October 17, 2017

Brian Aloia, Esq.

Corporation Counsel
James Farina
City Clerk
City of Hoboken
94 Washington Street
Hoboken, NJ 07030

Via: Hand Delivery

Dear Brian and James

This letter shall serve as an official complaint that the Mike DeFusco for Hoboken Mayor and Team
Defusco for Hoboken campaigns have willingly and intentionally received contributions in breach of the
Citys law codified in Chapter 20D: Political Contribution Limits. According to his ELEC filings on July 17th,
October 10th and October 13th, he lists the following as being received between June and September
2017:

July 17th ELEC for Michael DeFusco for Hoboken Mayor (July 15th ELEC)
- 6/17 Sprinkler Fitters #898, (s/b #696?) Millburn, NJ $600
- 6/17 Sprinkler Fitters #696 Millburn, NJ $600
- 6/17 Pipefitter Local 274 Political Action Committee - UA Parsippany, NJ $1,100
- 6/17 Local Union #164 IBEW Paramus, NJ $5,000
- 6/17 NRCC [National Republican Congressional Committee] Non-Partisan Political Education
Committee Edison, NJ $1,500
- 6/17 B.A.C Administrative District Political Action Committee Bordentown, NJ $1,500
- 6/17 UA Pipefitters 274 Parsippany, NJ $1,700
Subtotal of $12,000.

October 10th ELEC for Team Defusco for Hoboken (29 Day ELEC)
- 9/8 Local Union #464 [Food and Commercial Workers] Cope Account Paramus, NJ $24,600
- 9/11 NJ Association of Pipe trades PAC Account Manalapan, NJ $10,000
- 9/22 NRCC Non-Partisan Political Education Committee Edison, NJ $1,500
- 9/29 NJ Association of Pipe trades PAC Account Manalapan, NJ $20,000
Subtotal of $56,100

October 13th ELEC for Michael DeFusco for Hoboken Mayor (29 Day ELEC)
- 7/27 Local Union #164 IBEW Paramus, NJ $600
- 8/2 UA Plumbers Local 24 West Caldwell, NJ $300 (aggregate listed as $900)
- 8/11 NRCC Non-Partisan Political Education Committee Edison, NJ $1,500
- 8/11 UA Pipefitters Local 274 - Parsippany, NJ $900
Subtotal of $3,300

Total - $71,400
All three ELEC reports are attached for your reference.

Chapter 20D: was adopted in 2011 by ordinance Z-134. The stated purpose was to:

control the use of wheeling to usurp the goals of the New Jersey Campaign Contribution and
Expenditures Reporting Act for elected officials of the City of Hoboken. As a result, the City
hereby enacts this chapter to enforce contribution limits on a local level in an attempt to stifle
wheeling during the City's local municipal elections.

Effectively this chapter states that in Hoboken municipal elections, candidates and committees are
limited to receiving $500 in contributions from committees, as defined, and which includes
PACs. According to 20D-7 Violations and Penalties, if determined that a candidate has willingly
received contributions in excess of this amount, and has not returned the funds within 30 days shall be
liable to a penalty equal to four times the amount of the contribution made. And that any violation of
this chapter shall be noncurable. Although two of the contributions listed are inside of 30 days, they are
the tail end of a pattern of willful and intentional acts to secure large contributions in excess of local
laws. Therefore, applying to fine the entire amounts that were received by both the Mike DeFusco for
Hoboken Mayor Campaign and Team DeFusco Campaign since July 15th, the fine assessed should be
$285,600.

I ask that you investigate this and enforce the statutory code of Hoboken as a matter of urgency as the
amounts received provide a decided, unfair advantage to his campaign in the election for Mayor and
negatively prejudice all of the other campaigns who have honored and upheld this law.

Sincerely,

Tiffanie Fisher
Hoboken City Council, Second Ward

Cc: Mayor Dawn Zimmer

Business Administrator Director Stephen Marks