February 21, 2020

Michael C. O’Malley, Esq.

Cuyahoga County Prosecutor’s Office
The Justice Center
1200 Ontario Street, 9th Floor
Cleveland, OH 44113

Dear Prosecutor O’Malley:

I am writing on behalf of my client, the Ohio Democratic Party, to request that your office
investigate and, if warranted, prosecute Darrell Scott, Kareem Lanier, the Urban Revitalization
Coalition, and various currently unknown additional individuals (collectively, the “Conspirators”) for
violating R.C. 3599.01(A) by offering cash in exchange for votes in the 2020 presidential election.
As the evidence attached to this letter shows, the Conspirators have engaged in a scheme to offer
Cuyahoga County residents cash in exchange for supporting Donald J. Trump in the November 2020
general election. Additional crimes are likely to be uncovered as your investigation proceeds,
including potential money laundering and fraud.

Sometime prior to 2019, Scott and Lanier founded the Urban Revitalization Coalition (the
“URC”) as a 501(c)(3) charitable organization. Scott serves as CEO, and Lanier as Co-Chairman. In
2019, the URC put out a “Midterm Report” in which it laid out its goals for 2020. Among the goals
identified was to “increase the 8% African-American vote from 2016 by 25% in the 2020
Presidential Election.” A true and accurate copy of the midterm report is attached as Exhibit A. The
8% number is telling. 59.6% of African-Americans voted in the 2016 election. THOM FILE, VOTING
IN AMERICA: A LOOK AT THE 2016 PRESIDENTIAL ELECTION VOTING IN AMERICA: A LOOK AT THE
2016 PRESIDENTIAL ELECTION (2017), https://www.census.gov/newsroom/blogs/random-
samplings/2017/05/voting_in_america.html (last visited Feb 4, 2020). Exit polls, however, show that
only 8% of African-Americans voted for Trump. Exit Polls 2016, CNN (2016),
https://www.cnn.com/election/2016/results/exit-polls (last visited Feb 4, 2019). The only reasonable
reading of the URC Midterm Report is that the URC explicitly stated the URC’s primary purpose is
increasing Trump’s support among African-American voters.

One of the URC’s major funders is the America First Policies, described as “the nonprofit
arm of a pro-Trump super PAC” by CNN. Chandelis Duster & Maegan Vazquez, A PRO-TRUMP
GROUP HELPED FUND THE NONPROFIT HOLDING CASH GIVEAWAYS TO BLACK ATTENDEES CNN (2020),
https://www.cnn.com/2020/01/30/politics/trump-surrogates-cash-giveaway-black-voters/index.html
(last visited Feb 20, 2020). Last year, CNN reports that America First Policies gave the URC nearly
a quarter million dollars. If this was done to conceal the ultimate source of the funds being used for
illegal campaigning and bribery, it would seem the transfer of funds would constitute money
laundering and/or fraud. We encourage your office to also investigate this contribution and
prosecute, if warranted.

As part of the URC’s strategy to persuade African-American voters to support Donald

Trump, the URC held an event (the “Rally”) billed as a “Christmas Extravaganza” at the Galleria in
Cleveland on December 14, 2019. The Rally’s target audience were residents of low-income
housing, but the Rally was also open to the general public. In case there was any doubt as to the
purpose of the Rally, Scott’s verified Twitter account posted a video of part of the Rally with the
caption “This is how Black folks Pro-Trump events begin.
#UrbanRevitalizationCoalitionCommunityChristmashristmasExtravaganza” A true and accurate
copy of Scott’s tweet is attached as Exhibit B. The Rally included remarks by Donald Trump
surrogates, Lanier, and others. The Rally also featured $25,000 worth of cash giveaways to attendees
in exchange for their support of Trump. The Conspirators collected attendees names and contact
information as they entered the Rally, and Lanier drew names out of bucket at the end of the Rally.
Each attendee whose name was drawn was given an envelope stuffed with between $300 and $1,000
in cash. While the Conspirators did not explicitly state that the cash was an inducement to vote for
Trump, the attendees got the message, with at least one winner shouting “Four more years of Trump!
Yay!” as she claimed her cash-stuffed envelope. The Cleveland Plain Dealer recorded the prize
drawing on video. A true and accurate copy of that video is attached as Exhibit C.

The Conspirators may try to argue that they simply misspoke in their “Midterm Report,” and
that the cash giveaways were actually intended to boost overall African-American turnout. Even if
one were to ignore Scott’s tweet and accept that claim, the Conspirators’ conduct would still
constitute bribery under R.C. 3599.01(A)(3), which states that it is illegal to “[P]ay…or offer to
procure money or other valuable thing to or for the use of another, with the intent that it or part
thereof shall be used to induce such person to vote or to refrain from voting. Violating R.C.
3599.01(A)(3) would still be a fourth degree felony. R.C. 3599.01(B).

The Conspirators may also try to claim that the cash giveaway was not intended to influence
an election at all, but was instead part of the organization’s charitable purpose and was intended to
help low-income housing residents. However, there was no effort to verify that the people receiving
cash-stuffed envelopes were in need of financial assistance, and in some cases, Lanier openly
acknowledged the recipient was financially stable. For instance, when Teresita Jones-Thomas’s
name was called, Lanier shouted that “"She don't need the money. She do not need the money…I
ain't giving her the money! Her son plays for the Golden State Warriors in the NBA! She don't need
the money!” Lanier then proceeded to hand Jones-Thomas a cash-stuffed envelope. Exhibit C.
Jones-Thomas’s son is Taiyier Parks, who does, in fact, play for the Warriors. Lanier did the same
with another attendee, stating that “Lonnie don’t need the money” without further elaboration before
handing a man identified as Lonnie a cash-stuffed envelope. Id. It beggars belief that there is any
charitable purpose in giving Jones-Thomas and Lonnie cash-stuffed envelopes immediately after
stating that neither are in financial need.

Ohio law classifies offering or giving money in exchange for supporting a candidate as
bribery, a fourth-degree felony. R.C. 3599.01(B). In this case, the URC not only offered money for
supporting Donald Trump, they advertised doing so in advance, and put it on video! The
Conspirators have explicitly stated that they intend to encourage African-American voters to support
Donald Trump in the 2020 election, and Scott serves on various pro-Trump political committees. The
Conspirators advertised a pro-Trump rally where attendees would be entered for a chance to get up
to $1,000 in cash, regardless of financial need. The attendees got the message: support Trump and
make some money. One of them even said so on video while accepting her cash.

The Conspirators are flouting Ohio law by offering cash for votes and have announced they
intend to continue their criminal conduct. Your office must send a message that trying to buy votes
will not be tolerated, investigate the Conspirator’s actions and, if warranted, prosecute the
Conspirators under R.C. 3599.01 and any other statutes your office believes are appropriate.

Please do not hesitate to contact me if you should have any questions.

Sincerely,

Zach West

N. Zachary West, Esq.

Of Counsel
O’Connor, Haseley, & Wilhelm LLC