2018G-022 Pureval OEC Prelimary Review Hearing

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BEFORE THE OHIO ELECTIONS COMMISSION
IN THE MATTER OF:
MILLER CASE NO. 2018G-022
v.
PUREVAL, ET AL
PROCEEDINGS
before Chairwoman Degee Wilhelm, and Commission Members
Catherine A. Cunningham, D. Michael Crites, Otto Beatty
III, Dennis Brommer, Helen E. Balcolm, A. Scott Norman
at the Vern Riffe Center for the Arts, 31st Floor, Room
East B, Columbus, Ohio 43215, called at 10:37 a.m. on
Thursday, September 20, 2018.
DAVIS DEPOSITIONS, LLC

175 SOUTH THIRD STREET, SUITE 200
COLUMBUS, OHIO 43215
(614) 407 - 9337
Davis Depositions, LLC

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APPEARANCES:
FINNEY LAW FIRM

By: BRIAN C. SHRIVE, ESQ.
4270 Ivy Pointe Boulevard, Suite 225
Cincinnati, Ohio 45245
(513) 943-6656
On behalf of Mark W. Miller.
PERKINS COlE, LLP

By: BRIAN G. SVOBODA, ESQ.
700 Thirteenth Street, NW, Suite 600
Washington, DC 20005-3960
(202) 654-6200
On behalf of Aftab Pureval, Friends of Aftab Pureval,

and Evan Nolan.
KATZ TELLER
By: PETER J. O'SHEA, ESQ.
255 E. 5th Street, 24th Floor
Cincinnati, Ohio 45202
(513) 977-3401
On behalf of Aftab Pureval, Friends of Aftab Pureval,

and Evan Nolan.
ALSO PRESENT:
Phillip C. Richter, Executive Director, Ohio Elections

Commission
Betty Springer, Administrative Assistant, Ohio

Elections Commission

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I N D E X
WITNESSES:
Brian Shrive
Statement by Mr. Shrive 7
Brian G. Svoboda
Statement by Mr. Svoboda 15
EXHIBITS IDFD ADMITD
No Exhibits

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1 September 20, 2018
2
3 CHAIRWOMAN WILHELM: Next case is 2018G-022,

4 Miller versus -- is it "Pureval"? Am I saying that
5 correctly? "Pureval"?
6 MR. MILLER: [Affirmative head nod] .
7 CHAIRWOMAN WILHELM: Okay. I believe we have
8 counsel here for those parties. If the Complainant
9 could sit over here, and the Respondent over here,
10 please.
11 MR. RICHTER: While they are getting to their
12 seats, Madam Chair, this is a complaint, it's an
13 interesting complaint in terms of the Respondent and
14 the campaign committee. Mr. Pureval, is the current
15 holder of the office of Hamilton County Clerk of
16 Courts. He is also running for Congress in the 1st
17 District.
18 The assertions by the Complainant are that
19 there were improper contributions and expenditures by
20 the candidate's state campaign committee that should
21 have been made through the Federal campaign committee.
22 We received a response to those allegations. All of
23 those materials were presented to you.
24 When I entered the office this morning, there
25 was an email that I had received overnight from Mr.
26 Shrive, materials of which are currently sitting here

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1 at my left hand, including an additional affidavit from
2 Mr. Shrive and a certification and some information
3 that was a part of a hearing that the Hamilton County
4 Board of Elections had yesterday. I have not reviewed
5 those materials.
6 I'm not sure that it would be appropriate for
7 the Commission to take this late in the process, but
8 they are here. They've been presented. I don't know
9 whether the Respondents have had the opportunity to
10 review them, or go over them, or have anything to do
11 with them, because I haven't had that conversation with
12 the Respondents. But they are here.
13 I would presume that Mr. Shrive will at least
14 attempt to talk about them or hear what the Respondents
15 have to say about that. But that's essentially the
16 case in a nutshell. We can hear from the respective
17 counsel for the respective parties at your leisure.
18 CHAIRWOMAN WILHELM: Okay. Thank you.
19 Mr. Shrive, if you could go ahead and take the
20 podium, please. And we do have a motion before us for
21 permission to appear pro hoc vice from a couple of
22 attorneys for Mr. Pureval. What do we need to do to
23 MR. RICHTER: There is nothing. I talked to
24 the staff at the Supreme Court Attorney Registration
25 Office yesterday, just as a double-check. In leading

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1 up to this, I talked to both Mr. Svoboda and his
2 additional counsel who have come in from Washington,
3 and I informed them that there was additional efforts
4 that needed to be undertaken to be approved to come
5 into Ohio in this matter, which they have done
6 approaching the Supreme Court.
7 As I indicated to them, if you were to go back
8 about 10 years, we regularly accepted people on pro hoc
9 motions.
10 The Commission just kind of said, "Yeah, okay,
11 go ahead and do that."
12 And about two or three years ago, I found out
13 that the Supreme Court had changed their process. And
14 so you can't just do that as an administrative agency
15 or court. There is an obligation for them to go through
16 the Supreme Court to get approval, which they have done
17 as you all saw their request.
18 From talking to the court, there's nothing
19 else we need to do. Obviously, we have that in the
20 file, so it's here. But they are present and can go
21 ahead and argue on behalf of their clients.
22 CHAIRWOMAN WILHELM: Thank you, Mr. Richter.
23 Mr. Shrive?
24 MR. SHRIVE: Thank you, members of the
25 Commission.

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1 Chairwoman Wilhelm, members of the Commission,
2 as I stated earlier, Brian Shrive with Finney Law Firm
3 representing the Complainant in this matter. And just
4 as an administrative matter, we do not raise any
5 objection, whether it's necessary or not, we don't
6 object to their admission pro hoc vice.
7 CHAIRWOMAN WILHELM: So noted.
8 MR. SHRIVE: I want to touch on what happened
9 here. In the complaint that you have that was filed
10 with this Commission, there's a series of issues. And
11 this really begins in the summer of 2017, when Mr.
12 Pureval, who -- he was elected to the Clerk of Courts
13 office in November of 2016, took office in January of
14 2017. And in December of 2017, he began traveling
15 throughout the area beyond Hamilton County into Adams
16 County, to Atlanta, to Washington, D.C. for the
17 purpose, you know, what he calls "stakeholder
18 meetings."
19 And what these are, testing the waters to see
20 if there's support for a congressional run. And Adams
21 County is obviously not in Hamilton County. And it's
22 not even the 1st congressional district. It's actually
23 Ohio's 2nd district, which is where Mr. Pureval used to
24 live until he moved into Downtown Cincinnati to run in
25 the 1st district.

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1 But he traveled in December of 2017. He
2 stayed at the Murphin Ridge Inn in Adams County, had a
3 stakeholder meeting at the White Star Restaurant in
4 Adams County; traveled to Atlanta in August of 2017,
5 had a stakeholder meeting at the Meehan's Public House,
6 stayed at The Ellis Hotel in Atlanta in August of 2017.
7 These are clearly not related to the job of the
8 Hamilton County Clerk of Courts, and they're clearly
9 not related to a campaign for the Hamilton County Clerk
10 of Courts.
11 What they're related to is figuring out, "Is
12 someone going to support me if I run for Congress?"
13 These are what the Federal Election Commission
14 refers to as "testing the waters expenditures."
15 Further, in January of 2018, Aftab Pureval
16 announced his run for Congress. Immediately, his
17 mother, Drenko Pureval, gave him a maximum donation
18 under Federal Election Campaign law, of $5,400: $2,700
19 for the primary; $2,700 for the general.
20 She also, on the same day of the $5,400 check,
21 wrote a $15,000 to his state campaign. And then a few
22 months later, wrote another $15,000 check to the state
23 campaign.
24 Now where did that money go to pay for? That
25 money went to a poll. And in our complaint, we refer

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1 to a redacted check. And one of the documents that I
2 provided to the Commission late last night was a
3 certified copy of a record. The first is the
4 unredacted pages that the Pureval campaign filed with
5 the Board of Elections yesterday afternoon. And the
6 second part of that certified record is the actual
7 transcript of the hearing that the Board of Elections -
8 - or the special meeting at the Board of Elections of
9 Hamilton County called yesterday to find out what
10 happened with this redaction.
11 And what happened with this redaction -- so I
12 want you to see now, we had said in the complaint if
13 you look through even at the redacted version, if you
14 have the .PDF on your screen and you kind of blow it up
15 to about 300, you can see it looks like it says,
16 "poll. "
17 Well, it turns out it says, "poll balance,
18 $16,427.79 paid to GBA Strategies, a D.C. polling firm
19 for poll balance.
20 Now in the exhibits in the complaint, we have
21 the, and later filings with the Commission, we have
22 certified copies of filings from the clerk of courts
23 campaign from 2017 as well. Nowhere was the initial
24 payment. There was no initial payment of the first
25 half of the balance of this poll.

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1 Now anyone who knows politics knows that you
2 can't get a poll of a county or a congressional
3 district for $16,000. It's a $25-, $30,000 endeavor.
4 You look at the Federal election, and now Mr.
5 O'Shea yesterday, and in my affidavits, I was in the
6 room, I watched Mr. O'Shea say these -- I was about
7 four feet away from him, he said, regarding this
8 polling a reporter from Channel 12 in Cincinnati asked,
9 "Is that poll for the Federal race?"
10 And Mr. O'Shea responded, "It's for both
11 races."
12 So he did a poll in March, or paid for poll in
13 March of 2018, to be used for both the Federal and
14 state race; that's the story they're now telling.
15 But they redacted the check. And when they
16 initially filed their report, the 31-B form, stated the
17 purpose of this expenditure was consulting. But the
18 unredacted check shows that it was "poll balance."
19 That's a big difference.
20 And how did we get to the redaction? How did
21 it get to that? And this is in the testimony that was
22 given by Sally Krisel, who is one of the Democrat
23 employees of the Hamilton County Board of Elections.
24 Sarah Topy, who is the campaign manager for Mr.
25 Pureval's campaign, I'm not sure which or both, but

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1 identified as the campaign manager by Sally Krisele --
2 or Sally Krisel on August 1st, I asked for a copy of
3 Mr. Pureval's filings. I was provided the forms but
4 not the backup documentation.
5 So I called and said, "Hey, where's" -- and in
6 email "where's the documentation? We don't have
7 it."
8 Immediately calls went out to Sarah Topy, "You
9 need to bring those documentations in."
10 And then the testimony -- the transcript of
11 the sworn statement of -- Ms. Krisel was under oath at
12 the Board of Elections, she said that Sarah Topy and
13 Sally Krisel sat in Sally Krisel's office and Sarah
14 asked her if they could redact the memo lines. And
15 Sally determined that she thought you could.
16 Then Sally Krisel redacted the memos. And
17 what's interesting, and if you look at the copies that
18 were provided by the -- that was filed yesterday, this
19 was filed yesterday from the O'Shea -- from Mr. O'Shea
20 and the Pureval campaign, provided they redacted -- and
21 if you look, they actually redacted the memo line
22 initially on all four checks that were presented that
23 day.
24 And when you unredact it, the only one that
25 had anything written on it was the $16,000 check to the

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1 out-of-state agency. So they redacted blank memo
2 lines. Why would someone redact a blank memo line
3 other than to camouflage the guilty redaction?
4 And so they've now come clean and said, "Okay,
5 it wasn't consulting; it was actually for polling."
6 And I would submit to you that that alone is sufficient
7 evidence to indicate a potential violation.
8 Remember, this is what -- the level we're at
9 is evidence indicating a potential violation. We don't
10 have to prove our case here today. You don't have to
11 believe anyone's guilty or not today. What you have to
12 believe is, "Does this smell right?"
13 You have to ask that question, "Does this
14 smell right?"
15 Does it smell right when they say "consulting"
16 and then redact "poll balance"? And then when they're
17 asked by the press about it, they say, "Oh, it was a
18 poll for both the congressional and the state race."
19 Now the state race isn't until 2020. What
20 polling data conducted in March of 2018 is going to be
21 at all valid for a November 2020 election? We know
22 this doesn't smell right. But beyond the polling,
23 beyond the travel, we have the media expenditure to
24 Byron Photography.
25 Byron Photography, as the exhibits show,

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1 provided photographic and videographic services for
2 Aftab Pureval's congressional campaign kickoff. He
3 posted, Mr. Byron, posted those photos on his own
4 website. Mr. Pureval's campaign put up -- the Federal
5 campaign, posted photos and video and used some of
6 those photos and video in commercial for his Federal
7 campaign. There's no check that we produced -- the
8 expenditures from that time from the FEC reports,
9 there's no payment from the Federal campaign to Byron
10 Photography. Clearly, the state campaign paid for
11 assets that were for the Federal campaign.
12 The State campaign -- why is this a big deal?
13 The big deal is because the state campaign is unlimited
14 contributions, and the Federal campaign has very
15 limited, some say, some say too high, but has limits.
16 And then we finally get to the question of the
17 lack of documentation for these expenditures. We have
18 Venmo payments to the campaign manager for just "dinner
19 payments."
20 We have a refund to a person who turns out, I
21 believe, is the Aftab Pureval's campaign manager's
22 brother-in-law; refunded him and reimbursed him for
23 travel. Where did he travel? Did he travel or did he
24 front payments? Did he make payments on behalf of the
25 campaign that he was reimbursed for? Or was that for

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1 this Joe Levy? Was that for his travel, or was he
2 paying travel expenses of the campaign initially?
3 These are real questions that the public has a
4 right to know, particularly on the fact that it's very
5 clear, from my perspective, that this is -- these are
6 payments that were made for the purpose of skirting the
7 Federal campaign finance laws and were in violation of
8 Ohio campaign finance law. And I'd ask that you'd
9 initiate an investigation to get to the bottom of this.
10 CHAIRWOMAN WILHELM: Thank you.
11 I have a question for the Commissioners. Have
12 you received a response to this? Do you have this
13 document?
14 COMMISSIONER CRITES: Huh-uh.
15 CHAIRWOMAN WILHELM: The Response to
16 Complaint? So I think what we'll do is take a short
17 break so that the Commission can have a chance to read
18 this.
19 MR. RICHTER: That makes sense. I assumed
20 that that got circulated to everybody.
21 CHAIRWOMAN WILHELM: I don't think -- you made
22 a lot of materials from this one but --
23 MR. RICHTER: Yeah, there are a lot of
24 materials but --
25 CHAIRWOMAN WILHELM: -- I don't believe we

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1 have this.
2 MR. RICHTER: You know, when I went through
3 them looking through the materials, I knew I had it.
4 CHAIRWOMAN WILHELM: Sure.
5 MR. RICHTER: I thought I had made sure that
6 was with Chris so that he could circulate it.
7 CHAIRWOMAN WILHELM: Yeah, it's probably just
8 a clerical error with the --
9 MR. RICHTER: But if he didn't, that's my --
10 CHAIRWOMAN WILHELM: because there is a lot
11 of documents.
12 MR. RICHTER: -- fault.
13 CHAIRWOMAN WILHELM: No worries. No worries.
14 So what we're going to do is take a 10-minute
15 break while the Commission has a chance to look at the
16 response, okay? Thanks.
17 (Off the record from 10:51 a.m. to 11:14 a.m.)
18 CHAIRWOMAN WILHELM: We've got the
19 Commissioners in front of us. So the Respondents?
20 MR. SVOBODA: Thank you, Madam Chair. Thank
21 you, Commissioners, for the attention to our response.
22 I felt a little bit like being in law school and
23 watching my law professors grade my papers.
24 (Laughter)
25 CHAIRWOMAN WILHELM: Well, I know how hard it

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1 is to write one of those, so I wouldn't want it to go
2 unrecognized. So thank you for your patience,
3 everyone, while we did that.
4 THE COURT REPORTER: I'm sorry, what's your
5 name?
6 MR. SVOBODA: My name's Brian Svoboda. I'm
7 counsel to Mr. Pureval, his committee, and the
8 treasurer. And I'm here with Mr. O'Shea, who is
9 counsel with Katz Teller. So I'm the one who's here
10 from Washington. I appreciate your cooperation and
11 assistance in admission.
12 You heard a lot of argument from counsel to
13 the Complainant. You heard a lot of, frankly,
14 "evidence" in the guise of argument from Counsel, and I
15 hope the Commission will give that proper consideration
16 under jurisprudence, which is none at this stage.
17 But the one thing that you didn't hear from
18 Counsel is why any of this in the complaint, which is
19 before the Commission now, presents a violation of Ohio
20 law.
21 And there's two core problems with the
22 complaint as a matter of law. The first is what the
23 complaint presents prima facie are transactions that
24 are illegal under Ohio law and Federal law. Ohio law
25 and Federal law expressly provide for the concurrent

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1 operation of a local campaign and a Federal campaign at
2 the same time. They provide expressly for receipts
3 into those committees. They provide expressly for
4 disbursements for those committees.
5 And the complaint shows simply that they
6 occurred. It shows simply what both the local law and
7 the Federal law expressly contemplate, which is that
8 these committees will raise and spend money at the same
9 time, and it provides no affidavits, no documents, no
10 other evidence to show that anything other than what
11 was expressly permitted by Ohio and Federal law
12 occurred.
13 And then the second defect with the complaint
14 is that it asks the Commission to reach a determination
15 that the receipts for the Ohio committee were
16 contributions for the purpose of influencing the
17 Federal election; that the expenditures by the Ohio
18 Committee were expenditures for the purpose of
19 influencing the Federal election. And those are
20 questions of Federal law.
21 I mean, those are questions where exclusive
22 civil jurisdiction for that is given to the Federal
23 Election Commission, which is empowered with the
24 exclusive ability to form policy and resolve those
25 questions. So that's a second defect with the

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1 complaint, which the Commission should consider.
2 So I want to talk first about the receipts
3 that were alleged in the complaint. If you read the
4 complaint carefully, and in particularly paragraph 10,
5 the complaint alleges that every receipt that the Ohio
6 committee received during the first quarter of 2018,
7 was for the purpose of influencing the Federal
8 election; that every receipt that the Ohio committee
9 received was prohibited thereby under Ohio law.
10 And the problem with that is that Federal law
11 expressly Ohio law expressly provides that a
12 candidate can simultaneously maintain a local committee
13 and engage in activity from that committee while also
14 seeking Federal office. So if you look at the
15 Secretary of State's campaign handbook, for example, on
16 page 211 in says that Ohio law, "does not prevent a
17 local or statewide candidate from also having a Federal
18 committee and concurrent operation for the purpose of
19 seeking election to Federal office."
20 And if you look at the Federal statutes, I
21 mean, they're even more explicit than that. So 52 USC
22 30125 expressly allows Federal candidates who hold or
23 seek state office also to raise and spend funds from
24 the state committee in connection with the state
25 election. It expresses allowance, you know, under

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1 Federal law.
2 And the FEC's regulations for many years at 11
3 CFR 110.8 has allowed dual candidates, including those
4 seeking both Federal and state office, to allocate
5 expenditures between the dual Federal and state
6 campaigns. So these are activities for which the law
7 expressly allows. So let me juxtapose that against the
8 facts in the complaint.
9 And with respect to the contributions, the
10 complaint presents no evidence at all, it presents only
11 speculations, that the contributions were somehow used
12 in connection with the Federal election. It offers no
13 affidavits. It offers no documents. It offers nothing
14 that the Commission's rules say are supposed to be
15 present for the presentation of a prima facie case at
16 this stage.
17 And so as a result, the allegations regarding
18 the contributions need to be dismissed. So that brings
19 us to the disbursements. And the architecture of the
20 state law and the Federal law is the same; again, both
21 expressly contemplate that these two committees are
22 going to be raising and spending funds at the same
23 time.
24 So simply to assert that they did that, that
25 the state committee sent money while the Federal

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1 committee was ongoing, does not present or suggest a
2 violation of law. To the contrary: it presents a set
3 of facts that are consistent with the Ohio rules and
4 consistent with the express allowance of the Federal
5 laws.
6 And so then when you drill down on the
7 disbursements, you know, once again the complaint
8 suffers from the same defect as to the receipts. It
9 offers no documentation that any of the receipts or any
10 of the disbursements were made impermissibly or somehow
11 impermissible under Ohio law.
12 If you look at the list of the disbursements,
13 you see that they are for characters of the sorts of
14 expenses that campaigns incur all the time; that they
15 were for, you know, consulting; that they were for
16 travel; that they were for, as Mr. Shrive mentions,
17 support or meetings. These are customary, ordinary,
18 and necessary expenses that candidates are typically
19 going to incur under state law.
20 And that's no less true, you know, of Mr.
21 Pureval, even at this point in the election cycle. He
22 is a candidate for state office who maintains a state
23 campaign committee. He is also a prominent rising
24 start in the Democratic Party, both locally and
25 nationally, particularly as a member of the Asian-

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1 Pacific Islander community, which gives him
2 opportunities to network with those communities and be
3 active as an officeholder and a leader within the
4 party. And that creates the necessity for these sorts
5 of expenses.
6 Again, it's a critical defect in the
7 complaint. There is no documentation that any of these
8 expenses were anything other than what the Ohio and
9 Federal rules expressly contemplated that a committee
10 might ordinarily incur. It was only one disbursement,
11 only one disbursement, for which the complaint offered
12 any documentation at all, and it was a $360.50 payment
13 to a photographer. And it was a photographer who came
14 and took pictures at the event where Mr. Pureval
15 announced his campaign for Congress.
16 As we mentioned in our response, the Federal
17 committee determined on review that it was appropriate,
18 for Federal law purposes, to make payment for that
19 expense. And it's taken steps to do that. But that
20 still does not present a violation of Ohio law. That's
21 precisely the sort of expense that a campaign is going
22 to incur and it's going to be of utility for a
23 campaign.
24 If Mr. Pureval finds himself on the ballot for
25 clerk of court in three years having pictures of Mr.

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1 Pureval in front of the American flag, in front of his
2 supporters, you know, with children, it's going to be
3 of utility to that campaign. And, again, it's the sort
4 of ordinary and necessary expenditure that's permitted
5 under Ohio law.
6 So the complaint fails to present a violation
7 and fails to present any evidence to show anything
8 other than what the Ohio and Federal rules expressly
9 contemplated for somebody like Mr. Pureval, who is
10 seeking state office and Federal office at the same
11 time.
12 And so I want to touch last, you know, on the
13 issue, you know, of the Federal side of things here.
14 What's happened is that Mr. Miller has addressed what
15 is really a grievance under the Federal campaign
16 finance law, or so he thinks, as a violation of a
17 purported violation of the Ohio election laws. And
18 that's why they're here. And that's where the Federal
19 law comes in where, again, the FEC has exclusive civil
20 jurisdiction over questions of the Federal law.
21 So, again, the Federal law provides that
22 expenses between a Federal committee and a state
23 committee, you know, are to be allocated under FEC
24 regulations that are provided, you know.
25 Mr. Miller may think that Mr. Pureval didn't

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1 make the right call with respect to that, but that's a
2 matter for the FEC to decide; that involves question of
3 Federal law. It involves whether a particular receipt
4 is a contribution under Federal law, or whether a
5 particular expenditure is a disbursement under Federal
6 law. And so that's a subject where I think, you know,
7 that's a subject where historically, you know, the
8 Commission and courts have been reluctant about, you
9 know, trying to dress up these asserted, you know,
10 Federal claims somehow in the guise of state claims.
11 But that still leaves us with the basic defect
12 of the complaint, which is it fails to present evidence
13 sufficient to support a prima facie case. It fails to
14 present any evidence at all, except for the photos from
15 the photographer's website. And for that reason, we
16 respectfully request that it be dismissed. I
17 appreciate your time and I'm glad to answer questions.
18 CHAIRWOMAN WILHELM: Any questions?
19 All right. Thank you.
20 MR. SVOBODA: Thank you very much.
21 CHAIRWOMAN WILHELM: Mr. Shrive?
22 MR. SHRIVE: Thank you.
23 With all due respect to opposing counsel, this
24 is not an academic question that you're asked to answer
25 here today. This is a question of Ohio law. And we

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1 live in a federalist system where Ohio has its own set
2 of laws in addition to the state law -- the Federal
3 laws. And the Ohio Elections Commission is called upon
4 to be the arbiter of state law in this matter. And
5 state law does prohibit impermissible expenditures.
6 They need to be legitimate expenditures of the
7 campaign. Not potentially legitimate; but actually
8 legitimate.
9 And that's the question. Potentially, could
10 Mr. Pureval make use of photographs in his state
11 campaign? Probably. Certainly.
12 But the reality is: What did he use them for?
13 He used them for his congressional campaign. And who
14 paid for him? His clerk of court's campaign.
15 Could Mr. Pureval make some sort of state use
16 of these -- of the polling? Potentially. But what use
17 is he making it of? He's making it for his Federal
18 campaign.
19 Could Mr. Pureval make use of these contacts
20 or whatever that he's making in Atlanta and D.C. for
21 his state campaign? Potentially. Sure. But what did
22 he make use of them for? He's using them to advance
23 his Federal campaign. And the question before this
24 Board today is: Are these expenditures made for a
25 legitimate state campaign purpose?

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1 And the answer is no. But really beyond that,
2 your answer today is: Does it look like, does it
3 indicate, have I presented evidence that indicates a
4 potential violation?
5 And that's what we have to show here. And the
6 evidence we presented is a false filing at the Ohio
7 at the Board of Elections where they filed a form that
8 said a $16,000 check to GBA Strategies was for
9 consulting. They've now amended that filing by filing
10 an unredacted check that clearly shows it was for
11 polling.
12 There's a statement that Mr. O'Shea, counsel,
13 made. I move that my affidavit be put into the record
14 with or without the video. But my statement on its
15 own, I was standing in the room when Mr. O'Shea said
16 this just yesterday.
17 Again, he said, "Is the poll for the Federal
18 race?"
19 And Mr. O'Shea responded, "It is for both
20 races."
21 And, again, he said, "The poll was used is
22 for both purposes. It's for both races. There's just
23 no question."
24 So he's using it for the Federal race. We
25 provided the filings in the FEC -- the FEC filings of

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1 expenditures for that period, for the first quarter of
2 2018. There's no payment to GBA Strategies for the
3 from the FEC campaign -- from the Federal campaign.
4 Who paid the other half for that polling if it
5 wasn't the Federal campaign? And if it's being used
6 for the state campaign, let's inspect their argument.
7 Let's go ahead and accept their argument that this is
8 for the state campaign. Okay, then who paid for the
9 other half of this state campaign poll? You didn't
10 support that as an in-kind contribution or a debt. Who
11 paid for the other half of that poll?
12 And I think there's a potential violation
13 there that needs to be investigated. And I hope that
14 you take this matter under further investigation.
15 Thank you.
16 CHAIRWOMAN WILHELM: Thank you.
17 Does Respondent have anything else they want
18 to add?
19 MR. SVOBODA: I do not.
20 CHAIRWOMAN WILHELM: Okay. Mr. O'Shea?
21 MR. O'SHEA: No.
22 CHAIRWOMAN WILHELM: Okay. Any discussion by
23 Commissioners?
24 Mr. Richter?
25 MR. RICHTER: I believe there's enough for the

Page 27
1 Commission to proceed forward. My recommendation would
2 be that the Commission set the matter for hearing. If
3 it wanted to try and -- if the Commission were to
4 accept my recommendation and in order to try and do so
5 before the election, we have two opportunities:
6 October 11th and November 1st are two meetings that the
7 Commission has currently scheduled prior to the
8 upcoming election. Or we could set it beyond that
9 date.
10 My initial thought is that, at least right
11 now, I would recommend that the Commission hear the
12 matter on October 11th. We can hear from the parties
13 as to the availability possibility of doing so, but
14 that would be my recommendation: to set the matter for
15 hearing on October 11th for further proceedings.
16 CHAIRWOMAN WILHELM: I guess I would like to
17 ask you: What do you think of Respondent's argument
18 that their claims are speculative?
19 MR. RICHTER: I think everybody that comes
20 before us makes some element of that response and any
21 response that comes before the Commission. I mean, I'm
22 not totally discounting it.
23 Alternatively, we -- I think that while it may
24 be small, Complainant did make the argument as it
25 relates to the photographic, you know. The photographs

Page 28
1 were taken and then used as, essentially, a part of the
2 Federal campaign, only reflected in the state -- or in
3 the county filing.
4 As it relates to the polling, not that people
5 don't do polling all the time, but polling done in
6 January, I think it was, two years prior to a county
7 race, I would think would be a little bit out of the
8 ordinary. And so at least, you know, those two things
9 as I'm thinking about them would at least lead me to
10 question the propriety of those being county-related
11 expenses as opposed to Federal-related expenses.
12 And certainly the other thing he raised
13 additionally were the FEC, the Federal arguments. And
14 historically, I'm more than willing to cede to the Feds
15 those elements of any campaign that, you know, run here
16 in Ohio. Every once in a while you would see somebody
17 go and try and file a disclaimer complaint against a
18 Federal campaign. Well, there are Federal rules and
19 so, therefore, you know, we stay out of that in every
20 way, shape, or form.
21 But there are Ohio campaign finance laws, and
22 there are Federal campaign finance laws. And, you
23 know, Ohio places certain limits on what a candidate
24 can do with his campaign funds as it relates to the
25 expenses, related to his public office, or for

Page 29
1 campaigning. And if it's not campaigning, then it's
2 not, you know, at least there's a possibility that it
3 may not be a proper campaign expenditure. And there
4 hasn't been an assertion that these are related to his
5 duties as a public officeholder.
6 And so I think there is at least a reasonable
7 question as to the propriety of certain expenses as it
8 relates to whether they should have been made from the
9 county campaign fund.
10 CHAIRWOMAN WILHELM: Okay. Thank you.
11 COMMISSIONER CUNNINGHAM: I would say I'm also
12 a little troubled that we didn't have an affidavit from
13 the defendant. We had verification from his counsel,
14 in terms of defending against some of the claims that
15 were made. And maybe that's -- that affects the way I
16 view it as well.
17 COMMISSIONER CRITES: Well, I mean, there's
18 certainly sufficient evidence, based upon what I've
19 heard this morning, to support a hearing. So I would
20 move that we set this matter for hearing before the
21 Commission on October the 11th, 2018.
22 CHAIRWOMAN WILHELM: Do we want to include the
23 date in that motion?
24 COMMISSIONER CRITES: We don't have to. I
25 mean, I'll be glad to

Page 30
1 CHAIRWOMAN WILHELM: I think it's best not to
3 COMMISSIONER CRITES: Until we have a chance
4 to -- I move that we set the matter for hearing.
5 COMMISSIONER NORMAN: I'll second.
6 COMMISSIONER BEATTY: Well, do you think that
7 we should hear from the parties if they think that they
8 need additional discovery or something like that to
9 prepare for a hearing? Because, you know, a lot of the
10 argument involved lack of evidence, whether to support
11 these allegations or an interpretation of evidence, or
12 they were calling it evidence for the purposes of these
13 hearings, so would that be enough time? Or, you know,
14 given the circumstances, should we hear from them or
15 not?
16 MR. RICHTER: Good point. But does that go to
17 after we have already found that we're going to have
18 the hearing?
19 COMMISSIONER BEATTY: I understand. But it's
20 on the point of if we were going to put the date in the
21 motion.
22 MR. RICHTER: And I think we took
23 COMMISSIONER CRITES: No, I think I changed
24 that.
25 MR. RICHTER: I think he took the date out.

Page 31
1 COMMISSIONER CRITES: I did.
2 COMMISSIONER BEATTY: Okay.
3 MR. RICHTER: And so at this point, we're just
4 looking at -- I agree with you as it relates to that.
5 But I think we're looking at, you know, right now we
6 have a motion before the Commission to have the matter
7 set for hearing. I would encourage the Commission to
8 go forward on that at this point, and then we can hear
9 from the parties as to what the timing should be.
10 CHAIRWOMAN WILHELM: Okay. We also have a
11 second, correct?
12 MR. RICHTER: Correct. Mr. Norman seconded
13 the motion to set it for hearing.
14 CHAIRWOMAN WILHELM: Okay. Is there any other
15 discussion before we have a roll call vote?
16 Okay. Ms. Springer, please?
17 MS. SPRINGER: Commissioner Brommer?
18 COMMISSIONER BROMMER: No.
19 MS. SPRINGER: Commissioner Balcolm?
20 COMMISSIONER BALCOLM: Yes.
21 MS. SPRINGER: Commissioner Nor -- Norman, I'm
22 sorry.
23 COMMISSIONER NORMAN: Yes. It's a toughy, I
24 know.
25 (Laughter)

Page 32
1 MS. SPRINGER: Commissioner Beatty?
2 COMMISSIONER BEATTY: Yes.
3 MS. SPRINGER: Commissioner Crites?
4 COMMISSIONER CRITES: Yes.
5 MS. SPRINGER: Commissioner Cunningham?
6 COMMISSIONER CUNNINGHAM: Yes.
7 MS. SPRINGER: Chairman Wilhelm?
8 CHAIRWOMAN WILHELM: Yes.
9 MR. RICHTER: That motion passes 6 to 1.
10 CHAIRWOMAN WILHELM: All right. So
11 MR. RICHTER: And I appreciate what I am
12 saying, sometimes, you know, as it relates to, you
13 know, what we do here and so forth, and I also
14 appreciate the fact that we could go ahead and ram this
15 on a Commission's upcoming schedule very quickly and
16 then everybody comes in looking for a continuance
17 within short order. I've been doing this long enough
18 to know that's not necessarily out of the ordinary.
19 And so my recommendation for the 11th was,
20 like I said, an initial, in thinking about the
21 Commission's schedule when we're currently before the -
22 - when we're currently scheduled, what's the upcoming
23 election schedule, and the Elections Commission's
24 schedule.
25 Certainly, we have two dates available on the

Page 33
1 Commission's schedule prior to the election should we
2 decide to try to get this done prior to that, which
3 would be October 11th and November 1st. Presumably,
4 either one would work.
5 I appreciate the potential challenges of
6 discovery and all of those things, which Mr. Beatty
7 certainly has just mentioned. You know, I'll leave it
8 to the Commission. And certainly we can hear from the
9 parties to hear their respective positions, if that's
10 what the Commission wishes to do.
11 CHAIRWOMAN WILHELM: Sure.
12 MR. RICHTER: Because the Commission is the
13 one that's obviously in control of its schedule and is
14 the ultimate decider, as it relates to where we go from
15 here.
16 CHAIRWOMAN WILHELM: And I believe often you
17 have these discussions off line with the parties and
18 determine after the meeting or once they've had a
19 chance to figure out what they need to do.
20 MR. RICHTER: Sometimes that's the case. Yes.
21 And, you know, I can go back to, you know, a few weeks
22 ago we had the issue, Issue 1, Issue 2, whatever it
23 was, from last year where they finally came around to
24 working on Motions for Summary Judgment after they
25 you know, we had originally scheduled it for hearing.

Page 34
1 I think we actually had it scheduled for hearing prior
2 to the election then, too. Both parties then came in
3 asking for more time wanting to do discovery, all that
4 kind of stuff.
5 And so, you know, eventually we've got it to a
6 resolution. I think regardless of the -- whether it is
7 heard prior to the election or not, you know, I think
8 that there are serious issues here the Commission needs
9 to consider that the parties should remain interested
10 in and the Commission should remain interested in.
11 CHAIRWOMAN WILHELM: So it's your suggestion
12 that we do hear -- we discuss this now and figure it
13 out now?
14 MR. RICHTER: I would think at least, yeah, I
15 think at least we should hear from the parties, hear
16 what they have to say and then the Commission can go
17 ahead and figure out how it wants to proceed. I have
18 not yet -- I mean, if we're looking at longer term, I
19 have not yet scheduled into next year.
20 CHAIRWOMAN WILHELM: Right.
21 MR. RICHTER: But I will be doing that shortly
22 with all of the -- you know, so you'll get a memo
23 within a week or so, you know, the typical memo that I
24 send as it relates to scheduling. You've seen enough
25 of them through the years, Ms. Wilhelm.

Page 35
1 You know, so we'll do that. But the schedule
2 we have left in 2018, I think there's also November
3 15th, and there is at least one day in December, if not
4 two.
5 COMMISSIONER BROMMER: Yeah, two.
6 CHAIRWOMAN WILHELM: Okay.
7 MR. RICHTER: I think there's two. I just
8 haven't
9 COMMISSIONER BROMMER: The 6th and the 20th.
10 MR. RICHTER: So there you go.
11 CHAIRWOMAN WILHELM: Okay. Why don't we hear
12 from the parties and see how much time you think you'll
13 need for preparation.
14 Mr. Shrive?
15 MR. SHRIVE: On behalf of the Complainant, we
16 are prepared to go forward on October the 11th.
17 MR. SVOBODA: On behalf of the Pureval
18 Respondents, we are not prepared to go forward on the
19 11th. And part of it is I think we need to have some
20 discussion among counsel, you know, on opposing counsel
21 and counsel with -- you know, and Mr. Richter about
22 what the scope of the discovery is going to involve and
23 what the scope of our obligation's going to be
24 involved.
25 So, for example, I don't know from having

Page 36
1 listened to the Commission, specifically what is going
2 to be the object of the hearing to be held. Are we
3 proceeding with respect to the contributions received?
4 Are we proceeding with respect to the disbursements
5 made? Are we proceeding with respect to the
6 documentation in the Venmo accounts, which hasn't even
7 been discussed in this matter?
8 CHAIRWOMAN WILHELM: Right.
9 MR. SVOBODA: So we need to understand the
10 scope of what it is we're expected to produce evidence
l I o n before doing that. So that causes me to think there
12 needs to be some further discussion before we can set a
13 date by which that hearing can occur.
14 CHAIRWOMAN WILHELM: I think that's a fair
15 point. So I think I would request that you discuss
16 this with them in the coming days to figure out a date.
17 MR. RICHTER: I don't --
18 CHAIRWOMAN WILHELM: If the Commission's
19 comfortable with that?
20 MR. RICHTER: Yeah, I don't have any problem
21 doing that.
22 CHAIRWOMAN WILHELM: Okay. All right. So
23 we'll just put the date on hold, but it will be set for
24 hearing.
25 MR. SVOBODA: Thank you, ma'am.

Page 37
1 CHAIRWOMAN WILHELM: Okay.
2 MR. SHRIVE: If I may, I would just ask that
3 this be before the election that we do this; if not the
4 October hearing, then the November hearing.
5 CHAIRWOMAN WILHELM: Okay. That's noted for
6 the record.
7 MR. RICHTER: Thank you very much.
8 MR. SVOBODA: And if I can respond briefly to
9 that Madam Chair? May I?
10 CHAIRWOMAN WILHELM: Uh-huh.
11 MR. SVOBODA: You know, while we want this
12 resolved as quickly as possible and we don't want to
13 delay for delay's purposes, I think we both don't want
14 this to be any sort of sideshow or circus as well
15 that's distorting the decisions that the voters are
16 going to be making in November.
17 So while we don't fear any sort of swift
18 resolution on this matter, on the same token, we don't
19 want this to be an occasion where that's the purpose of
20 this, where this is being used by Mr. Pureval's
21 political adversaries to try to make points against
22 him, regardless of what the law ultimately ends up
23 being determined by the Commission and regardless of
24 the facts.
25 So I would hope that that -- you know, I would

Page 38
1 not view the election as an object for the election's
2 sake. I think this needs to be focused on a proper and
3 correct resolution of the law and the facts.
4 CHAIRWOMAN WILHELM: Thank you. So noted.
5 Okay, very good. Thank you.
8 (Thereupon, the proceeding concluded in this matter
9 at 11:39 a.m.)
10
11
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15
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Page 39
REPORTER'S CERTIFICATE
I, Elegra R. Davis, duly commissioned and
qualified, do hereby certify that the foregoing
proceedings were digitally recorded, electronically
transmitted, and transcribed via audible playback. The
undersigned to hereby certify that the foregoing
transcript of such proceedings is a true and correct
transcript from the electronic sound recording of said
proceedings in the above-entitled matter.
IN WITNESS WHEREOF, I have hereunto set my hand
and affixed my seal of office at Columbus, Ohio, on
this 21st day of September- - - - , 2018.
ELEGRA R. DAVIS,
Certified Digital Court Reporter
and Transcriber and
Notary Public in and for the
State of Ohio.
My commission expires October 5, 2019.

Page 40
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2018G-022 Pureval OEC Prelimary Review Hearing

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2018G-022 Pureval OEC Prelimary Review Hearing

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Page 1

BEFORE THE OHIO ELECTIONS COMMISSION

IN THE MATTER OF:

MILLER CASE NO. 2018G-022

before Chairwoman Degee Wilhelm, and Commission Members

Catherine A. Cunningham, D. Michael Crites, Otto Beatty

III, Dennis Brommer, Helen E. Balcolm, A. Scott Norman

East B, Columbus, Ohio 43215, called at 10:37 a.m. on

Thursday, September 20, 2018.

DAVIS DEPOSITIONS, LLC

Davis Depositions, LLC

FINNEY LAW FIRM

On behalf of Mark W. Miller.

PERKINS COlE, LLP

On behalf of Aftab Pureval, Friends of Aftab Pureval,

On behalf of Aftab Pureval, Friends of Aftab Pureval,

Phillip C. Richter, Executive Director, Ohio Elections

Betty Springer, Administrative Assistant, Ohio

Davis Depositions, LLC

Statement by Mr. Svoboda 15

Statement by Mr. Svoboda 35

Statement by Mr. Svoboda 37

EXHIBITS IDFD ADMITD

Davis Depositions, LLC

3 CHAIRWOMAN WILHELM: Next case is 2018G-022,

Davis Depositions, LLC

2 Mr. Shrive and a certification and some information

3 that was a part of a hearing that the Hamilton County

4 Board of Elections had yesterday. I have not reviewed

6 I'm not sure that it would be appropriate for

7 the Commission to take this late in the process, but

8 they are here. They've been presented. I don't know

9 whether the Respondents have had the opportunity to

10 review them, or go over them, or have anything to do

11 with them, because I haven't had that conversation with

12 the Respondents. But they are here.

13 I would presume that Mr. Shrive will at least

14 attempt to talk about them or hear what the Respondents

15 have to say about that. But that's essentially the

16 case in a nutshell. We can hear from the respective

17 counsel for the respective parties at your leisure.

18 CHAIRWOMAN WILHELM: Okay. Thank you.

19 Mr. Shrive, if you could go ahead and take the

20 podium, please. And we do have a motion before us for

21 permission to appear pro hoc vice from a couple of

22 attorneys for Mr. Pureval. What do we need to do to

23 MR. RICHTER: There is nothing. I talked to

24 the staff at the Supreme Court Attorney Registration

25 Office yesterday, just as a double-check. In leading

Davis Depositions, LLC

2 additional counsel who have come in from Washington,

3 and I informed them that there was additional efforts

4 that needed to be undertaken to be approved to come

5 into Ohio in this matter, which they have done

6 approaching the Supreme Court.

7 As I indicated to them, if you were to go back

8 about 10 years, we regularly accepted people on pro hoc

10 The Commission just kind of said, "Yeah, okay,

11 go ahead and do that."

12 And about two or three years ago, I found out

13 that the Supreme Court had changed their process. And

14 so you can't just do that as an administrative agency

15 or court. There is an obligation for them to go through

16 the Supreme Court to get approval, which they have done