in re: raquel regalado case no.: fec 15-372 / to: elliot s. berke ... · noh fec # 15-372 please...

NOH FEC # 15-372

STATE OF FLORIDA FLORIDA ELECTIONS COMMISSION

In Re: Raquel Regalado _____________________________________________/

Case No.: FEC 15-372

TO: Roland Sanchez-Medina, Jr., Esquire SM & GQ Attorneys at Law 201 Alhambra Circle, Suite 1205 Coral Gables, FL 33134-5107

Elliot S. Berke, Esquire Berke Farah LLP 1200 New Hampshire Avenue NW, Suite 800 Washington, DC 20036

NOTICE OF HEARING (INFORMAL HEARING) A hearing will be held in this case before the Florida Elections Commission on, November 16, 2016 at 8:30 am, or as

soon thereafter as the parties can be heard, at the following location: Senate Office Building, 404 South Monroe Street, Room 110-S, Tallahassee, Florida 32399

Failure to appear in accordance with this notice will constitute a waiver of your right to participate in the hearing. Continuances will be granted only upon a showing of good cause.

This hearing will be conducted pursuant to Section 106.25, Florida Statutes, which governs your participation as

follows: If you are the Respondent, you may attend the hearing, and you or your attorney will have 5 minutes to present your

case to the Commission. However, some cases (including those in which consent orders or recommendations for no probable cause are being considered) may be decided by an en masse vote and, unless you request to be heard or the Commission requests that your case be considered separately on the day of the hearing, your case will not be individually heard.

If you are the Complainant, you may attend the hearing, but you will not be permitted to address the Commission. In

addition, some cases (including those in which consent orders or recommendations for no probable cause are being considered) may be decided by an en masse vote and, unless the Respondent requests to be heard or the Commission requests that the case be considered separately on the day of the hearing, the case will not be individually heard.

If you are an Appellant, and you have requested a hearing, you may attend the hearing, and you or your attorney will have 5 minutes to present your case to the Commission.

Please be advised that both confidential and public cases are scheduled to be heard by the Florida Elections

Commission on this date. As an Appellant, Respondent or Complainant in one case, you will not be permitted to attend the hearings on other confidential cases.

The Commission will electronically record the meeting. Although the Commission’s recording is considered the

official record of the hearing, the Respondent may provide, at his own expense, a certified court reporter to also record the hearing.

If you require an accommodation due to a disability, contact Donna Ann Malphurs at (850) 922-4539 or by mail at 107

West Gaines Street, The Collins Building, Suite 224, Tallahassee, Florida 32399, at least 5 days before the hearing.

See further instructions on the reverse side. Amy McKeever Toman Executive Director

Florida Elections Commission November 1, 2016

NOH FEC # 15-372

Please refer to the information below for further instructions related to your particular hearing: If this is a hearing to consider an appeal from an automatic fine, the Filing Officer has imposed a fine on you for your failure to file a campaign treasurer’s report on the designated due date and, by filing an appeal, you have asked the Commission to consider either (1) that the report was in fact timely filed; or (2) that there were unusual circumstances that excused the failure to file the report timely. You are required to prove your case. If the Commission finds that the report was filed timely or that there were unusual circumstances that excused the failure, it may waive the fine, in whole or in part. The Commission may reduce a fine after considering the factors in Section 106.265, Florida Statutes. If the Commission finds that the report was not timely filed and there were no unusual circumstances, the fine will be upheld.

If this is a hearing to consider a consent order before a determination of probable cause has been made, the Commission will decide whether to accept or reject the consent order. If the Commission accepts the consent order, the case will be closed and become public. If the Commission rejects the consent order or does not make a decision to accept or deny the consent order, the case will remain confidential, unless confidentiality has been waived. If this is a hearing to consider a consent order after a determination of probable cause has been made, the Commission will decide whether to accept or reject the consent order. If the Commission accepts the consent order, the case will be closed. If the Commission rejects the consent order or does not make a decision to accept or deny the consent order, the Respondent will be entitled to another hearing to determine if the Respondent committed the violation(s) alleged. If this is a probable cause hearing, the Commission will decide if there is probable cause to believe that the Respondent committed a violation of Florida’s election laws. Respondent should be prepared to explain how the staff in its recommendation incorrectly applied the law to the facts of the case. Respondent may not testify, call others to testify, or introduce any documentary or other evidence at the probable cause hearing. The Commission will only decide whether Respondent should be charged with a violation and, before the Commission determines whether a violation has occurred or a fine should be imposed, Respondent will have an opportunity for another hearing at which evidence may be introduced. If this is an informal hearing, it will be conducted pursuant Sections 120.569 and 120.57(2), Florida Statutes; Chapter 28 and Commission Rule 2B-1.004, Florida Administrative Code. At the hearing, the Commission will decide whether the Respondent committed the violation(s) charged in the Order of Probable Cause. The Respondent will be permitted to testify. However, the Respondent may not call witnesses to testify. Respondent may argue why the established facts in the Staff Recommendation do not support the violations charged in the Order of Probable Cause. At Respondent’s request, the Commission may determine whether Respondent’s actions in the case were willful. The Respondent may also address the appropriateness of the recommended fine. If Respondent claims that his limited resources make him unable to pay the statutory fine, he must provide the Commission with written proof of his financial resources at the hearing. A financial affidavit form is available from the Commission Clerk.

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16 AUG 31 PM t: I 0

Florida Elections Commission, Petitioner,

Case No.: FEC 15-372 v.

Raquel A. Regalado, Respondent.

ORDER OF PROBABLE CAUSE

THIS MATTER was heard by the Florida Elections Commission (Commission) at its

regularly scheduled meeting on August 17, 2016, in Tallahassee, Florida.

Based on the Complaint, Report of Investigation, Staffs Recommendation, and oral

statements (if any) made at the probable cause hearing, the Commission finds that there is

probable cause to charge Respondent with the following violation(s):

Count 1:

On March 10, 2015, Raquel A. Regalado violated Section 106.19(1 )(a), Florida Statutes, when she accepted a contribution in excess of the limits prescribed by Section 106.08, Florida Statutes.

Count 2:


DONE AND ORDERED by the Florida Elections Commission on August 17, 2016.

P:/Order of Probable Cause.docx (07/14) FEC Case# 15-372

Copies furnished to:

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W~L M. Scott Thomas, Chairman Florida Elections Commission

Stephanie J. Cunningham, Assistant General Counsel Roland Sanchez-Medina, Jr., Attorney for Respondent Elliot S. Berke, Attorney for Complainant

NOTICE OF RIGHT TO A HEARING

As the Respondent, you may elect to resolve this case in several ways. First, you may elect to resolve this case by consent order where you and Commission staff agree to resolve the violation(s)s and agree to the amount of the fine. The consent order is then presented to the Commission for its approval. To discuss a consent order, contact the FEC attorney identified in the Order of Probable Cause.

Second, you may request an informal hearing held before the Commission, if you do not dispute any material fact in the Staff Recommendation. You have 30 days from the date the Order of Probable Cause is filed with the Commission to request such a hearing. The date this order was filed appears in the upper right-hand corner of the first page of the order. At the hearing, you will have the right to make written or oral arguments to the Commission concerning the legal issues related to the violation(s) and the potential fine. At the request of Respondent, the Commission will consider and. determine willfulness at an informal hearing. Otherwise, live witness testimony is unnecessary.

Third, you may request a formal hearing held before an administrative law judge in the Division of Administrative Hearings (DOAH), if you dispute any material fact in the Staff Recommendation. You have 30 days from the date the Order of Probable Cause is filed with the Commission to request such a hearing. The date this order was filed appears in the upper right-

. hand corner of the first page of the order. At the hearing, you will have the right to present evidence relevant to the violation(s) listed in this order, to cross-examine opposing witnesses, to impeach any witness, and to rebut the evidence presented against you.

If you do not elect to resolve the case by consent order or request a formal hearing at the DOAH or an informal hearing before the Commission within 30 days of the date this Order of Probable Cause is filed with the Commission, the case will be sent to the Commission for a formal or informal hearing, depending on whether the facts are in dispute. The date this order was filed appears in the upper right-hand corner of the first page of the order.

To request a hearing, please send a written request to the Commission Clerk, Donna Ann Malphurs. The address of the Commission Clerk is 107 W. Gaines Street, Collins Building, Suite 224, Tallahassee, Florida 32399-1050. The telephone number is (850) 922-4539. The Clerk will provide you with a copy of Chapter 28-106, Florida Administrative Code, and other applicable rules upon request. No mediation is available.

P:/Order of Probable Cause.docx (07/14) FEC Case# 15-372

I

Re: RR: FEC 15-372 [~ Stephanie Cunningham to: Roland

From: Stephanie Cunningham/OAG

To: [email protected]

Roland:

07/29/2016 05:02 PM

If you can provide a response by 8 a.m. on August 4th I will be able to include it in the materials that are sent to the Commissioners to review prior to the meeting. You can still submit a response prior to August 16th but it would be at the discretion of the Commission to review it during the meeting. The Commissioners have paused to read newly submitted documents during a meeting but that is not always the case.

You may also file a motion to continue with our office stating the specific reasons for the continuance. The motion would be presented at the August meeting and if granted, a hearing would be scheduled in November.

Stephanie J. Cunningham Assistant General Counsel Florida Elections Commission 107 W. Gaines Street Collins Building, Suite 224 Tallahassee, FL 32399-1050 [email protected] (850) 922-4539 (850) 921-0783 fax www.fec.state.fl.us

Roland Sanchez-Medina Jr. Please call me Roland. Thank you ver ...

From: Roland Sanchez-Medina Jr. <[email protected]> To: Date:

Stephanie Cunningham <[email protected]> 07/25/201610:03 AM RR: FEC 15-372

Please call me Roland. Thank you very much.

Roland

ROLAND SANCHEZ-MEDINA JR, ESQ. s ,'1,t\ ---·-;;-·,---::---------(

,, dMC:.G! LAW ]

201 Alhambra Circle I Suite 1205 I Coral Gables, Florida 33134-5107 Office: 305.377.1000 Ext. 108 I Direct Fax: 855.898.0454 I Toll Free: 855.213.4806

[email protected] I SMGQLA W.com I Attorney Bio

07/25/2016 10:03:14 AM

CONFIDENTIALITY NOTE: The information contained in this transmission may be privileged and confidential information, and is intended only fc recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received t~ communication in error and then delete it. Thank you.

CIRCULAR 230 NOTICE: To comply with U.S. Treasury Department and IRS regulations, we are required to advise you that, unless expressly statcc used, and cannot be used, by any person for the purpose of (i) avoiding penalties under the U.S. Internal Revenue Code, or (ii) promoting, ma:keting

From: Stephanie Cunningham [mailto:[email protected]] Sent: Monday, July 25, 2016 10:01 AM To: Roland Sanchez-Medina Jr. Subject: Re: RR: FEC 15-372

Mr. Sanchez-Medina:

The Commission meets quarterly so if the case is not heard in August it would be pushed back to November. I do not decide which cases appear on the agenda but as a matter of course, once a staff recommendation is issued that case is typically set for the next available meeting. The initial hearing is to determine if there is probable cause to go forward. There will be additional opportunities to submit information to the Commission if probable cause is found. However, I will still inquire as to whether we can accept your response after the deadline in light of your situation and will email you later this week.

Stephanie J. Cunningham Assistant General Counsel Florida Elections Commission 107 W. Gaines Street Collins Building, Suite 224 Tallahassee, FL 32399-1050 [email protected] (850) 922-4539 (850) 921-0783 fax www.fec.state.fl.us

Roland Sanchez-Medina Jr. ---07/24/2016 04:35:55 PM---Ms. Cunningham, I understand your scheduling and I'm not trying to be argumentative, but I see it as

From: Roland Sanchez-Medina Jr. <[email protected]> To: Stephanie Cunningham <[email protected]> Cc: Donna Malphurs <[email protected]> Date: 07/24/2016 04:35 PM Subject: RR: FEC 15-372

Ms. Cunningham,

I understand your scheduling and I'm not trying to be argumentative, but I see it as an issue of proper due process and simple fairness while you are responding to me with the proposed schedule. Your correspondence was received by my office on July 19, 2016 leaving one week to file a response. As it so happens, I am on vacation with my family this week, vacation that had been planned months ago. I will not be able to provide additional information, information that would be helpful to our position.

It is unclear to me why it's not in the best interest of the FEC to have all of the information it needs in order to reach a just conclusion. What is the prejudice to the FEC by delaying the probable cause determination until the following month? Thank you for your consideration.

Roland

*As an aside, in a world where everyone works via email, why would the FEC want to delay delivery of a letter that has time limitations?

ROLAND SANCHEZ-MEDINA JR, ESQ. S tvi ---~:-·--=.-::----------G. l1. .. :.M(:.q LAW

201 Alhambra Circle I Suite 1205 I Coral Gables, Florida 33134-5107

Office: 305.377.1000 Ext. 108 I Direct Fax: 855.898.0454 I Toll Free: 855.213.4806

[email protected] I S_MGQLAW.coJrL I At_tmne)'.]3io

CONFIDENTIALITY NOTE: The information contained in this transmission may be privileged and confidential information, and is intended only fc recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received tt communication in error and then delete it. Thank you.

CIRCULAR 230 NOTICE: To comply with U.S. Treasury Department and IRS regulations, we arc required to advise you that, unless expressly statec used, and cannot be used, by any person for the purpose of (i) avoiding penalties under the U.S. Internal J{evcnuc Code, or (ii) promoting, marketing

From: Stephanie Cunningham [mailto:[email protected]] Sent: Friday, July 22, 2016 3:08 PM To: Roland Sanchez-Medina Jr. Cc: Donna Malphurs Subject: Fw: RR: FEC 15-372

Mr. Sanchez-Medina:

The last day for my office to receive a response to the Staff Recommendation is July 29th. This case will likely be placed on the August agenda for a probable cause determination hearing to take place on August 16th or 17th. The Commission receives the case materials prior to the meeting so that they may have adequate time to review each case. If you submit a response after the July 29th deadline it will not be received in time to be provided to the commissioners prior to the hearing. The document would still be placed in the case file but it would be at the Commission's discretion as to whether they would like to review or consider the document at the probable cause hearing.

Stephanie J. Cunningham Assistant General Counsel Florida Elections Commission 107 W. Gaines Street Collins Building, Suite 224 Tallahassee, FL 32399-1050 [email protected] (850) 922-4539 (850) 921-0783 fax

www. fee.state. fl. us

-----Forwarded by Stephanie Cunningham/OAG on 07/22/2016 02:49 PM-----

From: Florida Elections Commission/OAG To: Stephanie Cunningham/OAG@OAG Date: 07/21/2016 04:24 PM Subject: Fw: RR: FEC 15-372 Sent by: Donna Malphurs

Stephanie,

Please respond to Mr. Sanchez's request for additional time to respond to the Staff Recommendation. The last day to submit information is July 29th.

Thanks,

Donna -----Forwarded by Donna Malphurs/OAG on 07/21/2016 04:23 PM-----

From: Roland Sanchez-Medina Jr. <[email protected]> To: "[email protected]" <[email protected]> Cc: Michael Montiel <[email protected]> Date: 07/21/2016 03:35 PM Subject: RR: FEC 15-372

To Whom It May Concern:

The attached correspondence is dated July 12, 2016, but was received by my office on July 19, 2016 leaving only one week to file a response. We intend to respond on behalf of our client, however, seven days (or 4 entire business days) is an inadequate amount of time and is compounded by the fact there are only 39 days left before the election.

We respectfully request an additional thirty (30) days to respond and amend the initial response with some additional information. While we understand how important it is to address potential violations of Florida's election laws, the FEC is not prejudiced in any manner by granting Ms. Regalado the additional time.

I look forward to your response.

Roland

ROLAND SANCHEZ-MEDINA JR, ESQ.

SM SMGQ LAW dt1~-··---···---·------------------------201 Alhambra Circle I Suite 1205 I Coral Gables, Florida 33134-5107

Office: 305.377.1000 Ext. 108 I Direct Fax: 855.898.0454 I Toll Free: 855.213.4806

[email protected] I SM.G_QLA W_,_<;:QJ1! .. I AttorneyJ3.io CONFIDENTIALITY NOTE: The information contained in this transmission may be privileged and confidential information, and is intended only fc recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received tt communication in error and then delete it. Thank you. CIRCULAR 230 NOTICE: To comply with U.S. Treasury Department and IRS regulations, we are required to advise you that, unless expressly statec used, and cannot be used, by any person for the purpose of (i) avoiding penalties under the U.S. Internal Revenue Code, or (ii) promoting, marketing

[attachment "Investigation Report - FEC 15-372 - Recommendation of Probable Cause.pdf" deleted by Stephanie Cunningham/DAG)

Stephanie,

RE: RR: FEC 15-372 Roland Sanchez-Medina Jr. to: Stephanie Cunningham 07/22/2016 03:29 PM Cc: Donna Malphurs, Michael Montiel Hide Details From: Roland Sanchez-Medina Jr. <[email protected]> To: Stephanie Cunningham <[email protected]> Cc: Donna Malphurs <[email protected]>, Michael Montiel <[email protected]>

Page 1of3

Thank you for your prompt response. I understand the tirneline that you have provided. Unfortunately, I will be out of the office next week due to prior engagements, and will be unable to

provide a comprehensive response prior to July 29th. This is prejudicial towards my client. Is there a reason that this hearing must proceed in August and cannot be pushed back to September? I'd like to reiterate that an extension will not prejudice the Commission, as we are still months away from the election. I am simply seeking the time and opportunity to provide the .FEC the best possible response on behalf of my client. Thank you for your consideration.

Roland

ROLAND SANCHEZ-MEDINA JR, ESQ. S.i\A ·---;;-~-------

·····"' "(~ dMGQ lAW C:i · .t "'-'"

201 Alhambra Circle I Suite 1205 I Coral Gables, Florida 33134-5107 Office: 305.377.1000 Ext. 108 I Direct Fax: 855.898.0454 I Toll Free: 855.213.4806

[email protected] I SMGQLA W.com I Attorney Bio

CONFIDENTIALITY NOTE: The information contained in this transmission may be privileged and confidential information, and is intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you arc hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this transmission in error, please immediately reply to the sender that you have received this communication in error and then delete it. Thank you.

CIRCULAR 230 NOTICE: To comply with U.S. Twasury Department and IRS regulations, we are required to advise you that, unless expressly stated otherwise, any U.S. federal tax advice contained in this transmittal, is not intended or written to be used, and cannot be used, by any person for the purpose of (i) avoiding penalties under the U.S. Internal Revenue Code, or (ii) promoting, marketing or recommending to another party any transaction or matter addressed in this e-mail or attachment.

From: Stephanie Cunningham [mailto:[email protected]] Sent: Friday, July 22, 2016 3:08 PM To: Roland Sanchez-Medina Jr. Cc: Donna Malphurs Subject: Fw: RR: FEC 15-372

Mr. Sanchez-Medina:

file:///C:/Users/malphursd/AppData/Local/Temp/notes5D3EFE/~web4486.htm 7/26/2016

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The last day for my office to receive a response to the Staff Recommendation is July 29th. This case will likely be placed on the August agenda for a probable cause determination hearing to take place on August 16th or 17th. The Commission receives the case materials prior to the meeting so that they may have adequate time to review each case. If you submit a response after the July 29th deadline it will not be received in time to be provided to the commissioners prior to the hearing. The document would still be placed in the case file but it would be at the Commission's discretion as to whether they would like to review or consider the document at the probable cause hearing.

Stephanie J. Cunningham Assistant General Counsel Florida Elections Commission 107 W. Gaines Street Collins Building, Suite 224 Tallahassee, FL 32399-1050 stl~phan ie. cunning [email protected] (850) 922-4539 (850) 921-0783 fax www.fec.state.fl.us

----··Forwarded by Stephanie Cunningham/OAG on 07/22/2016 02:49 PM-----

From: Florida Elections Commission/OAG To: Stephanie Cunningham/OAG@OAG Date: 07/21/2016 04:24 PM Supject: Fw: RR: FEC 15-372 Sent by: Donna Malphurs

Stephanie,

Please respond to Mr. Sanchez's request for additional time to respond to the Staff Recommendation. The last dc:w to submit information is July 29th.

Thanks,

D6nna ---~,Forwarded by Donna Malphurs/OAG on 07/21/2016 04:23 PM-----

From: Roland Sanchez-Medina Jr. <[email protected]> To.: "[email protected]" <[email protected]> Cc: Michael Montiel <[email protected]> Date: 07/21/2016 03:35 PM Subject: RR: FEC 15-372

To Whom It May Concern:

The attached correspondence is dated July 12, 2016, but was received by my office on July 19, 2016 leaving only one week to file a response. We intend to respond on behalf of our client, however, seven days (or 4 entire business days) is an inadequate amount of time and is compounded by the fact there are only 39 days left before the election.

We respectfully request an additional thirty (30) days to respond and amend the initial response with some a~·~itional information. While we understand how important it is to address potential violations of Florida's

file :///C :/U sers/malphursd/ AppData/Local/Temp/notes5D3 EFE/ ~we b4486 .htm 7/26/2016

of3

election laws, the FEC is not prejudiced in any manner by granting Ms. Regalado the additional time.

I look forward to your response.

Roland

ROLAND SANCHEZ-MEDINA JR, ESQ .

. ~!~~ SMG(;t LAW l1. c~~-··.·--·--···-·-··--·--········-·---······-20'i Alhambra Circle I Suite 1205 I Coral Gables, Florida 33134-5107 Office: 305.377.1000 Ext. 108 I Direct Fax: 855.898.0454 I Toll Free: 855.213.4806 [email protected] I SMGQLA W.com I Attorney Bio

CONFIDENTIALITY NOTE: The information contained in this transmission may be privileged and confidential information, and is intended only for the use of the individual or entity named above. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this transmission in error, please immediately reply to the sender that you have received this communication in error and then delete it. Thank you.

CIRCULAR 230 NOTICE: To comply with U.S. Treasury Department and IRS regulations, we are required to advise you that, unless exp_ressly stated otherwise, any U.S. federal tax advice contained in this transmittal, is not intended or written to be used, and cannot be used, by any person for the purpose of (i) avoiding penalties under the U.S. Internal Revenue Code, or (ii) promoting, marketing or recommending to another party any transaction or matter addressed in this e-mail or attachment.

[attachment "Investigation Report - FEC 15-372 - Recommendation of Probable Cause.pdf" deleted by Stephanie Cunningham/DAG]

file:///C:/U sers/malphursd/ AppData/Local/Temp/notes5D3EFE/~web4486.htm 7/26/2016

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In Re: Raquel A. Regalado Case No.: FEC 15-372 I --------------------------

STAFF RECOMMENDATION FOLLOWING INVESTIGATION

Pursuant to Section 106.25( 4)( c ), Florida Statutes, undersigned staff counsel files this written recommendation for disposition of the complaint in this case recommending that there is probable cause to charge Respondent with violating Section 106.19(1)(a), Florida Statutes. Based upon a thorough review of the Report of Investigation submitted on June 17, 2016, the following facts and law support this staff recommendation:

1. On June 29, 2015, the Florida Elections Commission ("Commission") received a sworn complaint from Darren Centinello ("Complainant"), alleging that Raquel A. Regalado ("Respondent") violated Chapter 106, Florida Statutes.

2. Respondent is a 2016 candidate for Mayor of Miami-Dade County. Respondent's Statement of Candidate form ("DS-DE 84") was filed on March 9, 2015. (ROI Exhibit 17)1

3. By letter dated November 23, 2015, the Executive Director notified Respondent that Commission staff would investigate the following statutory provision:

Section 106.19(1)(a), Florida Statutes: Raquel A. Regalado, a 2016 candidate for the office of Mayor of Miami-Dade County, may have accepted one or more contributions in excess of the limits prescribed by Section 106.08, Florida Statutes, as alleged in the complaint.

4. Complainant alleged that Respondent violated Florida's election laws by accepting contributions in excess of the limits prescribed by Section 106.08, Florida Statutes. More specifically, Complaint alleged that Respondent accepted excessive in-kind contributions from Serving Miamians in the form of a professionally produced campaign website and video.

5. Under Section 106.19(1 )(a), Florida Statutes, a candidate for county mayor who knowingly and willfully accepts a contribution in excess of $1,000 commits a violation of Florida's election laws. The contribution limit applies to each election, with the primary and general election being treated as separate elections so long as the candidate is not unopposed. The race for mayor of Miami-Dade County has a primary election scheduled for August 30, 2016, with a general election scheduled for November 8, 2016.

1 The Report oflnvestigation is referred to herein as "ROI."

Staff Recommendation FEC 15-372 1

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6. Complainant provided a print out of Respondent's website located at http://raquelregalado.com as of April 2, 2015. The website contains express advocacy stating, "Raquel Regalado for Miami-Dade County Mayor." The website contains the following disclaimer: "Paid and approved by Serving Miamians." The website also contains a video. (ROI Exhibit 3) Complainant alleged that the video depicts Respondent stating "I'm Raquel Regalado, and I'm asking for your support to be the next Mayor of Miami-Dade County." Complainant alleged that the video contains a disclaimer stating: "Paid for and approved by Serving Miamians."

7. Serving Miamians is an electioneering communications organization registered with the Division of Elections. The organization's chairperson is Roland Sanchez-Medina and its treasurer is Carlos Trueba. (ROI Exhibit 2) It should be noted that Mr. Sanchez-Medina is representing Respondent in this matter and Mr. Trueba is also the treasurer for Respondent's campaign. (ROI Exhibits 1-2; ROI Exhibit 5, page 1)

8. On March 6, 2015, Ennovva Inc. issued two invoices to Serving Miamians requesting payment in the amounts of $1,500 and $3,580 for video production and website design. The invoices show that the campaign video was filmed on February 26, 2015, March 5, 2015, and March 6, 2015. (ROI Exhibit 13)

9. Serving Miamians disclosed two expenditures to Ennovva Inc. on March 10, 2015 in the amounts of $1,500 and $3,580 for the purposes of web design and advertising production, respectively. (ROI Exhibit 4) The organization's bank records confirm the reporting of the expenditures. (ROI Exhibit 15, pages 1-2) The organization's bank records also show that Ennovva Inc. issued a check in the amount of $5,080 to Serving Miamians on September 25, 2015. (ROI Exhibit 15, page 3)

10. On April 8, 2015, Respondent filed her first campaign treasurer's report (2015 M3 Report). The report shows that at the time Serving Miamians paid the invoices and the work had already been completed (March 10, 201.5), Respondent had not yet received any campaign contributions. Respondent's first contribution was received on March 12, 2015 and was in the amount of $250. (ROI Exhibit 8)

11. Respondent's 2015 M9 Report shows two expenditures to Ennovva Inc. on September 25, 2015 in the amounts of $1,500 and $3,780 for the purposes of web design and advertising production, respectively. (ROI Exhibit 9, page 4) Commission staff requested that Respondent provide copies of the checks showing that Respondent paid Ennovva Inc. for the web design and advertising production, but Respondent failed to provide the records and Respondent's designated campaign depository was unable to locate an account in her name. (Attachment A, Phone Log Entries 15, 22-23)

12. Respondent stated that Serving Miamians mistakenly engaged Ennovva Inc. to design the website for Respondent. Respondent stated that Serving Miamians later requested and received a refund and that Respondent then paid for the work already performed along with an extra fee to change the disclaimer in the video found on the website and remove the references to Serving Miamians on the website and video. Respondent stated that Serving Miamians intended


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to engage Ennovva Inc. to create videos in furtherance of its purpose as an electioneering communications organization. She stated that the website went live on March 9, 2015 but was not intended to be accessed by visitors. She stated that the website was taken down upon receipt of the Commission's letter dated September 4, 2015. (ROI Exhibit 5, page 2)

13. Respondent stated that she did not have any communications with Serving Miamians regarding the creation of the website or video. She stated that she appeared in the video but did not review or approve it before it went live. She also stated that she became aware that the video was available on the website when she received a copy of the complaint in this matter. (ROI Exhibit 11)

14. Mr. Sanchez-Medina, chairperson, Serving Miamians, and attorney for Respondent, stated that the organization made an expenditure to Ennovva Inc. for web design and for the creation of a video. Mr. Sanchez-Medina stated that Ennovva Inc. created the disclaimer as a result of the execution of the contract between Serving Miamians and Ennovva Inc. He stated that the website was not approved or reviewed and not intended to go live. Mr. Sanchez-Medina thinks that Ennovva Inc. was testing the design and connectivity of the website when the video was erroneously uploaded. He stated that the language included in the video requesting support for Respondent was simply a mistake as the intent of video was to educate Miami-Dade County regarding various issues. (ROI Exhibit 12)

15. Mr. Sanchez-Medina stated that Amelie Ferro, CEO, Ennovva Inc. d/b/a Cimacast, was responsible for the verbiage on the website. (ROI Exhibit 12, page 1) Commission staff attempted to contact Ms. Ferro regarding Respondent's and Serving Miamians' involvement in the production of the campaign website and video, but Ms. Ferro failed to respond to Commission staffs investigation. (Attachment A, Phone Log Entries 19-21; ROI Exhibit 14)

16. On February 26, 2015, March 5, 2015, and March 6, 2015, Respondent filmed scenes for the campaign video. Between February 26, 2015 and March 6, 2015, the campaign website was designed. On March 9, 2015, the campaign website and video were published, and Respondent became a candidate for Mayor of Miami-Dade County. On March 10, 2015, Serving Miamians paid Ennovva Inc. for the production of the campaign website and video. On March 12, 2015, Respondent received her first campaign contribution which totaled $250. On April 2, 2015, Complainant printed a copy of Respondent's website which formed the basis of the complaint. On September 4, 2015, the campaign website and video were no longer available to the public.

1 7. The campaign video was filmed before Respondent became a candidate and published, along with the website, before Respondent ever received any campaign contributions. Serving Miamians had a contract with Ennovva Inc. Ennovva Inc. issued invoices to Serving Miamians for video production and website design and Serving Miamians paid those invoices. The website and video contained language expressly advocating for the election of Respondent and contained disclaimers stating that the website and video were paid for and approved by Serving Miamians. Respondent personally appeared in the video. The website and video were available to the public for at least 179 days.


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18. The website is currently active and contains a video showing Respondent speaking directly to the camera for approximately one and a half minutes. In the video Respondent announces her candidacy and briefly discusses her opponent and platform before asking for support in the coming election. It is likely that this is the same video that was originally published as Respondent stated that she appeared in the original video and that she had to pay a small fee at a later date to change the disclaimer in the video.

19. The campaign website and video are in-kind contributions. They expressly advocate for the election of a candidate and were coordinated with the candidate, who appears in the video. Therefore, they are not electioneering communications nor are they independent expenditures.

20. It is of no import that the campaign website and video were not intended to be released to the public when they ultimately were. On March 10, 2015, an excessive in-kind contribution had already been accepted by Respondent regardless if the public could view the website and video. Further, it is simply not believable that the language included in the video requesting support for Respondent was simply a mistake because it was the intent of Serving Miamians' that the video educate Miami-Dade County regarding various issues. Ennovva Inc. invoiced Serving Miamians prior to Respondent becoming a candidate and Serving Miamians paid the invoices at a time when Respondent did not have the funds to incur the expenditures for the professionally produced campaign website and video.

21. Respondent accepted in--kind contributions from Serving Miamians in excess of the limits prescribed by Section 106.08, Florida Statutes.

22. "Probable Cause" is defined as reasonable grounds of suspicion supported by circumstances sufficiently strong to warrant a cautious person in the belief that the person has committed the offense charged. Schmitt v. State, 590 So. 2d 404, 409 (Fla. 1991). Probable cause exists where the facts and circumstances, of which an [investigator] has reasonably trustworthy information, are sufficient in themselves for a reasonable man to reach the conclusion that an offense has been committed. Department of Highway Safety and Motor Vehicles v. Favino, 667 So. 2d 305, 309 (Fla. 1st DCA 1995).

23. The facts set forth above show that Respondent is a 2016 candidate for Mayor of Miami-Dade County. Respondent accepted in-kind contributions from Serving Miamians in excess of the limits prescribed by Section 106.08, Florida Statutes.

Based upon these facts and circumstances, I recommend that the Commission find probable cause to charge Respondent with violating the following:

Count 1:



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Count2:


Respectfully submitted on July \?", 2016.

Assistant General Counsel

I reviewed this Staff Recommendation this ~y of July 2016.


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FLORIDA ELECTIONS COMMISSION PHONE LOG


Respondent: Raquel Regalado

Complainant: Darren Centinello

I. Date and time: February 11, 2016 @3:10 p.m .. · Name: Barbara Herrera, SOE's office Phone#: 305-499-8376 Summary: Ms. Herrera stated that they had completed the affidavit and sent it to me certified. Ms. Herrera asked if I would like her to email the affidavit to me. I answered affirmatively and gave her my email address. Memo to File? No Entered by: MBW

2. Date and time: March 14, 2016@ 11:04 a.m. Name: Elliot Berke, C's attorney Phone #: 202-517-0585 Summary: I called Mr. Berke to introduce myself as the investigator assigned to the case and to inform him that I am preparing a questionnaire affidavit for his client. There was no answer; I left a message on his voice mail. Memo to File? No Entered by: MBW

3. Date and time: March 15, 2016@ 8:28 a .. m .. Name: Mr. Berke Phone#: 202-517-058.5 Summary: I returned an earlier call from Mr. Berke. He did not answer. I left a message. Memo to File? No Entered by: MBW

4. Date and time: March 15, 2016 @ 11 :23 a.m. Name: Mr. Berke Phone#: 202-517-058.5 Summary: Mr. Berke returned my call. I informed him that I had a couple of questions for his client to clarify information in the complaint narrative. I told him that I compiled a questionnaire and mailed it yesterday. I asked him to ask his client to complete and return the questionnaire.. He agreed. Memo to File? No Entered by: MBW

5. Date and time: March 23, 2016 @ 11 : 03 a .. m. Name: Ennovva Phone#: 855-366-6882 Summary: I called the vendor at the telephone number that is posted on their website .. The is a non-working number. Memo to File? No

InvOO I (I 0/07)

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Entered by: MBW

6. Date and time: April 7, 2016@ 8:51 a.m. Name: Roland Medina, R's attorney Phone#: 305-593-2644

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Summary: I returned a call from Mr.. Medina. He was not in; I left a message with his assistant. Memo to File? No Entered by: MBW

7. Date and time: April 8, 2016@ 11:07 a.m .. Name: Connie Pazos Phone#: 305-377--1000 ex108 Summary: Ms .. Pazos returned my earlier call. She stated that they are the treasurer for Respondent's campaign. I informed her that when I called yesterday, I thought this number was the number for Roland Medina; she stated that it was not. She asked what I needed, she stated that she would try to assist me. I informed her that when I called yesterday, I was returning a call from that number. She was not aware of anyone calling the FEC. Ms. Pazos gave me Mr. Medina's telephone number, 305-377-1000. Memo to File? No Entered by: MBW

8. Date and time: April 11, 2016@ 9::11 a . .m .. Name: Respondent Phone#: 786-306-9180 Summary: I returned an earlier call .. (Respondent called Friday at 4:52 p.m. and left a message on my voice mail that she was trying to reach me to ask for an extension on the deadline to return the affidavit.) There was no answer; the mailbox was full. Memo to File? No Entered by: MBW

9. Date and time: May 2, 2016 @2:06 p.m. Name: Roland Medina, R's atty Phone#: 305-377-1000 ex. 108 Summary: I called R's attorney to discuss resolving the case since I did not receive the affidavit back. He stated that he never received the affidavit. He stated that if I emailed the affidavit to him he would return it promptly. He stated that his email address is Roland(a)smgqlaw.com. I agreed .. Memo to File? No Entered by: MBW

10. Date and time: May 10, 2016@ 12:16 p.m. Name: Roland Sanchez·-Medina Phone#: 305-377-1000 Summary: I called R's attorney regarding the outstanding affidavits (R's and the ECO) .. He was not in; I left a message on his voice mail. Memo to File? No Entered by: MBW

INVOOI (12/01) 2

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11. Date and time: May 13, 2016@ 11 :11 a .. m .. Nariie: Roland Sanchez-Medina Phone#: 305-377-1000 Summary: I called R's attorney regarding the outstanding affidavits (R's and the ECO). He was not in; I left a message with the receptionist. Memo to File? No Entered by: MBW

12. Date an(t time: May 16, 2016 @4::13 p.m. Name: Roland Sanchez-Medina Phone#: 305-377-1000 Summary: I called R's attorney regarding the outstanding affidavits (R's and the ECO). According to the receptionist, he was on another line.. I left a message on his voice mail. Memo to File? No Entered by: MBW

13.. Date and time: May 19, 2016@ 1:51 p.m. Name: Roland Sanchez-Medina Phone#: 305-377-1000 Summary: I called R's attorney in response to an email in which he queried about a preprobable cause consent order. I explained the procedure for a pre-probable cause consent order. He stated that he would speak to his client and call me back tomorrow morning. Memo to File? No Entered by: MBW

14.. Date and time: May 20, 2016@ 12:02 p.m. Name: Roland Sanchez-Medina Phone#: 305-377-1000 Summary: I called R's attorney because we agreed that he would let me know this morning whether or not his client want to enter a pre-probable cause consent order. He was not in; I left a message on his voice maiL Memo to File? No Entered by: MBW

15.. Date and time: May 20, 2016@ 12:41 p.m. Name: Roland Sanchez-Medina Phone#: 305-377-1000 Summary: Mr .. Sanchez-Medina returned my call. He stated that Mr. Michael Montiel, another attorney with the firm, was also present on the calL He stated that he has decided to complete the affidavits and send the requested information (checks to and from the vendor). He asked if it were possible for me to re-send the affidavits. I answered affirmatively.. I asked when would I receive the affidavit and bank records (initial check to Ennovva, refund from Ennovva and the checks from Respondent's campaign to Ennovva) .. He stated that he would get the information to me by Tuesday. I agreed .. Memo to File? No Entered by: MBW

16.. Date and time: May 26, 2016@ 8::48 a.m.

INVOOl (12/01) 3

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Name: Roland Sanchez-Medina Phone#: 305-377-1000 Summary: I received a call from Respondent's atty.. He stated that he was aware that they missed the deadline for the affidavits. He stated that the candidate has been out of town. He asked for an extension until Monday. He stated he would scan an email the documents and overnight the originals. I agreed .. Memo to File? No Entered by: MBW

17. Date and time: May 26, 2016 @9:38 a.m. Name: Roland Sanchez-Medina Phone#: 305-377-1000 Summary: I received an email from Mr. Sanchez-Medina requesting that I call him. I called.. His assistant, Karen, stated that he was on another line. I left my name and number .. Memo to File? No Entered by: MBW

18. Date and time: May 26, 2016@ 1:35 p.m. Name: Roland Sanchez-Medina Phone#: 305--377-1000 Summary: Mr .. Sanchez-Medina returned my call .. I explained that the extension from Monday until Tuesday in my email was due to the Memorial Day Holiday. He thanked me for the correction. Memo to File? No Entered by: MBW

19. Date and time: June 1, 2016 @ 3 ::23 p .. m .. Name: Amelie Ferro, Web Designer Phone#: 305-938-0728 Summary: I called Ms. Ferro to query about Respondent's website. She stated that she was on the phone and asked me to call back in 5 or 10 minutes. I agreed .. Memo to File? No Entered by: MBW

20.. Date and time: June 1, 2016 @3:39 p .. m. Name: Amelie Ferro, Web Designer Phone#: 305-938-0728 Summary: I called Ms .. Ferro again as she requested .. I explained why I was calling. Ms .. Ferrn stated that it would be better for her if I sent a list of questions to her via email. I agreed.. She stated that her email address is aferro(Cl!cimacast.com. Memo to File? No Entered by: MBW

2L Date and time: June 9, 2016@ 10::03 a .. m. Name: Amelie Ferro, Web Designer Phone#: 305-938-0728

INVOOl (12/01) 4

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Summary: I called Ms .. Ferro to query about the email that I sent her after our previous conversation .. No one answered; I left a message. Memo to File? No Entered by: MBW

22. Date and time: June 14, 2016@ 10:31 a .. m. Name: Michael Montiel, R's atty. Phone#: 305-377-1000 Summary: I called Mr. Montiel to request copies of the checks Respondent issued to Ennovva. He was not in; I left a message. Memo to File? No Entered by: MBW

23. Date and time: June 15, 2016@ 9:45 p .. m. Name: Mayra Espinola, City National Bank Phone#: 305-577-·7294 Summary: I called Ms. Espinola regarding the Serving Miamians subpoena. She stated that she received two subpoenas from the FEC.. I affirmed that two were sent. She stated that they could not find the records for one (Regalado). She stated that the production for the other subpoena was mailed last week in the form of a disc. Memo to File? No Entered by: MBW

24. Date and time: June 16, 2016@ 9:18 a.m. Name: Michael Montiel, R's atty. Phone#: 305-377-1000 Summary: I called Mr. Montiel for the final interview. He was not in; I left a message. Memo to File? No Entered by: MBW

25. Date and time: June 16, 2016@ 1:37 p.m. Name: Michael Montiel, R's atty .. Phone#: 305-377-1000 Summary: Mr.. Montiel called me back at 12:29 p.m. and left a message on my voice mail. I returned his call. He was at lunch; I left a message. Memo to File? No Entered by: MBW

26. Date and time: June 16, 2016@ 3:44 pm. Name: Michael Montiel, R's atty .. Phone#: 305-377-1000 Summary: I called Mr.. Montiel for the final interview. He stated that the whole thing was just a mix-up because the company didn't really understand the election process. They didn't understand that the ECO and the candidate had different rules and restrictions. He stated that Ennovva stated that they were using the website as a test site and it wasn't supposed to be a "live" site and the vendor didn't tell them; therefore, they were not aware that the website was "live" until they received notification from the FEC.

INVOOl (12/01) 5

27.

28..

29.

30.

31.

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He stated that the ECO never paid the second half of the cost because it was their understanding that the website was still incomplete.. (The invoice requires that the remaining balance be paid upon completion.)

I explained that I had completed my report of investigation and I summarized the information in the report and asked if he had any additional comments.. He stated he did not.

I explained the remaining procedure and informed him that he would be notified when the case goes before the Commission. Memo to File? No Entered by: MBW

Date and time: Name: Phone#: Summary: Memo to File? No Entered by:

Date and time: Name:

· Phone#: Summary: Memo to File? No Entered by:




INVOOl (12/01) 6

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FLORIDA ELECTIONS COMMISSION REPORT OF INVESTIGATION


Respondent: Raquel A. Regalado Counsel for Respondent: Roland Sanchez-Medina, Jr.

Complainant: Darren Centinella Counsel for Complainant: Elliot S. Berke

On June 29, 2015, the Florida Elections Commission received a sworn complaint alleging that Respondent violated Chapter 106, Florida Statutes. Commission staff investigated whether Respondent violated the following statute:

Section 106.19(1 )(a), Florida Statutes, prohibiting a person or organiZation from accepting a contribution in excess of the legal limits.

I. Preliminary Information:

1. Respondent is a 2016 candidate for the office of Mayor for Miami-Dade County. There are five other candidates in the race including incumbent candidate, Carlos Gimenez. Respondent is not a first-time candidate. In 2010, she was elected to the school board. In 2014, she was re-elected, unopposed. In 2002, Respondent was admitted to the Florida Bar.

2. On March 9, 2015, Respondent filed her Appointment of Campaign Treasurer and Designation of Campaign Depository for Candidates (DS-DE) form. Respondent named Carlos M. Trueba as her treasurer. To review the DS-DE 9 form, refer to Exhibit 1.

3. investigation. investigation.

Respondent was represented by Roland Sanchez-Medina, Jr. during this Michael Montiel, another attorney with the firm, also assisted during the

4. Serving Miamians is an active electioneering communication organization (ECO) registered with the Division of Elections. Roland Sanchez-Medina. Jr. is listed as its chairman and Carlos M. Trueba (Respondent's treasurer) is listed as its treasurer. To review the printout from the Division of Elections website, refer to Exhibit 2.

5. Complainant is the digital communications manager for American Commitment based in Washington, D.C. He has been involved with a number of election campaigns including the 2012 Romney for President Campaign.

II. Alleged Violation of Section 106.19(l)(a), Florida Statutes:

6,, I investigated whether Respondent violated this section of the election laws by accepting an excessive in-kind contribution from Serving Miamians.

7. According to Complainant, Respondent accepted an excessive in-kind contribution from Serving Miamians in the form of her campaign website and a campaign video, which contained express advocacy that supported her campaign. To review the printout of the website, refer to Exhibit 3.

Inv002 (7/08) 1

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8. Complainant provided a printed copy of Respondent's webpage. It appears to contain a button from a video; however, Complainant did not include a copy of the video. The webpage states, "Raquel Regalado for Miami-Dade County Mayor." The disclaimer reads, "Paid and approved by Serving Miamians."

9. According to the Division of Elections website, Serving Miamians disclosed two expenditures on its 2015 M3 Report to "Ennovva, Inc." The information on the 2015 M3 Report revealed that the two expenditures occurred on March 10, 2015; one for $1500 for "Web Design" and one for $3580 for "Advertising Production." To review the printout of the expenditures from the 2015 M3 Report from the Division of Elections website, refer to Exhibit 4.

10. Respondent's attorney, Mr. Sanchez-Medina, filed a response on behalf of Respondent. He stated that Serving Miamians, ECO,

Mistakenly engaged Ennovva, Inc. (the Vendor) to design the website for www.raquelregalado .. com.... The Vendor has since returned the funds to Serving Miamians ... Ms. Regalado's [Respondent] campaign account has since paid the Vendor for the work performed, as well as an extra fee for changing the disclaimers on the video found on the Website, and removing all references to Serving Miamians, both on the Website and in the video.

Currently, the Website is offline and any visitors will find a message with states that the Website is under construction.

To review the written statement, refer to Exhibit 5 .. To review the refund check, refer to Exhibit 6 ..

11. The table below is a time line of events regarding the publication of Respondent's website.

03/09/15 Website, ~~_ww.raquelregalado.ccom, went live 3

03/09/15 Respondent filed her DS-DE 9

03110/15 Serving Miamians pays vendor 7

03/12/15 CTR shows Respondent's first contribution for $250 8

04/02/15 Complainant printed copy of website 3

06/25/16 Complainant swore to the complaint

06/29/15 FEC received complaint

09/04/15 Copy of website provided by R's attorney 5, page 3

09/25/15 · CTR shows Respondent pays vendor 9

01/21/16 I printed Respondent's website 10

lnv002 (7 /08) 2

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12. According to Respondent, she did not become aware of the website until she received the letter from the Florida Elections Commission regarding the complaint. When asked if she reviewed the video before it was posted on the website, Respondent replied, "though I appear in the video, I had not reviewed the final product." Respondent also stated that she did not discuss the website with any of the officers or members of Serving Miamians. To review Respondent's affidavit, refer to Exhibit 11.

13. When asked what actions were taken to prevent visitors from accessing the website, Respondent replied, "The Website was not intended to be viewed by any visitors during the time the video was posted. Upon receipt of the letter from the Florida Elections Commission dated June 30, 2015, I contacted Ennova (sic), Inc. and demanded that the video and the website be taken offline immediately." To review Respondent's affidavit, refer to Exhibit 11.

14. According to Mr. Roland Sanchez-Medina, the ECO's chairman, the ECO did not pay for advertising. ML Sanchez-Medina stated that the ECO paid for the web design and the creation of one video.. He stated that the officers and members of the ECO did not discuss the website with Respondent. To review Mr. Sanchez-Medina's affidavit, refer to Exhibit 12.

15. When questioned about who reviewed and approved the website, Mr. Sanchez-Medina stated,

The Website had not been approved or reviewed. As referenced in the letter above, the website was in a period of initial construction and was not intended to go "live" at the time of posting of the video. The Website was not completed and no content was available on Website. To my knowledge, Ennovva, Inc. was in the process of testing the design and connectivity of the website at the time the video was erroneously uploaded.

To review Mr. Sanchez-Medina's affidavit, refer to Exhibit 12. To review the website, refer to Exhibit 3 ..

16. When asked why the ECO published the website, Mr. Sanchez-Medina stated,

Servicing Miamians was in the process of publishing a new website about Raquel Regalado in conformity with IRS rules and regulations.. Serving Miamians has been informing Miami-Dade County residents regarding Raquel Regalado and Tomas Regalado for five (5) years. The language included in the video requesting support for Ms. Regalado was simply a mistake, as the intent of the video was to educate Miami-Dade County regarding various issues. The video was immediately removed from the Website.

To review Mr .. Sanchez-Medina's affidavit, refer to Exhibit 12 .. To review the website, refer to Exhibit 3.

17. Invoices provided by Mr. Sanchez-Medina show that the video was filmed and edited on February 26, 2015, March 5, 2015 and March 6, 2015. The cost for the video was $3,580 .. 00 .. The invoice for the web design shows a cost of $3000; half due up front and half due at the completion of the website. To review the invoices, refer to Exhibit 13.

18.. Serving Miamians issued two checks on March 10, 2015; one for $3580 and one for $1500. On September 25, 2015, Ennovva, Inc .. issued a check to Serving Miamians for $5080.. (The Commission received the complaint on June 29, 2015.) To review copies of the

Inv002 (7 /08) 3

checks, refer to Exhibit 7.

19. Mr. Sanchez-Medina also stated on his affidavit that Ms. Amelie Ferro was responsible for the verbiage on the website. I called Ms. Ferro to query about whether Respondent assisted with the development of the website. During a telephone interview, she stated that she preferred for me to send her my questions in writing via email. I emailed the questions to Ms. Ferro: however, she did not respond. To review my email to Ms. Ferro, refer to Exhibit 14.

20. I requested that Respondent's attorney provide copies of the checks issued from Respondent's campaign to Ennovva, Inc. (the vendor); however, the checks were never provided. I subpoenaed bank records from the bank listed on Respondent's DS-DE 9, City National Bank; however, the bank stated that they could not find an account in Respondent's name.

21. I subpoenaed the ECO's bank records. The bank records confirmed that the ECO issued the checks to Ennovva, Inc. on March 10, 2015. Ennovva, Inc. issued a refund check to the ECO on September 25, 2015. To review the bank records, refer to Exhibit 15.

22.. No record of Respondent having previously violated this section of the election laws was found.

III. FEC History:

23.. Respondent was named in FEC 12-041 that alleged a violation of Section 106.07(5), Florida Statutes. Respondent entered a pre-probable cause consent order and paid a $2,000 fine on March 9, 2012. Respondent was also named in FEC 12-087; however, it was deemed legally insufficient

Conclusion:

24. On June 16, 2016, I interviewed Mr. Montiel, Respondent's attorney, by telephone. He stated that the entire thing was a "mix-up" because the vendor really didn't understand the election process. He stated that Ennovva (vendor) didn't realize that the ECO and the candidate had different rules and restrictions. He added that Ennovva told them that they were using the website as a test site. He stated that they (the ECO) were not aware of the test site. He added that they were not aware that the website was "live" until they received the notification from the Florida Election Commission. He stated that the invoice shows that half of the cost is required up front and the remaining balance is due upon completion; the ECO never paid the remaining balance because it was their understanding that the website was incomplete.

25. Respondent's filing officer is the Miami-Dade Supervisor of Elections. According to the Affidavit of Filing Officer, Respondent was not a first-time candidate. According to the affidavit, Respondent was initially elected to the County School Board, District 6, in 2010. In 2014, she was unopposed. The filing officer stated that Respondent received copies of Chapters 104 and 106, Florida Statutes, and the 2016 Candidate and Campaign Treasurer Handbook. To review the Affidavit of Filing Officer, refer to Exhibit 16.

26. Respondent acknowledged receiving copies of Chapter 106, Florida Statutes and the Candidate and Campaign Treasurer Handbook. She stated that she served as treasurer for Tomas Regalado's mayoral campaign in 2008.. When asked what actions she had taken to determine her responsibilities under Florida's election law, Respondent stated, "I am a constitutionally elected official." To review Respondent's affidavit, refer to Exhibit 11.

27. On March 9, 2015, Respondent filed the Statement Candidate form certifying that

Inv002 (7 /08) 4

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she had been provided access to read and understand the requirements of Chapter 106, Florida Statutes. To review the statement of candidate, refer to Exhibit 17.

The Honorable Raquel Regalado 1985 NW 88th Court, Suite 101 Doral, Florida 33172

Roland Sanchez-Medina, Jr. SM & GQ Attorneys at Law 201 Alhambra Circle, Suite 1205 Coral Gables, Florida 33134-5107

Ms. Christina White Miami-Dade Supervisor of Elections Post Office Box 521550 Miami, Florida 33152-1550

Copy furnished to:

Mr. David Flagg, Investigator Manager

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Respectfully submitted on June 17, 2016.

5

Mr. Darren Centinello c/o Berke Farah LLP 1200 New Hampshire Ave. NW, Suite 800 Washington, DC 20036

Elliot S. Berke, Esquire, Managing Partner Berke Farah, LLP 1200 New Hampshire, NW, Suite 800 Washington, DC 20036

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Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

Exhibit 7

Exhibit 8

Exhibit 9

Exhibit 10

Exhibit 11

Exhibit 12

Exhibit 13

Exhibit 14

Exhibit 15

Exhibit 16

Exhibit 17

Inv004 (5/08)

FLORIDA ELECTIONS COMMISSION REPORT OF INVESTIGATION

Raquel Regalado -- FEC 15-372

DS-DE 9 Form

Printout from the Division of Elections Website

Printout of Website

Written Statement from the Attorney

ECO's 2015 M3 Report Expenditures

Refund Check

ECO's Checks to Vendor

2015 M3 Report

2015 M9 Report

Website Printout

Respondent's Affidavit

Mr. Sanchez-Medina Affidavit

Invoices

Email to Ms. Ferro

Bank Records

Affidavit of Filing Officers

Statement of Candidate

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APPOINTMENT OF CAMPAIGN TREASURER AND DESIGNATION OF CAMPAIGN DEPOSITORY FOR CANDIDATES

(Section 106 .. 021(1), F S)

(PLEASE PRINT OR TYPE)

NOTE: This form must be on file with the qualifying officer before opening the campaign account.

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2015 MAR ~9 AM IQ: t 8

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•. ~yHECK APPROPRIATE BOX(ES):

. U-'·--l.r@al Filing of Form Re-filing to Change: D Treasurer/Deputy D Depository 0

OFFICE USE ONLY

Office D Party

2 Name of Candidate (in this order: First, Middle, Last) 3. Address (include post office box or street, city, state, zip

Raquel A Regalado code) --·-·--···--··---~-----·-------! 1850 SW 36th Avenue 4. Telephone 5. E-mail address Miami, FL 33145 ( 305 ) 593·-2644 [email protected]~ ·----·-------~·-----·--------·---'--~c··--·-·------·····-··-·-·---------·---6. Office sought (include district, circuit, group number)

Miami··Dade County Mayor

7. If a candidate for a nonpartisan office, check if applicable:

D My intent is to run as a Write-In candidate. -·--------------·------·---------------~·------·----·-----------·------------

8. If a candidate for a partisan office, check block and fill in name of party as applicable: My intent is to run as a

0 Write .. ln [] No Party Affiliation 0 -----.. ------··--·-------·-·-·Party candidate

9. I have appointed the following person to act as my lZJ Campaign Treasurer 0 Deputy Treasurer ---··-- ·---------... ···--·-----------·

10. Name of Treasurer or Deputy Treasurer

Carlos M. Trueba

11;8~~: ;~~~~~ - ~ ··-=_J2~~::~h;;_::---·-· 13 .. City 14 .. County 15 .. State 16 Zip Code 17 E-mail address

Doral Miami-Dade FL 33172 [email protected]

UNDER PEt,.Jf.~ Tl.~S Of PERJURY, I .DESf;;~~:~:A'T I HAVE READ THE FOREGOING FORM FOR APPOINTMENT OF CAMPAIGN TREASURER AND '~· '°"' '" . ' bESIGNA'libN~f!?(:i)'.'~pAJGN DEPOSITORY AND THAT THE FACTS STATED IN IT ARE TRUE.

11-2-5--D-at-e----·~·· 11 • 1

., • ,;z:·.···..:+..4-·~' ~·· ----·-----,-2-6-.. -§9Jirui·~~~··~· ;_(i-~~~~-§.:.--~;;;;;;;;;;;;;;:---------·-0 \ '· . - .. - ,: ' .· . ,, , ..... - i.i .. -;;;-· / -~l:.·~-;;r---·-

21

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~ ~ "71'"') I\---~ ... ...... d.. A ,--'J " -- ] :.~O ~;oei'Jt1ts~E#11.S A.6'~tiniee of Appointment (fill in th; blanks a'nd check the appropriate block)

~!@3M. Trueba ·-----.. ----------· , do hereby accept the appointment

Alli~ '' l 1 'IN..:, '"' (fii@cki~W¥rht-or Type Name)

designated-above a-:;·,, .. v;·,;,.,.;,@' · --eampaign Treasurer O (:'C:_.-_~::: ....... -~--1f-:7'~~: .~" ,-,,xw<! _X ___ S_i_g_r-)a-tu-re-of_C_a_m_p_a-ig-~-·-,__. re_a_s-ur-·e-r-or--D-e_p_u-ty-T-re_a_s-ur_e_r -·--

OS-DE 9 (Rev. 10/10) Rule 1$-2.0001, F.A.C.

EXHIBIT_-""'---

Committee Tracking systen;i - Florida Division of Elections - Departµ:ient of State / ( .

Committee Tracking System·

Serving Miamians

Type: Electioneering Communications Organization

Status:Active

Address:1985 Northwest 88th Court

Suite 101

Doral, FL 33172

Phone: (305 )593-2644

Chairperson:Roland Sanchez-Medina

Treasurer:Carlos Trueba

1985 Northwest 88th Court

Suite 101

Doral, FL 33172

Registered Agent:Parker D Thomson

Purpose:

Affiliates:

200 South Biscayne Boulevard

Suite 400

Miami, FL 331310000

Finance Activity

EXHIBIT _ __.8'.___ __

http://dos.elections.myflorida.com/committees/ComDetail.asp?account=60265

Page 1of1

6/16/2016

(

-··-------·· .. ·--·--·--r'<'--"-»>--............. ~ ..... , ........ --·---~.:-----··"··-·-~ . ... ~"""'---~--- .. ···~--~-·.-·-·-···-·-----

out I:laqu.~J aegalad.o Raquel Reg~lado l$ a lifelong r~slq~nt of the Miami-Dade County School Board

Distrt.ct a, whith encompasses tne areas tifKey Blscayne, the Roads, East uttre Hava.na, $hemmcioah, Sllw~r Bluff; Cqconut Grove. Coral Gable.~, south Miami and

Wast~hester. Ort the Board, Ms. Regala.dp ppatrs the Facilities and Consttuctic:m

Reform Committee; and serves as a member of the Instructional Excellence. & • . .- .. , ' ' . ., : ., . .,<. ' . ~ ·, ' • , . . ' ' ·.. ' .' . . . •

Gf.imrriunity Eng~gemeht Schoo1 $1.lppott & Acc~l!ntttoillty. and 1nnov~tio11,

EXHIBIT

R;ll;Qti~ R!!CJAlADG I fl>i: Mia~l Dad,tl Ci>~ntvMavy.r I

p~~!l€If~ ~~ 't@~Ph t,fl~ b~C$ of compµter pro~remlng. also 1<119w11 as Code. to all

MP~P$,sttl4f~ntsAA$. ~egaI$¢h;? nti$ ~l~m tirgariized several !aw daY$ throughout

th~ ~tmt~ f<>r ~~1derits ~nd p~retlt$ to me~t wtth pro bano attorney$ ~ru:l ... ··. :.·.·· ..• . •' . ' . ,. .•. ' .'<". . .

~~rr1m,ent~~~rt¢1es Where p$'tttctp~fu$ r~af\la atiVice regarding issues ranging

frpm :fqr~plq~µre ~ng i~ndl'ord t~nanttl~ht$t(J ~isaf;lility benefits.

ff.,~ ~ Scff!l91 '~P~t~ Mem~et ~h~ h~$ ~\lB,4 'mt:l W$Y fer Hti provements ln tiisttict wide traris~e~tton and brougl'lho ttie board a ffveyear pfain which r~ultl?d In

~me ~pf~tzemeflt C>f ol~ ~ml inefficient ~cliqa! bµses with energy efficient bt!Set:i

ttiat ax~ed the Sli~te's safety l"e:qufreme:nts; As a mern ber of th~ sot;rtl:teast

Ft~tilii8 Reginfiial Partn~rshtp Exe'c(!tive committee~ $he Fief ped de\fise the

severiso plan to secure the economic future and improving the quality orlfre tn tn~ s$~t1;..~tJ.unty tt\gfqn ¢~rf1prJslng M9rttoe. Miamt~oaae, Brow~rd, Palm i3e~chi

Marifn, st. Lucie arid Illdlan River cotil1t1es dwring the next ~O yea~ and beyond~

Afth~ n~tlqn~l lavel. Ms. Re~f;llado ~as partJcip~t~(:l rn pr0:grams rega-rt!lng

comp,reheos!ve 'fmmlgratibfl i~fotm a;htf the scihbdl districts role in asslmll~tron

a.n,g Engllsh l@mfag, As a board memb~r Of the National ASsoc.fation of Latino

Elect~d and Appointed officials CNAJ.EO) Ms. Re~alado has spoken natiottalty on

the need for immigration reform and on jt:Jvenne justice and the ben~fits of

Florrda1s cMf ¢itatioh ~.ltemative. As a Hlspanlc English learner. Ms. Regalado has

also been an aqvoc~te for bflingual et,iupatJon, a frequent speaker at conferences to $¢ll~1n pt.i~U~ edubatioh tr~tn an EngUsh learner$' perspective, debunk the

myth that tl1f$liSh i~am~rs are not t1cadernic ~chfevers; and champion~d the

important rote that bilingual equcatlon wm have In l=!orlda's new economy.

A graduate af Coral Gables High, Ms. Regalado attended Miami-Dade Community

Collegi;i a.nd then Florid~ lnternatlon~I University •. earning a degree ln Liberal

Studies With hor1ors, earning a Juris Doctorate degree from St Thomas University

~pheol of Law, At St. Thom~sj she WP1s the recipient of the Florida Bar's Young

Lawyers Division Scholarah!p and wtnner oftheSt ihomas University Schoof of

L~w c. Clyde Atkins Memorial Mo.at court Competition and Amerlcan Trial

Lawyers Associatrbn Open/Cfos.e competitlon. Ms. Rega la.do was a memb13r of the

St. Thema$ U!IW Revi~w and the Moot Court T~am.

Ms. Regalado is admitted to practice law in Florida state courts and in the United

EXHIBIT

G:a@jn~JJ~l~~~~~~O.to~:. :;:::;::.~:;;!\!~*".'.. • Q;1t1U. ~IQ':liH1l l'*!m P.<:ilr.k tA<lnm. St. t11t::1{· 1H1rl lflcttartRWet COI!lltit::. tlunng lhe t!Oh! SO yeais ,1rr(l tle'\'l'lfltl.

A; tho n.1tio;•at tcvr:t Ms. Rcgai;nlo has µu11n:1pamd m pr<?£1;lfl)? t~arclmg comprt>Mns1ve ;;nrn1{tr.auoa !'(>!mm M1tl i!Y.: scl10:ll

drswcts n:dC m 11ss1m!l~tion <.•nrl Engl1sn 1e:m0mg M a bcmnl mcmiiu1 ni 11¥.i t<L1;mn;il f!.r.sn::rnllnf• o! l;it1no Bocwd ;uul Ao1w:w111:ti

Olfitiafs f1*Alf:Ol Mi;. He~'\lnoo ti,-n; 'Sf;!pk<m.!~llt!\)M!l'{'01'l the nea<l lot 1mni<gaitmn rntnnn mod <ITT Jll\ltltll!e JUSIH:u ;ind !h~ ueooltl> of

rtorict;l"~ CIVIi ClillilfJn tl~lemrilMl f\S:.!! ll!Sj)nOIC .Engllsl\ kh:'.1111!:1. M~ Regalm:k; h<1$ i!OO' 0000 M i\rtli'l'Y..UIC llil b!lmftUlll C(ftll'.;at»on. <r

iroquClntspt;llker al :::onl>fronc(:s to r.~p111m mlbhc· oouca1mn rro:n M f:n&!hsn 1c;inmrs· ji(!{>;pc;cuv&. c1<:1>m1Kth~ myll'l 11·m1 tngl!sl'

!e;)rnm~ are not ocaoon11c acll:MM:1:S: Mui ctl;impwned 11'1<: impc11,;mt 101010;;; 1>1hn11ual OOW:~ll witt navi! m Hond<i's new er.nnnmy.

•\ ~1;H!vah1 Ol (\l1 !ll (Jaillet; il1gh. Yi!i. Rt:'aill;1(lo ~!tC:'l!fOO Mt.1nu·Oadc t-0m1lmnu~· COliege- ;111i:i men Fll)tW11 lmemm1<10'111Jn1v.;r$H'f.

i:;1mu~ "' :t(!{lrne m uber.;I swaic~ wall l'li>imrs. Mmmg a Jurts frru:h11;11l: o~reo uom SI. 'fn{lm,"ls Ul\:11c1sw; StMOI ct 1.t1.-r. A; Sl.

\'\;~Hnr.s. £t.r: \'111$ tne l&lf!l<'!lt nt it'.$ fh"Jr!da ufl(S"fl:l1tllU,LWJV1\IS Dl!(J&rl:l Str.r>l;w,;.ltjfl aml \'.'lmlf:f 01 tnc SL Tt10ntl1: ll!lWi'.!!Slty SCIW!Ol

or lilW C. r.tl'(le Atkins Memon;;! Moor f.'Q<.H1 C<impoillm~ ond N;wac;in fn.:tt wwyers Assot•<inoo Qpan;t1osa Compe11Hcn. Ms.

~i:<ga!Mlo was i'\ 1¥100\!mttil lht'. ::.1. 11w1ih•~ L:!w :Revww <'l'ltl !ht Moot <:0011 ·nwm

:.ts. <?i::g111;1do is aomntm'l m prnct1en tiw1111 flo11d<1 s1t1ti'.:' courts .«no tn me: 1.1111100 suncs Oh>tt!Ct Cou1t f-Ot 1f1c ':><:Mhi:ttn !J1s1nct 01

?l-Orrd'1. l;J$, Rcg{'tt:aoo 1:> 110 t.clivc f!tl?moc·r ()< sever<i! tmr nssccmtrons. mt;tvdmg the Amencnn ~()1 As:scc1ti1mrt Cul'.liln Am.cni::oo &ti

A:>soo~1101't.. am:hs ~ti& nl\imb!:r OI tr«! 1111~K<tuill ?toperty l;iw Msoc1i/lt1on {It noncll:i. SIW: WM! an AtlJlllliCl f'r<Jte:isru •.14 £.(!Sl.OO>ss taw ,1t Mrnnu D;m~ toH<::gc-. Vl<l!!sm1 tatrtpvs. Ms. Rogaitltlo was li'lltled a P.mng s;;:u m 1mcucr:iu;it Proof.'rtY ~1t1gvtron b';' nem:ia Trnncl

mllsil:N1t" it!'\~ n.nrmuf tllllOJlg the !Op .HJ llllcmcys 111 Mm1m·l!!1dC COW~l\' vndci 1\0 years Q1(1 by Jlte C't'S!tc fl!lrnS!S fOO!tllr>!!O•t.

su~cc 2009. Ms. flt.«g~{lu hns comJucioo" tli!ilY Sl);}n1:m 1angm1g0 w<l10 pmgram on lil P(l(loiosil. ~!O AM. dectic<11er1to1flio1rn1ng

'.iS!CfiCI!. i!llt.lll! hn:nl OO!tt1ts.10tluc;r11-0n i\ntl socml iiCflllO:S. /\nmhN IJl ill!! j)ll\JC<l!l IS ESJ,'I ScmH!WtCOO Ra{Juc;, a ~·ro<:!d\i le!C">'!S!(t:I

si1oww11h jID\lt1c1ii unti nc-i.'Js Jit1i1!ys15, ;u1mr; on ieif:mmrrn 1nw11g!1out Hie s;ste 01 f!nm1n. lalmvtow lto:n i:£!il scmimn t-On 1t:i<1ttc!

t:llil ne S{:N'< nn htti:rJlwi'fl,Y.yootub~.com/m-Or1Raquef1u1!l()gatc3dO/vldoos. Ms. ncgnlndo also ~mtes !or £1 hlut"llU He1;1!el ilntl llm

!!t:llin~um r>:is1 ;mt! llM cc11:nllu1~1 Ju !Jl(? Mwrm l!erntr.. El Omn(J m: !;1s. Arncni:a:. tlf)(C. L!b~micf ;inti curnrrmntly ?apet:. tti•wns

w11ttor1 ti(YJ.N\~ 01 ;iH1clcs. !?tr 1;iw::.r 91;c\, i:1111 l.ll:? ioul'ld on llnp:!/mque!tegarndoopinims.blogspol.etim/ flm111y. Ms. Rc;;.alnoo t<; r,

mal\l i.x:t o! m~ Com01uru1y i.iWl!;('l;y ~1r<101 WL~. Chnnruil 11. m !.'.:arm. f'kmmt.

Ms. ?.CI!illl1dt:HS the prntitl mo!hm N twfr c:tu<omn ;imJ the tlatigllwr o! Tomas ll.eg;il?:•o. Inc M;1yo1 o! me C11y of M1t1m1.

~

\'I)

I-= 00 -~

Campaign Expenditures - Division of Elections - Florida Department of State

Campaign Expenditures Serving Miamians

Florida Department of State Division of Elections

Page 1of1

This information 1s being provided as a convenience to the p_ublic, has been processed by the Div1s1on of Elections ana should be cross referenced with the onginal report on flle with the Div1s1on of Elections in case of questions. About the Campaign Finance Data Base

Rpt Yr Rpt Type Date

2015 M3 2015 M3 2015 M3 2015 M3 2015 M3

03/10/2015 03/10/2015 03/10/2015 03/17/2015 03/23/2015

5 Expenditure(sJ Selected

Amount Expense Paid To

1,500.00 ENNOVVA INC. 3,580.00 ENNOVVA INC.

350.00 RODRIGUEZ, TRUEBA ~ CO., CPA 10,000.00 BRifu~ ANDREWS USA, LLC

5, 000. 00 REGALADO JOSE L

20,430.00

Address

100 N BISCAYNE BLVD, SUITE 2906 100 N BISCAYNE BLVD, SUITE 2906 1985 NW 88TH COURT, SUITE #101 255 MOCKINGBIRD TRAIL 2424 SW 20TH STREET

Query the Campaign Finance Data Base

City State Zip

MIAMI I, FL 33132 MIAMI!, FL 33132 DORAL, FL 33172 PALM BEACH, FL 33480 MIAMI, FL 33i45

[Department of State! [Div1s1on of Elections! [Candidates and Races] !Campaign Finance lnformat1on1

http://dos.elections.myflorida.com/cgi-bin/TreFin.exe

Purpose

WEB DESIGN ADVERTISING PRODUCTION ACCOUNTING o REPORTING SERVICES MARKETING CONSULTING SOCIAL MEDIA

1/21/2016

~

..... as s: x w

ATTORNEYS AT LAW

September 4, 2015

Via Certified Mail Return Receipt Requested

Erin R.iley Deputy Agency Clerk Florida Elections Commission 107 W. Gaines Street Suite 224 Tallahassee, FL 32399

Re: Case No.: FEC-15-372; Respondent: Raquel Regalado

Ms. Riley:

This correspondence is in response to the letter from the Flodda Elections Commission ("FEC") dated June 30, 2015 (the "FEC Letter"). Ms. Regalado has addressed all of the issued and concerns found in the FEC Letter .. Please see Ms. Regalado's response to the FEC Letter, attached hereto. If you have any questions, please contact me directly at 305.377.1000.

el:RSM

Copy to: Raquel Regalado (Via E-mail) Michael Montiel

Sincerely,

Roland Sanchez-Medina, Jr

EXHIBIT ;) ~0e I ~ _; SANCHEZ MEDINA. GONZALEZ, QUESADA, LAGE, CRESPO, GOMEZ, MACHADO£~~ PREIRA LLP i SMGO.LA'N COM

201 ALHAMBRA CIRCLE SUITE 1205 CORAL GABLES FL33134-5107 I TEL: 305 .. 377 1000 I FAX: 305.424.0237 I TOLL FREE: 855 213 4806

(

RAQUEL REGALADO'S RESPONSE TO THE FEC LETTER

Serving Miamians, an Electioneering Communications Organization ("ECO") mistakenly engaged Ennovva, Inc (the "Vendor") to design the website for :xvww"rfill.uelregalado"!,:_Qm (the "Website"). Serving Miamians contacted the Vendor regarding this error in order to take steps to correct the error. The Vendor has since returned the funds to Serving Miarnians. The refund will be reflected in the September ECO report and will be provided to the FEC Furthermore, Ms. Regalado' s campaign account has since paid the Vendor for the work performed, as well as an extra fee for changing the disclaimers on the video found on the Website, and removing all references to Serving Miamians, both on the Website and in the video. 11lis will also be reflected in Ms. Regalado' s September campaign report which will be provided to the FEC when it is due on October 10, 2015. Some of the confusion in connection with the error was likely caused by the fact that Serving Miamians intended to engage the Vendor to create videos which are in furtherance of its purpose as an ECO.

The Website, although "live" on March 9, 2015, was never fully completed by the Vendor. In fact, the Vendor's bill for the creation of the Website indicates that the Website was still currently under construction at the time it went "live". As such, it was never the intention of Serving Miamians, nor Ms. Regalado, for the Website to be accessed by visitors, nor to serve as a campaign advertisement for Ms. Regalado's campaign.. The Website was simply a "landing page" as opposed to an advertised or marketed website.

Currently, the Website is offline and any visitors will find a message which states that the Website is under construction. The video which was previously featured on the Website is no longer accessible. Please see the screenshot of the Website attached hereto ..

As referenced above, Serving Miamians intends to continue to engage the Vendor for the creation of additional videos which fully comply with Florida law Despite Serving Miamians' unintentional mistake described above, moving forward Serving Miamians will continue to exist as an ECO. As the mistake has been corrected, Serving Miamians does not need to, and will not, register as a Political Committee. All acts undertaken by Serving Miamians in the future will be fully in accordance with its purpose as an ECO, in accordance with Florida law.

F: \General Clients \Raquel Regalado \RegaladoResponse ToFECdocx

EXHIBIT 5

www .. raquelregalado.com

< <

<J () []

( 1 \

I \I \ ( ( \ )·

i 11

fEXHIBIT _,_Wl/p:;,.__ __ _ ....,....,, _______ ··--·-·-- ..

-w====---~~~~~--~~~~~~~~~-~~~~~~~~~~~~--~ 0 SERVING MIAMIANS ECO"

1985 NW sen; CT #101 MIAMJ, FL 33172 .. 2648

PAY TO THE Ennovva Inc. OADEROF---·,--------------------

1146

3/1012015

l i

$ ~3.5a0.00 j Three Thousand Five Hundred Eighty and 001100•••••••00••"1 '" .. ""'"'"" .... • .......................... , .. d .... .

-------~- . --- 001.t..ARS ~

MEMO

1146

-r:.-..

Ennovva Inc. 100 N Biscayne Blvd,. Suile2906 Miami, FL33132

Invoice 00438

$3,SSO .. OO 3/13/2015

--------. -.:::J

EXHIBIT -_ .. 1 fk''" l ~ 1

(

P"'V1'0THE OROEA or

"SERVING MIAMIANS ECO" 1985 NW 8STH CT 1'1' 101 MIAM1. P .. 33172 ·2548

Ennovva Inc

/

(

=~ ..... ::;;·--··---~-;~-;, -·~- '-''ll.'\Q

31101::015

a s

J _ __::ne ~ousand_Flve HJndred and co11co ---------------------===---- OOUAAS ©

MEMO

1145

Ennowalnc 100 N Biscayne Blvd Suite2906 Miami, FL 33132

Invoice #0437

$1,500.00

I -~·_ .... ___ j

3/13/2015

(

CAMPAIGN TREASURER'S REPORT SUMMARY

(1) Raquel A.-~:-~!.~.~-<: ................... - ... - .......... ______ _ OFFICE USE ONLY ONL~INE SUBMISSIOI\T

[1086828) Name

(2) 1850 SW 36th Av_e_n_1:1.::. ....... --............ ---···-·----Submitted on:

Address·(number and street) 4/8/2015 11:34:17 (eastern)

Miami, FL 33145 ··----···--·-----· .. ·---··-------

City, Staie, Zip Code

0 Check here if address has changed

(4) Check appropriate box( es):

(3) JD Number: ________ 1 __ 4 __ 2_1 _____ J

I!! Candidate Office Sought: _ May~r-------------------------------0 Political Committee (PC) D Electioneering Communications Org .. (-ECO) D Party Executive Committee-(P'fY")

D Independent Expenditure (IE} (also covers an individual making electioneering communica.:ti.ons)

D Check here if PC or ECO has disbanded 0 Check here if PTY has disbanded 0 Check here if no other IE or EC reports will be filed

(5) Report. Identifiers

Cover Period: From 3 I 1 /_2015 To 3 I 31 12015 Reporttype: 15M03

~Original [] Amendment 0:...Special Election Report

(6) Contributions This Report

Cash & Checks $ 48' 310 00

Loans $ ' ' 0 00 ··~~--- ~----- --

Total Monetary $ 48' 310 00

ln··Kind r :. ,J ... '; .i ~ ... ... ' ,, . . ... . 0 00 ~ :, • .,J.t'~'"tld.•"\1!.·I' .~.!.~ ' ._............... ·-·-·--

· ·· ·~·~:1 ~Y:~·tr."~::l/or :~<~ ~:.r~1

~:-~- 1

, I ,> :::t:::.~fr'.-' :2 ·i•: "'.~ 1 ; ' ;>. ' • , , .... ~ .... ... :-1; . . _.~; ,.'i:··~ ... ~ .... ,.

(9) To::tru.: Nra~~t~iY c~HMoiitions'To Date ' .. ·, : ..

$ .. :..:.:~.1t:..... 1 . LA.§. , -~ 3 lo . o o ~~.,; ~ ''. . "" .... ,; . ..

(7) Expend~tures This Report

Monetary Expenditur-es $ '

0 -- ----

00

Transfers to Office Account $ 0 00

Total Monetary $ '

0 00 ................... -·---·

(8}- Other Distributions

$ _ .... --·-···" ' ........................... ' ....................... Q 00

(10) TOTAL Monetary Expenditures To Date

$ -·- '-···--' 0 00

.. : i'\ . •.• ... . (11) Certification It is a first degree misdemeanor for any person to falsify a public record (ss. 839.1"3, F .S.)

I certizy;J~ITT'.! tl9Y!1' exam;ii[ied 'this report and it is true, correct, and complete:

(Type name) .. --··--';:"'"1:'""':'"''"""''':"'1"'----:~------~-~--.---·-

0 lndividu<'ll ictniy for IE ~O "Treasurer .· · D Deputy Treasurer or electioneering comm )

x ------------·--------------Signature

DS-DE 12 {Rev .. 11/13)

EXHIBIT

(Type name)

0Candidate

x Signature

0 Chairperson (only for PC and PTY)

SEE REVERSE FOR INSTRUCTIONS

(

CAMPAIGN TREASURER'S REPORT - ITEMIZED C:ONTRlBUTiONS

(1) Name Raquel A Rega J ado {2) LD. Number 1421

3/1/2015 3/31/2015

(3) Cover Period t I through I I {4) Page 1 of 16

(SJ 0 (~) (B) . .(1(}) :(11)

D$te Full Name (6) (Last, SUffix, First; Middle',)

$eq.uence Str~.E:\t AdtJ.fE:\ss & Cdhtributor GoritribUtibn Jn.kffid +----~N_u.~m'-b~e_r ---+--·~C_ify~,_s_ta~t'-e_,_,._Z__,_iP_C~~o_,_d~e---+_T__,v+P·.'-,e"-+-~o~·c;~c~.U'~P.a~ti~·o_n-+ __ T~v-P ~e-· --+-D_e~15~c;_ri~p1t_io~n_. --;-A_m_e_n_dm_•e_r._t--r-- Amount

Regalado, Tomas P :t [city of CH $250. oc 3/12/2015 2424 sw 20th street ttiiami

, ___ / __ ~{ __ --<Miami, F.C 33145 mayor

1

Fourth Amended & 3/20/2015 Restated , ___ !~--~'----Declaration

2060 Biscayne Blvd

2

3/20/2015

2nd Floor Miami, FL 33137

Braman, Norman 2060 Biscayne Blvd

,__ _______ _.Miami, FL 33137

3

I

B ireal ~state

I f'.3.Uto peal er

CH

CH

3/20/2015 Braman, Irma

2.0.60 Biscayne Blvd Miami, FL 33137

I ~omemaker CH

f J t---------1

4

CH 13 f'.3.UtO

~ealer 312012015 ,. Braman\ C~dillac

~ 1nc., •. ,. / n ~ ''.''.:. ,;<9,@",~ispMM 8.lv.d

.• Miami, FL 33137

~ ' . .i. .... ,

l ' '

$1, ODO DC

$1, ODO OC

$1, 000 DI

$1,DDO .. DI

,__--'.--· -·-r.:;T'-1-'t. B"t;~ri'~:.~· ... -.:~~ -I----+--B-+--,,-_u_t_o----+-C-H------r--------+---·---+---$-1-, D-D-Ooc 312. 0;2·0,1·"'"'", .... ._ ... J;'f!W~f\., .. u,t;()., • nc .. ~

.J.,;;J ... , ' ' ;2·060 Brscayne' Bl'(ftt' dealer f 7 Miami, FI:;· 331.3 7 ! !

.~~ i~

6

J,,'\ ~- ........ ,. ···-····"· ... ··~··· Braman Hyundai,

3/20/2015 2060 Biscayne Blva'

____:!.:.:_: ..... ~._1._;_,_______ Ml ams. , ···FL 3.313 1

7

312012015 Braman .Mot.ors, 2060 )3isc.o.yne Blvd

I I Miami; ·FL 3313 7 r-~------~

8

B auto dealer

B auto dealer

CH

CH

bS-DE 13 (Rev .. 11113 ) SEE REVERSE FCiR INSTRUCTIONS AND CODE VALUES

EXHIBIT

$1, DOO DC

$1, DOO DI

CAMPAIGN TREASURER'S REPORT SUMMARY

(1) Raquel A .. Regalado

Name (2) 18 5 0 SW 3 6th Avenue

·-----Address (number and street) Miami, FL 33145

OFFICE USE ONLY IN.E SUBMI SS

[1092635]

Submitted on:

10/13/2015 09:49:21 (eastern) ________ ,, __ , _____ .... _ .. __________ _ City, State, Zip Code

0 Check here if address has changed (3) ID Number: --------· 1421 __

(4) Check appropriate box( es):

~ Candidate Office Sought: . May::_:_ ______ ·----·------··---·--·---·-·----···--------D Political Committee (PC) 0 Electioneering Communications Org .. (ECO) 0 Party Executive Committee (PTY) 0 Independent Expenditure (IE) (also covers an individual making electioneering communications)

0 Check here if PC or ECO has disbanded 0 Check her.e if PTY has disbanded 0 Check here if no other IE or EC reports will be filed

(5) Report Identifiers

Cover Period: From 9 I 1 I 2015 To 9 1 30 12015 Report Type: 15M09

89 Original 0Amendment [] Special Election Report

(6) Contributions This Report

Cash & Checks $ I 4 I 455 00 -·----·-·· ·--.. ·--·· --··--· ·-··-·-··

Loans $ I I 0 00 ... - ............. --.. ·--·· --· ---

Total Monetary $ I 4 , 455 00 ··-·"•"•···

__ .. ____ . ....... -.... -... ···-·--·

In-Kind $ ' ' 0 00

--- ----·- --.. -· -··-·-

(9) TOTAL Monetary Contributions To Date

$ -------· I -·~_Q_§... I - 5 6 ~ 0 0

(7) Expenditures This Report

Monetary Expenditures $ 15,402 .70

--···--- ... -·--··"-" ·---·--·-· ····--·-···-··

Transfers to Office Account $ ' ' 0 00

--·····- ·---- -- --

Total Monetary $ ' 15 ' 402 70

·---····- -·-- --- -·--

(8) Other Distributions $

·-·-....... -... I -----·- I _, ...... - .... .Q 00

(10) TOTAL Monetary Expenditures To Date

$ ---.. --- I 23 I 704 16

( 11) Certification It is a first degree misdemeanor for any person to falsify a public record (ss. 839.13, F.S.)

I certify that I have examined this report and it is true, correct, and complete:

(Type name) ---·-------------··---·--------0 Individual (only for IE D Treasurer 0 Deputy Treasurer or electioneering comm )

x Signature

OS-DE 12 (Rev .. 11/13)

EXHIBIT

(Type name)

0 Candidate D Chairperson (only for PC and PTY)

x ---····-·-------------·---·-Signature

SEE REVERSE FOR INSTRUCTIONS

(

CAMPAIGN TREASURER'S REPORT - ITEMIZED CONTRIBUTIC'iNS

{1) Name Raqnel A Regalado (2) 1.0. Number J42]

(3) Cover Peri.od 9/1/2015

J j

9/30/2015 thr.ough I I (4) Page 1 of 2

.{5) fl) (8) (9) (10) (11) (12)

Date Full Name (t)) (Last, Suffix, First, Middle)

Sequence Streiet Address & Contributor Contribution In-kind

.. ___ f\!_ll_J'!lbeL _______ -·-· _ _fJ!}'., __ §_t<¥_~_:?i_e__fod~----Wol f son, Ellen D

J:Y.P.~--·- OC£~~_()_!1 ________ T_ye_~--- _ _ ___ Q~~c:rlr_![c:>l! __ Amen~~-~~-- ~9unt~_ I !homemaker CH $1, ooo 01

9/~8/201~ 5'.59~J~1.nne~s r;ndlane +··--·-·····--········-····'-----------'------····--·--·- Coral CoabJ e.,, ! L 3 .ll 56

l

------·--------·- --·------------1-------·----------·--·-----------·-----i-------l------" Wolfson III, Louis I k:l.eveloper CH

9/28/2015 9595 ,Journeys End Lane _____ J_ ____ ___;/ __ --IC:oral Gabl.es, fl., 33156

2

9/28/2015 I I !---·-------------

3

Naulilus Spearfishing Corp

G4E,4 W(:.st Fla9le1 St:re.et

CoL~.1 Gables, Fr, ·n111

912812015 1250 Garcia Investments, LLC,

1----f __ ___:_f __ --I PO Box. #16123 Mi:1mi, Fl 3"3116

912812015 Caribe Cafe Restaurant, Inc ,

+------'-! __ __;{ ____ 39~;3 NW 7th St:reet Miami, FL 331::'.6

5

B k:iive shop

B !real k::state

CH

CH

B !restaurant CH

1----

9--1-2--

8-1_2_0_1_5-----li--C-a_r_i_b_e_R_e_s_t_a_· -u--ran t , -B-restaura n 1 - CH

Inc .. , 1---__;:._! __ __;__J ____ , 7169 We::.;t: F.l.aglf:.r. Stn':e.!.

6

9/30/2015

MLuni, FL 3"3144

Herrera Tire Service, Inc ,

!-----'-/ __ __;! _____ 2101 NW Jt:h Avenue

B :tire services

CH

$1, 000 01

$5 0,

$100 .. Qi

$400 01

$400 0'

$300 01

~~i-M--i-"n-ti __ ·_F_l_. -33-l--2-J~------li---;------~-----1----------1------I~----~ 9 / ~01201; J:,~~~:a ,~:~,~=~ Inc· 1 B .~~~nes

$500 Q1 CH

8 1,, ... , n ,,,, I

DS-DE 13 (Rev..11/13 ) SEE REVERSE FOR INSTRUCTIONS AND CODE VALUES

CAMPAIGN TREASURER:;S REPORT- ITEMIZED ·CONTRIBUTIONS

11) Name __ RaqJJel A Regal ado

9/1/2015

(3) .Cd~er Period 1 I

.(~) (7)

D;ate Full Name (6) (last, Suffix, First, Mk.Idle)

Sequence Street Addres~~

-------~"'!_u_!!1_be~--------- ---~L~1§t~te, ~-~O~E;l __ Kaloti Metals &

9/30/2015 Logistics, t---····-····-·-··· '··--·········--··--·-·--'···-·····-···-····----···-! 5 5 NE 1 st St Y. e.E: t

Unit 34

9 Miami, FI. 33132

•(2) l.D. Number ___ --1.4_2.J__ __ _

9/30/2015 I I (4) Page 2 Of 2

(&) (9) (10) (12J

Contributor Contributibn In-kind Tv>Ye OccJ:P;ation ______ .IY::e~----- ___ Q~~Q~j_e!is>E__ Ame~~ent _ Amj_)tJrlt __

B logistics CH $750 oc

!------- --+----~-------·--·-----------~--··----+--------

I

_____ /_ ____ _!_ __ _

_ ! ___ I ___ _I

DS-DE 13 (Rev .. 11/13 ) SEE REVERSE .FOR INSTRUCTIONS AND CODE VALUES

EXHIBIT

(

CAMP'AIGN TREASURER'S REPORT - JTEM.IZE.D EXPENDITURE$ (1)Name_ Raquel A .. Regalado {2) l.D. Number 1421

9/1/2015 9/30/2015 (3)"Cover P·eriod __ 1_· __ 1_· __ through __ l __ /__ (4) P(Jge __ l ____ o"f ___ 2 ___ ,

(5) o.ate

(6.) Sequence Number

9/4[2015 LJ_L_

1

(7)

FUJI.Name (Last, Suffi')\, .First, Middle) · Street Ad~ress &

City, state, Zip Co.de

Mario's Kids Photo Studio, J 601 Le Jeune Rd Coral Gables, FL 33134

(~)

PJ,Jrpose (add Offfoe sought if

contribution to a candidate)

photography

(9} (1Q) {11}

Expenditure ryp:e Amendmi,rtt

MO $1, 388 7'

1---------+-------·------·-------·-1---------------------+-------1-------9/11/2015

2

9/12/2015

,___/_/ __ 3

Rodriguez Trueba & Co. CPA, 1985 NW 88th Court Suite 101 Doral, Fl 33172

Newwegg BusJ.ness, 17560 Rowland Street City of Industry, CA 91748

accounting & reporting services

check voided

MO $1, 275 oc

MO $-1, 566 ,, o:

1--=9....,.,,./1~5~/~2~0~1~5=-+-=B-o_r_c_e_g_u_e-.,-J~u-a_r_1--------+-c-a_m_p--a-i~g-n_w_o_r~k---1--~M~O=----'f--------11--·~~$-s-o-o-o~<

5 41 ~>W 4. 2nd Avenue.

I I Apt 126 f---"'----#.------1 Miami, Fl 3 3134

4

1--------+-------·----------t---------~1-------+-----1--------9/24/20l5 Outfront Media, outdoor MO $7,500.oc

8530 NW 23rd Street advertising

LL Dora.l, FL 33122

-- - --5

·---·--·------- ---------------·---··--·-----·w- 1----------w--i---·----·---t---••-•- ----w•-w·---•••-

9/24/2015

I I 6

Outfront Media, 8530 NW 23rd Street Doral, FL 33122

advertising production

MO $ 52 5 oc

~·--· -- ·-·---------------·-----·--- ----·-·-----·--·-------·-t------ -------9/25/2015 Ennovva, Inc., web design MO $1, soo .. o<

100 N Biscayne Blvd

/ _f_ S~ite 2906 ~---4"-· ·- Mianu, FL "3.1132

7

9/25/2015 Ennovva, Inc .. ,

I I 100 N Biscayne Blvd Suite 2906

1--------1 Miami, FL 3'132

8

advertising production

MO

DS-DE 14{Rev .. 11/13 ) SEE REVERSE FOR INSTRUCTIONS AND COD.E VALUES

EXHIBIT

$3,780.0(

CAMPAISN TREA.$URER~$ ~EP:QRT- ITEMIZED EXPENPJTU~ES f1) Name. Raquel A, Regalado (2) 1.0. Number 1421

9/1/2015 9/30/2015 {3)"Cover Period __ / __ 1_· __ through __ ;/_ __ }__ (4) ~<il9~ 2 of __ 2 __

9

.(5) Date

(6:) Sequence Number

(7)

FulfName (Last; Suffix, First, Middle} · Street Address &

City, State, Zif) Co.de

Borcegue, Juan 541 SW 42nd Avenue

Apt 126 Miami, FL 3 3134

(8)

Purpose (add office sought if · contribution to. a

candldate}

campaign work

f9) f10J

Expenditure Typ:e Afl!emim~rit

MO

(11)

Amount

$500 0(

1-------'f-----------·---·-----+-------·----~- ------- -------------

_LI

_ _j_ ___ f_~

.~l_L_

f------ --·-------------1-----------1------+-----+-----~

I / __

- .. ---~---·-----------------~·--··--------------·--------~··---·-- ---~------ --·~-----·+----·--·--

l I

--------- ·---·--·-----··-···------·- ·----------·----- -·-----------!-·------

__ __j___L_

t----£-1__.I.__. __

OS-DE 14 (Rev..11113 ) SEE REVERSE FOR INSTRUCTIONS AND CODEVALUES

EXHIBIT

"'"<. ._,,~ ..... ,.,..._, """"'· ........................ I " ._ ......... ,. .... """'"" ........... ._..,.__, ·- .............. • •• .............. ·• ......... .

) . .. '"""<. . .._...._,, .... , , .............. ,. ,,...._ .. ,....., ....... I·• -···· ·•""'"'·· .... ·•••• .................... , ._......,. ._.. .. ·• •• ....... "·• ......... .

Via E-Mail

Margie B. Wade Investigation Specialist II Florida Elections Commission 107 West Gaines Street, Suite 224 Tallahassee, FL 32399

Re: FEC 15-372

Dear Ms. Wade:

(

May 31, 2016

This office represents Ms. Raquel Regalado .. Please find attached the affidavits requested in connection with the above-referenced matter.

In addition to the attached affidavits, it is important to clarify a number of items. The website described in the affidavits, www.raquelregalado.com (the "Website"), was simply a "landing" website. In other words, there was no content available to be viewed on this website. During the time that the video referenced in the affidavits was erroneously uploaded to the Website, the Website was currently under construction and not a finished product.

The contract between Serving Miamians and Ennova, Inc., attached hereto, references payment in the amount of 50% of the invoice upon execution of the contract, and 50% payment upon completion of the Website. At the time the video was posted, the final 50% had not been paid, as work on the Website was still ongoing. Neither Ms. Regalado nor Serving Miamians had been advertising the Website .. In fact, it was not intended that the Website be viewed by any visitors at the time the video was posted.

If you have any questions or require additional information, please do not hesitate to contact me directly at 305..377.1000. Thank you for your time and attention ..

MM;ka Ends. Copy to: Raquel Regalado, Esq.

Roland Sanchez-Medina Jr., Esq.

Sincerely,

F'\38210001\R"i>O"""'""'- FEC15-372do~ EXHIBIT // /l"6' Ii ;'i SANCHEZ-MEDINA, GONZALEZ, QUESADA, LAGE, CRESPO, GOMEZ, MACHA: 0 .f§t PRE.IRA LLP I SMGQLAW COM ------·-----·---

?()1 Al 1-lAMRRA l:IR!:I f:' !=;I ll'TI=' 1 ?()<=; rnRAI <::ARI f:'C: l='I "l':\ 1':\L[,,<=;1 ()'7 I 'T'l='I '':\()<=; ':\77 1()()() I l='A)( R<=;<=; ':\?7 ()':\Q1

AFFIDAVIT OF BACKGROUND INFORMATION Case Number: FEC 15-372

STATE OF FLORIDA County of Miami-Dade

Raquel Regalado, being duly sworn, says:

1. This affidavit is made upon my personal knowledge.

2. I am of legal age and competent to testify to the matters stated herein. I am currently

employed by Miami-Dade County Public Schools as School Board Member.

3. Have you ever run for public office? If so, please name the office(s) you ran for and the date(s) of the election(s) you ran in.

Yes, I ran for School Board Member in 2010. I was elected for a four (4) year term, and I ran again for re-election in 2014. I was re-elected to a second fom (4) year term.

4. Have you ever been appointed to act as a campaign treasurer for a candidate? If so, please name the candidate(s) you served as treasurer, the office(s) the candidate ran for, and the dates of the election(s).

Yes, I was campaign treasurer for Tomas Regalado's mayoral campaign in 2008.

5. Have you ever held the office of chairperson, treasurer, board member, or other similar position for a political committee? If so, please list the names and addresses of the committees and dates when you held the position.

No.

6. Have you ever prepared or signed a campaign treasurer's report? If so, please list the name of the candidate or committee whose report you prepared or signed.

Yes, as campaign treasurer for Tomas Regalado's mayoral campaign in 2008.

7. What action have you taken to determine your responsibilities under Florida's election laws?

I am a constitutionally elected official.

8. Do you possess a copy of Chapter 106, Florida Statutes?

9. If so, when did you first obtain it? 2010, 2014, and 2015.

10.

11.

Have you read Chapter 106, Florida Statutes?

Do you possess a copy of Chapter 104, Florida Statutes?

12. If so, when did you first obtain it? 2010.

13.

14.

Have you read Chapter 104, Florida Statutes?

Do you possess a copy of the Handbookfor Candidates?

EXHIBIT Inv040 ( 6/08)

~Yes D No

~Yes

~Yes

D No

D No

~Yes D No

~Yes D No

(


16. Have you read the Handbook for Candidates? rgj Yes D No

17. List any additional materials you received from the Supervisor of Elections.

None at this time.

18. Please describe your communication with the officers and members of Serving Miamian regarding the creation and "launching" of the website and video. Please include the time and place the communications occurred. If there were any written communications, please provide copies.

None.

These questions below pertain to the campaign website.

19. Did you review the website before it became "live"?

No, I did not review the website before it became "live".

20. Did you approve the website before it became "live"?

No, I did not approve the website before it became "live".

21. When did you become aware of the website?

I became aware of the website upon receipt of the letter from the Florida Elections Commission dated June 30, 2015 ..

22. How did you become aware of the website?

I became aware of the website upon receipt of the letter from the Florida Elections Commission dated June 30, 2015.

23. According to the written response submitted by your attorney, it was not intended for the website to be accessed by visitors. What did you and/or your campaign do to prevent visitors from accessing the website?

The Website had not been approved or reviewed at the time it went "live". Neither I nor my campaign had been advertising the Website. The Website was not intended to be viewed by any visitors during the time the video was posted. Upon receipt of the letter from the Florida Elections Commission dated June 30, 2015, I contacted Ennova, Inc. and demanded that the video and the website be taken offline immediately.

The questions below pertain to the video.

24. Did you review the video before it was posted on the website?

No, though I appear in the video, I had not reviewed the final product.

25. Did you approve the video before it was posted on the website?

No, I had not reviewed the final product. Furthermore, it was not my position to approve the posting of the video.

26. When did you become aware of the video?

EXHIBIT Inv040 (6/08)

.I became aware of the video, with respect to its posting on the website, upon receipt of the letter from the Florida Elections Commission dated June 30, 2015.

27. How did you become aware of the video?

I became aware of the video, with respect to its posting on the website, upon receipt of the letter from the Florida Elections Commission dated June 30, 2015.

EXHIBIT Inv040 ( 6/08)

(

I HEREBY SWEAR OR AFFIRM THAT THE FOREGOING INFORMATION IS TRUE AND CORRECT TO nm BEST OF MY KNOWLEDGE.

Case Investigator: MBW

Inv040 (6/08)

------~&A~.._'tQHPl/'-----·--' 2016 I

Signature

Print, Type, or tamp Commissioned Name of'Nota1y Public

Personally Known ____ 01 Produced Identification /

Type of Identification Produced: !Fi..-,-.,a.t.;JA i")R.XVc;@(\

-------~------>=k=.zi=J_,,..-Y:au::~.~<-·~~--~-

~-;:--;:;;~,;~., -~--··-·---i~0~ Af<.(;\ J~M Fl !HENIE : ~-. i*) MY COMMISSION #FF151526 -:,·.-1-~;.:Q~::

{~0(;;;.f' EXPiRES August 14, 2018 407) ·39;;· 0153 FloridaNotaryService.com ---

EXHIBIT ____.it..t..1_,.f?i"51:l~....,e.. _E"-l!f-f-~ .... 4

/

1. ( t_

AFFIDAVIT OF ADDITIONAL INFORMATION Case Number: FEC 15-372

STATE OF FLORIDA COUNTY OF MIAMI-DADE

ROLAND SANCHEZ-MEDINA JR., being duly sworn, says:


2. I am of legal age, sui juris and competent to testify to the matters stated herein. I am currently employed by Sanchez-Medina, Gonzalez, Quesada, Lage, Gomez & Machado, LLP as an attorney.

3. My telephone number is 305-377-1000, Ext.108.

4. According to the information disclosed on your 2015 M3 Report, you made an expenditure to Ennova, Inc. for "Web design." Please provide copies of the artwork and invoice for the web design.

Copies of the artwork and invoice for the web design are attached.

5. According to the information disclosed on your 2015 M3 Report, you made an expenditure to Ennova, Inc. for "advertising." Please provide copies of the adverting and the invoices.

No expenditure was made to Ennova, Inc. for advertising. The attached invoice was limited to web design and the creation of one video.

The following questions pertain to Attachment A.

6. The disclaimer on the web site states, "Paid and approved by Serving Miamians." Please provide the name and contact information for the person responsible the verbiage in the disclaimer.

No disclaimer was provided to Ennova, Inc. The disclaimer language was created by Ennova, Inc. as a result of the execution of the contract between Serving Miamians and Ennova, Inc.

7. Please provide the name and contact information for the person responsible for verbiage on the web site.

Amelie Ferro. She may be contacted at 305-938-0728.

8. Please provide the name and contact information for the person that reviewed and approved the web site and the person that reviewed and approved the video.

The Website had not been approved or reviewed. As referenced in the letter above, the website was in a period of initial construction and was not intended to go "live" at the time of the posting of the video. The Website was not completed and no content was available on the

EXHIBIT

lnv041 ( 6/08) 1

/

i

Website. To my knowledge, Ennova, Inc. was in the process of testing the design and connectivity of the website at the time the video was erroneously uplOaded.

9. Please provide the invoices for the web site and video that appears on the web site.

The invoices are attached hereto.

10. Please provide a copy of the payment instruments for the web site and the video.

The payment instruments are attached.

11. Please provide a copy of the video.

I am not in possession of the video, though I am attempting to obtain a copy from Ennova, Inc.

12. Was Ms. Regalado aware that your published the web site? ( ) Yes ( X) No

To the best of my knowledge, Ms. Regalado was unaware that the Website was "live" and published

13. Did any officer or member of Serving Miamians discuss the web site with Ms. Regalado? No.

If so, please provide the name(s) and contact information for each person that communicated with Ms. Regalado. Not applicable.

14. Did Ms. Regalado provide the information for the web site? ( ) Yes ( X) No

There was no information on the Website.

15. Did Ms. Regalado review the web site? ( ) Yes ( X) No

16. Did Ms. Regalado review the video? ( ) Yes ( X) No

17. Did Ms. Regalado approve the web site? ( ) Yes ( X) No

18. Please explain why Serving Miamians published the website?

Serving Miamians was in the process of publishing a new website about Raquel Regalado in conformity with IRS rules and regulations. Serving Miamians has been informing Miami-Dade County residents regarding Raquel Regalado and Tomas Regalado for five (5) years. The language included in the video requesting support for Ms. Regalado was simply a mistake, as the intent of the video was to educate Miami-Dade County regarding various issues. The video was immediately removed from the Website.

lnv041 ( 6/08) 2

/

( (

I HEREBY SWEAR OR AFFIRM THAT THE FORGOING INFORMATION IS TRUE AND CORRECT TO THE

BEST OF MY KNOWLEDGE.

+() .... ~:,v.~'::'t- MICHAEL A. MONTIEL * * MY COMMISSION #FF 923292

EXPIRES: October 1, 2019 Bonded Thru Budget Notary Services


Inv04 l ( 6/08)

EXHIBIT

Signature of Affiant

Sworn to (or affirmed) and subscribed before me this S 1 ,,-r day of May, 2016

Signature '\f Nitary Public - State of Florida

Print, Type\ir Stamp Commissioned Name of Notary Public

I ;1.. 12'f!r ,Jj 3

3

----------·--·--. (

February 25, 2015

we are thrilled to assist with your production needs.. Below please find two options. Both include the

different needs we discussed. In the first option I have also included as a value added the use of our studio for your campaign commercials as well as the ability to perform live streaming with interaction from third parties .. This may be very interesting for any kind of survey and to increase engagement with

your constituents

Option .1: All Inclusive

~·-------·--··-----·--·----- ---------- - -·--·-·····---

Service Unlimited Monthly Access to Studio Facility and Production Team Unlimited Access for:

Short format segments with director and editors that provide all post-production work .. ··--Digital Platform Live Streaming with interaction of unlimited concurrent users ..

Production of Campaign Commercials. (Studio Use)

Design of Website

Hosting of Website and a secured FTP server Video Platform Sites: Development ofYouTube branded channel with campaign website color and image theme and the publishing all productions on platform ..

-- Monthly Fee: $10,000 ''··

Option 2: Per Usage ____ , ___________ ...,.._ ____________ ..., _____ ... --Service FuHDay Half Day

Studio, camera lighting and audio equipment, camera operator, fiber line $1,40( $1,080

Editing, Grafic Package and Post Production $600 $500

Publish productio.ns on company website, secure FTP, social media & video platforms $20 per production

Design of Website $3,000

Hosting of Website and a secured FTP server $40a month

Access to Live Streaming with Interaction of Unlimited and Concurrent Users TBD Access to Studio Facility for Campaign Commerical Production TBD

I look forward to seeing you tomorrow and continuing to explore opportunities to work together!

Best,

www.CIMACAST.com 100 N Biscayne Boulevard Suite 2906 Miami Florida 33132 ..

-· -----·------·-· ··-·-··· ----·---

INVOICE

ENNOWAINC. 100 N Biscayne Blvd, Suite 2906 Miami, FL 33132 Phone: (855) 366 6882 EIN 45-3765499

(

·<~ :\ : . ~~:

~ ..

invoice N(). -···--'-- Date 0438 3 6 2015

Bill To· i------··..__;.;_-· -··-~---~· --- Shi To ----··-·· .. ·--'-·------Setvings Miamians

""---·--------·-·---

Ou:antiru · bescription ·.

-··--···--·-..:. ... _,. . ...;, __ . Anfount ... ·Tetanus~

1 Full day February 26, .2015 and March 5, 2015 Studio, camera lighting and audio equipment, camera operator, fiber line $ 1,400.00 $ 1,400.00 Editing, graphic package and postproduction $ 600.00 $ 600.00

1/2 Day ·March 6, 2015 Studio, camera lighting and audio equipment, camera operator, fiber line $ l,080.00 $ 1,080.00 Editing, graphic package and postproduction $ 500.00 $ 500.00

Please make payments to: ENNOWAINC.

100 N. Biscayne Blvd. Suite 2906 Miami, FL 33132

,..,_:'.: . . ..

L ..

TOTALUSD $ 3,580.00

EXHIBIT ll

INVOICE


,.,..B_ill_~_o..,... ---·---;·--·---.. ·------·--.. -------------------

Servings Miamians

I OuaintitY · -Qescdption - . .. Web Design

50% due upon receipt of invoice

50% Due at completion of website

'


100 N. Biscayne Blvd. Suite 2906·

Miami, FL 33132

--~-----. ' ---·i invoice No. · · Date · 0437 - 3/6/2015

.--. ----------. ·-------. Shi. To

--·-----------'

--· ---:-.. Amount. -·· .TotaHJSD.

$ 3,000.00 $ 3,000;00

--DUENOW $1,500.00 BALANCE $, i,soo~oo

. .,,

EXHIBIT J S . fk'f;< $ g :s z

- Regalado website Margie Wade to aferro

Dear Ms .. Ferro,

/ (

06/01/2016 04:25 PM

As we discussed in our earlier telephone conversation, when I reviewed the initial website, www .. raquelregalado .. com, the site appears to be a website for Ms .. Regalado's mayoral campaign but the disclaimer reads, "Paid and approved by Serving Miamians .. " I need to know the following

1.. Who contacted your company to produce the website? 2.. Who contacted your company to produce the video on the website? 3.. Was the website Ms .. Regalado's website or Serving Miamians' website? 4.. Who decided what content the website would contain? 5.. Who decided on the verbiage used in the disclaimer? 6.. What instructions, if any, were you given regarding the content of the website? 7.. When was the website scheduled to be accessible to the public? 8.. How was Ms .. Regalado involved in the design/production of the website? 9.. Did Ms .. Regalado review the website? If so, how do you know that she reviewed the website?

10.. Did Ms .. Regalado review the video? If so, how do you know that she reviewed the video? 11.. When (on what date) was the website completed and ready for public viewing?

~g', 'Wade Investigation Specialist II Florida Elections Commission 107 West Gaines Street, Suite 224 Tallahassee, FL 32399 850-922-4539 (phone) 850-921-0783 (fax)

EXHIBIT _...._1__..L/_. __

,, .. (

"S~~\l'IN«:i\ WilfAMDbl.~$ IEC©" 1985 NW 88TH CT #10~ MIAMI, FL. 33172·2648

PAY TO THE Ennowa Inc ORDER OF---------·-·------------ ----·----·--·------

·--------·------------·-- ·---

MEMO

Ennowalnc WO N Biscayne Blvd .. Sulte2908 Miami, Fl 33132

Invoice #0437 J

Check#: 1145 for $1,500.00 Posted: 3/13/2015

i145

3110/2015

$ "'°'i,500.00

~ :5 c c. <. n . -J r

- -----·-···-----·-· -- ---·-··-·----------· - - ----·-·----- -- --- --------- .. ------·-------

Check#: 1145 for $1,500.00 Posted: 3/13/2015

EXHIBIT

CltY C!At!CC\IAL !!lAl41( 1146 """"·~"""'

0 SEJPJV!til;!JG lillli6il.l\ll1ANS EC@• 1134311/iCO

1985 NW 88TH CT #101 MIAlllll, FL 33172-2648

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8 PAY TO THE Ennowalnc. J $ ""3,580.00 j ORDER OF -·

Thr~ Thousand five Hundred EigMy and 001100•••••••••••••000-••••••-•••

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Ennowa Inc. ~ 100 N Biscayne Blvd 1 Suite2906

~ j Miami, FL 33132

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t AlJTl10AILED SIGNATURE

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Check #: 1146 for $3,580.00 Posted: 3/13/2015

6/9/2016 Page 2

===================================~~-================~1r-~~·~

Check#: 1146 for $3,580.00 Posted: 3/13/2015

EXHIBIT

... - -- -.••-. _,.. -- .. ·- :....:.:- -··-

Ennowa,lnc 100 Biscayne, Blvd Suite 2906 Miami, Fl.33132

Transit - 10/1/2015

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DEPOSIT TICKET

TOTAL ITEMS rn OEP0Sf1S AMY 1'0T BE AVAii.ABLE FOTI

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'----------- ---.. ------------------------"-------__, DDA Credi ts - 10/l/2~xl5_1B'T ~

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AFFIDAVIT OF FILING OFFICER Case Number: FEC 15-372

1. Please provide certified copies of the listed items from the following can~~~~tf~ bai:pr.aigt!;fil~; t n Raquel Regalado. -- - · ' :,(. · '- v

f"l .·

' Check ITEM

./ The Statement of Candidate form for 2016. (Statement of Candidate provided was signed on 03109115)

Appointment of Treasurers and Designation of Campaign Depository form for 2016 .. (Appointment of Campaign

./ Treasurer and Designation of Campaign Depository provided was signed on 03109115)

./ 2015 M3, M4, and M5 Reports (attached)

Un-redacted copies of any checks issued to your office. (NIA - Payment to the Elections Department is due at the ./ time of qualifying in June 2016)

--./ Statements of financial interest (Form 1 and Form 6) for 2016 .. (NI A - The required Statement of Financial

Interest is due at the time of qualifying in June 2016) -

2.. Please check each item provided to the candidate or his or her staff, and list the date that the item was provided. (If the item is published by the Division of Elections, it is unnecessary to provide a copy of the item. If your office published the item, please send a copy of the item with this affidavit.)

Check ITEM

Chapter 106, Florida Statutes (Provided to the candidate as part of A Comnilation of ./ .The Election Laws of the State of Florida. (Link to this page is found in the Elections

Department website in Candidate Qualifyjng Handbook) -

Chapter 104, Florida Statutes (Provided to the candidate as part ofA Comnilation of ./ The Election Laws of the State of Florida Link to this page is found in the Elections

Department website in Candidate Qualifj;ing Handbook)

Candidate Handbook Please indicate Year -(2016 Candidate Qualifying ./ Handbook.)

Political ad and disclaimer supplement (Provided as part of the 2016 Candidate and ./ Campaign Treasurer Handbook. Link to this page isfound in the Elections

Department website in Candidate Qualifj;ing Handbook)

DATE

03/09/15

03/09115

03/09/15

03/09/15

·-

·-

./ Calendar of Election dates (Calendar of Election Dates is available on the Elections 03/09/15; 03/16/15; and

Department website. Calendar of Reporting Dates was provided to the candidate as 12/28/15

an attachment to the Acknowledgement Letter dated 03116115, and as part of thee-mail to candidates dated 12128115). In addition, the Calendar of Reporting Dates can befound in the Election Department's website in Candidate Qualifj;ing Handbook)

Any other election related document, Please indicate the title of the related 03/16/15 ./ document (Guidelines to a Success[_ul Cameaign Reeort was provided to the

candidate along with the Acknowledgement Letter)

( '

3 Please list all other written materials provided to the candidate or his or her staff, the date ofreceipt, and a brief description of the written materials. Did you notify the candidate that the campaign handbook was available on the Division of Elections website?

The following written materials were provided: Acknowledgement Letter dated 03116115, Incomplete Report letter for l 5-M03 dated 04108115 and delivered 04113115; E-mail regarding campaign reporting dates sent on 12128115. The candidate was notified that the campaign handbook was available on the Division of Elections website through submittal o[the MD-ED 2 "Access to Handbook and the Election Laws of the State of Florida" (attached). This iriformation is also provided to the candidate via the Candidate QualifVing Handbook and the Oualifving Information Handbook package for Mayoral Candidates 20 I 6)

4. Please list all training seminars that were attended by the candidate, along with the date of attendance .. If a staff member attended for the candidate, list his name and position.. If available, please attach a copy of any attendance sheets from the seminar(s)..

NIA. Please refer this question to the Miami··Dade County Commission on Ethics and Public Trust as they coordinate candidate trainings.

5.. Please list the su~jects covered during these seminars .. If available, please provide a copy of the syllabus and outline for the seminar.

NIA. Please refer this question to the Miami-Dade County Commission on Ethics and Public Trust as they coordinate candidate trainings. The Elections Department covers a portion of the training relating to becoming a candidate; .campaign financing; legislative changes, and other information.

6.. Please list any other contacts with this candidate by you or your staff concerning a provision of Chapter 104, Section 105 .. 071, or Chapter 106, Florida Statutes.. Indicate whether the contact was in person, in writing, or by telephone and the subject matter of the contact. Also,provide copies of any documentation of the contact Please provide a separate affidavit from anymember of your staff who was in contact with this candidate or his or her staff, detailing thesubject matter of the contact Candidate and Treasurer received routine e-mail notifications regarding upcoming deadlines for the filing of campaign reports (see attached).

7. Please list each year the candidate ran for office, the office the candidate ran for, the dates of the elections, and the results of the elections ..

08124110 School Board, District 6 Elected (http;/ lresults. enr. clarityelections. comlF LIDadel203471325 781enlsummary.htmlJ

08126114 School Board, District 6 Elected Unopposed (htto./lwww. voterfocus. comlwslmdccand/candidate pr.php? c=miamidade&el= I 7)

08130116 Mayor, Miami-Dade County Announced Candidate (http./lwww. voterfocus. comlwslmdccand/ candidate pr. php? c=miamidade&el= 20)

EXHIBIT

(,-- (.'

I SWEAR OR AFFIRM THAi ~ .AE INFORMATION CONTAINED rt, L~iS DOCUMENT IS COMPLETE

AND ACCURATE TO THE BEST OF MY KNOWLEDGE.

EXHIBIT

Sworn to (or affirmed) and subscribed before me this-~: ;,_;; ___ day of -- . /"Z ;~; 1.AAA.> ··1 r.,;:i

d ------~ 2016

·1 I 1'

•'":i/vvv! { > ~~i',L:'.S: .. i.;_. /)[,hr_;: tt. vt

Signature of · otary PubJfc .. State of Florida

Pr~--11111111ilftlllllltll1mimoofil11iflfiMmffit1t~fNotary Public = ' . -= ~ = § ~<;~ ANNE VANESSA INNOCENT i § ":·, ~ Notary Public. State of Florida ~. Si ' • ,o.~- My Comm Expires Jun 2 2018 § - f?.".... ~ -§ 1,19:,:,;'2-.•" Commission # FF 116919 § !ID111111111111!•i!!l!lilllllflli!llllllllllllllJ.llllillllllllllllllllllllllllllllllllllll~. • •

Personally Known~or Produced Ident1ficat10n _____ _

Type of Identification Produced: -------------

---·---·--------

STATEMENT OF CANDIDATE

(Section 106.023, F.S.)

(Please print or type)

I, _ Raquel A. Regalado

{ '

H~tJ~W.SE8'!LY

2015 HAR .. 9 AM m: ~ 6

MlA.Ml-DA~E eLEtT\ONS

candidate for the office of Miami-Dade County Mayor

have been provided access to read and understand the requirements of

Chapter 106, Florida Statutes.

'tJ:"t~r, ;~~ffi ' ' ~l :~~ ::;;(1 ('./\!

,• ~·~ll~ " .. ~~~ t;

Each canditlate ... mu$t fi!e ... ~;,.statem~nt with the qualifying officer within 10 days after the Appointment of Campaign Treasu.rer ~nd Designation of Campaign Depository is filed. Willful fa,ilure .to f:tl§»~:Yfyf~mJi§d} .{lr,:s.bp.~S,ree misdemeanor and a civil violation of the Campa!gn Financing Act which may resuft tna fine of up to $1,000, (ss. 106 .. 19(1)(c), 106..265(1), Florida Statutes).. i3ViOll~):LJ

Al!fHr· [ ~ t'(i~Uf;,;) ~(~'~.u ~ j:-,lf.(1

DS-DE 84 (05/11)

EXHIBIT t 17

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Via E-Mail

Margie B. Wade Investigation Specialist II Florida Elections Commission 107 West Gaines Street, Suite 224 Tallahassee, FL 32399

Re: FEC 15-372

Dear Ms. Wade:

ATTORNEYS AT LAW ~- - .~ .. ... '')

,., .• •' iH ...,...~ .• ~J

May 31, 2016

This office represents Ms. Raquel Regalado. Please find attached the affidavits requested in connection with the above-referenced matter.

In addition to the attached affidavits, it is important to clarify a number of items. The website described in the affidavits, www.raquelregalado.com (the "Website"), was simply a "landing" website. In other words, there was no content available to be viewed on this website. During the time that the video referenced in the affidavits was erroneously uploaded to the Website, the Website was currently under construction and not a finished product.

The contract between Serving Miamians and Ennova, Inc., attached hereto, references payment in the amount of 50% of the invoice upon execution of the contract, and 50% payment upon completion of the Website. At the time the video was posted, the final 50% had not been paid, as work on the Website was still ongoing. Neither Ms .. Regalado nor Serving Miamians had been advertising the Website. In fact, it was not intended that the Website be viewed by any visitors at the time the video was posted.

If you have any questions or require additional information, please do not hesitate to contact me directly at 305.377.1000. Thank you for your time and attention.

MM;ka En els. Copy to: Raquel Regalado, Esq ..

Roland Sanchez-Medina Jr., Esq.

F:\3821.0001\Responseletter2 - FEC 15-372 .docx

Sincerely,

SANCHEZ-MEDINA, GONZALEZ, QUESADA, LAGE, CRESPO, GOMEZ, MACHADO & PREIRA LLP I SMGQLAW COM

201 ALHAMBRA CIRCLE, SUITE 1205, CORAL GABLES, FL 33134-5107 I TEL: 305 .. 377 .. 1000 I FAX: 855.327 .0391

(\

AFFIDAVIT OF ADDITIONAL INFORMATION Case Number: FEC 15-372

STATE OF FLORIDA ) COUNTY OF MIAMI-DADE )

ROLAND SANCHEZ-MEDINA JR., being duly sworn, says:


2. I am of legal age, sui furis and competent to testify to the matters stated herein. I am currently employed by Sanchez-Medina, Gonzalez, Quesada, Lage, Gomez & Machado, LLP as an attorney.

3. My telephone number is 305-377-1000, Ext. 108.

4. According to the information disclosed on your 2015 M3 Report, you made an expenditure to Ennova, Inc. for "Web design." Please provide copies of the artwork and invoice for the web design.

Copies of the artwork and invoice for the web design are attached.

5. According to the information disclosed on your 2015 M3 Report, you made an expenditure to Ennova, Inc. for "advertising." Please provide copies of the adverting and the invoices.

No expenditure was made to Ennova, Inc. for advertising. The attached invoice was limited to web design and the creation of one video.

The following questions pertain to Attachment A.

6. The disclaimer on the web site states, "Paid and approved by Serving Miamians." Please provide the name and contact information for the person responsible the verbiage in the disclaimer.

No disclaimer was provided to Ennova, Inc. The disclaimer language was created by Ennova, Inc. as a result of the execution of the contract between Serving Miamians and Ennova, Inc.

7. Please provide the name and contact information for the person responsible for verbiage on the web site.

Amelie Ferro. She may be contacted at 305-938-0728.

8. Please provide the name and contact information for the person that reviewed and approved the web site and the person that reviewed and approved the video.

The Website had not been approved or reviewed. As referenced in the letter above, the website was in a period of initial construction and was not intended to go "live" at the time of the posting of the video. The Website was not completed and no content was available on the

Inv04 l ( 6/08) 1

i '

Website. To my knowledge, Ennova, Inc. was in the process of testing the design and connectivity of the website at the time the video was erroneously uploaded.

9. Please provide the invoices for the web site and video that appears on the web site.

The invoices are attached hereto.

10. Please provide a copy of the payment instruments for the web site and the video.

The payment instruments are attached.

11. Please provide a copy of the video.

I am not in possession of the video, though I am attempting to obtain a copy from Ennova, Inc.

12. Was Ms. Regalado aware that your published the web site? ( ) Yes ( X) No

To the best of my knowledge, Ms. Regalado was unaware that the Website was "live" and published

13. Did any officer or member of Serving Miamians discuss the web site with Ms. Regalado? No.

If so, please provide the name(s) and contact information for each person that communicated with Ms. Regalado. Not applicable.

14. Did Ms. Regalado provide the information for the web site? ( ) Yes ( X) No

There was no information on the Website.

15. Did Ms. Regalado review the web site? ( ) Yes ( X) No

16. Did Ms. Regalado review the video? ( ) Yes ( X) No

17. Did Ms. Regalado approve the web site? ( ) Yes ( X) No

18. Please explain why Serving Miamians published the website?

Serving Miamians was in the process of publishing a new website about Raquel Regalado in conformity with IRS rules and regulations. Serving Miamians has been informing Miami-Dade County residents regarding Raquel Regalado and Tomas Regalado for five (5) years. The language included in the video requesting support for Ms. Regalado was simply a mistake, as the intent of the video was to educate Miami-Dade County regarding various issues. The video was immediately removed from the Website.

Inv04 l ( 6/08) 2

(

I HEREBY SWEAR OR AFFIRM THAT THE FORGOING INFORMATION IS TRUE AND CORRECT TO THE

BEST OF MY KNOWLEDGE.

:\~ll.Y l'IJ~ • 0 .····./to MICHAEL A. MONTIEL

* ~ * MY COMMISSION# FF 923292 .. ~... EXPIRES: October 1, 2019 ~"eOF ,...&-<s Bonded Thrv Budget Notary Seriices


Inv041 (6/08)

~-Signature of Affiant

Sworn to (or affirmed) and subscribed before me this '".>I sf day of May, 2016

Print, Type, Stamp Commissioned Name of Notary Public

3

I

1.

AFFIDAVIT OF BACKGROUND INFORMATION Case Number: FEC 15-372

STATE OF FLORIDA County of Miami-Dade

Raquel Regalado, being duly sworn, says:



employed by Miami-Dade County Public Schools as School Board Member.

3. Have you ever run for public office? If so, please name the office(s) you ran for and the date(s) of the election(s) you ran in.

Yes, I ran for School Board Member in 2010. I was elected for a four (4) year term, and I ran again for re-election in 2014. I was re-elected to a second four (4) year term.

4. Have you ever been appointed to act as a campaign treasurer for a candidate? If so, please name the candidate(s) you served as treasurer, the office(s) the candidate ran for, and the dates of the election(s).

Yes, I was campaign treasurer for Tomas Regalado's mayoral campaign in 2008.

5. Have you ever held the office of chairperson, treasurer, board member, or other similar position for a political committee? If so, please list the names and addresses of the committees and dates when you held the position.

No.

6. Have you ever prepared or signed a campaign treasurer's report? If so, please list the name of the candidate or committee whose report you prepared or signed.

Yes, as campaign treasurer for Tomas Regalado's mayoral campaign in 2008.

7. What action have you taken to determine your responsibilities under Florida's election laws?

I am a constitutionally elected official.

8. Do you possess a copy of Chapter 106, Florida Statutes? IZI Yes D No

9. If so, when did you first obtain it? 2010, 2014, and 2015.

10. Have you read Chapter 106, Florida Statutes? IZI Yes D No

11. Do you possess a copy of Chapter 104, Florida Statutes? IZI Yes D No


13. Have you read Chapter 104, Florida Statutes? IZI Yes D No

14. Do you possess a copy of the Handbook for Candidates? IZI Yes D No

Inv040 ( 6/08) 1

( ( \


16. Have you read the Handbook for Candidates? 1:2:] Yes 0 No

17. List any additional materials you received from the Supervisor of Elections.

None at this time.

18. Please describe your communication with the officers and members of Serving Miamian regarding the creation and "launching" of the website and video. Please include the time and place the communications occurred. If there were any written communications, please provide copies.

None.

These questions below pertain to the campaign website.

19. Did you review the website before it became "live"?

No, I did not review the website before it became "live".

20. Did you approve the website before it became "live"?

No, I did not approve the website before it became "live".

21. When did you become aware of the website?


22. How did you become aware of the website?


23. According to the written response submitted by your attorney, it was not intended for the website to be accessed by visitors. What did you and/or your campaign do to prevent visitors from accessing the website?

The Website had not been approved or reviewed at the time it went "live". Neither I nor my campaign had been advertising the Website. The Website was not intended to be viewed by any visitors during the time the video was posted. Upon receipt of the letter from the Florida Elections Commission dated June 30, 2015, I contacted Ennova, Inc. and demanded that the video and the website be taken offline immediately.

The questions below pertain to the video.

24. Did you review the video before it was posted on the website?

No, though I appear in the video, I had not reviewed the final product.

25. Did you approve the video before it was posted on the website?

No, I had not reviewed the final product. Furthermore, it was not my position to approve the posting of the video.

26. When did you become aware of the video?

Inv040 (6/08) 2

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1.


27. How did you become aware of the video?


Inv040 (6/08) 3

I HEREBY SWEAR OR AFFIRM THAT THE FOREGOING INFORMATION IS TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE.


Inv040 ( 6/08)

~·-fgfultUre of Affiant /}/JI

Sworn to (or affirmed) and subscribed before me this 2 7 day of

__, 2016

Personally Known ____ or Produced Identification / __ _

Type ofldentification Produced: FL.ol??j)A Dt?....tVeyeQ

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JIM R RE.NE MY COMMISSION #FF151526

EXPIRES August 14, 2018

FloridaNotaryService.com

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cimacasl

February 25, 2015

We are thrilled to assist with your production needs. Below please find tw o options. Both include the

alue added the use of our

streaming with interaction

different needs we discussed .. In the first option I have also included as a v studio for your campaign commercials as well as the ability to perform live

from third parties. This may be very interesting for any kind of survey and t o increase engagement with

your constituents.

Option 1: All Inclusive

-·-·--------Sel"V.ice

Unlimited Monthly Access to Studio Facility and Production Team Unlimited Acee SS for:

Short format segments with director and editors that provide all post-productio nwork.

Digital Platform Live Streaming with interaction of unlimited concurrent users.

Production of Campaign Commercials. (Studio Use)

Design of Website

Hosting of Website and a secured FTP server Video Platform Sites: Development of YouTube branded channel with campaign website color and image theme and the publishing all productions on platform.

- Monthly Fee : $10,000

Option 2: Per Usage

-·-.....,.._-----.---------· Service Full Day Half Day

Studio, camera lighting and audio equipment, camera operator, fiber line $1,40 $1,080

Editing, Grafic Package and Post Production $600 $500

Publish productions on company website, secure FTP, social media & video pla tforms $20 per production

Design of Website $3,000

Hosting of Website and a secured FTP server $40 a month

Access to Live Streaming with Interaction of Unlimited and Concurrent Users TBD

Access to Studio Facility for Campaign Commerical Production TBD

I look forward to seeing you tomorrow and continuing to explore opportuni ties to work together!

Best, ...,;; .. ""' ..

Am~rr;o ,

~,l__/~------

www.CIMACAST .. com

100 N Biscayne Boulevard Suite 2906 Miami Florida .. 33132

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INVOICE


Date· 3 6 2015

Shii:>'To. ··.··.

'------------·-------··ouer>ate·

3 6 2015

Oliantltv ·. ·Description .. .. ···:"• .· ·Amount · ::'.: Totafusp --·-.... ·-·- ·-1 Full day February 26, 2015 and March 5, 2015

Studio, camera lighting and audio equipment, camera operator, fiber line $ 1,400.00 $ 1,400.00 Editing, graphic package and postproduction $ 600.00 $ 600.00

1/2 Day ·March 6, 2015 Studio, camera lighting and audio equipment, camera operator, fiber line $ 1.,080.00 $ 1,080.00 Editing, graphic package and postproduction $ 500.00 $ 500.00


100 N. Biscayne Blvd. Suite 2906 Miami, FL 33132

·.;;: .... '··

TOTALUSD $ 3,580.00

.. •

INVOICE


Bill To Servings Miamians

IOuantitv · · · · Qe5c:dptfon· ..

Web Design

50% due upon receipt of invoice

50% Due at completion of website


100 N. Biscayne 'Blvd. Suite 2906' Miami, FL 33132

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$

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·Amount 3,000.00

Date· · · 1 3/6/2015

.Due.bate . 3 6 2015

.· TotafUSD. "

$ 3,000:'00

DUENOW $1.500.00 BALANCE .1$ 1;.500~00

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PAY TO THE

"SERVING MIAMIANS Eco· 1985 NW SSTI-1 CT #101 MIAMI, FL 331 T.M?648

Ennovva Inc. OADEROF~~~~~~~~·~~~~~~~~~~~~-~~~~~~~--'

311012015

$ '"3,580.00

Three Thousand Five Hundred Eighty and 00/100 .................................................................... ,

MEMO

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Ennovva Inc. 100 N Biscayne Blvd .. Suite 2906 Miami, FL 33132

Invoice #0438

$3,580.00 3/13/2015

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"SERVING MIAMIANS Eco· 1ses NW 88TH CT # 101 N.IAMI P ... ~3172 2~8

~:o~~~~-E_n_no_w_a_ln_c_.~~~~~~~~~~~~~~~~~~~·J $ One Thousand f"ive HJndred ar.d CMC~,----------

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Ennowalnc 100 N Biscayne Blvd .. Suile2905 Miami, FL 33132

Invoice #0437

$1,500.00 .3/13/2015

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Ennowa, Inc 100 Biscayne, Blvd Suite 2906 Miami, FL 33132

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Affidavit Margie Wade to Roland 05/02/2016 03:54 PM

Dear Sanchez-Medina,

As chairman of Serving Miamians, please complete the attached affidavit and return it to me by Monday, May 9, 2014 ..

Thanks.

Aff to ECO .. docx

11tM<jie g', 'ifJade Investigation Specialist II Florida Elections Commission 107 West Gaines Street, Suite 224 Tallahassee, FL 32399 850-922-4539 (phone) 850-921 ·-0783 (fax)

STATE OF FLORIDA

AFFIDAVIT Case Number FEC 15-372

County of _________ _

Roland Sanchez-Medina, being duly sworn, says:



3. Please provide the name and contact information for the person who authorized you to

contact Ennovva on behalf of Ms. Regalado's campaign? _____________ _

4. If no one authorized you to contact Ennovva, please explain why you contacted

Ennovva?

.5. When (on what date) did you contact Ennovva? ---------------

6. Who was responsible for the verbiage on the website? ___________ _

7. Did you discuss contacting Ennovva with Ms. Regalado? ( ) Yes ( ) No

8. During your conversation with Ms. Regalado, did she give you any instructions about the

website? ( ) Yes ( ) No If yes, please provide a summary of her instructions.

Inv04 7 ( 6/08)

9. When (on what date) did you discuss contacting Ennovva with Ms .. Regalado? ----

10.. When (on what date) did you receive the refund check from Ennovva? _____ _

1 L Please provide a copy of the front and back of the refund check.

I HEREBY SWEAR OR AFFIRM THAT THE FOREGOING INFORMATION IS TRUE AND CORRECT TO

THE BEST OF MY KNOWLEDGE.

Signature of Affiant

Sworn to (or affirmed) and subscribed before me this __ day of

_______________ ,2016

Signature of Notary Public - State of Florida

Print, Type, or Stamp Commissioned Name of Notary Public

Personally Known ___ or Produced Identification __ _

Type ofldentification Produced:----------


lnv047 (6/08)

FLORIDA ELECTIONS COMMISSION 107 W. Gaines Street,

Suite 224 Collins Building Tallahassee, Florida 32399-1050

Telephone: (850) 922-4539 Fax: (850) 921-0783

November 23, 2015

Roland Sanchez-Medina, Jr., Esquire SM & GQ Attorneys at Law 201 Alhambra Circle, Ste. 1205 Coral Gables, FL 33134-5107

RE: Case No.: FEC 15-372; Respondent: Raquel A. Regalado - AMENDED LETTER OF LEGAL SUFFICIENCY

Dear Mr. Sanchez-Medina:

On June 29, 2015, the Florida Elections Commission received a complaint alleging that your client violated Florida's election laws. I have reviewed the complaint and find that it contains one or more legally sufficient allegations. The Commission staff will investigate the following alleged violation:

Section 106.19(1)(a), Florida Statutes: Raquel A. Regalado, a 2016 candidate for the office of Mayor of Miami-Dade County, may have accepted one or more contributions in excess of the limits prescribed by Section 106.08, Florida Statutes, as alleged in the complaint.

You may respond to the allegation above by filing a notarized statement providing any information regarding the facts and circumstances surrounding the allegation. Your response will be included as an attachment to the investigator's report.

When we conclude the investigation, a copy of the Report of Investigation will be mailed to you at the above address. You may file a response to the report within 14 days from the date the report is mailed to you. Based on the results of the investigation, legal staff will make a written recommendation to the Commission on whether there is probable cause to believe you have violated Chapter 104 or 106, Florida Statutes. A copy of the Staff Recommendation will be mailed to you and you may file a response within 14 days from the date the recommendation is mailed to you. Your timely filed response(s) will be considered by the Commission when determining probable cause.

The Commission will then hold a hearing to determine whether there is probable cause to believe you have violated Chapters 104 or 106, Florida Statutes. You and the complainant will receive a

ComOll (10/07)

notice of hearing at least 14 days before the hearing. The notice of hearing will indicate the location, date, and time of your hearing. You will have the opportunity to make a brief oral statement to the Commission, but you will not be permitted to testify or call others to testify, or introduce any documentary or other evidence ..

At any time before a probable cause finding, you may notify us in writing that you want to enter into negotiations directed towards reaching a settlement via consent agreement.

The Report of Investigation, Staff Recommencfation, and Notice of :Hearing will be mailed to the above address as this letter. The:refo:re, if you:r address changes, you must notify this office of your new address. Otherwise, you may not :receive these important documents. Failure to receive the documents wm not delay the probable cause hearing.

Under section 106.25, Florida Statutes, complaints, Commission investigations, investigative reports, and other documents relating to an alleged violation of Chapters 104 and 106, Florida Statutes, are confidential until the Commission finds probable cause or no probable cause. The confidentiality provision does not apply to the person filing the complaint. However, it does apply to you unless you waive confidentiality in writing. The confidentiality provision does not preclude you from seeking legal counsel. However, if you retain counsel, your attorney must file a notice of appearance with the Commission before any member of the Commission staff can discuss this case with him or her.

If you have any questions or need additional information, please contact Margie Wade, the investigator assigned to this case.

Since.· .. f. ely, 1:

\ ()\ ;l\Jl)\1· ~ J, / l( '-J»j .. I ,_)\" ~ /(/ /11 l Amy McK~~f Toman --·· ..... ~--~,~~~--

Executive (°-ire9tor

---··; /

···- .. -AMT/enr

ComOl l (8/08)

FLORIDA ELECTIONS COMMISSION 107 W. Gaines Street,

Suite 224 Collins Building Tallahassee, Florida 32399-1050

Telephone: (850) 922-4539 Fax: (850) 921-0783

November 5, 2015

Roland Sanchez-Medina, JL SM & GQ Attorneys at Law 201 Alhambra Circle, Ste. 1205 Coral Gables, FL 33134-5107

RE: Case No.: FEC 15-372; Respondent: Raquel A. Regalado

Dear Mr. Sanchez-Medina:

On June 29, 2015, the Florida Elections Commission received a complaint alleging that your client violated Florida's election laws. I have reviewed the complaint and find that it contains one or more legally sufficient allegations. The Commission staff will investigate the following alleged violation:

Section 106.19(1)(a), Florida Statutes: Raquel A. Regalado, a 2016 candidate for the office of Mayor of Miami-Dade County, may have accepted one or more contributions in excess of the limits prescribed by Section 106.08(3)(b ), Florida Statutes, as alleged in the complaint.

You may respond to the allegation above by filing a notarized statement providing any information regarding the facts and circumstances surrounding the allegation. Your response will be included as an attachment to the investigator's report.

When we conclude the investigation, a copy of the Report of Investigation will be mailed to you at the above address. You may file a response to the report within 14 days from the date the report is mailed to you. Based on the results of the investigation, legal staff will make a written recommendation to the Commission on whether there is probable cause to believe you have violated Chapter 104 or 106, Florida Statutes, A copy of the Staff Recommendation will be mailed to you and you may file a response within 14 days from the date the recommendation is mailed to you. Your timely filed response(s) will be considered by the Commission when determining probable cause.

The Commission will then hold a hearing to determine whether there is probable cause to believe you have violated Chapters 104 or 106, Florida Statutes.. You and the complainant will receive a notice of hearing at least 14 days before the hearing. The notice of hearing will indicate the

ComOI l (10/07)

location, date, and time of your hearing. You will have the opportunity to make a brief oral statement to the Commission, but you will not be permitted to testify or call others to testify, or introduce any documentary or other evidence.

At any time before a probable cause finding, you may notify us in writing that you want to enter into negotiations directed towards reaching a settlement via consent agreement.

The Report of Investigation, Staff Recommendation, and Notice of Hearing will be mailed to the above address as this letter. Therefore, if your address changes, you must notify this office of your new address. Otherwise, you may not receive these important documents. Failure to receive the documents will not delay the probable cause hearing.

Under section 106.25, Florida Statutes, complaints, Commission investigations, investigative reports, and other documents relating to an alleged violation of Chapters 104 and 106, Florida Statutes, are confidential until the Commission finds probable cause or no probable cause. The confidentiality provision does not apply to the person filing the complaint. However, it does apply to you unless you waive confidentiality in writing. The confidentiality provision does not preclude you from seeking legal counsel. However, if you retain counsel, your attorney must file a notice of appearance with the Commission before any member of the Commission staff can discuss this case with him or her.

If you have any questions or need additional information, please contact Margie Wade, the investigator assigned to this case.

Sincerely,

----·----·-.....

AMT/em

ComOll (8/08)

Case No.: FEC-15-372; Respondent: Raquel Regalado Michael Montiel to: [email protected] 09/04/2015 05:09 PM Cc: Raquel Regalado, Roland Sanchez-Medina Jr. Show Details

2 Attachments

imageOO l .jpg RegaladoResponseToFEC..pdf

Ms .. Riley,

Bage 1of1

( \

Please see the attached response from Raquel Regalado in connection with the above referenced matter. If you have any questions, please do not hesitate to contact me. Thank you ..

Michael

MICHAEL A. MONTIEL, ESQ.

SMGQ LAW

SA NCI IEZ-MEDTNA, CONZALEZ, QUESADA,

LAGE, CRESPO, GOMEZ, MACHADO & PREIRA LLP

201 Alhambra Circle I Suite 1205 I Coral Gables, Florida 33134-5107

Office: 305 .. 377.1.000 Ext. 140 I Toll Free: 855.213.4806

[email protected] I SMGQLA W.com I Attorney Bio I vCard

CONFIDENTIALITY NOTE: The information contained in this transmission may be privileged and confidentiill information, and is intended only for the use of the individual or entity named above If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited Tf you haver eceived this transmission in error, please irnmediatc•ly reply to the sender. that you have received this communication in euor and then delete it. Thank you

CIRCULAR 230 NOTICF: To comply with US Treasury Department and IRS regulations, we m:e required to advise you that, unless expressly stated otherwise, any US .. federnl tax advice contained in this trnnsmittal,is not intended or w.ritten to be used, and cannot be used, by any person for the pur:pose of (i) nvoiding penalties under the US Tnte1 nal Revenue Code, or (ii) promoting, mm keting or: recommending to another party any trnnsaction 01. matter addressed in this e-mail or attachment

file:///C:/Users/Malphursd/AppData/Local/Temp/notesFCBCEE/-web9532.htm 9/8/2015

ATTORNEYS AT LAW

September 4, 2015

Via Certified Mail Return Receipt Requested

Erin Riley Deputy Agency Clerk Florida Elections Commission 107 W. Gaines Street Suite 2.24 Tallahassee, FL 32399

(

Re: Case No.: FEC-15-372; Respondent: Raquel Regalado

Ms. Riley:

This correspondence is in response to the letter from the Florida Elections Commission ("FEC") dated June 30, 2015 (the "FEC Letter"). Ms. Regalado has addressed all of the issued and concerns found in the FEC Letter Please see Ms. Regalado' s response to the FEC Letter, attached hereto. If you have any questions, please contact me directly at 305.3771000.

el:RSM

Copy to: Raquel Regalado (Via E-mail) Michael Montiel

Sincerely,

Roland Sanchez··Medina, Jr.

SANCHEZ-MEDINA, GONZALEZ QUESADA, LAGE, CRESPO, GOMEZ, MACHADO & PREIRA LLP ! SMGQLAW COM

201 ALHAMBRA CIRCLE SUITE 1205. CORAL GABLES. FL33134-5107 I TEL: 305 377.1000 I FAX: 305 424.0237 I TOLL FREE: 855 213 4806

( ,_ (

RAQUEL REGALADO'S RESPONSE TO THE FEC LETTER

Serving Miamians, an Electioneering Communications Organization ("ECO") mistakenly engaged Ennovva, Inc. (the "Vendor") to design the website for www.raquelregalado .. ~om (the "Website"). Serving Miamians contacted the Vendor regarding this error in order to take steps to correct the error. The Vendor has since returned the funds to Serving Miamians. The refund will be reflected in the September ECO report and will be provided to the FEC Furthermore, Ms. Regalado's campaign account has since paid the Vendor for the work performed, as well as an extra fee for changing the disclaimers on the video found on the Website, and removing all references to Serving Miamians, both on the Website and in the video. This will also be reflected in Ms. Regalado's September campaign report which will be provided to the FEC when it is due on October 10, 2015. Some of the confusion in connection with the error was likely caused by the fact that Serving Miamians intended to engage the Vendor to create videos which are in furtherance of its purpose as an ECO.

The Website, although "live" on March 9, 2015, was never fully completed by the Vendor .. In fact, the Vendor's bill for the creation of the Website indicates that the Website was still currently under construction at the time it went "live" .. As such, it was never the intention of Serving Miamians, nor Ms. Regalado, for the Website to be accessed by visitors, nor to serve as a campaign advertisement for Ms. Regalado' s campaign.. The Website was simply a "landing page" as opposed to an advertised or marketed website.

Currently, the Website is offline and any visitors will find a message which states that the Website is under construction. The video which was previously featured on the Website is no longer accessible. Please see the screenshot of the Website attached hereto.

As referenced above, Serving Miamians intends to continue to engage the Vendor for the creation of additional videos which fully comply with Florida law. Despite Serving Miamians' unintentional mistake described above, moving forward Serving Miamians will continue to exist as an ECO. As the mistake has been corrected, Serving Miamians does not need to, and will not, register as a Political Committee All acts undertaken by Serving Miarnians in the future will be fully in accordance with its purpose as an ECO, in accordance with Florida law..

F: \General Clients\ Raquel Regalado\ RegaladoResponse T oFECdocx

2

----·-----------------SANCHEZ-MEDINA, GONZALEZ, QUESADA LAGE CRESPO. GOMEZ, MACHADO & PREIRA LLP I SMGQLAW COM

0 www.raquelregalado.com

*Confidential: Re: Confidential Complaint: FEC 15-372 Florida Elections Commission to: Raquel Regalado

From: Florida Elections Commission/OAG

To: Raquel Regalado <raquelregaladopa@gmaiLcom>

08/28/2015 09:53 AM

Thank you .. Your request for an extension of time to respond is GRANTED .. Please submit your response by Friday, September 4, 2015 .. If you have any questions, please let me know ..

Sincerely,

Donna Ann Malphurs Agency Clerk

Raquel Regalado Mrs .. Malphurs I left you a voice mail yesterday r. ..

From: To: Date: Subject:

Raquel Regalado <[email protected]> Florida Elections Commission <[email protected]> 08/28/2015 07:30 AM Re: Confidential Complaint: FEC 15-372

.,, ...... _.,,. "

08/28/2015 07:30::33 AM

·----·.. ' ~· ·----------------·----·

Mrs. Malphurs I left you a voice mail yesterday regarding my response to this comolaint that is due today. As I explained in the voicemail we are waiting on several screen shots and exhibits from the web manager and company who did the video in question. As a result of tropical storm Erika several businesses are in hurrican preparedness mode and I dont know if we will have the exhibits by close of business today. And so I am requesting an extention until Tuesday to insure that the response is complete .. If said request can not be granted I ask that you please advise if and how we may supplement the response once we recieve the exhibits. Thank you in advance for your attention to this matter. Kindest regards Raquel Regalado

This electronic correspondence was sent from my LG 04 please excuse any errors or misspellings as a result of transmission from a smart phone device.

On Jul 30, 2015 10:54 AM, "Florida Elections Commission" <[email protected]> wrote: Your request for an extension of time to respond to the complaint is GRANTED. Please submit your response by

the close of business on August 28, 2015 .. Thank you ..

Sincerely,

Donna Ann Malphurs

Agency Clerk

.. Raquel Regalado ---0712912015 06:43 :30 PM---Mrs .. Riley Please accept the following as my formal request for

an extention of time

/

I

From: Raquel Regalado <[email protected]> To: [email protected] Date: 07/29/2015 06:43 PM

Subject: Request for extention of time to respond to complaint

Mrs. Riley

(

Please accept the following as my formal request for an extention oftime of ten (10) days to respond to the complaint filed in case number FEC 15-372. Please be advised that said request is not made for the purpose of delay but rather because we are finalizing our budget process and school rollout at Miami Dade County Public Schools and my duties as an elected official have not afforded me the opportunity to review and respond to the above referenced complaint with the assistance of counsel. I thank you in advance for your attention to this request and will be available to discuss the same over the phone should it be required.

Kindest regards

Raquel Regalado

This electronic correspondence was sent from my LG 04 please excuse any errors or misspellings as a result of transmission from smart phone device.

15-39~

Elliot Berke to: [email protected] 07/30/201511:49AM

History: This message has been replied to ..

This email is to serve as notice that I am counsel of record for the complaint filed with the Florida Elections Commission, which was received by your office on June 29, on behalf of Darren Centinello against Raquel Regalado. My contact information is below. Thanks.

Elliot S. Berke Managing Partner Berke Farah LLP 1200 New Hampshire Ave. NW Suite 800 Washington, DC 20036

202.517.0585 (Tel.) [email protected] http://www.berkefa.rah.com

PLEASE NOTE NEW ADDRESS ABOVE

This e-mail may contain confidential or privileged information. If you are not the intended recipient, please advise by return e-mail and delete immediately without reading forwarding to others. The following statement is provided pursuant to U.S. Treasury Department Regulations;· This communication is not intended or written to be used, and cannot be used, by a taxpayer for the purpose of avoiding penalties that the Internal Revenue Service may impose on the taxpayer.

(

Confidential Complaint: FEC 15-372 Florida Elections Commission to:: Raquel Regalado 07/30/2015 10:54 AM

From: Florida Elections Commission/OAG

To: Raquel Regalado <raquelregaladopa@gmaiLcom>

Your request for an extension of time to respond to the complaint is GRANTED .. Please submit your response by the close of business on August 28, 2015 .. Thank you.

Sincerely,

Donna Ann Malphurs Agency Clerk

Raquel Regah;ido Mrs .. Riley Please accept the following as my tor .. From: To: Date: Subject:

Mrs. Riley

Raquel Regalado <raquelregaladopa@gmaiLcom> fec@myfloridalegal .. com 07/29/2015 06:43 PM Request for extention of time to respond to complaint ----·-"-" ------------·----

·--· -07/29/2015 06:43.:30 PM

Please accept the following as my formal request for an extention of time often (10) days to respond to the complaint filed in case number FEC 15-372. Please be advised that said request is not made for the purpose of delay but rather because we are finalizing our budget process and school rollout at Miami Dade County Public Schools and my duties as an elected official have not afforded me the opportunity to review and respond to the above referenced complaint with the assistance of counsel.. I thank you in advance for your attention to this request and will be available to discuss the same over the phone should it be required.

Kindest regards

Raquel Regalado

This electronic correspondence was sent from my LG G4 please excuse any errors or misspellings as a result of transmission from smart phone device.

/ I,


107 West Gaines Street, Suite 224, Tallahassee, Florida 32399-1050 Telephone Number: (850) 922-4539

www. fee.state. fl. us

CONFIDENTIAL COMPLAINT FO:&M

The Commission's records and proceedings in a case are confidential until the Commission rules on. p-r6fiai>fe- · cause. A copy of the complaint will be provided to the person against whom the comp faint is'brought~i" ,, " •. · ... • ,

1. PERSON BRINGING COMPLAINT:

Name: Darren Centinello

Address: c/o Berke Farah LLP, 1200 New Hampshire Ave .. NW, Suite 800

Work Phone: ( 202) 517-0585

Home Phone: ( 202) 517-0585

City: Washington County: _N_IA ___ _ State: DC --- Zip Code: _2_0_03_6 __ _

2. PERSON AGAINST WHOM COMPLAINT IS BROUGHT:

A person can be an individual, political committee, committee of continuous existence, political party, electioneering communication organization, club, corporation, partnership, company, association, or any other type of organization.. (If you intend to name more than one individual or entity, please file multiple complaints.)

Name of individual or entity: Raquel Regalado ~~~~~~~~~~~~~~~~~~~~~~~~-

Address: 1985 NW 88th Court, Suite 101 Phone: ( 305) 593-2644

City: Doral County: Miami-Dade State: _F_L __ Zip Code: _3_3_1_72 __ _

If individual is a candidate, list the office or position sought:: Miami-Dade County Mayor

Have you filed this complaint with the State Attorney's Office? (check one) D Yes IZI No

3. ALLEGED VIOLATION(S):

Please list the provisions of The Florida Election Code that you believe the person named above may have violated. The Commission has jurisdiction only to investigation the following provisions: Chapter 104, Chapter 106, and Section 105.071, Florida Statutes .. Also, please include:

./ The facts and actions that you believe support the violations you allege,

./ The names and telephone numbers of persons you believe may be witnesses to the facts,

./ A copy or picture of the political advertisements you mention in your statement,

./ A copy of the documents you mention in your statement, and

./ Other evidence that supports your allegations.

Please see attached complaint and supporting documentation ..

FEC 002 (Rev 05-05-14)

Additional materials attached (check one)? 0Yes IZ]No

I swear or affirm, that the above information is true and correct to the best of my knowledge.

,,.. •,,,, . , .. co... 1·~-. --- ___ ~' 2

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Original Signature of Person Bringing Complaint

Sworn to and subscribed before me this ?§:t. day of ---..'::> U.\0 Q_ ' 20 \ ~

Signature of Officer Authorized to Administer Oaths or Notary public

FLEUR V. PHILLS Namm' PUBLIC DISTRICT OF COLUMBIA My Cooimission Expires November 30, 2019

(Print, Type, or Stamp Commissioned Name of Notary Public)

Personally known Or Produced Identification '/...

Type ofldentification Producedtl· '-\ .~a.:.-\-e_

Any person who files a complaint while knowing that the allegations are false or without merit commits a misdemeanor of the first degree, punishable as provided in Sections 77.5 082 and 775 .. 083, Florida Statutes ..

FEC 002 (Rev 05-05-14)

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I

COMPLAINT

This complaint is filed pursuant to Fla. Stat. § 106.25(2) and is based on information and belief that Raquel A. Regalado, a candidate for Miami-Dade County Mayor; Raquel Regalado for Miami-Dade County Mayor, her campaign committee; and Serving Miamians, an Electioneering Communications Organization ("ECO") registered with the Florida Secretary of State's Office (collectively, the "Respondents") violated provisions of the Florida Campaign Financing Act (the "Act"), Fla. Stat.§§ 106.011 et seq.

Specifically, Ms. Regalado appears to have accepted an illegal in-kind contribution from Serving Miamians in the form of her campaign website and a campaign video, which expressly advocates for her election, being paid for and approved by Serving Miamians. In paying for and approving her campaign website, Serving Miamians may have also violated campaign finance laws that prohibit an ECO from making expenditures that expressly advocate for a candidate, and may have also failed to register as a political committee. Each potential violation, along with supporting facts and documentation, are outlined below and attached as exhibits to this complaint.

Raquel Regalado May Have Accepted an Illegal In-Kind Contribution from Serving Miamians

Raquel Regalado registered as a candidate for Miami-Dade County Mayor on March 9, 2015.1 Serving Miamians is an ECO that registered with the Florida Secretary of State's Division of Elections on February 5, 2013.2 Ms. Regalado's campaign yvebsite, www.raquelregalado.com, went live on March 9, 2015, the same day she registered as a candidate. Since then and to at least date of filing, the website has contained campaign videos and language that expressly advocates the election of Ms. Regalado to Miami-Dade County Mayor. Instead of being paid for by Ms. Regalado's campaign committee, however, a disclaimer on the bottom of the website explicitly states that it is "Paid and approved by Serving Miamians. "3 Likewise, the video posted on the website, which depicts Ms. Regalado stating directly to the camera, :'I'm Raquel Regalado, and I'm asking for your support to be the next Mayor of Miami-Dade County," also contains a disclaimer stating that the video was "Paid for and approved by Serving Miamians."

The Act defines a "contribution" as "a gift, subscription, conveyance, deposit, loan, payment, or distribution of money or anything of value, including contributions in kind having an attributable monetary value in any form, made for the purpose of influencing the results of an election or making an electioneering communication." Fla. Stat.§ 106.011(5)(a)(emphasis added). Serving Miamians' payment for a professional quality campaign video and website most certainly has an attributable monetary value, as such products and services can cost as much as several thousand dollars. Such payments would therefore constitute an in-kind contribution to Ms. Regalado's campaign. Moreover, they would also amount to the receipt of an excessive contribution by Regalado, in violation of Fla. Stat§ 106,.08(1)(a)(2).

1 Copies of Ms. Regalado's candidate registration forms, filed March 9, 2015, are attached to this complaint. 2 Copies of Serving Miamians' Electioneering Communications Organization registration forms, filed February 5, 2013, are attached to this complaint. 3 Printouts and screenshots ofwww . .raquelregalado .. com from April 2, 2015 are attached to this complaint.

/ I

Under Florida law, ECOs are prohibited from making contributions, including in-kind contributions, to candidates, political parties, or political committees, and candidates are precluded from accepting contributions from EC Os. Fla. Stat. § 106. 011 (9). In fact, the only election-related activities in which ECOs may engage are making expenditures for electioneering communications or accepting contributions for the purpose of making electioneering communications. Id.

By accepting an in-kind contribution from Serving Miamians, in the form of a professionally produced campaign website and a campaign video, Ms. Regalado and her campaign appear to have violated Florida law. If such violations were knowing and willful, and it appears they may have been, given that the campaign video depicts Regalado speaking directly to the camera and contains a Serving Miamians disclaimer, Ms. Regalado, her campaign and Serving Miamians should be investigated for potential criminal penalties pursuant to Fla. Stat. § 106.19(1 )( d).

Serving Miamians May Have Violated Florida Law By Making Express Advocacy Communications

As discussed above, an ECO's election-related activities are limited to making expenditures for electioneering communications or accepting contributions for the purpose of making electioneering communications. Importantly, ECOs may not "expressly advocate" the election or defeat of a candidate. See Fla. Stat. § 106.011(8)(a)(l). An "electio~eering communication" is defined as a:

communication that is publicly distributed by a television station, radio station, cable television system, satellite system, newspaper, magazine, direct mail, or telephone and that:

1. Refers to or depicts a clearly identified candidate for office without expressly advocating the election or defeat of a candidate but that is susceptible of no reasonable interpretation other than an appeal to vote for or against a specific candidate;

2. Is made within 30 days before a primary or special primary election or 60 days before any other election for the office sought by the candidate; and

3. Is targeted to the relevant electorate in the geographic area the candidate would represent if elected.

Fla. Stat. § 106.011(8).

A web video and website dedicated entirely to expressly advocating the election of Regalado, a clearly identified candidate, are far from "electioneering communications." Rather,

(

they are fully coordinated express advocacy expenditures that are impermissible for an ECO, like Serving Miamians, to pay for or sponsor. Serving Miamians is therefore in violation of Florida law for engaging in prohibited election-related activities by an ECO.

Serving Miamians Should Have Registered as a Political Committee

Because Serving Miamians has engaged in express advocacy communications through Regalado's website and web video, it would have triggered political committee status after it made over $500 in expenditures in a calendar year. In fact, a Statement of Organization for a political committee must be filed within 10 days after its organization when a group receives contributions or makes expenditures in excess of $500 in a calendar year. Fla. Stat. § 106.03(1)(a). Considering the cost to produce a professional quality web video and website, it is likely Serving Miamians spent over $500 for both. Therefore, Serving Miamians was required to relinquish its ECO status and register as a political committee.

Failure of a political committee to file a statement of organization pursuant to Fla. Stat. § 106.03 falls within the scope of Fla. Stat. § 106.19(1 )( c ); therefore, the deliberate failure to furnish the information required by the statement could constitute a misdemeanor. State v. Greco, 479 So. 2d 786, 1985 Fla. App. LEXIS 16786 (Fla. 2nd DCA 1985).

Conclusion

The Florida Elections Commission should take steps to immediately investigate Ms. Regalado, her campaign, and Serving Miamians for violating the foregoing sections of the Florida Campaign Financing Act. In doing so, the agencies should find probable cause to believe Respondents violated the Act, determine and impose appropriate sanctions for any and all violations, and enjoin them from any and all violations in the future. The foregoing is correct and accurate to the best of my knowledge, information and belief.

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I . ~()W(Sijge that . it )s rt\Y re,pon~i~fltnr t() rea(I, . un({~tantf and foffQW the reqUltQn.te~~ ·. d$t)gri,bQ'd, in th• foU~wing resources ~vaifabltl) en the Miami-Dade O~un~y El~~fon~ D'partffi$ntWe&fllite! . .

f!l Candid~te Q~~fifylng Hana~pbk (tittb4/twiiw.urliartildade~gov/ele~tionsleandlgata~tm> Ctm~tns. iiJtarmafiori on. State. Laws. and ff14n(i}b<:rok$i the ·Elect/cm Laws of the· state of Fk>rlt;J.~1 County Laws a17d Htjtrc/Qopks, Qualffylng lnfOrrnationi Electronic Reporting Dates and Prqoed.ures, lmportsnt·cantlldafe lnfarmatioli1 arJd Recent Legislative Changes.

D Political Committee H~ndbook (httr;:J.Jwww,roiamldade.g2v/elections/pacs.asp) Contains infbrmation on$~ Laws ;mq ffanabr)ok$, the Election Laws of the State of Ftotlde1 C:qunty Law~ 1J1nc/ flsndb()ok~, Eleatro_nfc Reportlng Dates and Procedµres, lmportsnt comml~e.tnrormatloti and Recent Legislative Changes.

I Chairperson Signature

305~693-2644 PrimaryTef~phone Number: ......_. _____________ _

Alternate Tefephone Number: ---------------

E·man address: _ra_q ....... u_e_l_re-.;.g_a_la_d_o_p_a_@_· :_m_a_i_Lc_o_m ___ .

'· t

..... . .. . .. e~mllafgq Treasufert~ R~pttrt . Nfi~~f;.Jj~q~· GQitrtW. E•,ctroni~ Filing R~qqfr~ment,s

o Party ExeotiWe committee: N/A ---·---.... ~.__,,,.,,,.,.... ......... -........... ____ ....; NIA

O Other: ----------··········--·---·····--·~·-··------.1

~u~ A. Rt?saJado Ii ...__...__...__....__..___. · - ··-~prmfoomf:~ti:andiaatF.t arCha'lfPar30'i'i}

• (0

""""" ::tli* = ~

tmd,erstaf:Jd that campaign Treasttrer's Reports must be filed ele:ob'onically via the

s,up~rvi£;,()i" pf Efeqtions we~iaite PY mi~t:dsf;lt 9f t~¢ qay designated in order to comply wltb M~mi .. Qatf~ OotintY requ~menfs. I atso e:C~nowte<lge that S~ctions 12~17 and 12w 21 of the Code of F11Uaml·.fJ.lade County reg{irding the filing of the eampaig.n ffnan~

·re~rt$ W!tb th.a Supervisor of Elections wet$ 1'$centty amended in that original signed

hardcopfes are no longer required.

I also Qnder$tand that, in accordance with Section 12-14.1 of the Code of Miami-Dade

Counfy1 Florida, candidates running for the Offices Of Mlaml-Dacls County Mayor,

Commissioner, Property App~iser, Cler~ of the Circuit Courts, and Community Council

mu~t now ftl~ the A~~ntee 6~1fot Campaign R,eport (MD .. ED 26) to dlscfqse the names

of paid campaign workers engaged fn absentee baUot actMt!es.

~· 11 w1d-- ... Date Signature of Candidate or Chair~son

?ay Time Telephone Number: .305""593-2644

______ ~-----------

lternate Contact Number: ·---··-·· .. ···----·-··-·-·-~··----------·---

1afl Address: ~~azos@rtc .. cp~~:.o_m ___ _

~torm mu:$t b~ filed with fhe qualifying offl<;er within 1 O days after th(:) Appointment of •ptjlgn Tfll!'fl~lJrer ~d l:Je:?igneJion of ~tn1:ralgif t:)epqsitory fQrm Is filed. . . . . .

Raquel Regs}ado for Miami-Dade County Mayor

----·----............ ------···..,.-·~. ---·--........ - ...... - .. ,-.--............... --..... --........ _ .... _.

About Raqael B.egata.Q.o RaqqeJ Regala.t'.fo Is a lffe)fpng resident of the Miami-Dade county School Board

Di'strtct s. which enco:mpasses the areas 6rl<ey Biscayne, the R(lads, East Little

Havanai$henam:tpah. Silver Blum Coconut Grove. Coral Gables. South Miami and

westehester. On the Board. Ms. Regalado chaitstne Facilities and constructfon

Reform committee, and serves as a member of the Instructional Excellence & ' ' ,•,; N, ,• ' • ' ' ¥ ' ' ' >' •; '0 >

cemmunlty Eng~gement School ~.upport & Aqcountapmw. and lnnQVl;ltion.

Poage1of4

~d,t!EL RECALAPO U'~rM!amt Pad~~~· tvJaYQr I ',

p~f\nt::~ 1P ~acn tti,. P~$fcs, qf' compJ,Jter prg~rfilUtn~ also kno¥Jn as Cqd~. to al! MPCP$ stutJ~nts. Ms. Rligai~tfq nas also Qr~anized several law daYs throughout

t~r; ~i~r(~ ~or r~fgents an~ .pater:it$ to ma~t with pro bono aftomeya ~nd

~~$r~.fu$mag~tretaswhet'e pertrctp~rits receive advrce regardtng issues ranging rr-0m fQrgC~$Ur$ an~ J~ndlorcj t~mantr(ghtstO qisabiUty benefits.

Ar; a scn{;}QI eo.ard Memoet, ~he h.a.s P?Vet.1 th~ way for improvements tn district

wkte tfansp6~tlon and brought to the board a five year plan which resulted in

tftls re,gl~q&m$nt Of olct and ihefflclent ~chooI buses with energy efflcierit buses

that exceed the state's safety requirements. As a member of the Sot;Jtl')east

Fl9rida ~~gional Partnership E5.<.ect;Jtive commltte.e. she helped devise the

sevenSO pf an to secure the economic future and imprciving the quality of life in

tile se~n-.county regiqn c~mprlslng Monroe. Miami-Dade, Broward, Palm Beacht

Marth1, st; Lucie and Indian River cot.n1tres during the next 50, years and lley.oncl

Atih~ n~tfQn~l level .. ~. Regalado has participated in pr~grams regarding

c;omprell&nslva lrnrnigtation reform and the school districts role in assimilatron

eind EngU:sh learning. As a board. memb(:}r of the National Association of latlno

Elected and Appointed Officta!s CNALEOl Ms. Regalado has spoken nationally on

the need for immigration reform and on Juvenile justice and the benefits of

Florida's cMI citation alternative. As a Hispanic English learner, Ms. Regalado has

a1$0 been an <idvoc9)~ for bilingual education, a frequent speaker at conferences

to e>(pfain public education from an English learners' perspective, debunk the

myth that English learners are not academic achievers; and championed the

fmpottant role that omngual education wm h~ve in Florida's new economy.

A graduate of Coral Gables Hight Ms. Regalado attended Miamt-Dade Community

College and then Florida tntemational university, earning a degree ln Liberal

Studieswith honors, earning a Juris Doctorate degree from St. Thomas University

school of Law. At St Thomas, she was the recipient of the Florida Bar's Young

Lswyers Division Scholarship and winner of the St. Thomas University School of

Lt;Jw c. Clyde Atkins Memorial Moot court competition and American Trial

Lawyers Association Open/Close Competitlon. Ms. Regalado was a member of the

st. Thoma$ ~w Review and the Moot Court ream.

Ms. R.&~filadd is admitted to practice law in Florida state courts and fn the United

(

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A: 1M .n~mnnl lc•.n:t Ms. R~rido hasi:muu:~i;med m p1Qt:1ams1e:gtiro1~1g coa1pt.e1'1ens.1ve·tmrn1~\'aticn w!tlrtn afitl Ult: sul'ltio.t

d1swt1s. rote m ;1ssm111:i1mri£mo Engfrsn 1<:amma As :i b!)111d mombn1 cl llro:N;nio1}ill·Asstt.ir.ttlM,.()fl;im1r> t!IN:tud jtfli1 Ari'!X!1u1£itl

D!f1cinls tllfAl8J:ll Ms. Ree,~msu ti."'IS spr.ko>n ll:f•lronat!V'On tt\e riea<t kn •tt11t1J~Thi1Gn nilntm <iti,9:1'.¥1 JU\•Qn1lil1ustt1<"P·Wml 1!'1¢ l1.:1noh1$ nf

!foncta's.cl\ill c11a11or1 .. auerm11we; A!. a Hl:>pruw:: fngJttll warnm. u.s.. fiegatr.(ltl h1lS:aL%l:Jife6ttm'l rutw.t;:;tim (l}f · l11l1flgua1 c<rut;atl!llt.&

lrequontsj)Ciilf<er al ::onlerenc.esoo cxpJnmtwbllcc-ttucauon rro:rinn f;ngtlshft'l'fl'l~ts·.fl«(SIJ&eitve;.t1ebmUNhe m'ft!l'that £1\g.l1s1w

!eemr:r:: ara not nc-aoon1ic ;ictneW.H$; M\d cl:tl'ftY!PJCrteet 1M 1mt}!lrl.ilnt 101,,.10:11 tli1ogt~ ~.iji;:~tion wtli'M\'<111\ Hornfa,:s new c~imon1y;

A ~t<itlui1lt: ()t «:1a1 GtJl>ICS.i~tgt<. M$. RE-iJ!llatto altMtlen M1an1H:tatte t<lmmu:nAJY~1rege-MW·1hen:fl¢tftlaittre1m1n<inait1nf\filrs1w.'.

i;'iln\lll!VHl*lltCe iil liberal Sm(11a> v11m !IC>tWIS, Mrtt1J1€ a .Jurrs DQCll'.IW:(C rtcgreo:J((1tft'tit;tf).{lrit,"1£, UllN¢tS1.lY:~~()(l4,()t 1.~l't(; ti; St •.

ill!:!inas. Slit: W1lS the H!Clf,lC:ll! ot ihe.flilf!d<itlill"S'f(l110(; LlWV~t Dl~'l$ttitl Si>Mll'.i(S]t1j'l'lli'id-Wlnt1t'.f('Gtfltn SL TNlnitlS Uo1vc1s1ty.S¢li'llil1

of l'1W c. Cl;'d!lAtltlM t•WtnOtJ:,r M-OOI ('{l•JitCon'ipc!iuor. ;mcl lilill!l:tt'111 Inat t-0~.!\'t!fS /\$®1i\tl.Oft0!)\ll1it!osr:rCctn1)PtlliCltliMS;

1<i:gal<1do ...:.as ;:1 mcmtbel" Cil lfl(7 s1. l1m111ris. Lrwif<ev1l?l·; 1mr.l 11\~ t/l()ot t'Oilt'i Team,

:.1:::. ~i::g;:ila'<:lo 1s aom1m:>l'.I to prnctu:e 1a1-: m f!Gi1da statr.n:wiurts &Ol'.I m the IJfllleti 1>1nws Dls~Cl Cfuntf(lt lhc: Soittnem l>lstntrot.

Ilorult1 .. M'.5. R!.lgf)lada lS M.l<Cli'lC t'l'li!l'l10C·r i'Jl sovcrnl !;Jill' llS9!lCttltmn$. tn~!11d1ng·tl\(! Al¥1Ct1C!fi\'ff.{ii.A$SaC1aJ1M.·CubMlAfllCfle-J& Eat·

A$Sul:l!il1Gl'I.; MdlSih<· il't\1011Jcr or !ft.:: Hl~iCCltllll ?l'Pt)eity L<1wAsst>1:1aUOt'l ol'Ffo1itfa:1JSl'li:«·\'.('1ff.fl!l li~1u11t1.f1}·0J~S1lt'Ji1Ell$H"IO'S$ la\'{

M Milltm Dam: .co1icgi:;. 'WilHsoa. C<Mnpu:L.Ms .. mis:,ainuo \'l'a~ r1D1t1eti a P.1stog snu 1n.intelferauat11r-0pert>t:l'.1llgaoon:~v flom1a Ti cha tnllgaz1r1c- .;111cl n*1mod t1mc11.J.! lhcc 1op .m 11t1omey$ 1n M1r11nHJat1c- Coum~· un!.'Jcrc:tll).}~ari>J»d'bi\1\le:Cysiu: f1lm::is,J:$:foo1~1;1<mol'k

S1m:c 1009. Ms. ii~laoo hns comtu1.m:-ti l1 (.!Jlly soomsn tangimg<' rncho Jl.r11~mn on. t.n,Pc·d~wsll, ,jj1ll iiM; tl\JdtCflli1t1· to 1n.ltum1ng ·

;1sumc1 ~ lll.lov1 !ilea! 1:1ot1tits. cducuw.111 •111in;oc1n! serv1res. 111unMr -0111er p1.!JJOOlLI$ Es1a 'Sel'rH•ll!'I coo nariµ;.it a we1.?llty lt1l(:V!St0n

st1t.1w wnh pollttcl:ll amt m: .. 'ts :11'li1lys1s. a 111ng on iel!:mmnu till ol1ii.1louulm state·Ot rn:x1tJa-. tnte!Wcw JrorWEStll :st'limim ten ft~QttOl

Cili1 o.o SCOO. ~n http;i/ih'l'nll'.y0U1ube..i;om{Use~~que!itaRcg<1iadt1Mdoos. Msdllfga.lndo afso ~tlt'.'S for $f t.lm.'V-0 I ~illtl nntt 1hc

11umngr011 f.'!ist am1 nai: c<mintm1cd lo tt10Milfrol J 1cr;11tl. rt omno cc Ms. Arnenc.-is. U.l'.irc; lib.~nM .ancl CO.nm1vnitv ~aper~. tl<Wt1'1£

·rmmin !loJm . .:i or iltl!c11$ flet l<tt';S• r..mcs.ciw bcHcmM mt 11tlp://raquiiftegatattoopintOJ'iS'.bfOl!$patftOm/. r1m11ty, Ms: Ri:it,alllcib 1~ 11

menn;cr al me cmnrnuruly AdiJl$('ff;• !Waro ot .\Ulf!R Clrnnnat 11. irn'4mm1. Flamm.

Ms. ~cg11i.nan ;s t!te pr-0u:l mo1hcr Qf two t:;,luirtHm and th(l l.lm;gmer 01 Toioos l'l..O&ll#l(fQAlltt Maym of me City ur Mitani,

,,- ',

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---·--------------.---·~-····--·-·-·-·~--··-------.... ---····-------t=Iorlda Department of State

~oom 316; RA. Stay BU!lding 5(1Q !South eronough $tteet Tu!faba$$ee. Fl 3239~0250

caso1245-awo Division of Elections

Committee Tracking System

Serving Miamians

rype: ElaQtioneertng Communtootiona Org~tzation

Smtu$; AGtive

Addi~$$: 1~85 Ni:lrttiwest sstn Court Suile101 Dbml1 Fk331'12

P·hone: (305)593-2644

Ciiairpersom Roland Sanchez-Medina

Treasurer: Csrlos Trueba 1985 Northwest 88th Court sune101 Doral, FL 33172

Re;J~tere:f;i Ag~nt: Parker o Thomson

F'urp:o~:

A:ffiUates:

200 ~outh BJsoayne Boufevatd Suite40o Miami, Pl ss1s10000

·1219~~a!App0fn~t CJ C1~itgit pf• M~lfng.~tf~tes.a

(j Oh~rige of'Apj)Ofn~ent iJ 9b~rt111;t <it #n~ ~ttress

Former Registered Agf!fntaot::t Office lrifqrmatton.(for changes orily)

(:o~mtttae or Or$Janfutton Information ---~-------

tA(fdteft h Court. Suite 101

cmy Doral

Signature of Cbalrpemon

Parker D. Thomson

..

1. 1=un Name ttt:Of$<rn~~ serving. ~iamian$

(

aa1a FEB-§· AM IU: aa

~l~i~U:;: 6f f:.Li~rtOtJt· ·. l\l ... AHA S~EE:; Ft ·"

T~fephpne

{305) SS!"'.2&«

t--~~~~..,..,..;..~ ........ _,..~__,.__,....,......~..,.....~~~~-,..~--~~----'-~ ~~-Mailing Addren (.incruite o~ $late and 'ziPeode) · 1a$$ Nw®tlf09~rt.,sti~e 1~1. Q~riil, F19.rr~ $~112 ,, 0. , • • • ,. ;·. ' • • , • ,., ··.;~' '. "' • • " •• ' • '• • ' ' •• ,, •• '

streei).ij~ Qri41~~ cl!Y; statii~odZJp ~<tej 19$5 fiJwS81ti covrt. $uite -tot Doral. i:ttcirida-$$.112.· . . . . . . .

(f ..•. Affltfafi:i(.fof cc~nect~t1 OtgiinIZat~~ns Name of Affiliated or

ccmnected <:,>rganlzetton _,,., .. ,.~_.,_,, ..... ....,..,... .. _ '

NONE

3, Area. Scope ~nd Jurisdlctton of the Organtzation

Refatlonshlp

ihI$ oma11izatiot1 wilf promote and edueate voters lo Miaml-0i;1de and Bl'QW~i'd Counties on ootl!'lty and local political cancffc#Jtes.

4~ tr:!entff:y PY Nan,ie, Ad~l'e$s a® Pcisitit:m, tJ!e tus,tq<iJ~ll of-~oki an(j Acceqnts for the qr~niZatfon ~.___ ..... __ .....,,.._....,_.,.,_._,.._...,.. _________ ,__ __________ . _ _,._ ....... ~-----·--!

FuU Narne Malling i\;ddress . ~treet Aq~t~ Title Qr Pos~ion

Carlos '.I.'rueba. 1985 NW 88th court St1:!t\a l 01 norai, 1t. 33114

19~5 NW $Sth Court S1;1i~e 101 tlonl~ 'FL 33172

---1

(

' ~· , • A ' • :: ·.>· ..

ELECTJ()f'li·e~RlNG ~OMMUNleArtON STATEl!fENT QF QR~ANfZATIQN

1. ?ult N~e of orsanlzatton Setvlng M~n'1feri$

StreetAdii~~~ (ff1Qlu~ CltY. stat~a~ tlp c<ld~) U~S! NW 88th Court, StJite.101, OQmt. Flortd~ 3$'11~

TelephO,ne

(SOS} 59$ .. 2$44

2. A;ffJU~til~ i.'.>r connected C>rganJQtfon$

Name of Affmated or ,,..-...... ~.-- .... _ .. , ........ -.... ....,....,,, _________ , __ _

connected Or9t::inlzatlon r----···''""'''-··~

NONE

3, Area, $CQ~e and Jurist$lctlon ofthe Organtllat!on

This organization wilt promote and educate voters io Mlaml--Oade and Broward Counties on county and local political candidates,

4. lden~~y ~y Name, Address and Po~ilon, tile C.m~te>dian of Soolcs ~n(f Aceounts for the Organization Full Name Mailing Addre&s Street A<ltrress Tltle or Positron

Cat"los Trueba 1985 NW 88th Court Suite 101 Doral. FL 33172

198~ Nw 8Sth Court Si.\ite 101 Doral, n 33172

Treasurer

~

.

tttclt$CQT'r ·aB:v~s1iaf

Mt. Farler D. fhomS()n> Chairperson Seryittg Miunit~ 2@e Sfil.tt11 Bis$tY!le ao~l~v~rd, suite4Qo bei:aI~. Florida 33172

Paa.r f\!!r. Thomso*

KEND~R ~#r~aF¥ or state

This wilt acknowle~ge receipt oft~ Applicati0n,f~r Certifieaticm for Serving M:iamians;i whiCh w~ placed Pri fil~ in our oftt(!e ~n Febtua:ry $~ 29J3 ... This ip.font1~tkn;t app~ars to comply with. therequtninienifdfSeet1qri1Q~;Q1la~d 10o.r13, Flotida·statutes.· Tifo name of1hiS tirgan.izatfon ha$ been placed on 9\.lr active list as rm· electioneeril'tg cpmmwications organization.

Your first (:Wnpaign trea~~s ~~911. will. be due. on April 10, lQlS.. The rep.Ort wm cover the perio~ nf January), 2013 ':March 3.112013. AU ele~tkmeerlng C<Jmmurucations organizations tl:tat .file ~ortS: with th~ Oivi~ion of Ble.et,kms a:r~ required to file by mean~ of th~ Divisfon"s electtoni~ fit ing ~st¢ti!. ()3FS).

~reg(mtials .and §ign ... ons.

Below 1$ t11e web address to ~cQess the EFS and the orgm'lh:atfon's user identification number. The encl<>Sed se~led en-V¢lope ¢ontfl,:1ns the C>tg~ization's initial pa,ssword. Once you have logged in using the initial pas_sword, you wUl be immediately prompted to change it to a confidential sfg~ .. ~m~ The chairperson, treasurer. and deputy tr~nsurers are responsible for protecting tbis password from a1s~ostrre and are respom11btc for all filings using these credential$, UnI¢ss the Divisidp l$ nOt.ified that your cred~ntiats have been compromised.

EFS Wf.lb site Addl"¢5S: https:/lefs,dos.state;fl.us Ident:fficatfon Number: 60265

i:t A. Gray l1ttll4' • SDO Sollth l:ifOJ!.Ollg:h Stteet • 'ta1la1luseef F!orl.da 32399..0250 Tel.ef>~one~ · · J 24$-6240 ~ ~a®i~ (SS<)} 24S-62s~ www.dos.st\'l.te.ll.us

tJYJ•'l · · · · t::oin.#tiimof(#J'~ 'f10(JUf!.(if'~ ~f.:tn~e tib,rto.~· WVIW·flasoo.omn

Mt. Ptir'i<~P:. ~l~~n~ .~~1~itP¢r~()n F~hti!~J76.*im$ . . . P•Tlll'.$

Instru.t.-tio!§. tintl.As~tstlue~

At1 ~111.1e ia$truction guide is available to · cm the ~PS 1<> assist with n.avigation; data entry~ andsul)rnis§fdfl ot2rt;p~tts:- T~~ Divi~fon o ... / )>n$ wjtl ufs~ provide assfstan~ to aii users by cont~¢ting ~e BFS H~lp O~slt £tt (8~0) 24S;.fi2$Q. . .

AP ~r tbe l)ivisi0:n's puJ:tji~~o~s ~nd r~port!ng forms ~re ~w~ilable on the Division of Ekctto~~· .· weti . at JJ.ttp;/Mecfllln$.mj,~t!4~<;9~ . It. is your r~p~n1sibility to read, unders•»tf, and ·. Ute r,cquirel:nents ~f F!orifk\~s .~I.e~tron ~~'ys •. 'fJter~fore, pl~s~ prtnt a, c~py of the follttWhlg dcu:iu~cn:ts:. Chapters 104 ~nd 1®~ Fforl~ Statutes, 2(i12 ~{~~1911e~rf11g ~f!1fl~11~f!/fo~~ Q~~t~~loµ. ~nd~'tlok, 21)1 .1 Ca/eadar of Rep(Jttl1!1f />at~ ~nd ~le l$-l~Ql1, Fic.tnd~ A:dn,i~~~~fJN~ C9ti~.

J'l~~e let nm k}lOW if)'-<)U 11~ed additional information~

Sifiecrely~

~~¥-:B-Kristi Reid Bronson> Chief Bureau of Eleetiort Records

p~: Mr. Carlos Tr\leba, Treasurer

Fforida oE!partment i>f State DN1$t~ qf Ef~~ions a.A:. Gt~y &unding, Room a1s $0,e $<ti.¢tt arijn(),u~l1?~rf:?et fariaha~see, PL~iS99'-025.0

~y ·this m~ns w~ w~Jd like to h1f91w you we have appointed a new Chalrma1:1. AS of today the new cnatrman WJ!t ~e Roh1nd Sanchez..;Medlna. Mr. Medina's addre$$ ts 101 Alhambra Ctrc:te, Suite l!OS, Co~I <$ables, FL 33134~

ihank you very much for y~ur prompt attention and CC>Operation In this matter.

ireasuter

Florid~ Statutes title ix ELECTOQS ANO ELE'CTIONS

Chapter 106 bAMtiAlGN FINANCING

100.oi 1 ~eflnitions.·-.A.s usea in tMis Gh~pter; the foUowfng terms have th~ foUQW:ing me~ning~ u,nles$ t~ ~pnt~}(t de~rly i.ndfoat~$ otherwise:

. ' . . . ·. "/ ' . ' ,· ·. ..

{9} ~'El~ctf~meering communic~tions erganiztitio.n'' means any group, other than a political p(lrt:y, affiliated parfy committee, .. o.r polftiµal t!om·mi~t~e, wh~ eleqfion~re~ted. ~tiVlties are timit~d ~a.making expenrjitures for electf©neerfli~ communicatitms or accepting con~ributfons for the purpQ$e of m~~f:rrg et~~tione~nng cemmumcations and whose activities would not othel'Wise req.Uire the group to register as f4 pf?U~t~l pany or poUtic~t c;ommitt~e under this ch13,pter ~

(16)(~} . <'Pqlf~c,1 committ~~;,, means; 1 •. A ~©11lb1R~fen of ~WQ Qr more lrtdWi~u~ts, or a persgh 9ther t,h~n tln il1dfvidual, tl1at, fn an aggregate amo~mt in excess of $500 during a .single <;:alendar Y~ar: ·· a. · A<:ztepts contributions fer the purpose &f making ·contributions to any czmdid~te, political committee, affiliated party commftteet or political parcy; b. Accepts contributions for the purpose of expressly advocating the election or defeat of a candidate or the passage or defeat of an issue; c .. Makes expenditures that expre~ly advoca~e the election or defeat of a candidate or the passage or defeat of an issue; or d. Ma~~~ q:mtripµtions to a c;omm~n fµnd, oth~r than a joint checking account between spouses,. from. wfiich contributions are made to any candidate, political committee, c:tff'.Uiated p.arty committee, or political party;

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From: (202) 517-0585 ElliotS. Ber1<e

Origin ID: BZSA

Ber1<e Farah LLP 1200 Now Hllllpshiro Ave. NW Su~e 800 WASHINGTON, DC 20036

SHIP TO: (850) 922.4539

Amy McKeeverToman Florida Elections Division 107 West Gaines Street

TALLAHASSEE, FL 32399

Jt5121~

BILL SENDER

Ship Date: 26JUN15 ActWgt 0.1 LB CAD: 106638485/INET3610

Oefivery Address Bar Code

111111111111111111111111111111111111111111111111~~11111111111111111111111111 Ref II Centinello Invoice# POii Dept#

[;:i 7739 2548 3905

MON - 29 JUN AA STANDARD OVERNIGHT

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537JitaAOEJEE48

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