Cacioppo Complaint Full Package 11oct16

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Campaign Finance Complaint

Re: Michael Joseph Cacioppo, Republican Candidate for Colorado House District 26
O2 October 2016
FACTS IN EVIDENCE:
1) There are two 2016 active candidates for Colorado House District 26, representing Eagle and Routt
counties (see Exhibit A).
Democrat Diane Mitsch Bush
Republican Michael Joseph Cacioppo
2) Michael Joseph Cacioppo is the registered agent controlling Business Briefs, a monthly mass media
publication sponsored by advertising with extensive free distribution in Eagle County, 10,000 copies
provided at over 900 locations. (see Exhibit B).
3) Business Briefs has recently printed a range of material relevant to the 2016 election for Colorado
House District 26.
Comment on Diane Mitsch Bush Financial support on 28 July 16 (Exhibit C)
Letter to Editor supporting Michael Cacioppo (Ye old publisher) on 28 July (Exhibit D)
Comment on Diane Mitsch Bush Campaign on 29 Sept 16 (Exhibit E)
Comment on Diane Mitsch Bush conduct on 29 Sept 16 (Exhibit F)
4) The four placements cover approximately 1.22 pages of material. At the normal commercial
advertising rate of $450 per half a page this would cost approximately $1,098.
5) The five financial reports filed by the Committee to Elect Michael Capioppo with the Colorado
Secretary of State from June 13, 2016 to September 19 2016, do not include any contributions, in
kind, or expenditures related to this promotional activity in the Cacioppo owned Business Briefs.
(See Exhibit G).
LEGAL GUIDELINES
This activity is specifically prohibited in the Colorado Constitution, Article XXVIII (Exhibit H).
Section 2 (8) defines expenditure as any purchase, payment, or advance for the purpose of
expressly advocating the election or defeat of a candidate. Section 2(8)(b) states that this does not
apply to news, articles, editorial endorsement, letters, or commentary in a newspaper, magazine, or
other periodical not owner or controlled by a candidate or political party. As Business Briefs is
controlled by Michael Capioppo, it would not fall under this exception.
Section 5(3) states that any expenditure that is coordinated with or controlled by a candidates or
a candidates agent shall be considered a contributions to the candidates committee.
CONCLUSION
As the placement of material supporting Michael Capioppos candidacy in Business Briefs has not been
reported as in kind contributions or paid for with campaign funds, the spirit and letter of the law has not
been observed.
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List of Exhibits
A
2016 General Election Candidates for Colorado House District 26
Documentation of Michael Joseph Cacioppo as Principle Agent representing Business Briefs
Business Briefs Presentation of 28 July 16 on Diane Mitsch Bush financial support
Business Briefs Letter to Editor of 28 July 16 Supporting Publisher (AKA Michael Cacioppo)
Business Briefs Opinion of 29 Sept 16 on Diane Mitsch Bush Campaign
Business Briefs Comment of 29 Sept 16 on Diane Mitsch Bush
Financial Reports filed by committee to Elect Michael Capioppo
Relevant Sections of Colorado Constitution Article XXVIII
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2016 General Election Candidates for Colorado House District 26
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Documentation of Michael Joseph Cacioppo as Principle Agent

representing Business Briefs
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Business Briefs Presentation of 28 July 16 on Diane Mitsch Bush financial

support
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Business Briefs Letter to Editor of 28 July 16 Supporting Publisher (AKA

Michael Cacioppo)
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Business Briefs Opinion of 29 Sept 16 on Diane Mitsch Bush Campaign
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Business Briefs Comment of 29 Sept 16 on Diane Mitsch Bush
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Financial Reports filed by committee to Elect Michael Capioppo
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Relevant Sections of Colorado Constitution Article XXVIII
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Cacioppo Complaint Full Package 11oct16

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Cacioppo Complaint Full Package 11oct16

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10/3

Campaign Finance Complaint

2016 General Election Candidates for Colorado House District 26

Documentation of Michael Joseph Cacioppo as Principle Agent representing Business Briefs

Business Briefs Presentation of 28 July 16 on Diane Mitsch Bush financial support

Business Briefs Opinion of 29 Sept 16 on Diane Mitsch Bush Campaign

Business Briefs Comment of 29 Sept 16 on Diane Mitsch Bush

Financial Reports filed by committee to Elect Michael Capioppo

Relevant Sections of Colorado Constitution Article XXVIII

2016 General Election Candidates for Colorado House District 26

Documentation of Michael Joseph Cacioppo as Principle Agent

Business Briefs Presentation of 28 July 16 on Diane Mitsch Bush financial

Business Briefs Letter to Editor of 28 July 16 Supporting Publisher (AKA

Business Briefs Opinion of 29 Sept 16 on Diane Mitsch Bush Campaign

Business Briefs Comment of 29 Sept 16 on Diane Mitsch Bush

Financial Reports filed by committee to Elect Michael Capioppo

Relevant Sections of Colorado Constitution Article XXVIII

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