Texas Ethics Commission Complaint Filing for WeAreFrisco Nature of Alleged Violation Statement of Facts Listing of Documents and

Other Materials In Print Exhibit A: 2010 Flier Exhibit B: 2010 Postcard Exhibit C: 2011 Flier Exhibit D: 2011 Runoff Flier Online Exhibit E: Current Site Exhibits F-K: Archived Site January 13, 2010 June 30, 2009 May 30, 2009 August 22, 2008 July 1, 2008 May 8, 2008 Exhibit L: Facebook Page News Articles Exhibit M: Dallas Morning News May 24, 2010 Election Laws Referenced Title 15, Election Code 251.001 Definitions 252.009 Authority With Whom Appointment Filed: General -Purpose Committee 253.031 Contribution and Expenditure Without Campaign Treasurer Prohibited 253.037 Restrictions on Contribution or Expenditure by General -Purpose Committee 254.001 Recordkeeping Required 254.153 Semiannual Reporting Schedule for Committee 255.001 Required Disclosure on Political Advertising

Nature of Alleged Violation Include the specific law(s) or rule(s) alleged to have been violated. The Texas Ethics Commission has jurisdiction to enforce only the following laws: (1) Title 15 of the Election Code; (2) Chapters 302, 303, 305, 572, 2004 of the Gov't Code; (3) 334.025 and 335.055 of the Local Gov't Code; (4) Subchapter C, Chapter 159 of the Local Gov't Code, in connection with a county judicial officer who elects to file a financial statement with the commission; (5) 2152.064 and 2155.003 of the Gov't Code; (6) 306.005 of the Gov't Code. Alvin Huerta is the editor and founder of WeAreFrisco, which acts as a General Purpose Political Committee as defined by 251.001(12 & 14) in Title 15, Election Code. The group has never appointed a campaign treasurer, as required by 252.009 and 253.037(a). Its political expenditures exceed the limits for a committee without a treasurer set by 253.031(b&c). It has never filed a report with the commission disclosing all reportable activity, as required by 254.001(b). The political advertisements it produces lack a disclosure statement, as required by 255.001(a). Statement of Facts State the facts constituting the alleged violation(s), including the dates on which or the period of time in which the alleged violation(s) occurred. Identify allegations of fact not personally known to the complainant, but alleged on information and belief. Please use simple, concise, and direct statements. Alvin Huerta, Dudley Wilson, and Fran Wilson, created WeAreFrisco on May 1 or 2, 2008 to support the unidentified measure of deannexing portions of Frisco, Texas from Lewisville ISD into Frisco ISD (Exhibit M). Since then, the groups focus has expanded to include many other issues. According to the groups website (Exhibit E), WeAreFrisco is dedicated to helping citizens become informed voters and to supporting candidates who share our conservative values and vision. The site also includes direct endorsement of various candidates, including those running for municipal, county, and judicial offices. This indicates that the group qualifies as a General Purpose Political Committee. The site, which qualifies as a political advertisement under 251.001(16)(B)(ii), does not include a disclosure statement. Additionally, the site has been archived by the Internet Archives Wayback Machine six times (Exhibits F-K) since May 8, 2008. During that time, the group has supported various unidentified ballot measures and candidates. At none of these points did the group include the required disclosure statement on the site. The group also maintains a Facebook page (Exhibit L) that includes a timeline of its activities since 2010. In September of 2010, WeAreFrisco produced and distributed a flier (Exhibit A) and a mailed postcard (Exhibit B) opposing a bond measure. For the municipal elections in May 2011, the

group produced a flier (Exhibit C) endorsing candidates for Lewisville ISD Board of Trustees and Frisco City Council, referring to this as the WeAreFrisco Slate. The group also produced a flier (Exhibit D) for the June 2011 runoff election endorsing John Keating for Frisco City Council. None of these included a disclosure statement. Several people interviewed alleged that WeAreFrisco and its supporters had participated in many other similar activities to those listed here, but this complaint regards only the evidence submitted with it. Listing of Documents and Other Materials List all documents and other materials filed with this complaint. Additionally, list all other documents and other materials that are relevant to this complaint and that are within your knowledge, including their location, if known. In Print Exhibit A: 2010 Flier http://www.scribd.com/doc/87422608/ a3e70641-b690-e949 Exhibit B: 2010 Postcard http://www.scribd.com/doc/87422483/47615076- ba3b-534e Exhibit C: 2011 Flier http://www.scribd.com/doc/91267804/ WeAreFrisco-2011-Color-Flyer Exhibit D: 2011 Runoff Flier http://www.scribd.com/doc/91267074/ WeAreFrisco-2011-Runoff-Flyer Online Exhibit E: Current Site http://wearefrisco.com Exhibits F-K: Archived Site January 13, 2010 http://web.archive.org/web/20100113062050/ http://www.wearefrisco.org/ June 30, 2009 http://web.archive.org/web/20090630073716/ http://www.wearefrisco.org/ May 30, 2009 http://web.archive.org/web/20090530061607/ http://www.wearefrisco.org/

August 22, 2008 http://web.archive.org/web/20080822055255/ http://www.wearefrisco.org/ July 1, 2008 http://web.archive.org/web/20080701192919/ http://www.wearefrisco.org/ May 8, 2008 http://web.archive.org/web/20080508174741/ http://www.wearefrisco.org/ Exhibit L: Facebook Page http://www.facebook.com/WeAreFrisco News Articles Exhibit M: Dallas Morning News May 24, 2010 http://www.dallasnews .com/news/education/headlines/20100524-Southwest-Friscoresidents-effort-to-56.ece

Election Laws Referenced Title 15, Election Code 251.001 Definitions (14) "General-purpose committee" means a political committee that has among its principal purposes: (A) supporting or opposing: (i) two or more candidates who are unidentified or are seeking offices that are unknown; or (ii) one or more measures that are unidentified; or (B) assisting two or more officeholders who are unidentified. (16) "Political advertising" means a communication supporting or opposing a candidate for nomination or election to a public office or office of a political party, a political party, a public officer, or a measure that: (A) in return for consideration, is published in a newspaper, magazine, or other periodical or is broadcast by radio or television; or (B) appears: (i) in a pamphlet, circular, flier, billboard or other sign, bumper sticker, or similar form of written communication; or

(ii) on an Internet website. 252.009 Authority With Whom Appointment Filed: General-Purpose Committee A general-purpose committee must file its campaign treasurer appointment with the commission. 253.031 Contribution and Expenditure Without Campaign Treasurer Prohibited (b) A political committee may not knowingly accept political contributions totaling more than $500 or make or authorize political expenditures totaling more than $500 at a time when a campaign treasurer appointment for the committee is not in effect. (c) A political committee may not knowingly make or authorize a campaign contribution or campaign expenditure supporting or opposing a candidate for an office specified by Section 252.005(1) in a primary or general election unless the committees campaign treasurer appointment has been filed not later than the 30th day before the appropriate election day. 253.037 Restrictions on Contribution or Expenditure by General-Purpose Committee (a) A general-purpose committee may not knowingly make or authorize a political contribution or political expenditure unless the committee has: (1) filed its campaign treasurer appointment not later than the 60th day before the date the contribution or expenditure is made; and (2) accepted political contributions from at least 10 persons. 254.001 Recordkeeping Required (b) Each campaign treasurer of a political committee shall maintain a record of all reportable activity. 254.153 Semiannual Reporting Schedule for Committee a) The campaign treasurer of a general-purpose committee shall file two reports for each year as provided by this section. (b) The first report shall be filed not later than July 15. The report covers the period beginning January 1, the day the committees campaign treasurer appointment is filed, or the first day after the period covered by the last report required to be filed under this subchapter, as applicable, and continuing through June 30. (c) The second report shall be filed not later than January 15. The report covers the period beginning July 1, the day the committees campaign treasurer appointment is filed, or the first day after the period covered by the last report required to be filed under this subchapter, as applicable, and continuing through December 31. 255.001 Required Disclosure on Political Advertising

(a) A person may not knowingly cause to be published, distributed, or broadcast political advertising containing express advocacy that does not indicate in the advertising: (1) that it is political advertising; and (2) the full name of: (A) the person who paid for the political advertising; (B) the political committee authorizing the political advertising; or (C) the candidate or specific-purpose committee supporting the candidate, if the political advertising is authorized by the candidate. (b) Political advertising that is authorized by a candidate, an agent of a candidate, or a political committee filing reports under this title shall be deemed to contain express advocacy. (c) A person may not knowingly use, cause or permit to be used, or continue to use any published, distributed, or broadcast political advertising containing express advocacy that the person knows does not include the disclosure required by Subsection (a). A person is presumed to know that the use of political advertising is prohibited by this subsection if the commission notifies the person in writing that the use is prohibited. A person who learns that political advertising signs, as defined by Section 255.007, that have been distributed do not include the disclosure required by Subsection (a) or include a disclosure that does not comply with Subsection (a) does not commit a continuing violation of this subsection if the person makes a good faith attempt to remove or correct those signs. A person who learns that printed political advertising other than a political advertising sign that has been distributed does not include the disclosure required by Subsection (a) or includes a disclosure that does not comply with Subsection (a) is not required to attempt to recover the political advertising and does not commit a continuing violation of this subsection as to any previously distributed political advertising. (d) This section does not apply to: (1) tickets or invitations to political fund-raising events; (2) campaign buttons, pins, hats, or similar campaign materials; or (3) circulars or flyers that cost in the aggregate less than $500 to publish and distribute. (e) A person who violates this section is liable to the state for a civil penalty in an amount determined by the commission not to exceed $4,000.