermont law because PP Vermont Action Fund IE PAC does not qualify as an IE PAC under Vermont law. (On October 18, 2016 Planned Parenthood Vermont Action Fund IE PAC reported a Mass Media expenditure of $131,929.00 for television ads in support of Sue Minter. There is reason to believe these ads violate Vermont law because they are related expenditures, not independent expenditures, which exceed the contribution limit to a candidate for Governor. aid for By the Vermont Republican Party ‘woew.vigop. ong ot authorized by any candidate or candidate's committeeREPUBLICANS P.O. Box 70 * Montpelier, VT 05601 Further Planned Parenthood Vermont Action IE PAC is using the GMIMB Inc, agency for the production ‘and media buying. This is the same company that Sue Minter is using to produce and place her ads. Using the same agency to produce and coordinate media buys would also appear to preclude Planned Parenthood Vermont Action Fund IE PAC from being an independent expenditure PAC. These matters need to be investigated immediately, And we ask that you and your office seek to have Planned Parenthood Vermont Action Fund IE PAC take down their advertisements immediately. We all recall that in 2010, Planned Parenthood violated the law when it ran over $100,000 worth of ads in support of Peter Shumlin in the last weeks of the campaign ~ ads that may well have changed the ‘outcome of the election. Unfortunately, their illegal activity was not discovered until after the election. Given that PP Vermont Action Fund IE PAC reported $16,685 in contributions on October 15, and today reports a $131,929 Mass Media expenditure, itis very likely that they solicited and received very large contributions, which they should be made to return immediately if they do not qualify as an IE-only PAC under Vermont law. | look forward to your prompt response. Sincerely, lige Jeff Bartley Executive Director Vermont Republican Party ieff@vtgon.org 802-223-3411, Paid for by the Vermont Republican Paty wow.vigop.org Not authorized by any candidate or eandidate’s committee