IN THE OHIO ELECTIONS COMMISSION

DONALD E. CARPENTER, JR. :

5227 South Gate Boulevard, Unit F :
Fairfield, Ohio 45014 :
(513) 470-6782 :
:
Complainant, :
:
vs. : Case No.
:
BRUCE CARTER and :
FRIENDS OF BRUCE CARTER, :
MICHAEL DECRESCE, CHAIR :
5454 Yosemite Drive :
Fairfield, Ohio 45014 :
:
Respondents. :

COMPLAINT

State of Ohio :
County of Franklin : SS.

I, Donald E. Carpenter Jr., being first duly sworn, deposes and says as follows:

1. I am a registered Ohio voter and make this Complaint based upon my personal

knowledge.

2. Respondent Bruce Carter is the Democratic candidate for the Ohio House of

Representatives for the 54th District in the general election to be decided on November 2, 2010.

Respondent Friends of Bruce Carter is Bruce Carter’s authorized campaign committee. Michael

DeCresce is the Chair of that campaign committee.

3. Attached hereto as Exhibit A is a fundraiser flier promoting Bruce Carter’s

candidacy, which Respondents have distributed to the public.

 4. R.C. 3517.20(A)(2) requires campaign committee disclaimers to appear on

political publications published and distributed by a campaign committee that support or oppose

the election of a candidate.

5. R.C. 3517(A)(2) requires ‘the name and residence or business address of the candidate

or the chairperson, treasurer, or secretary of the campaign committee, legislative campaign fund,

political party, or other entity that issues or otherwise is responsible for that political publication

or that makes an expenditure for that political communication appears in a conspicuous place on

that political publication or is contained within that political communication.’

6. R.C. 3517(A)(13) requires that a disclaimed publication ‘shall be identified by the

words “paid for by” followed by the name and address of the campaign committee and the

appropriate officer of the committee, identified by name and title.’

7. Respondents’ fundraiser flier promoting Bruce Carter’s candidacy does not

contain a disclaimer with the words ‘paid for by’ followed by the name and address of Bruce

Carter’s campaign committee and the designated campaign committee official.

8. By publishing the fundraiser flier without the required disclaimer, Respondents

have violated R.C. 3517.20.

2
 WHEREFORE, Complainant requests that Respondents be found in violation of R.C.

Section 3517.20 and that they be appropriately sanctioned.

Further Affiant sayeth nought.

________________________________

Sworn to before me and subscribed in my presence, this day of August, 2010.

________________________________
Notary Public