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Statement of Facts Missouri Ethics Commission Nicholas D. Kasoff v.

Patricia Bynes
1. Patricia Bynes is the Democratic Committeewoman for Ferguson Township, having been
elected to that position in the primary election of August, 2012.
2. Bynes established a candidate committee, Citizens for Patricia Bynes, for lawful political
purposes pertaining to aforementioned office.
3. Bynes registered this committee with the St. Louis County Election Board, and not with
the Missouri Ethics Commission. All reports for this committee, when filed, were filed
only with the Election Board.
4. Upon formation of this committee, Bynes appointed one Thomas Lemp as treasurer.
(Exhibit A)
5. On or about October 24, 2013, St. Louis County Election Board served notice upon
Bynes and Lemp that quarterly reports for April, July, and October 2013 had not been
filed. (Exhibit B)
6. On or about October 30, 2013, Lemp filed a handwritten response with the Election
Board, stating the following (Exhibit C):
I have been the treasurer for the Bynes campaign since approx.. 12/12.
Ms. Bynes has told me on numerous occasions that she has secured another treasurer for
her campaign and has made alternative arrangements with you and the bank. I am not
aware of the new treasurers identity.
Please advise.
7. On or about February 20, 2014, Election Board served notice upon Bynes that quarterly
reports for April, July, and October 2013, and January 2014, had not been filed. Each
failure constitutes a violation of or RSMo 130.056(9). (Exhibit D)
8. On or about April 24, 2014, Election Board served notice upon Bynes that quarterly
reports for April, July, and October 2013, and for January and April 2014, remained
unfiled. This notice indicated that Failure to respond to this letter will result in your
committee being forwarded to the Missouri Ethics Commission. (Exhibit E)
9. On or about September 10, 2014, Bynes filed an amended statement of committee
organization with Election Board, removing Lemp as treasurer, and appointing herself as
treasurer.
10. On or about September 10, 2014, Election Board service another final notice upon
Bynes, indicating that quarterly reports for April, July, and October 2013, and for
January, April, and July 2014, all remained unfiled.

Statement of Facts Missouri Ethics Commission Nicholas D. Kasoff v. Patricia Bynes


11. On or about September 23, 2014, Bynes filed aforementioned reports with Election
Board.
12. For those reports prior to September 10, 2014, Lemp was the treasurer for the committee.
However, the reports which Bynes filed covering these periods include Bynes signature
for both treasurer and candidate.
13. Bob Hudgins and Lee Smith were candidates for city council, city of Ferguson, in the
election of April 7, 2015.
14. Patricia Bynes served as treasurer for the campaigns of both Hudgins and Smith.
15. Upon information and belief, Bynes served as campaign manager for the campaigns of
both Hudgins and Smith.
16. On or about April 15, 2015, Bynes filed a quarterly report for Citizens for Patricia Bynes,
indicating two expenses to Mulligan Printing, on February 13, 2015, in the amounts of
$468.88 and $468.89. (Exhibit H)
17. Aforementioned report indicated that the committee made direct expenditures to Hudgins
and Smith, in the same amounts. (Exhibit I)
18. Having made direct expenditures on behalf of candidates in these elections, Bynes came
under the obligation to conform to reporting requirements of that election cycle, pursuant
to RSMo 130.046(1).
19. Bynes was therefore required to file both an 8 day before report and a 30 day after
report.
20. On information and belief, at 9:00 am on May 18, 2015, Bynes had not filed either of
these reports.
21. On information and belief, on April 4, 2015, Bynes received a contribution of $1,000
from one Joseph H. Field, of Bala Cynwyd, Pennsylvania, by means of her NationBuilder
and Paypal Accounts.
22. Aforementioned contribution having been received within 11 days of the election, it was
subject to the Late Contribution Report requirements of RSMo 130.050.
23. Upon information and belief, no Late Contribution Report was filed.
24. Having failed to file a 30 Day After report, aforementioned contribution has not been
disclosed in any report required in the election cycle for which it was received.

Statement of Facts Missouri Ethics Commission Nicholas D. Kasoff v. Patricia Bynes


25. On or about March 30, 2015, Bynes filed an 8 Day Before report for Bob Hudgins for
the People, the candidate committee for Hudgins. This report listed an in-kind
contribution of $461.88, on February 25, 2015. (Exhibit K)

26. This conflicts with Bynes quarterly report, which indicated an earlier contribution date,
and which listed this as a direct expenditure.
27. On or about March 30, 2015, Bynes filed an 8 Day Before report for Supporters of Lee
Smith, the candidate committee for Smith. This report listed an in-kind contribution of
$461.88, on February 25, 2015. (Exhibit J)
28. This conflicts with Bynes quarterly report, which listed this as a direct expenditure.
29. Because Bynes serves as treasurer for all three committees, these discrepancies cant be
explained by a difference of opinion between different reporting parties regarding the
nature of the contribution.
30. On or about September 23, 2014, Bynes filed a report indicating that for the April 15,
2014 reporting period, Citizens for Patricia Bynes had $34.42 cash on hand. (Exhibit L)
31. For each report following, up and until her quarterly report which was due on April 15,
2015, Bynes filed a Statement of Limited Activity.
32. In the report for the period ending on March 13, 2015, which report was the first Full
Disclosure Report filed since the aforementioned report, an opening cash on hand balance
of zero is indicated. No expenses are listed to explain the disposition of the $34.42 cash
on hand at the end of the last Full Disclosure Report.
33. Because a Statement of Limited Activity indicates that a committee has received more
than $500 in contributions since the last Full Disclosure Report, the committee could not
have accrued sufficient funds for the aforementioned direct expenditures, which amount
to a total of $937.77.
34. Therefore, the contributions received and reported in Bynes quarterly report on April 15,
2015, were in fact raised and spent for the April 7, 2015 election.