Campaign Finance Complaint Cover Sheet oa RECEIVED Senet“ sep 27 08 ae jail You must specifically dent violation of Colorado Constitution Article XVI, the Fair Campaign Practices Zet, or the Secretar of State's rules concerning Campaign and Pollial Finance and allege specific facts to ‘support logal and factual bate forthe complaint Denotes required fed ‘Your Information -rfarmation abot the persona ett ing the complaint (complainant) FullName’ Daniel Lee Sapienza Mating Adsress:_ 1301 Cherry Street, Fort Collins, CO 80521 Telephone Number: 970-222-0224 mai Aaaress:_ dan sapienza@ gmail.com Respondents Information - formation abou th person or ety allege to have commited the Viton FuName: Angela Myers | ‘Mailing Address: 205 E. Thunderbird Drive, Fort Collins, CO 08525 Telephone Number: 970-207-0848 Emai/Address:myersclerk@gmail.com Briefly summarize the allegations made in the attached complaint. ‘Angela Myers, Larimer County Clerk and Recorder, violated CRS 1-45-117, prohibiting a subdivision of the state from contributing a thing of value to a candidate for election, by authorizing and providing monthly payments to herself from the county for purposes of funding her campaign cell phone. Since her first candidate affidavit filed in 2073 to campaign literature printed in 2018, Myers has used the county-paid cell phone as the primary point of contact for her election campaign. ‘By submiting this form wih the attached complaint and any supporting evidence, | hereby certify that | am aware of the provedue outlined in Secretary of State Campaign and Poltice! Finance Rue 18.2, scompinnts Signa: Levees te 26 eVComplainant: Daniel L Sapienza Responcent: Angela Myers, Latimer County Clerk and Recordar ‘Complaint Summary ‘This complaint alleges hat Angela Myers, as Larimer County Clerk and Recorder, uses and has used since 2013, a mobile phone funded solely by Larimer County offical funds as the {exclusive phane number of her poltical campaign, in violation of Section 1-86-117 CRS, Prohibiting ay state subdivision from contributing funds to an election campaign ‘Complaint has been ‘ely fled Complainant eared ofthis violation after receipt of ‘Re-elect Angela Myers” printed literature {and contribution envelope, both featuring the phone number in question, on September 12, 2018, Factual Allegations 1 Im 2013, Angela Myers was employed inthe fice ofthe Larmer County Clerk and Recorder Under Clerk Scott Doyle. Myers was Chief Deputy Clerk, delegated with management of the Clerk's office n all matters in the absence of Doyle. {See Atachment 1 - Email from Doyle to Larimer County Commissioners, dated ‘ve9r2013 In 2013, Myers mobile phone number was 970-227-0348, used in official communications to roach Myers urgent situations ‘a. See Atachment 1 - Email from Doyle to Larimer County Commissioners, dated 112972013 and , Attactment 2 - Emall From Myers to BOCC with signature block inckading cell number, dated 4/1/2013, 1n20'3, the phone with number 970-227-0348 was paid for by Larimer County through the county wicslss device reimbursement program in the amount of $111 par month, $1,932 per year. a. See Atachment 3-2013 Reimbursement Form, submited on 12/19/2012 In May 2013, angela Myers was appointed as Cierk and Recorder by the Larimer Board of County Commissioners. (On October 4 2013, Myers filed a Candidate Affidavit with the Colorado Secretary of State for the 2014 elecion, isting the phone number 970-227-0348 as the candidate's phone. 8, See Atachment 4 2018 Candidate Affidavit for Angela Myers, submited 1014/2013, (On October 4 2013, a campaign event for Angela Myers took place, hosted by the Larimer County Republican Party. The phone number 970-227-0348 was posted for RSVPs, ‘a. Seo Atachment 5 - Screenshot of Facebook Event dated 10/4/20137. On October 7, 2013, Myers campaign fled @ Commitee Registration Form with he Colorado ‘Secretary of State, isting 970-227-0348 asthe candidate committee phone. ‘a, See Atachment 6 - 2013 Committee Registration Form, submitted 10/27/2013, 8. Betwaon 2013 and 2017, Myers was reimbursed between $1,320 to $1,440 par year for phone number 970-227-0348 by Larimer County ‘a. See Atachment 7 List of annual payments from Larimer County to Angela Myers, receive from the Larimer County Human Resources Departmen! on September 2, 2018 trough CORA Request 9. Between 2013 and 2017, including during her election campaign of 2074, Myers used phone ‘number 970-227-0348 on re-election materials (printed and aga communications and all flings withthe Colorado Secretary of State) and on oficial communications as Clerk and Recorder (n email signature, on press releases from Clerk, and on Larimer County website) 10. On Novambe' 13, 2017, Myers renewed her application with Larmer County for reimbursement for cell phone 970-227-0348 at arate of $120 per month forthe year 2018. AS of September, 2018, Myers has been paid $1,080 forthe year ‘2. See Atachment 7 List of annual payments from Larimer County to Angela Myers, receive from the Larimer County Human Resources Department on September 21 2018 rough CORA Request and b._Allactment 8 - 2018 Reimbursement Form, submitted 11/13/2017 11. On January 22, 2018, Myers fila a candidate affidavit for Clerk and Recorder for the 2018 election, using 970-227-0348 as the candidate and committee phone number. ‘a. See Atachment 9 - 2018 Candidate Affidavit for Angela Myers, submited 12, Printed campaign Itorature to re-elect Myers inthe 2018 election feature 970-227-0348 as her contact information. ‘a, See Aitachment 10 - Photo of printed election campaign iterature and '._Attactment 11 - Photo of printed contribution envelope 13, n September 2018, Myers website and a digital invitation to an August campaign event sts 970-227-0348 as the phone number to RSVP. ‘a, See Altachment 12 Screenshot of www slectangslamvers.com and »._Allactment 13 -Photo of campaign event invitation posted to Facebook by Angela Myers 14, 2018 omaile om Myore tothe BOC and other aia continue te feature 970-227 0248, ‘a. See Atachment 14 - Screenshot of emall from Angela Myers to BOCC, dated June 15, 2018 15, No campaign finance reports filed with the Colorado Secretary of State between 2013 and ‘September 2018 lst payments from Larimer County forthe cellphone used for campaign purposes. 18, As of Seplember 26, 2018, 970-227-0348 remains the phone numberof record for both the Campaign to Reelact Angela Myers and the cell contact forthe oes ofthe Larimer County Clerk and Revorder. ‘8, See Atachment 15 - Business Card received atthe office ofthe Clerk on September 26, 2018 displaying cll phone number 970-227-0348 Reimbursement fr Wireless Device Constitutes @ Prohibited Contribution