beth mason elec complain part 2

NEW JERSEY ELECTION LAW ENFORCEMENT COMMISSIONP.O. BOX 185

Trenton, New Jersey 08625-0185

NEW JERSEY ELECTION LAWENFORCEMENT COMMISSION

Complainant

v.

ELIZABETH MASON,Candidate for Municipal Office, City of Hoboken,Hudson County

and

RICHARD MASON, Campaign Treasurer,

Respondents

COMPLAINT AND NOTICE OF

OPPORTUNITY FOR A HEARING FOR

LATE FILING OF REPORTS AND

LATE FILING OF CONTRIBUTION

AND EXPENDITURE INFORMATION

IN THE 2011 MUNICIPAL ELECTION

C-9 0905 14 04 M2011

PLEASE TAKE NOTICE that the New Jersey Election Law Enforcement Commission

(hereafter, the Commission) hereby files a complaint against Elizabeth Mason (hereafter, the

Respondent Candidate), and Richard Mason (hereafter, the Respondent Treasurer), and offers the

Respondent Candidate and the Respondent Treasurer an opportunity for a hearing pursuant to the

“Administrative Procedure Act,” N.J.S.A. 52:14B-1 et seq., to determine whether or not the

Respondent Candidate and the Respondent Treasurer had the responsibility under the terms of

"The New Jersey Campaign Contributions and Expenditures Reporting Act," N.J.S.A. 19:44A-1,

et seq. (hereafter, the Act) for the filing of campaign reports or information required to be filed

pursuant to the Act, and to determine whether or not the Respondent Candidate and the

Respondent Treasurer failed, neglected or omitted to file any such report or information at the

time and in the manner prescribed by law, or in any other way violated the provisions of the Act,

and are therefore subject to penalties provided by the Act. The hearing will be conducted under

the legal authority and jurisdiction conferred upon the Commission to impose penalties for

violations of the Act, specifically Sections 6(b) and 22.

The Commission by way of Complaint alleges:

ELEC v. Elizabeth Mason and Richard MasonC-9 0905 14 04 M2011

FIRST COUNT

PROPOSED FINDINGS OF FACT:

1. Elizabeth Mason sought election to municipal office in the City of Hoboken, Hudson

County, in the 2011 municipal election held on May 10, 2011. Hereafter in this Complaint,

Elizabeth Mason shall be referred to as the Respondent Candidate.

2. The Respondent Candidate formed a single candidate committee for the purpose of

receiving contributions and making expenditures to support her candidacy in the 2011 municipal

election.

3. The Respondent Candidate designated her single candidate committee as “Friends of

Beth Mason for City Council” on a Single Candidate Committee – Certificate of Organization

and Designation of Campaign Treasurer and Depository” (Form D-1) filed with the Commission

on April 14, 2011.

4. The Respondent Candidate designated on the Form D-1, described in paragraph three

above, Richard Mason as her campaign treasurer relevant to the 2011 municipal election. The

Respondent Candidate and the Respondent Treasurer Richard Mason certified the Form D-1.

5. Richard Mason was a person who acted in the capacity of campaign treasurer for the

Respondent Candidate in the 2011 municipal election. In his capacity as campaign treasurer,

Respondent Treasurer Richard Mason undertook activity including the certification of campaign

reports filed by the Respondent Candidate in the 2011 municipal election. Hereafter in this

Complaint, Richard Mason shall be referred to as the Respondent Treasurer.

6. The Respondent Candidate and the Respondent Treasurer received and deposited

contributions into and made expenditures from a campaign depository account established and

maintained for the 2011 municipal election at “Wells Fargo, N.A.” in Hoboken, NJ (hereafter,

the 2011 municipal election campaign depository account).

7. The Respondent Candidate and the Respondent Treasurer certified as correct and filed

with the Commission on June 24, 2011, a Report of Contributions and Expenditures (Form R-1)

as a 20-day post election report for the 2011 municipal election (hereafter, 20-day post election

report), reporting outstanding obligations and a balance in the 2011 municipal election campaign

depository account.

8. The Respondent Candidate and the Respondent Treasurer also filed with the

Commission on July 21, 2011, a Report of Contributions and Expenditures (Form R-1) as an

amended 20-day post election report for the 2011 municipal election, and on July 11, 2012, a


Report of Contributions and Expenditures (Form R-1) as a second amended 20-day post election

report for the 2011 municipal election, which reported outstanding obligations and a balance in

the 2011 municipal election campaign depository account.


with the Commission on July 19, 2012, a Report of Contributions and Expenditures (Form R-1)

as a 2011 third quarter report for the 2011 municipal election (hereafter, 2011 third quarter

report), to report financial activity for the first time, for the 2011 municipal election for the time

period from May 28, 2011 through September 30, 2011 (hereafter, the 2011 third quarter report

period). The Respondent Candidate and the Respondent Treasurer reported on July 19, 2012,

receipts totaling $31,800.00 and expenditures totaling $35,407.50 relevant to the 2011 third

quarter report period for the 2011 municipal election.

10. The Respondent Candidate and the Respondent Treasurer reported on July 19, 2012

on the 2011 third quarter report on Schedule B (“In-Kind Contributions in Excess of $300”)

contribution information for seven contributions of goods or services (hereafter, in-kind

contributions), totaling $15,800.00, received in amounts greater than $300.00 in the aggregate in

the 2011 municipal election as of September 30, 2011, and relevant to the 2011 third quarter

report period.


on the 2011 third quarter report on Schedule C (“Loans Received in Excess of $300 and All

Currency Loans”) contribution information to report receipt of two loans received in the amounts

of $7,000.00 and $9,000.00, as contributions totaling $16,000.00, reported as received from

“Elizabeth Mason.”

12. The Respondent Candidate and the Respondent Treasurer deposited, or caused to be

deposited, into the 2011 municipal election campaign depository, two deposits in the amounts

described in paragraph eleven above, an amount of $7,000.00 by check drawn on the account of

“Elizabeth Mason” and an amount of $9,000.00 by check drawn on the account of “Richard and

Elizabeth Mason,” in the 2011 third quarter report period for the 2011 municipal election.

PROPOSED CONCLUSIONS OF LAW:

1. The Respondent Elizabeth Mason was a “candidate,” as the term “candidate” is

defined at N.J.S.A. 19:44A-3c, for municipal office in the City of Hoboken in the 2011

municipal election held on May 10, 2011, and therefore was subject to the reporting


requirements of the Act, N.J.S.A . 19:44A-1 to 47 and Commission Regulations, N.J.A.C. 19:25-

1 to 21.

2. The Respondent Richard Mason was the Respondent Candidate’s campaign treasurer

in the 2011 municipal election and was therefore subject to the requirements of the Act and

Commission Regulations.

3. The Respondent Candidate and the Respondent Treasurer were required, pursuant to

N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.1, N.J.A.C. 19:25-8.3, N.J.A.C. 19:25-10.2, and

N.J.A.C. 19:25-10.4 to certify as correct and file with the Commission on October 17, 2011, a full

cumulative Report of Contributions and Expenditures (Form R-1) as a 2011 third quarter report for

the 2011 municipal election, to report all contributions received and all expenditures made during

the time period from May 28, 2011 through September 30, 2011, that is the 2011 third quarter

report period for the 2011 municipal election.

4. The Respondent Candidate and the Respondent Treasurer were required pursuant to

N.J.S.A. 19:44A-16, N.J.A.C. 19:25-8.3, N.J.A.C. 19:25-10.2, N.J.A.C. 19:25-10.4, and N.J.A.C.

19:25-10.15 to report on October 17, 2011, on the 2011 third quarter report for the 2011 municipal

election, all contributions received, including all moneys, loans, paid personal services, or other

things of value, including contributions of goods and services (in-kind contributions), contributed

to the Respondent Candidate during the time period from May 28, 2011 through September 30,

2011. For each contribution received that was in excess of $300.00, either alone or when

aggregated with prior contributions received in the 2011 municipal election, through September

30, 2011, and for all contributions received in currency, the Respondent Candidate and Respondent

Treasurer were required to report the name and address of the contributor, the date of receipt of the

contribution, and the contribution amount, and to report for each contribution received from an

individual that was in excess of $300.00 in the aggregate, the occupation of said contributor and

the name and address of said contributor’s employer.

5. The Respondent Candidate and the Respondent Treasurer violated N.J.S.A. 19:44A-16

and N.J.A.C. 19:26-8.3, N.J.A.C. 19:25-10.2, and N.J.A.C. 19:25-10.4 by failing to certify as

correct and file with the Commission on October 17, 2011, a 2011 third quarter report (Form R-1)

for the 2011 municipal election, and to report contribution information relevant to the receipt of

seven in-kind contributions, totaling $15,800.00, as described in paragraph ten of the Proposed

Findings of Fact in this Count above. The Respondent Candidate and the Respondent Treasurer


reported contribution information for the seven in-kind contributions totaling $15,800.00, on July

19, 2012, after the October 17, 2011 due date and 276 days late.



correct and file with the Commission on October 17, 2011, a 2011 third quarter report (Form R-1)


contributions including all contributions received as loans, as described in paragraphs eleven and

twelve of the Proposed Findings of Fact in this Count above. The Respondent Candidate and the

Respondent Treasurer reported contribution information for two contributions received in the

amounts of $7,000.00 and $9,000.00 as loans, totaling $16,000.00, on July 19, 2012, after the

October 17, 2011 due date and 276 days late.

7. The Respondent Candidate and the Respondent Treasurer are each subject to imposition

by the Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et

seq., which penalties may not be more than $6,800.00 for each reporting transaction, that is, for

each contribution received which has not been reported in the manner or in the time established for

reporting by the Campaign Reporting Act or Commission Regulations.

SECOND COUNT


1. The Proposed Findings of Fact contained in the First Count of this Complaint are

repeated and incorporated herein as if set forth in full below.

2. The Respondent Candidate and the Respondent Treasurer reported for the first time on

July 19, 2012, on the 2011 third quarter report described in paragraph nine of the Proposed

Findings of Fact in the First Count above on “Schedule 1 (D) – Disbursements, Campaign

Expenses,” expenditure information relevant to the making of four expenditures totaling

$19,107.50, during the 2011 third quarter report period for the 2011 municipal election.


July 19, 2012 on the 2011 third quarter report on “Schedule 3 (D) – Disbursements, Contributions

made to other Candidates/Committees,” expenditure information relevant to the making of one

expenditure in the amount of $500.00, during the 2011 third quarter report period for the 2011

municipal election.


4. Upon information and belief, the Respondent Candidate and the Respondent Treasurer

made, incurred, or authorized the five expenditures totaling $19,607.50, described in paragraphs

two and three above during the 2011 third quarter report period for the 2011 municipal election.


July 19, 2012 on the 2011 third quarter report on “Table II, Expenditures, Line 6” (“In-kind

Contributions in Excess of $300”), an amount of expenditures totaling $15,800.00, relevant to the

receipt of seven in-kind contributions totaling $15,800.00, as described in paragraph ten of the

Proposed Findings of Fact in Count One above.


1. The Proposed Conclusions of Law contained in the First Count of this Complaint is

repeated and incorporated herein as if set forth in full below.


N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3 and N.J.A.C. 19:25-12.2 to certify as correct and

report on October 17, 2011, on the 2011 third quarter report for the 2011 municipal election,

expenditure information, including the date the expenditure was made, the full name and address

of the payee, the purpose of the expenditure, the amount of the expenditure, and the number of the

check for each expenditure transaction made during the time period beginning with the first

expenditure made, incurred or authorized in the 2011 municipal election from May 28, 2011

through September 30, 2011, that is, the 2011 municipal election third quarter report period.


and N.J.A.C. 19: 25-8.3 and N.J.A.C. 19:25-12.2 by failing to certify as correct and file with the

Commission on October 17, 2011, a 2011 third quarter report (Form R-1) for the 2011 municipal

election, and to report expenditure information relevant to the making of five expenditures, totaling

$19,607.50, in the 2011 municipal election third quarter report period, as described in paragraphs

two and three in the Proposed Findings of Fact in this Count above. The Respondent Candidate

and the Respondent Treasurer reported expenditure information for the five expenditures, totaling

$19,607.50, on July 19, 2012, after the October 17, 2011 due date and 276 days late.



Commission on October 17, 2011, a 2011 third quarter report (Form R-1), and to report

expenditure information relevant to the receipt of seven in-kind contributions totaling $15,800.00


in the 2011 municipal election third quarter report period, as described in paragraph five in the

Proposed Findings of Fact in this Count above. The Respondent Candidate and the Respondent

Treasurer reported an amount of $15,800.00, on July 19, 2012, after the October 17, 2011 due date

and 276 days late.




each expenditure that is not reported in the manner or not filed on the date established for reporting

by the Campaign Reporting Act or Commission Regulations.

THIRD COUNT


1. The Proposed Findings of Fact contained in the First and Second Counts of this

Complaint are repeated and incorporated herein as if set forth in full below.


with the Commission on July 19, 2012, a Report of Contributions and Expenditures (Form R-1) as

a 2011 fourth quarter report for the 2011 municipal election (hereafter, 2011 fourth quarter report),

to report financial activity for the first time, for the 2011 municipal election for the time period

from October 1, 2011 through December 31, 2011 (hereafter, the 2011 fourth quarter report

period). The Respondent Candidate and the Respondent Treasurer reported on July 19, 2012,

receipts totaling $47,002.85 and expenditures totaling $53,012.85 relevant to the 2011 fourth



on the 2011 fourth quarter report on Schedule B (“In-Kind Contributions in Excess of $300”)

contribution information for nine in-kind contributions, totaling $47,002.85, received in amounts

greater than $300.00 in the aggregate in the 2011 municipal election as of December 31, 2011,

and relevant to the 2011 fourth quarter report period.


1. The Proposed Conclusions of Law contained in the First and Second Counts of this





N.J.A.C. 19:25-10.4 to certify as correct and file with the Commission on January 17, 2012, a

Report of Contributions and Expenditures (Form R-1) as a 2011 fourth quarter report for the 2011

municipal election, to report all contributions received and all expenditures made during the time

period from October 1, 2011 through December 31, 2011, that is the 2011 fourth quarter report

period for the 2011 municipal election.



19:25-10.15 to report on January 17, 2012, on the 2011 fourth quarter report for the 2011

municipal election, all contributions received, including all moneys, loans, paid personal services,

or other things of value, including contributions of goods and services (in-kind contributions),

contributed to the Respondent Candidate during the time period from October 1, 2011 through

December 31, 2011. For each contribution received that was in excess of $300.00, either alone or

when aggregated with prior contributions received in the 2011 municipal election, through

December 31, 2011, and for all contributions received in currency, the Respondent Candidate and

Respondent Treasurer were required to report the name and address of the contributor, the date of

receipt of the contribution, and the contribution amount, and to report for each contribution

received from an individual that was in excess of $300.00 in the aggregate, the occupation of said

contributor and the name and address of said contributor’s employer.



correct and file with the Commission on January 17, 2012, a 2011 fourth quarter report (Form R-1)


nine in-kind contributions, totaling $47,002.85, as described in paragraph three of the Proposed


reported contribution information for the nine in-kind contributions totaling $47,002.85, on July

19, 2012, after the January 17, 2012 due date and 184 days late.







FOURTH COUNT


1. The Proposed Findings of Fact contained in the First through Third Counts of this


2. The Respondent Candidate and the Respondent Treasurer reported on July 19, 2012, on

the 2011 fourth quarter report described in paragraph two of the Proposed Findings of Fact in the

Third Count above on “Schedule 1 (D) – Disbursements, Campaign Expenses,” expenditure

information relevant to the making of one expenditure in the amount of $210.00, during the 2011

fourth quarter report period for the 2011 municipal election.


the 2011 fourth quarter report on “Schedule 2 (D) – Disbursements, Other,” expenditure

information relevant to the making of one expenditure in the amount of $800.00, during the 2011

fourth quarter report period for the 2011 municipal election.

4. The Respondent Candidate and the Respondent Treasurer reported on July 19, 2012 on

the 2011 fourth quarter report on “Schedule 3 (D) – Disbursements, Contributions made to other

Candidates/Committees,” expenditure information relevant to the making of one expenditure in the

amount of $5,000.00, during the 2011 fourth quarter report period for the 2011 municipal election.

5. Upon information and belief, the Respondent Candidate and the Respondent Treasurer

made, incurred, or authorized the three expenditures totaling $6,010.00, described in paragraphs

two through four above during the 2011 fourth quarter report period for the 2011 municipal

election.


the 2011 fourth quarter report on “Table II, Expenditures, Line 6” (“In-kind Contributions in

Excess of $300”), an amount of expenditures totaling $47,002.85, relevant to the receipt of nine in-

kind contributions totaling $47,002.85, as described in Paragraph Three of the Proposed Findings

of Fact in Count Three above.



1. The Proposed Conclusions of Law contained in the First through Third Counts of this




report on January 17, 2012, on the 2011 fourth quarter report for the 2011 municipal election,




expenditure made, incurred or authorized in the 2011 municipal election from October 1, 2011

through December 31, 2011, which is the 2011 municipal election fourth quarter report period.



Commission on January 17, 2012, a 2011 fourth quarter report (Form R-1) for the 2011 municipal

election, and to report expenditure information relevant to the making of three expenditures,

totaling $6,010.00, in the 2011 municipal election fourth quarter report period, as described in

paragraphs two through four in the Proposed Findings of Fact in this Count above. The

Respondent Candidate and the Respondent Treasurer reported expenditure information for the

three expenditures, totaling $6,010.00, on July 19, 2012, after the January 17, 2012 due date and

184 days late.



Commission on January 17, 2012, a 2011 fourth quarter report (Form R-1), and to report

expenditure information relevant to the receipt of nine in-kind contributions totaling $47,002.85 in

the 2011 municipal election fourth quarter report period, as described in paragraph six in the

Proposed Findings of Fact in this Count above. The Respondent Candidate and the Respondent

Treasurer reported an amount of $47,002.85, on July 19, 2012, after the January 17, 2012 due date

and 184 days late.







FIFTH COUNT


1. The Proposed Findings of Fact contained in the First through Fourth Counts of this



with the Commission on July 23, 2012, a Report of Contributions and Expenditures (Form R-1)

as a 2012 first quarter report for the 2011 municipal election (hereafter, 2012 first quarter report),

to report financial activity for the first time, for the 2011 municipal election for the time period

from January 1, 2012 through March 31, 2012 (hereafter, the 2012 first quarter report period).

The Respondent Candidate and the Respondent Treasurer reported on July 23, 2012, receipts

totaling $20,890.00 and expenditures totaling $29,197.35 relevant to the 2012 first quarter report

period for the 2011 municipal election.


on the 2012 first quarter report on Schedule B (“In-Kind Contributions in Excess of $300”)

contribution information for eight contributions of goods or services (hereafter, in-kind

contributions), totaling $18,890.00, received in amounts greater than $300.00 in the aggregate in

the 2011 municipal election as of March 31, 2012, made by the Respondent Candidate and the

Respondent Treasurer relevant to the 2012 first quarter report period.


on the 2012 first quarter report on Schedule C (“Loans Received in Excess of $300 and All

Currency Loans”) contribution information to report receipt of one loan as a contribution of

$2,000.00, reported as received from “Elizabeth Mason.”

5. The Respondent Candidate and the Respondent Treasurer deposited, or caused to be

deposited, into the 2011 municipal election campaign depository, one deposit of $2,000.00,

drawn on the account of “Richard and Elizabeth Mason,” in the 2012 first quarter report period

for the 2011 municipal election.



1. The Proposed Conclusions of Law contained in the First through Fourth Counts of this




N.J.A.C. 19:25-10.4 to certify as correct and file with the Commission on April 16, 2012, a Report

of Contributions and Expenditures (Form R-1) as a 2012 first quarter report for the 2011 municipal

election, to report all contributions received and all expenditures made during the time period from

January 1, 2012 through March 31, 2012, that is the 2012 first quarter report period for the 2011

municipal election.



19:25-10.15 to report on April 16, 2012, on the 2012 first quarter report for the 2011 municipal

election, all contributions received, including all moneys, loans, paid personal services, or other

things of value, including contributions of goods and services (in-kind contributions), contributed

to the Respondent Candidate during the time period from January 1, 2012 through March 31, 2012.

For each contribution received that was in excess of $300.00, either alone or when aggregated with

prior contributions received in the 2011 municipal election, through March 31, 2012, and for all

contributions received in currency, the Respondent Candidate and Respondent Treasurer were

required to report the name and address of the contributor, the date of receipt of the contribution,

and the contribution amount, and to report for each contribution received from an individual that

was in excess of $300.00 in the aggregate, the occupation of said contributor and the name and

address of said contributor’s employer.



correct and file with the Commission on April 16, 2012, a 2012 first quarter report (Form R-1) for

the 2011 municipal election, and to report contribution information relevant to the receipt of eight

in-kind contributions, totaling $18,890.00, as described in paragraph three of the Proposed


reported contribution information for the eight in-kind contributions totaling $18,890.00, on July

23, 2012, after the April 16, 2012 due date and 98 days late.




correct and file with the Commission on April 16, 2012, a 2012 first quarter report (Form R-1) for

the 2011 municipal election, and to report contribution information relevant to the receipt of

contributions including all contributions received as loans, as described in paragraphs four and five

of the Proposed Findings of Fact in this Count above. The Respondent Candidate and the

Respondent Treasurer reported contribution information for one contribution received as a loan,

totaling $2,000.00, on July 23, 2012, after the April 16, 2012 due date and 98 days late.






SIXTH COUNT


1. The Proposed Findings of Fact contained in the First through Fifth Counts of this



the 2012 first quarter report described in paragraph two of the Proposed Findings of Fact in the

Fifth Count above on “Schedule 1 (D) – Disbursements, Campaign Expenses,” expenditure

information relevant to the making of five expenditures totaling $3,807.35, during the 2012 first



the 2011 first quarter report on “Schedule 3 (D) – Disbursements, Contributions made to other

Candidates/Committees,” expenditure information relevant to the making of seven expenditures in

the amount of $6,500.00, during the 2012 first quarter report period for the 2011 municipal

election.


the 2012 first quarter report on “Table II, Expenditures, Line 6” (“In-kind Contributions in Excess

of $300”), an amount of expenditures totaling $18,890.00, relevant to the receipt of eight in-kind


contributions totaling $18,890.00, as described in Paragraph Three of the Proposed Findings of

Fact in Count Five above.


1. The Proposed Conclusions of Law contained in the First through Fifth Counts of this




report on April 16, 2012, on the 2012 first quarter report for the 2011 municipal election,




expenditure made, incurred or authorized in the 2011 municipal election from January 1, 2012

through March 31, 2012, that is, the 2011 municipal election 2012 first quarter report period.



Commission on April 16, 2012, a 2012 first quarter report (Form R-1) for the 2011 municipal

election, and to report expenditure information relevant to the making of twelve expenditures,

totaling $10,307.35, in the 2011 municipal election 2012 first quarter report period, as described in

paragraphs two and three in the Proposed Findings of Fact in this Count above. The Respondent

Candidate and the Respondent Treasurer reported expenditure information for the twelve

expenditures, totaling $10,307.35, on July 23, 2012, after the April 16, 2012 due date and 98 days

late.



Commission on April 16, 2012, a 2012 first quarter report (Form R-1), and to report expenditure

information relevant to the receipt of eight in-kind contributions totaling $18,890.00 in the

outstanding 2011 municipal election 2012 first quarter report period, as described in paragraph

four in the Proposed Findings of Fact in this Count above. The Respondent Candidate and the

Respondent Treasurer reported an amount of $18,890.00, on July 23, 2012, after the April 16, 2012

due date and 98 days late.







OPPORTUNITY FOR HEARING:

Pursuant to N.J.A.C. 19:25-17.1, the Respondents and all parties shall have the opportunity

to appear personally or by attorney at a hearing pursuant to the “Administrative Procedure Act,”

N.J.S.A. 52:14B-1 et seq., and to present evidence and argument on all relevant issues. All

parties shall have the opportunity to examine and cross-examine witnesses. However, failure of

each Respondent to file with the Commission a written answer within twenty (20) days after

service of this Complaint shall constitute a default pursuant to N.J.A.C. 19:25-17.1A and

thereupon the Commission may enter a Final Decision (including imposition of a monetary

penalty).

NEW JERSEY ELECTION LAWENFORCEMENT COMMISSION

BY: ________________________ CAROL L. HOEKJE Legal Director

DATE: February 26, 2014

Elizabeth Mason, CandidateCERTIFIED MAIL NO. 7009 3410 0001 8443 4947RETURN RECEIPT REQUESTED

Richard Mason, TreasurerCERTIFIED MAIL NO. 7009 3410 0001 8443 4930RETURN RECEIPT REQUESTED

beth mason elec complain part 2

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