October 26, 2018

By electronic mail to:

Jared.DeMarinis@maryland.gov

Jared DeMarinis, Director

Candidacy and Campaign Finance Division
Maryland State Board of Elections
51 West St., Suite 200
Annapolis, MD 21401 – 0486

RE: Illegal Contribution to Montgomery County Neighbors Pac

Dear Mr. DeMarinis:

By this letter we are filing an official complaint against Montgomery Neighbors PAC for
exceeding the $6,000 limit on transfers to a Maryland Campaign Finance entity from an out of
state political committee, in violation of Election Law §13-227.

As disclosed in the most recent Montgomery Neighbors PAC public filing, dated October 26 th,
2018, Empower PAC, a Delaware-based political committee with a Washington, DC address,
contributed $20,000 to Montgomery County Neighbors PAC, far in excess of the $6,000 legal
contribution limit that applies to out of state political committees. This clearly illegal
contribution was received by Montgomery Neighbors PAC on October 17, 2018, according to
their report, and comprises nearly 3/4ths of all of their funding during this period.
Page 36 of the Maryland State Board of Elections Summary Guide to Maryland Candidacy and
Campaign Finance Laws clearly describes the applicable limits in Maryland election law, as well
as a requirement that out of state political committees report within 48 hours any $6,000
contribution to a Maryland PAC within 48 hours, which they do not appear to have done, and
which may be another potential violation we ask you to investigate.
We hereby request the Board take appropriate action immediately to address what appears to be
a clear violation of Maryland campaign finance law.
Sincerely,
Sally Sternbach, Chair

Montgomery County for Nancy Floreen