21-02-cd dunbar for mayor v. alaskans for change - bronson

21-02-CD Dunbar for Mayor

v. Alaskans for Change - Bronson

Presented by:

Tom Lucas

Campaign Disclosure Coordinator

BEFORE THE ALASKA PUBLIC OFFICES COMMISSION Dunbar for Mayor, Complainant, vs. Alaskans for Change - Bronson, Respondent.

) ) ) ) ) ) ) ) ) ) )

Case No. 21-02-CD

NOTICE OF HEARING AND PROCEDURAL ORDER

A hearing in this case will take place before the Alaska Public Offices Commission at

approximately 1:15 p.m. on Wednesday, September 29, 2021.

The Commissioners will be present via Webex and will receive evidence regarding this matter.

You may attend the hearing either by telephone (1-650-479-3207, Access Code: 24648241379#,

Meeting Password: 37494594#), in-person (2221 E. Northern Lights Blvd, Ste 128, Anchorage,

Alaska, 99508), or online via Webex.1 You may be, but are not required to be, represented by an

attorney or agent.

If you wish to participate by telephone and are an individual who requires a special

accommodation to participate, you must advise the Commission office on or before

September 20, 2021, so that a special accommodation can be made.

PREHEARING AND HEARING PROCEDURES

1) Parties. The parties in this case are Commission Staff and Respondent.

2) Issues. At the hearing, the Commission will consider whether the Respondent failed to comply

with AS 15.13 by failing to register with the Commission prior to making expenditures for the

2021 Anchorage Municipal Runoff election.

1 Please contact APOC if you would like to attend using Webex. Webex meeting invitation will be sent via email.

Notice of Hearing and Procedural Order Page 2 21-02-CD, Dunbar for Mayor v. Alaskans for Change - Bronson

3) Procedural history. Dunbar for Mayor filed a complaint on April 29, 2021. Respondent filed

an Answer denying the allegations of the Complaint on May 7, 2021. Staff’s investigation

report recommending that the Complaint be dismissed was issued on June 29, 2021.

Respondent filed a response to the staff report on July 6, 2021.

4) Hearing procedures. The hearing will be conducted as provided in AS 15.13.380,

2 AAC 50.891, and the Alaska Administrative Procedure Act, AS 44.62.330 – 44.62.630. All

testimony must be presented or submitted under oath. A party may call witnesses, cross-

examine witnesses, present and rebut evidence. If the respondent does not testify, the

respondent may be called and examined as if under cross-examination.

5) Evidence and exhibits. All relevant evidence may be admissible at the hearing. In passing

upon the admissibility of evidence, the Commission may consider, but is not bound to follow,

the rules of evidence governing general civil proceedings in the courts of the State of Alaska.

The Commission may exclude inadmissible evidence and order repetitive evidence

discontinued.

6) Prehearing filings. No later than September 17, 2021, a party:

a) may file a list of witnesses expected to testify at the hearing;

b) may file copies of exhibits to be presented at the hearing that are marked and identified (for

example, Resp.’s Ex. A);

c) may file a prehearing memorandum;

d) may file prehearing motions, including motions to dismiss, for summary judgment, or to

exclude evidence, and

e) shall serve all parties and the Complainant with filings submitted.

7) Response to motions and requests for subpoenas. No later than September 23, 2021, a party

a) may respond to a motion; and

b) may request the Commission to issue subpoenas to compel the attendance of witnesses, the

production of documents, or other things related to the subject of the hearing, and is

responsible for serving the subpoena and paying the appropriate witness fee.

8) Extensions of time. Requests to extend the deadlines in this order must be in writing, filed

with the Commission, served on all parties and the Complainant, and supported by good cause.

9) Burden of proof. The Commission staff has the burden to prove any charges by a

preponderance of the evidence.

Notice of Hearing and Procedural Order Page 3 21-02-CD, Dunbar for Mayor v. Alaskans for Change - Bronson

10) Order of proceedings. Matters considered at a hearing will ordinarily be disposed of in

substantially the following order:

a) pending motions, if any;

b) complainant may present argument under 2 AAC 50.891(d)

c) presentation of cases as follows, unless otherwise ordered by the Commission:

i) The Commission Staff’s direct case, including the investigative report, evidence, and

testimony of witnesses;

ii) Respondent’s direct case;

iii) Rebuttal by the Commission Staff; and

iv) Closing statements, if any, by Respondent and Commission Staff.

10) Decision and Order. The Commission will issue an order no later than 10 days after the close

of the record.

Dated: September 9, 2021 ___________________________________ Heather Hebdon, Executive Director Alaska Public Offices Commission

CERTIFICATE OF SERVICE I hereby certify that on this date, I caused a true and correct copy of the foregoing to be delivered as indicated to the following:

Paula DeLaiarro Forrest Dunbar for Mayor P.O. Box 211686 Anchorage, Alaska 99521 [email protected]

Email Certified Mail

Thomas Amodio Reeves Amodio, LLC 500 L. Street, Suite 300 Anchorage, Alaska 99501 [email protected]


Signature Date

raferguson

Typewritten Text

09/10/2021

raferguson

Typewritten Text

9171-9690-0935-0265-9866-27 9171-9690-0935-0265-9866-34

From: Paula DeLaiarroTo: Lucas, Tom R (DOA); Stormont, Charles R (DOA); Odena, Jacqueline S (DOA)Subject: Request re 21-02-CD HearingDate: Tuesday, September 14, 2021 11:31:29 AM

Mr Lucas, I am requesting to be designated a Party to the 21-02-CD hearing on 9/29/21 inorder to prevent a recurrence of the situation during the Pruitt hearing in which I wasprevented from answering questions from the Commissioners due to Counsel's objectionthat I was not a Party to the proceedings. In the interest of information exchange, Commissioners should be allowed to question me and I should be allowed to respond as wellas comment, not only after my own presentation but after the Respondent's and the APOCStaff Report.

Thank you.

Paula DeLaiarro

-- Paula DeLaiarro(907) 441-1935

mailto:[email protected]




From: Tom AmodioTo: Paula DeLaiarro; Ferguson, Rachel A (DOA)Cc: Lucas, Tom R (DOA); Odena, Jacqueline S (DOA); Stormont, Charles R (DOA); StaffSubject: RE: Notice of Hearing and Procedural OrderDate: Tuesday, September 14, 2021 2:11:44 AM

Although we do not believe that Ms. DeLaiarro’s request requires any response from us, since she isnot and cannot be a party to this proceeding, we want to let you know that Respondent objects toher request. There is no basis in the applicable statutes or regulations to allow a complainant tobecome a party, and we object to any attempt to make her one.Regards, Tom Amodio Thomas [email protected] main phone907.222.7104 direct phone907.222.7199 fax

-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-REEVES AMODIO LLC

CONFIDENTIAL ATTORNEY-CLIENT COMMUNICATION.IF YOU RECEIVED THIS E-MAIL MESSAGE BY MISTAKE, PLEASE DO NOT READ IT.

REPLY TO SENDER AND DELETE THIS MAIL.THANK YOU.

-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-

From: Paula DeLaiarro <[email protected]> Sent: Saturday, September 11, 2021 11:23 PMTo: Ferguson, Rachel A (DOA) <[email protected]>Cc: Tom Amodio <[email protected]>; Lucas, Tom R (DOA) <[email protected]>; Odena,Jacqueline S (DOA) <[email protected]>; Stormont, Charles R (DOA)<[email protected]>Subject: Re: Notice of Hearing and Procedural Order I would like to attend this hearing via Webex. Kindly send me a meetinginvitation. I would also like to request to be made a Party in this case. Thank you. On Fri, Sep 10, 2021 at 12:17 PM Ferguson, Rachel A (DOA) <[email protected]> wrote:

Good Afternoon, Please find the attached document(s) being issued to you from the Alaska Public OfficesCommission. You will receive physical copies as indicated within the attachment.










Please note if there are any timeframes established to take action within these documents. Should you have any questions, please contact our office. Thank you, Rachel FergusonLaw Office Assistant IAlaska Public Offices Commission2221 E. Northern Lights Blvd STE 128Anchorage, AK 99508Phone: (907) 276-4176Toll-Free: 1-800-478-4176Fax: (907) 276-7018 CONFIDENTIALITY NOTICE: This communication with its content and anyattachments may contain confidential and/or legally privileged information.It is solely for the use of the intended recipient(s). Unauthorized interceptionreview, use, or disclosure is prohibited and may violate applicable lawsincluding the Electronic Communications Privacy Act. If you are not theintended recipient, please contact the sender and destroy all copies of thecommunication.

--Paula DeLaiarro(907) 441-1935

Department of Administration

ALASKA PUBLIC OFFICES COMMISSION

2221 E. Northern Lights Blvd., Rm. 128 Anchorage, AK 99508-4149

Main: 907.276.4176 Fax: 907.276.7018

www.doa.alaska.gov/apoc

TO: APOC Commissioners DATE: June 29, 2021 FROM: Jacqueline Odena, Paralegal I SUBJECT: Staff Report, 21-02-CD, Dunbar for Mayor v. Alaskans for Change - Bronson

SUMMARY OF COMPLAINT

In its Complaint filed on April 29, 2021, Forrest Dunbar for Mayor alleges that

Alaskans for Change – Bronson (AFCB) violated AS 15.13 by failing to register with the

Alaska Public Offices Commission (APOC) prior to making its first expenditures during

the 2021 Anchorage Municipal Runoff Election.1

SUMMARY OF ANSWERS TO COMPLAINT

On May 7, 2021, AFCB filed an answer to the complaint in which it contended: (1)

it was registered under a slightly different name with the Commission prior to making any

expenditures; and (2) the expenses in question were not required to be reported to APOC

as they were incurred for corporate and organizational reason to ensure AFCB was properly

formed in accordance with applicable Alaska law and registered with APOC.2 As such,

AFCB asserts that the complaint should be dismissed.

BACKGROUND

The Municipality of Anchorage held a regular municipal election on April 6, 2021,

where the city’s mayoral office seat was up for election.3 As no mayoral candidate secured

more than 45% of the votes cast, a runoff election was scheduled to take place on May 11,

1 Exhibit 1, Complaint. 2 Exhibit 2. Answer to Complaint and Motion to Dismiss. 3 Exhibit 3. Notice of Vacancy

2021, between the top two candidates, David Bronson and Forrest Dunbar.4 The runoff

election result was certified on May 15, 2021, where the majority of voters voted for David

Bronson to be the next mayor of Anchorage.5

FACTS

A. Registration

AFCB is a limited liability corporation that was organized on November 5, 2020,

under NAICS Code 813940 – Political Organizations.6 AFCB subsequently registered as

an entity with APOC on November 25, 2020, with a purpose of “supporting balanced and

business-friendly candidates.”7 Filing as an entity appears to have been a mistake inasmuch

as AFCB consists of two or more individuals with a principal purpose of influencing the

outcome of elections.8 No campaign disclosure reports were filed under AFC’s entity

registration.

On April 27, 2021, AFCB filed as an independent expenditure group with the

purpose to “elect a conservative mayor to public office”.9 The registration indicated AFCB

planned on campaigning in the 2021 Anchorage municipal runoff election where more than

one-third of its total spending would be spent supporting candidate David Bronson.

Accordingly, on April 28, 2021, AFCB amended its registration to update its group name

to “Alaskans for Change – Bronson” as required by AS 15.13.050(b).10

B. Expenses Paid

AFCB filed its first independent expenditure report on April 28, 2021.11 The report

disclosed three payments made to Reeves Amodio, LLC on February 9, March 12, and

March 31, 2021 for attorney fees; all made prior to AFCB registering as a group instead of

4 Anchorage Municipal Charter Section 11.02(b); AMC 28.20.010C. If no mayoral candidate receives more than 45%

of the votes cast for mayor, a runoff election must be held within three weeks of election certification between the top two candidates who received the highest number of votes.

5 Exhibit 4. Municipality of Anchorage Election Summary Report, Official Results. 6 Exhibit 5. Articles of Incorporation. 7 Exhibit 6. Alaskans for Change Entity Registration. 8 AS 15.13.400(9). 9 Exhibit 7. Alaskans for Change Group Registration. 10 Exhibit 8. Alaskans for Change – Bronson Amended Group Registration; AS 15.13.050(b). 11 Exhibit 9. Alaskans for Change Independent Expenditure Report filed April 28, 2021.

an entity.12 AFCB also reported a $43,000 payment to Cabildo Strategy Services, LLC on

April 27, 2021 for its website and digital ad creation, production, and placement.13

A majority of the February 9, 2021, payment for attorney fees was incurred from

September 18, 2020, to November 18, 2020 for “work [that] consisted of giving advice and

other work related to the creation and operation of a corporation or other organization in

Alaska. We assisted in the corporate formation of a limited liability company.”14

AFCB then incurred additional attorney fees on November 19, 2020, November 30,

2020, and December 2, 2020 to Reeves Amodio, LLC for “work [that] consisted of giving

advice and other work related to corporate matters… also involved assisting in getting the

entity registered with APOC” which accounted for the remainder of the February 9, 2021

payment and for the entirety of the March 12, 2021 payment.15

The March 31, 2021, payment was incurred for legal services provided from January

1, 2021 to January 26, 2021 for “giving advice, responding to questions, and other work

relating to APOC reporting requirements and related matters.”16

LAW AND ANALYSIS

A. Expenses Incurred to Reeves Amodio are not Expenditures

Under AS 15.13.400, expenditure “means a purchase or transfer of money or

anything of value, or promise or agreement to purchase or transfer money or anything of

value, incurred or made for the purpose of influencing the nomination or election of a

candidate…”17

Moreover, an independent expenditure is defined as

an expenditure that is made without the direct or indirect consultation or cooperation with, or at the suggestion or request of, or with the prior consent of, a candidate, a candidate’s campaign treasurer or deputy treasurer, or another person acting as a principal or agent of the candidate.18

12 Exhibit 9. Alaskans for Change Independent Expenditure Report filed April 28, 2021. 13 Id. 14 Exhibit 10. Questions to and Responses from Tom Amodio. 15 Id. 16 Id. 17 AS 15.13.400(7)(A)(i). 18 AS 15.13.400(11).

With limited exception, every person who makes an independent expenditure must

file an independent expenditure report with APOC disclosing expenditures made and

contributions received.19 Unless the expenditure is made within nine days before an

election, an independent expenditure must be filed within 10 days after the expenditure is

made.20

The controlling phrase in this case is “made for the purpose of influencing… the

election…” As set forth below, incurring attorney fees for the purpose of influencing the

outcome of an election is by definition an expenditure, but incurring attorney fees for any

purpose other than influencing the outcome of an election is not generally regulated under

AS 15.13. Thus, at issue is (1) whether all the attorney fee expenses in this case were made

for the purpose of influencing the outcome of an election; and (2) if some or all are not,

whether campaign funds may be used to pay them.

In advisory opinion 890127-CD, State Representative Curt Menard asked the

Commission to advise whether contributions used to pay legal fees incurred in a suit to

defend his right to remain on the primary ballot were subject to campaign disclosure law.21

There, APOC advised Rep. Menard that because the funds were not intended to influence

the outcome of the election but were instead personal debt incurred in a civil suit, they were

not reportable.22

In advisory opinion 960311-CD, the nonprofit organization, Home and Landowners

Organization (HALO), intended to raise and spend money to file suit against the Anchorage

municipality to remove a ballot measure from the ballot and, should the lawsuit fail, use

the remaining funds raised to campaign against it.23 The solicitation of funds had two

purposes: primarily to pay for the lawsuit and secondarily to influence the outcome of the

ballot measure. There, the Commission advised that if the funds were to pay for the lawsuit

only, and not to influence the results of an election, then no registration or reporting

19 AS 15.13.040(d). The exception is for an individual acting independently of any other person and if the expenditures

do not cumulatively exceed $500 within a calendar year for billboards, signs, or other printed material concerning a ballot proposition. AS 15.13.040(h).

20 AS 15.13.110(h). 21 AO 890127-CD (Menard) (available at https://aws.state.ak.us/ApocReports/Paper/Download.aspx?ID=5554). 22 Id. 23 AO 960311-CD (HALO) (available at https://aws.state.ak.us/ApocReports/Paper/Download.aspx?ID=5485).

https://aws.state.ak.us/ApocReports/Paper/Download.aspx?ID=5554


requirements would be triggered.24 The Commission further advised, however, that should

HALO’s suit fail and remaining funds were instead used to influence the subsequent ballot

measure election, then it would be required to register and report as a group before making

a campaign expenditure.25

Further, in advisory opinion 19-03-CD, the nonprofit corporation, Alaska Cabaret,

Hotel, Restaurant and Retailers Association (CHARR), commissioned an opinion poll to

ascertain the public’s view of a ballot proposition to help determine if it would expend

resources to influence the outcome of the proposition. In requesting an advisory opinion,

CHARR and asked the Commission whether the opinion poll expenditure needed to be

reported.26 There, APOC advised that because the expenditure was not made for the

purpose of influencing the outcome of the ballot proposition, it was not an expenditure that

required registration and reporting. However, APOC did advise that should CHARR

choose to engage in activities intended to influence the outcome of the proposition based

on the results of the poll, and/or use the polling information to guide its campaign efforts,

then the polling expenditure would need to be reported.27

Finally, in advisory opinion 12-17-CD, candidate for state house, Barbara

Bachmeier, asked the Commission for an opinion on whether she could use campaign

contributions to pay for her legal fees associated with a residency challenge to her

candidacy for office.28 There, the Commission concluded that legal fees related to a

campaign challenge were reasonably related to the campaign. As such, the Commission [or

APOC] advised Bachmeier that she could establish a separate legal fund, disburse unused

campaign contributions to a legal fund in accordance to AS 15.13.116(a)(6), or pay for the

legal fees out of her campaign account directly because the expense was reasonably related

to her campaign.29

1. Attorney fees incurred for incorporation are not expenditures.

24 AO 960311-CD (HALO) (available at https://aws.state.ak.us/ApocReports/Paper/Download.aspx?ID=5485). 25 Id. 26 AO 19-03-CD (Alaska CHARR) (available at https://aws.state.ak.us/ApocReports/Paper/Download.aspx?ID=19068) 27 Id. 28 AO 12-17-CD (Bachmeier) (available at https://aws.state.ak.us/ApocReports/Paper/Download.aspx?ID=8755). 29 Id.




This complaint also involves expenses not explicitly made for the purpose of

influencing the outcome of an election. Specifically, attorney fees related to the creation

and operation of a corporation. A primary purpose of incorporating is to limit the liability

of the corporation’s participants. A group is not required to incorporate by any means, but

it may do so if its participants desire to limit their liability while still remaining a group.30

Here, because the attorney fees incurred were for a purpose other than to influence the

outcome of an election, AFCB was not required to register or file an independent

expenditure report.

2. Attorney fees incurred for general APOC advice are not expenditures.

Attorney fees incurred for assistance concerning APOC registration receiving

advice and answers to questions concerning APOC law, and other assistance relating to

APOC reporting requirements might be considered a different matter if the investigation

revealed evidence that the advice given pertained to candidate strategy or if the legal

services included the drafting of candidate communications or the like. However, staff’s

investigation revealed no such evidence. Instead, the investigation revealed that AFCB

simply sought and received advice concerning compliance with APOC statutes and

regulations – something APOC staff does for groups and candidates regularly. Therefore,

because the attorney fees incurred by AFCB were for a purpose other than to influence the

outcome of an election, AFCB was not required to register with APOC or file an

independent expenditure report.

3. AFCB may use campaign funds to pay the attorney fees incurred.

AFCB used campaign funds to pay the attorney fees incurred in this case. Under AS

15.13.112(a), campaign contributions held by a group may only be used to pay the expenses

of the group and expenses that reasonably relate to the group’s election campaign activities.

Here, consistent with the commission’s decision in 12-17-CD, the attorney fees incurred

for AFCB’s incorporation were legitimate expenses of the group. Moreover, attorney fees

AFCB incurred for legal advice on compliance with Alaska campaign disclosure law were

legitimate expenses reasonably related to election campaign activities.

30 AO 97-08-CD (Republican Party of Alaska) Part 2. (available at

https://aws.state.ak.us/ApocReports/Paper/Download.aspx?ID=4721).


4. Cabildo Strategy Services, LLC

Cabildo Strategy Services, LLC (CSS) sent AFCB a proposal for an ad campaign

for the 2021 Anchorage municipal runoff election on April 16, 2021.31 Subsequently, CSS

submitted an invoice to AFCB on April 26, 2021.32 AFCB did not enter into an agreement,

nor did it have an obligation to pay CSS until it accepted CSS’s proposal. AFCB accepted

the proposal by paying the April 26th invoice on April 27, 2021.33 While the proposal

included ad concepts created by CSS for a pitch, CSS informed staff that doing so is

customary in political consulting and is done at the consultant’s own risk.34 Therefore,

AFCB timely reported the independent expenditure on its April 28, 2021 report.

The complaint alleges that AFCB updated a domain registration for the website

AlaskansForChange.com on October 21, 2020.35 AFCB’s April 27, 2021, expenditure to

CSS is detailed as “Digital Ad Creation & Production, Placement of Digital Media Ad &

Website”.36 In response, AFCB asserts it did not have a website or web domain, nor did it

develop any for the 2021 municipal runoffs.37 Indeed, in its investigation staff found no

evidence to show that AlaskansForChange.com”, created on July 21, 2008 belonged to

AFCB.38

B. Registration Before Expenditure

“Before making an expenditure in support of or in opposition to a candidate…each

person, other than an individual” must register with APOC.39

Both AFCB’s entity registration and group registration show its principal purpose

was to influence the outcome of an election. The entity registration states its purpose is to

support “balanced and business-friendly candidates” while its group registration states its

31 Exhibit 11. Responses regarding Cabildo Strategy Services, LLC; Exhibit 12. Proposal from Cabildo Strategy

Services, LLC. 32 Exhibit 13. Cabildo Strategy Services, LLC Invoice. 33 Ex. 11. 34 Exhibit 14. Letter from Preston Robinson, Cabildo Strategy Services, LLC. 35 Ex. 1. 36 Ex. 9. 37 Ex. 11. 38 Exhibit 15. WhoIs Domain Information for “AlaskansForChange.com”. 39 AS 15.13.050.

purpose is to “elect a conservative mayor to public office.”40 Despite incorporation, AFCB

apparently recognized it met the statutory definition of group and should have first

registered as an independent expenditure group. Regardless, AFCB’s November 25, 2020,

registration satisfies the requirements of the statute.41 Yet, because staff has concluded that

the attorney fees incurred by AFCB were not expenditures, AFCB was not required to

register until it incurred advertising expenses with Cabildo Strategies. Since this expense

was incurred on April 27, 2021, AFCB satisfied the registration requirement by both its

November 25 registration as an entity and its April 27, 2021 registration as a group.

CONCLUSION

Staff concludes that all allegations of the complaint should be dismissed because

the attorney fees paid were not expenditures that would trigger a registration or reporting

requirement and because AFCB otherwise timely reported its expenditures.

I hereby certify that on this date, I caused a true and correct copy of the foregoing to be delivered as indicated to the following: Thomas Amodio Reeves Amodio LLC 500 L Street, Ste 300 Anchorage, Alaska 99501 [email protected]


Paula DeLaiarro Forrest Dunbar for Mayor PO Box 211686 Anchorage, Alaska 99521 [email protected]


Signature

40 Ex. 6, and Ex. 7. 41 AS 15.13.050(a) simply requires registration on forms provided by the commission.

06/29/2021

9171-9690-0935-0265-9745-87

9171-9690-0935-0265-9745-94



APR 29 2021

Exhibit 1 Page 1 of 11

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21-02-CD

MAY 07 2021


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MUNICIPALITY OF ANCHORAGE REGULAR ELECTION OF APRIL 6, 2021

NOTICE OF VACANCIES

Notice is hereby given that the following offices will be filled at the Regular Municipal Election on APRIL 6, 2021. The period in which to file a declaration of candidacy will open JANUARY 15, 2021 at 8:00 a.m. and will close JANUARY 29, 2021 at 5:00 p.m. Candidate filing forms are available online at www.muni.org/elections. Forms are also available at the Municipal Clerk’s Office, City Hall, 632 W. 6th Avenue, Suite 250, Anchorage, Alaska 99501 and at the MOA Election Center, 619 E. Ship Creek Avenue, Door D Entrance, Anchorage, Alaska 99501.

On JANUARY 14, 2021, at 1:00 p.m. at the Election Center (619 E. Ship Creek Avenue, Door D), the public is invited to witness the random drawing of letters of the alphabet by the Municipal Clerk, which will determine the order candidates' names will appear on the 2021 Regular Municipal Election ballot. Face masks and social distancing are required.

The Municipal Clerk’s Office believes it is important to vote in local elections because doing so impacts a citizen’s quality of life. The Regular Municipal Election on April 6, 2021 is a Vote at Home (or Vote by Mail) election where qualified registered voters will be mailed a ballot package. Traditional polling locations are no longer an option. Why did Anchorage change to a Vote at Home (or Vote by Mail) system? A group of stakeholders recommended voting at home because it is more convenient for Anchorage voters, including voters who are elderly or disabled, work long hours in child care or the medical field, work on the slope, are deployed in the military, or are out of state at college. Voting at home keeps regular voters engaged while at the same time encourages new voter participation. Voters receive their ballot package in the mail 21 days before Election Day and have time to study the candidates and propositions on the ballot, in order to make well-informed decisions. Voters may return their voted ballot to one of 18 secure drop boxes, to an Anchorage Vote Center, or by mail with first-class postage. Questions about the election may be directed to MOA Elections by calling the Voter Hotline at 907-243-VOTE (8683), emailing [email protected], or visiting muni.org/elections.

To vote in a Municipal Election, you must be registered to vote: it is imperative to update your voter registration to reflect where you currently reside. The deadline for voter registration, including updates, for the current election is Sunday, MARCH 7, 2021. Make sure your vote counts by updating your voter registration to ensure you receive the correct ballot in the mail for your current residence address.

A candidate elected on April 6, 2021, will be elected to a three-year term expiring upon certification of the Regular Municipal Election in April 2024, unless otherwise noted.

MAYOR

Areawide One person to be elected. A three-year term, expiring June 30, 2024.

A candidate for mayor must be a qualified voter of the Municipality of Anchorage and of the State of Alaska and shall have been a resident of Anchorage for at least two (2) years immediately preceding this election. Election is areawide.

SCHOOL BOARD

Seat B One member to be elected. To complete one (1) final year of a three-year term, expiring upon certification of the Regular Municipal Election in April 2022.

Seat E One member to be elected. A three-year term. Seat F One member to be elected. A three-year term. Seat G One member to be elected. A three-year term.

A candidate for one of the above seats must be a qualified voter of the Municipality of Anchorage and of the State of Alaska. Election is areawide.

SERVICE AREAS

A candidate for one of the seats listed below must be a qualified voter of the Municipality of Anchorage and of the State of Alaska and shall have been a resident of the stated Service Area for three (3) months immediately preceding this election. Write in candidates must register with the Municipal Clerk at least seven (7) days before the election. If no candidate files, the vacancy will be filled by Mayoral appointment upon confirmation by the Assembly. Election is by service area.

BEAR VALLEY LIMITED ROAD SERVICE AREA BOARD OF SUPERVISORS Seat C One member to be elected. A three-year term.

BIRCH TREE/ELMORE LIMITED ROAD SERVICE AREA BOARD OF SUPERVISORS Seat B One member to be elected. A three-year term.

CHUGIAK FIRE SERVICE AREA BOARD OF SUPERVISORS Seat B One member to be elected. A three-year term.

GIRDWOOD VALLEY SERVICE AREA BOARD OF SUPERVISORS Seat A One member to be elected. A three-year term. Seat B One member to be elected. A three-year term.

GLEN ALPS SERVICE AREA BOARD OF SUPERVISORS Seat E One member to be elected. A three-year term.

HOMESTEAD LIMITED ROAD SERVICE AREA BOARD OF SUPERVISORS Seat A One member to be elected. A one-year term expiring in 2022. Seat B One member to be elected. A two-year term expiring in 2023. Seat C One member to be elected. A three-year term expiring in 2024.

LAKEHILL LIMITED ROAD SERVICE AREA BOARD OF SUPERVISORS Seat B One member to be elected. A three-year term.


http://www.muni.org/elections


MOUNTAIN PARK ESTATES LIMITED ROAD SERVICE AREA BOARD OF SUPERVISORS Seat A One member to be elected. A three-year term. MOUNTAIN PARK/ROBIN HILL LIMITED ROAD SERVICE AREA BOARD OF SUPERVISORS Seat A One member to be elected. A three-year term. Seat B One member to be elected. A three-year term. PARADISE VALLEY SOUTH LIMITED ROAD SERVICE AREA BOARD OF SUPERVISORS Seat C One member to be elected. A three-year term. RABBIT CREEK VIEW AND RABBIT CREEK HEIGHTS LIMITED ROAD SERVICE AREA BOARD OF SUPERVISORS Seat A One member to be elected. A three-year term. RAVEN WOODS/BUBBLING BROOK LIMITED ROAD SERVICE AREA BOARD OF SUPERVISORS Seat A One member to be elected. A three-year term. ROCKHILL LIMITED ROAD SERVICE AREA BOARD OF SUPERVISORS Seat A One member to be elected. A three-year term. SECTION 6/CAMPBELL AIRSTRIP ROAD LIMITED ROAD SERVICE AREA BOARD OF SUPERVISORS Seat B One member to be elected. A three-year term. Seat C One member to be elected. A three-year term. SEQUOIA ESTATES LIMITED ROAD SERVICE AREA BOARD OF SUPERVISORS Seat E One member to be elected. A three-year term. SKYRANCH ESTATES LIMITED ROAD SERVICE AREA BOARD OF SUPERVISORS Seat A One member to be elected. A three-year term. SOUTH GOLDENVIEW AREA RURAL ROAD SERVICE AREA BOARD OF SUPERVISORS Seat B One member to be elected. A three-year term. Seat C One member to be elected. A three-year term. SRW HOMEOWNER’S LIMITED ROAD SERVICE AREA BOARD OF SUPERVISORS Seat A One member to be elected. A three-year term. TALUS WEST LIMITED ROAD SERVICE AREA BOARD OF SUPERVISORS Seat B One member to be elected. A three-year term. TOTEM LIMITED ROAD SERVICE AREA BOARD OF SUPERVISORS Seat C One member to be elected. A three-year term. UPPER GROVER LIMITED ROAD SERVICE AREA BOARD OF SUPERVISORS Seat A One member to be elected. A three-year term. UPPER O'MALLEY LIMITED ROAD SERVICE AREA BOARD OF SUPERVISORS Seat B One member to be elected. A three-year term. Seat E One member to be elected. A three-year term. VALLI VUE ESTATES LIMITED ROAD SERVICE AREA BOARD OF SUPERVISORS Seat A One member to be elected. A three-year term. Seat D One member to be elected. A three-year term. VILLAGES SCENIC PARKWAY LIMITED ROAD SERVICE AREA BOARD OF SUPERVISORS Seat C One member to be elected. A three-year term. Questions about the election or this notice may be directed to MOA Elections by calling the Voter Hotline at 907-243-VOTE(8683), emailing [email protected], or visiting muni.org/elections. /s/ Barbara A. Jones, Municipal Clerk /s/ Erika McConnell, Deputy Clerk - Elections Publish: January 10, 2021



Articles of OrganizationDomestic Limited Liability Company

Web-11/5/2020 2:03:10 PM

1 - Entity Name

Legal Name: Alaskans for Change, LLC

2 - Purpose

Any lawful purpose

3 - NAICS Code

813940 - POLITICAL ORGANIZATIONS

4 - Registered Agent

Name: REEVES AMODIO CORPORATE SERVICES INC.

Mailing Address: 500 L Street, Suite 300, Anchorage, AK 99501

Physical Address: 500 L Street, Suite 300, Anchorage, AK 99501

5 - Entity Addresses

Mailing Address: 740 Centre View Blvd, Crestview Hills, KY 41017

Physical Address: 500 L Street, Suite 300, Anchorage, KY 99501

6 - Management

The limited liability company is managed by its members.

7 - Officials

Name Address % Owned Titles

Reeves Amodio Corporate Services Inc. Organizer

Name of person completing this online application

This form is for use by the named entity only. Only persons who are authorized by the above Official(s) of the named entity may makechanges to it. If you proceed to make changes to this form or any information on it, you will be certifying under penalty of perjury that youare authorized to make those changes, and that everything on the form is true and correct. In addition, persons who file documents withthe commissioner that are known to the person to be false in material respects are guilty of a class A misdemeanor. Continuation meansyou have read this and understand it.

Name: Keri-Ann C Baker

Department of Commerce, Community, and Economic Development Division of Corporations, Business, and Professional Licensing PO Box 110806, Juneau, AK 99811-0806 (907) 465-2550 • Email: [email protected]: corporations.alaska.gov

CORFOR DIVISION USE ONLY

Page 1 of 1

AK Entity #: 10147006Date Filed: 11/05/2020

State of Alaska, DCCED


IN TESTIMONY WHEREOF, I execute the certificate and affix the GreatSeal of the State of Alaska effective November 5, 2020.

Julie Anderson Commissioner

Alaska Entity #10147006

State of Alaska Department of Commerce, Community, and Economic Development

Corporations, Business, and Professional Licensing

Certificate of Organization

The undersigned, as Commissioner of Commerce, Community, and Economic Development of the State ofAlaska, hereby certifies that a duly signed and verified filing pursuant to the provisions of Alaska Statutes hasbeen received in this office and has been found to conform to law.

ACCORDINGLY, the undersigned, as Commissioner of Commerce, Community, and Economic Development,and by virtue of the authority vested in me by law, hereby issues this certificate to

Alaskans for Change, LLC


6/1/2021 Division of Corporations, Business and Professional Licensing

https://www.commerce.alaska.gov/cbp/main/Search/EntityDetail/10147006 1/2

Department of Commerce, Community, and Economic DevelopmentCORPORATIONS, BUSINESS & PROFESSIONALLICENSING

Show Former

State of Alaska / Commerce / Corporations, Business, and Professional Licensing / Search & Database Download /Corporations / Entity Details

ENTITY DETAILSName(s)

Entity Type: Limited Liability Company

Entity #: 10147006

Status: Good Standing

AK Formed Date: 11/5/2020

Duration/Expiration: Perpetual

Home State: ALASKA

Next Biennial Report Due: 1/2/2022

Entity Mailing Address: 740 CENTRE VIEW BLVD, CRESTVIEW HILLS, KY 41017

Entity Physical Address: 500 L STREET, SUITE 300, ANCHORAGE, KY 99501

Registered AgentAgent Name: REEVES AMODIO CORPORATE SERVICES INC.

Registered Mailing Address: 500 L STREET, SUITE 300, ANCHORAGE, AK 99501

Registered Physical Address: 500 L STREET, SUITE 300, ANCHORAGE, AK 99501

Officials

Type NameLegal Name Alaskans for Change, LLC

AK Entity # Name Titles OwnedCP MANAGEMENT, INC. Member 100.00

DEREK HAUGHT Manager

JOSEPH YUNG Manager


http://www.alaska.gov/

https://www.commerce.alaska.gov/

https://www.commerce.alaska.gov/web/cbpl

http://www.alaska.gov/

https://www.commerce.alaska.gov/web/

http://commerce.alaska.gov/web/cbpl

https://www.commerce.alaska.gov/cbp/main/

https://www.commerce.alaska.gov/cbp/main/Search/Entities

6/1/2021 Division of Corporations, Business and Professional Licensing

https://www.commerce.alaska.gov/cbp/main/Search/EntityDetail/10147006 2/2

Filed Documents

COPYRIGHT © STATE OF ALASKA · DEPARTMENT OF COMMERCE, COMMUNITY, AND ECONOMIC DEVELOPMENT ·

AK Entity # Name Titles OwnedTHOMAS DRAKE Manager

WILLIAM YUNG Manager

Date Filed Type Filing Certificate11/05/2020 Creation Filing Click to View Click to View

11/09/2020 Initial Report Click to View

11/19/2020 Amendment Click to View Click to View

11/19/2020 Change of Officials Click to View


https://www.commerce.alaska.gov/

https://www.commerce.alaska.gov/cbp/main/Document/Corp/?r=1004377&v=1324275&d=2429346






6/1/2021 EntityRegistration

https://hickory.state.ak.us/ApocAdmin/Filings/ViewForm/1459?Type=620 1/1

E�� R�� F��

C��Submission Date: 11/25/2020Filer First Name: Keri-AnnFiler Middle Name (Optional): CalderwoodFiler Last Name: BakerFiler's Title with Entity: Attorney

E�� I��

Election Year: 2020Entity Name: Alaskans For ChangeAbbreviation:Purpose: supporting balanced and business-friendly candidatesState Initiative Support/Oppose: No (No Involvement)Entity Mailing Address: 740 Centre View Blvd.City, State Zip: Crestview Hills, Kentucky 41017

C��

Name: Tom DrakeAddress: 740 Centre View Blvd.City, State Zip: Crestview Hills, Kentucky 41017Phone: 859-578-1180E-mail: [email protected] (Optional): Did Not Report

O�� D��

Name Address Title

William J. Yung III 740 Centre View Blvd. Crestview Hills, Kentucky 41017

President

Joseph A. Yung 740 Centre View Blvd. Crestview Hills, Kentucky 41017

Vice-President

Thomas L. Drake 740 Centre View Blvd. Crestview Hills , Kentucky 41017

Secretary / Treasurer

Derek J. Haught 740 Centre View Blvd. Crest View Hills, Kentucky 41017

VP Finance

B�� A�� / P�� A�� A��

Name of Bank: Huntington National BankBank Address: 6666 Industrial RoadCity, State Zip: Florence, Kentucky 41042


6/1/2021 GroupRegistration (Amended)


G�� R�� F��

A��

C��Submission Date: 04/27/2021Filer First Name: ChristyFiler Middle Name (Optional):Filer Last Name: StrutzFiler's Title with Group: Consultant

G�� I��

Previously Registered: NoElection Year: 2021Group Name: Alaskans for ChangeAbbreviation:Purpose: Elect a Conservative Mayor to Public OfficeGroup Type: Independent ExpenditureGroup Mailing Address: 740 Centre View BlvdCity, State Zip: Crestview Hills, Kentucky 41017Additional Email Addresses to Notify: [email protected];[email protected]

C��

Name: William YungAddress: 740 Centre View BlvdCity, State Zip: Crestview Hills, Kentucky 41017Phone: 859-578-1184E-mail: [email protected] (Optional): Did Not Report

T��

Name: Thomas DrakeAddress: 740 Centre View BlvdCity, State Zip: Crestview Hills, Kentucky 41017Phone: 513-304-9150E-mail: [email protected] (Optional): Did Not Report

D�� T�� / C�-��

Name Address Title

No Deputy Treasurers / Co-chairs / Nothing to Report

T�� G��

INDEPENDENT EXPENDITURE GROUP

More than 1/3 of total spending going to the following candidate(s).David W Bronson

C�� P��

Election Type Election Municipality

Municipal Runoff 2021 - Anchorage Municipal Runoff Anchorage, City and Borough

B�� A�� / C�� D��Exhibit 7

Page 1 of 2

6/1/2021 GroupRegistration (Amended)


Name of Bank: Huntington National BankBank Address: 17 South High StreetCity, State Zip: Columbus, Ohio 43216


6/1/2021 GroupRegistration Amendment


G�� R�� F��

A��Amendment Description: Need to amend Group name to include Bronson

C��Submission Date: 04/28/2021Filer First Name: ChristyFiler Middle Name (Optional):Filer Last Name: StrutzFiler's Title with Group: Consultant

G�� I��

Previously Registered: NoElection Year: 2021Group Name: Alaskans for Change- BronsonAbbreviation:Purpose: Elect a Conservative Mayor to Public OfficeGroup Type: Independent ExpenditureGroup Mailing Address: 740 Centre View BlvdCity, State Zip: Crestview Hills, Kentucky 41017Additional Email Addresses to Notify: [email protected];[email protected]

C��

Name: William YungAddress: 740 Centre View BlvdCity, State Zip: Crestview Hills, Kentucky 41017Phone: 859-578-1184E-mail: [email protected] (Optional): Did Not Report

T��

Name: Thomas DrakeAddress: 740 Centre View BlvdCity, State Zip: Crestview Hills, Kentucky 41017Phone: 513-304-9150E-mail: [email protected] (Optional): Did Not Report

D�� T�� / C�-��

Name Address Title

No Deputy Treasurers / Co-chairs / Nothing to Report

T�� G��

INDEPENDENT EXPENDITURE GROUP

More than 1/3 of total spending going to the following candidate(s).David W Bronson

C�� P��

Election Type Election Municipality

Municipal Runoff 2021 - Anchorage Municipal Runoff Anchorage, City and Borough


6/1/2021 GroupRegistration Amendment


B�� A�� / C�� D��

Name of Bank: Huntington National BankBank Address: 17 South High StreetCity, State Zip: Columbus, Ohio 43216


6/3/2021 IndependentExpenditures


I�� E�� F�� 15-6

C��Submission Date: 04/28/2021

F�� I��

Filer First Name: ChristyFiler Middle Name:Filer Last Name: StrutzFiler Full Address: 4024 Brentwood Circle, Anchorage, Alaska 99502Filer Occupation: ConsultantFiler Employer: Self-EmployedFiler's Title with Other Entity: Consultant

R�� I��

Election Year: 2021Report Type: Twenty-four HourFiler Type: Registered Group

B��/O�� E�� I��

Business/Other Entity Name: Alaskans for Change- BronsonType of Business or Organization: Registered GroupAddress: 740 Centre View BlvdCity: Crestview HillsState: Kentucky 41017Country: United StatesBusiness/Other Entity Contact Person: Thomas DrakeContact E-mail: [email protected] Phone: 513-304-9150

E�� I��

Election: Anchorage Municipal Runoff

O��

Name Full Address Title

William Yung 740 Centre View Blvd Crestview Hills, Kentucky 41017

Chair

Thomas Drake 740 Centre View Blvd Crestview Hills, Kentucky 41017

Treasurer

E��

Date Recipient Payment Type

Candidate / Proposition Amount

02/09/2021 Reeves Amodio, LLC500 L St #300 Anchorage, Alaska99501

Check CheckNumber: 501

SUPPORT: 2021 - David W Bronson Election: Anchorage Municipal Runoff Attorney Fees

$8,352.00




$447.00




Date Recipient Payment Type

Candidate / Proposition Amount




$1,368.00

04/27/2021 Cabildo StrategyServices, LLC 4204 Pine Park Drive Baton Roug,Louisiana 70809


SUPPORT: 2021 - David W Bronson Election: Anchorage Municipal Runoff Advertising Expense- Digital Ad Creation & Production,Placement of Digital Media Ad, & Website

$43,000.00

C��

Contribution Date Contributor Details Amount

01/14/2021 Type: Other Name: CP ManagementInc 350 Kings Town Drive Naples, Florida 34102

Officers / Directors


William J YungIII

350 Kings Town Drive, Naples, FL34102

Owner/Chairman

$50,000.00




William J YungIII


Owner/Chairman

$50,000.00




William J YungIII


Owner/Chairman

-$40,000.00

D��

Date Recipient Candidate / Proposition Amount

No Debts / Nothing to Report

R�� S��

Number of Expenditures Reported with this Report: 4

Total of paid Expenditures: $53,167.00

Previous Contributions: $0.00

Number of Contributions Reported with this Report: 3

Total of Contributions Reported with this Report: $60,000.00

Cumulative Contribution Amounts: $60,000.00

Number of Officers: 2

Number of Debts Reported with this Report: 0

Total of Debts Incurred but not yet paid: $0.00



https://hickory.state.ak.us/ApocAdmin/Filings/ViewForm/5100?Type=571 3/3Exhibit 9 Page 3 of 3

1

Odena, Jacqueline S (DOA)

From: Tom Amodio <[email protected]>Sent: Monday, June 14, 2021 3:55 PMTo: Odena, Jacqueline S (DOA); Michelle Hanlon-DehnerCc: Lucas, Tom R (DOA); Kevin BootsSubject: RE: Inspection of Records: 21-02-CD Dunbar for Mayor v. Alaskans for Change

Jackie, Without waiving any objections, the work described was performed on 11/19, 11/30, and 12/2. Tom

Thomas Amodio [email protected] 907.222.7100 main phone 907.222.7104 direct phone 907.222.7199 fax

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REEVES AMODIO LLC CONFIDENTIAL ATTORNEY-CLIENT COMMUNICATION.

IF YOU RECEIVED THIS E-MAIL MESSAGE BY MISTAKE, PLEASE DO NOT READ IT. REPLY TO SENDER AND DELETE THIS MAIL.

THANK YOU. -.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-

From: Odena, Jacqueline S (DOA) <[email protected]> Sent: Friday, June 11, 2021 1:34 PM To: Tom Amodio <[email protected]>; Michelle Hanlon‐Dehner <[email protected]> Cc: Lucas, Tom R (DOA) <[email protected]>; Kevin Boots <[email protected]> Subject: RE: Inspection of Records: 21‐02‐CD Dunbar for Mayor v. Alaskans for Change Good Afternoon Mr. Amodio, Under the second bullet point, you provide a date range of November 19, 2020 to December 3, 2020 for “work consisted of giving advice and other work relating to corporate matters, including the filing of corporate amendments and biennial reports; it also involved assisting in getting the entity registered with APOC, in accordance with law.” Do you have the exact date, from within this period of time, of when services were provided to AFC – Bronson that were for “assisting in getting the entity registered with APOC, in accordance with law.”? Thank you,


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Jacqueline Odena Paralegal I Alaska Public Offices Commission 2221 E. Northern Lights Blvd STE 128 Anchorage, AK 99508 Phone: (907) 276‐4176 Toll‐Free: 1‐800‐478‐4176 Fax: (907) 276‐7018

CONFIDENTIALITY NOTICE: This communication with its content and any attachments may contain confidential and/or legally privileged information. It is solely for the use of the intended recipient(s). Unauthorized interception review, use, or disclosure is prohibited and may violate applicable laws including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and destroy all copies of the communication.

From: Tom Amodio <[email protected]> Sent: Thursday, June 10, 2021 11:43 AM To: Odena, Jacqueline S (DOA) <[email protected]>; Michelle Hanlon‐Dehner <[email protected]> Cc: Lucas, Tom R (DOA) <[email protected]>; Kevin Boots <[email protected]> Subject: RE: Inspection of Records: 21‐02‐CD Dunbar for Mayor v. Alaskans for Change

Hi Jackie, I have reviewed the invoices in question. I believe we can respond generally to the questions you ask without violating any privileges. We of course continue to assert the attorney‐client privilege and work product documents with regard to further disclosures, but I believe our response should satisfy your inquiry within the bounds of the privileges notes. Our providing this information in no way constitutes a waiver or modification of any applicable privileges. The amounts were incurred when the work was performed. There were no earlier requests to perform any specific work. Our firm was hired initially to provide corporate advice, and other advice relating to registration and reporting requirements pursuant to APOC’s rules. In addition, I want to reiterate that by providing this information, we do not waive any of our arguments or objections raised in our response to the unfounded complaint. In fact, we expressly reserve the right to raise all such arguments and objections, and any other applicable ones, should staff not agree that the complaint should be dismissed. I’m also a little perplexed at how you think APOC has jurisdiction over corporate affairs, as opposed to election and campaign finance matters, as I told Tom Lucas in a phone call earlier this week. Be that as it may, here is our response:

On various dates from September 18, 2020 through November 18, 2020, the bulk of our work consisted of givingadvice and other work relating to the creation and operation of a corporation or other organization inAlaska. We assisted in the corporate formation of a limited liability company. The work performed during thistime accounts for most of the 02/08/21 reported payment of $8,352.

From about November 19, 2020 through December 3, 2020, our work consisted of giving advice and other workrelating to corporate matters, including the filing of corporate amendments and biennial reports; it also involvedassisting in getting the entity registered with APOC, in accordance with law. This work accounted for theremainder of the $8,352 reported payment, roughly $710, and for the 03/02/2021 reported payment of $447.

No work was performed or incurred from December 4, 2020 through December 31, 2020.

From January 1, 2021 through January 26, 2021, our work consisted of giving advice, responding to questions,and other work relating to APOC reporting requirements and related matters. This work accounted for the03/30/2021 reported payment of $1,368.

No work was performed or incurred from January 27, 2021 through the date of the municipal run‐off election.Regards, Tom

Thomas Amodio


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[email protected] 907.222.7100 main phone 907.222.7104 direct phone 907.222.7199 fax

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THANK YOU. -.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-

From: Odena, Jacqueline S (DOA) <[email protected]> Sent: Friday, June 4, 2021 2:41 PM To: Tom Amodio <[email protected]>; Michelle Hanlon‐Dehner <[email protected]> Cc: Lucas, Tom R (DOA) <[email protected]>; Staff <[email protected]>; Kevin Boots <[email protected]> Subject: RE: Inspection of Records: 21‐02‐CD Dunbar for Mayor v. Alaskans for Change Good Afternoon Tom, Thank you for your response. Unfortunately, inasmuch as civil penalties for potential violations are measured for each day a violation continues, it would be helpful to know when your client asked you to perform work. For example, I would presume when you were first retained, there was an agreement as to the work that would be performed – in this case (according to the Answer to Complaint and Motion to Dismiss), to help with incorporation. However, It appears that the client may have asked for your help on other matters from time to time, with each time incurring another separate (for APOC purposes) expense. I fully understand the potential attorney client privilege issues that may be present, but to the extent that you can, would it be possible to give us a date for each separate undertaking you were asked to perform and a rough idea of what you were asked to do? Thank you, Jacqueline Odena Paralegal I Alaska Public Offices Commission 2221 E. Northern Lights Blvd STE 128 Anchorage, AK 99508 Phone: (907) 276‐4176 Toll‐Free: 1‐800‐478‐4176 Fax: (907) 276‐7018 CONFIDENTIALITY NOTICE: This communication with its content and any attachments may contain confidential and/or legally privileged information. It is solely for the use of the intended recipient(s). Unauthorized interception review, use,


4

or disclosure is prohibited and may violate applicable laws including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and destroy all copies of the communication.

From: Tom Amodio <[email protected]> Sent: Thursday, June 3, 2021 3:28 PM To: Odena, Jacqueline S (DOA) <[email protected]>; Michelle Hanlon‐Dehner <[email protected]> Cc: Lucas, Tom R (DOA) <[email protected]>; Staff <[email protected]>; Kevin Boots <[email protected]> Subject: RE: Inspection of Records: 21‐02‐CD Dunbar for Mayor v. Alaskans for Change Good afternoon, Jackie, According to our records, the fees relating to the three payments were incurred from September 18, 2020 through January 26, 2021. Regards, Tom


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THANK YOU. -.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-

From: Odena, Jacqueline S (DOA) <[email protected]> Sent: Friday, May 28, 2021 5:04 PM To: Michelle Hanlon‐Dehner <[email protected]> Cc: Lucas, Tom R (DOA) <[email protected]>; Staff <[email protected]>; Kevin Boots <[email protected]>; Tom Amodio <[email protected]> Subject: RE: Inspection of Records: 21‐02‐CD Dunbar for Mayor v. Alaskans for Change Importance: High Good Afternoon, Thank you for the providing the requested documentation. Alaskans for Change – Bronson reported three payments made to Reeves Amodio, LLC on February 9, March 12, and March 31, 2021 for attorney fees. When were these fees incurred? Thank you,


5

Jacqueline Odena Paralegal I Alaska Public Offices Commission 2221 E. Northern Lights Blvd STE 128 Anchorage, AK 99508 Phone: (907) 276‐4176 Toll‐Free: 1‐800‐478‐4176 Fax: (907) 276‐7018 CONFIDENTIALITY NOTICE: This communication with its content and any attachments may contain confidential and/or legally privileged information. It is solely for the use of the intended recipient(s). Unauthorized interception review, use, or disclosure is prohibited and may violate applicable laws including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and destroy all copies of the communication.

From: Michelle Hanlon‐Dehner <[email protected]> Sent: Tuesday, May 18, 2021 9:48 AM To: Odena, Jacqueline S (DOA) <[email protected]> Cc: Lucas, Tom R (DOA) <[email protected]>; Staff <[email protected]>; Kevin Boots <[email protected]>; Tom Amodio <[email protected]> Subject: Inspection of Records: 21‐02‐CD Dunbar for Mayor v. Alaskans for Change Good morning Jacqueline. Per your May 7 request, we attach for your review Alaskans for Change records. We apologize for not getting these to you sooner. Tom Amodio is currently out of the country and pertinent communications were not immediately

forwarded to the attorney overlooking his cases in his absence. Thank you for bearing with us. Michelle

Michelle Hanlon-Dehner Paralegal Main: 907-222-7100 Direct: 907-222-7111 [email protected]


1

Odena, Jacqueline S (DOA)

From: Tom Amodio <[email protected]>Sent: Monday, June 28, 2021 12:59 PMTo: Lucas, Tom R (DOA)Cc: Hebdon, Heather R (DOA); Odena, Jacqueline S (DOA); StaffSubject: RE: 21-02-CD Dunbar v. Alaskans for ChangeAttachments: Cabildo Strategy Services Letter re Alaskans for Change.pdf

Tom – Here’s a letter from Cabildo confirming what I told you in my email earlier today. Tom


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THANK YOU. -.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-.-

From: Tom Amodio Sent: Monday, June 28, 2021 10:55 AM To: Tom R Lucas (DOA) <[email protected]> Cc: Hebdon, Heather R (DOA) <[email protected]>; Odena, Jacqueline S (DOA) <[email protected]>; Staff <[email protected]> Subject: 21‐02‐CD Dunbar v. Alaskans for Change Tom – According to my client’s IT guy, Alaskans for Change (AFC) did not have a website, web domain, or Facebook page in 2020, nor did it develop any for the run‐off election. There is an entry for “Website” on the attached invoice from April 26, 2021 (and the April 16th proposal), and I’m trying to track that down and see if Cabildo Strat. Set one up for the run‐off. Re the attachments, I have redacted several items from the proposal which relate to issues of strategy, and do not relate to whether something was properly or timely reported. Similarly, from the invoice, I have redacted all banking info (bank, account, etc.), and one reference relating to strategy, which also is not relevant to the issue here.


2

As to the proposal and invoice, I’m told that there was no agreement or obligation until AFC accepted the proposal, which it did when it paid the invoice on April 28th. (As I mentioned already, AFC reviewed the proposal internally and decided to accept it on April 27th.) According to Cabildo, Creating a concept for ‘a pitch’ such as here is usual and customary in political consulting, and is done at its own risk. I’ve asked for this in writing, and will get it to you as soon as I do. I believe this responds to all of your additional questions. Regards, Tom


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1

2 4/13/2021

3

4 TO: Tom Drake

s FR: G. Kennedy, P. Robinson

6 RE: Second Primary, Anchorage Mayor's Race

7

8 RECOMMENDATIONS:

9 1. ... display ads for internet placement.

10 2. 11111':30 ads for internet/digital placement.

11 3. Begin internet placement April a continue until May ■ This gives usf12 weeks of saturation.

13

14 COSTS:

1s 1. DIGITAL MEDIA PLACEMENT (f weeks) $30,000

16 2. PRODUCTION (fdisplay,tTv spots) $5500

17 3. PROFESSIONAL FEE: $7500

18 4. WEBSITE: $2500

19 5. RESEARCH: $2000

20

21 TOTALS: $47,000

22

23

24

Page 1 of 2


2s OPTIONAL (To be discussed}:

26

27

1. NETWORK TV - week} $50,0002. DIRECT MAIL (-week,

28

29 Thanks, let us know. Any questions, give us a call.

30

31 GcK* /Pres

Page 2 of 2

households} $7500


CABILDO STRATEGY SERVICES

4204 PINE PARK DRIVE BATON ROUGE, LA 70809 (225) 636-1263PRES. RO BIN SO [email protected]

June 28, 2021

To Whom It May Concern:

,\ -��·-�

On April 16, 2021 CSS submitted a proposal to Mr. Tom Drake for an ad campaign related

to municipal elections in Anchorage.

On April 26, CSS submitted an invoice to Mr. Drake to secure our engagement in the

Anchorage mayoral election.

On April 2 7 the invoice was paid and we were put in contact with Alaskans for Change

counsel to confirm disclosure requirements, and complete advertisements.

Ads were then completed, and distribution order placed on May 4th.

(I

Cabildo Strategy Services had no contract with the client. Prior to invoicing we did develop

ad concepts with no obligation from the client to complete any payment. Creating a concept

for "a pitch" at our own risk is usual and customary in political consulting.

Sincerely,

Preston Robinson

CABILDO STRATEGY SERVICES, LLC

4204 PINE PARK DR.· BATON ROUGE, LA 70809 · (225) 636-1263 PRES. RO BIN SO [email protected] Exhibit 14

Page 1 of 1

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Whois Record for AlaskansForChange.com

- Domain Profile

Registrant

Registrant Org

Domain Administrator

CSC Corporate Domains, Inc.

Registrant Country us

Registrar

Registrar Status

Dates

Name Servers

Tech Contact

IP Address

IP Location

ASN

Domain Status

IP History

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CSC CORPORATE DOMAINS, INC. CSC Corporate Domains, Inc. IANA ID: 299 URL: www.cscprotectsbrands.com,http:#cscdbs.com Whols Server: whois.corporatedomalns.com

[email protected] (p) 18887802723

cl I entTra nsferProhiblted

4,726 days old Created on 2008-07-21 Expires on 2021-08-01 Updated on 2020-10-21

DNS1.CSCDNS.NET (has 969,568 domains) DNS2.CSCDNS.NET (has 969,568 domains)

DNS Administrator CSC Corporate Domains, Inc. 251 Little Falls Drive, Wilmington, DE, 19808, us

[email protected] (p) 13026365400 (f) 13026365454

165.160.13.20 - 765,900 other sites hosted on this server

ll!il - Delaware - Wilmington - Corporation Service Company

IJiiii!AS19574 CSC, US (registered Dec 21, 2007)

Registered And Active Website

6 changes on 6 unique IP addresses over 13 years

3 registrars

2 changes on 3 unique name servers over 13 years

https:/lwhols.domaintools.com/alaskansforchange.com

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AlaskansForChange.com WHOIS, DNS, & Domain Info - Domain Tools

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Whois Record ( last updated on 2021-06-29)

Domain Name: alaskansforchange.com Registry Domain ID: 1509515470_DOMAIN_COM-VRSN Registrar WHOIS Server: whois.corporatedomains.com Registrar URL: www.cscprotectsbrands.com Updated Date: 2020-10-21T10:13:06Z Creation Date: 2008-07-21T14:51:04.000-04:00 Registrar Registration Expiration Date: 2021-08-01T23:59:59.000-04:00 Registrar: CSC CORPORATE DOMAINS, INC. Registrar IANA ID: 299

Registrar Abuse Contact Email: [email protected]

Registrar Abuse Contact Phone: +1.8887802723

,..

Domain Status: clientTransferProhibited http://www.icann.org/epp#clientTransferProhibit ed Registry Registrant ID: Registrant Name: Domain Administrator Registrant Organization: CSC Corporate Domains, Inc. Registrant Street: 251 Little Falls Drive Registrant City: Wilmington Registrant State/Province: DE Registrant Postal Code: 19808 Registrant Country: US Registrant Phone: +1.3026365400 Registrant Phone Ext: Registrant Fax: +1.3026365454 Registrant Fax Ext: Registrant Email: [email protected]

Registry Admin ID: Admin Name: Domain Administrator Admin Organization: CSC Corporate Domains, Inc. Admin Street: 251 Little Falls Drive Admin City: Wilmington Admin State/Province: DE Admin Postal Code: 19808 Admin Country: US Admin Phone: +1.3026365400 Admin Phone Ext: Admin Fax: +1.3026365454 Admin Fax Ext: Admin Email: [email protected]

Registry Tech ID: Tech Name: DNS Administrator Tech Organization: CSC Corporate Domains, Inc. Tech Street: 251 Little Falls Drive Tech City: Wilmington Tech State/Province: DE Tech Postal Code: 19808 Tech Country: US Tech Phone: +1.3026365400 Tech Phone Ext: Tech Fax: +1.3026365454 Tech Fax Ext:

Tech Email: [email protected]

Name Server: dns1.cscdns.net Name Server: dns2.cscdns.net DNSSEC: unsigned

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