SlideShare a Scribd company logo
1 of 15
NEW JERSEY ELECTION LAW ENFORCEMENT COMMISSION
P.O. BOX 185
Trenton, New Jersey 08625-0185

NEW JERSEY ELECTION LAW
ENFORCEMENT COMMISSION

COMPLAINT AND NOTICE OF
OPPORTUNITY FOR A HEARING FOR

Complainant
LATE FILING OF REPORTS AND
v.
LATE FILING OF CONTRIBUTION
ELIZABETH MASON,
Candidate for Municipal Office,
City of Hoboken,
Hudson County
and

AND EXPENDITURE INFORMATION
IN THE 2011 MUNICIPAL ELECTION
C-9 0905 14 04 M2011

RICHARD MASON,
Campaign Treasurer,
Respondents
PLEASE TAKE NOTICE that the New Jersey Election Law Enforcement Commission
(hereafter, the Commission) hereby files a complaint against Elizabeth Mason (hereafter, the
Respondent Candidate), and Richard Mason (hereafter, the Respondent Treasurer), and offers the
Respondent Candidate and the Respondent Treasurer an opportunity for a hearing pursuant to the
“Administrative Procedure Act,” N.J.S.A. 52:14B-1 et seq., to determine whether or not the
Respondent Candidate and the Respondent Treasurer had the responsibility under the terms of
"The New Jersey Campaign Contributions and Expenditures Reporting Act," N.J.S.A. 19:44A-1,
et seq. (hereafter, the Act) for the filing of campaign reports or information required to be filed
pursuant to the Act, and to determine whether or not the Respondent Candidate and the
Respondent Treasurer failed, neglected or omitted to file any such report or information at the
time and in the manner prescribed by law, or in any other way violated the provisions of the Act,
and are therefore subject to penalties provided by the Act. The hearing will be conducted under
the legal authority and jurisdiction conferred upon the Commission to impose penalties for
violations of the Act, specifically Sections 6(b) and 22.
The Commission by way of Complaint alleges:
ELEC v. Elizabeth Mason and Richard Mason
C-9 0905 14 04 M2011
Page 2
FIRST COUNT
PROPOSED FINDINGS OF FACT:
1. Elizabeth Mason sought election to municipal office in the City of Hoboken, Hudson
County, in the 2011 municipal election held on May 10, 2011. Hereafter in this Complaint,
Elizabeth Mason shall be referred to as the Respondent Candidate.
2. The Respondent Candidate formed a single candidate committee for the purpose of
receiving contributions and making expenditures to support her candidacy in the 2011 municipal
election.
3. The Respondent Candidate designated her single candidate committee as “Friends of
Beth Mason for City Council” on a Single Candidate Committee – Certificate of Organization
and Designation of Campaign Treasurer and Depository” (Form D-1) filed with the Commission
on April 14, 2011.
4. The Respondent Candidate designated on the Form D-1, described in paragraph three
above, Richard Mason as her campaign treasurer relevant to the 2011 municipal election. The
Respondent Candidate and the Respondent Treasurer Richard Mason certified the Form D-1.
5. Richard Mason was a person who acted in the capacity of campaign treasurer for the
Respondent Candidate in the 2011 municipal election. In his capacity as campaign treasurer,
Respondent Treasurer Richard Mason undertook activity including the certification of campaign
reports filed by the Respondent Candidate in the 2011 municipal election. Hereafter in this
Complaint, Richard Mason shall be referred to as the Respondent Treasurer.
6. The Respondent Candidate and the Respondent Treasurer received and deposited
contributions into and made expenditures from a campaign depository account established and
maintained for the 2011 municipal election at “Wells Fargo, N.A.” in Hoboken, NJ (hereafter,
the 2011 municipal election campaign depository account).
7. The Respondent Candidate and the Respondent Treasurer certified as correct and filed
with the Commission on June 24, 2011, a Report of Contributions and Expenditures (Form R-1)
as a 20-day post election report for the 2011 municipal election (hereafter, 20-day post election
report), reporting outstanding obligations and a balance in the 2011 municipal election campaign
depository account.
8. The Respondent Candidate and the Respondent Treasurer also filed with the
Commission on July 21, 2011, a Report of Contributions and Expenditures (Form R-1) as an
amended 20-day post election report for the 2011 municipal election, and on July 11, 2012, a
ELEC v. Elizabeth Mason and Richard Mason
C-9 0905 14 04 M2011
Page 3
Report of Contributions and Expenditures (Form R-1) as a second amended 20-day post election
report for the 2011 municipal election, which reported outstanding obligations and a balance in
the 2011 municipal election campaign depository account.
9. The Respondent Candidate and the Respondent Treasurer certified as correct and filed
with the Commission on July 19, 2012, a Report of Contributions and Expenditures (Form R-1)
as a 2011 third quarter report for the 2011 municipal election (hereafter, 2011 third quarter
report), to report financial activity for the first time, for the 2011 municipal election for the time
period from May 28, 2011 through September 30, 2011 (hereafter, the 2011 third quarter report
period). The Respondent Candidate and the Respondent Treasurer reported on July 19, 2012,
receipts totaling $31,800.00 and expenditures totaling $35,407.50 relevant to the 2011 third
quarter report period for the 2011 municipal election.
10. The Respondent Candidate and the Respondent Treasurer reported on July 19, 2012
on the 2011 third quarter report on Schedule B (“In-Kind Contributions in Excess of $300”)
contribution information for seven contributions of goods or services (hereafter, in-kind
contributions), totaling $15,800.00, received in amounts greater than $300.00 in the aggregate in
the 2011 municipal election as of September 30, 2011, and relevant to the 2011 third quarter
report period.
11. The Respondent Candidate and the Respondent Treasurer reported on July 19, 2012
on the 2011 third quarter report on Schedule C (“Loans Received in Excess of $300 and All
Currency Loans”) contribution information to report receipt of two loans received in the amounts
of $7,000.00 and $9,000.00, as contributions totaling $16,000.00, reported as received from
“Elizabeth Mason.”
12. The Respondent Candidate and the Respondent Treasurer deposited, or caused to be
deposited, into the 2011 municipal election campaign depository, two deposits in the amounts
described in paragraph eleven above, an amount of $7,000.00 by check drawn on the account of
“Elizabeth Mason” and an amount of $9,000.00 by check drawn on the account of “Richard and
Elizabeth Mason,” in the 2011 third quarter report period for the 2011 municipal election.
PROPOSED CONCLUSIONS OF LAW:
1. The Respondent Elizabeth Mason was a “candidate,” as the term “candidate” is
defined at N.J.S.A. 19:44A-3c, for municipal office in the City of Hoboken in the 2011
municipal election held on May 10, 2011, and therefore was subject to the reporting
ELEC v. Elizabeth Mason and Richard Mason
C-9 0905 14 04 M2011
Page 4
requirements of the Act, N.J.S.A. 19:44A-1 to 47 and Commission Regulations, N.J.A.C. 19:251 to 21.
2. The Respondent Richard Mason was the Respondent Candidate’s campaign treasurer
in the 2011 municipal election and was therefore subject to the requirements of the Act and
Commission Regulations.
3. The Respondent Candidate and the Respondent Treasurer were required, pursuant to
N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.1, N.J.A.C. 19:25-8.3, N.J.A.C. 19:25-10.2, and
N.J.A.C. 19:25-10.4 to certify as correct and file with the Commission on October 17, 2011, a full
cumulative Report of Contributions and Expenditures (Form R-1) as a 2011 third quarter report for
the 2011 municipal election, to report all contributions received and all expenditures made during
the time period from May 28, 2011 through September 30, 2011, that is the 2011 third quarter
report period for the 2011 municipal election.
4. The Respondent Candidate and the Respondent Treasurer were required pursuant to
N.J.S.A. 19:44A-16, N.J.A.C. 19:25-8.3, N.J.A.C. 19:25-10.2, N.J.A.C. 19:25-10.4, and N.J.A.C.
19:25-10.15 to report on October 17, 2011, on the 2011 third quarter report for the 2011 municipal
election, all contributions received, including all moneys, loans, paid personal services, or other
things of value, including contributions of goods and services (in-kind contributions), contributed
to the Respondent Candidate during the time period from May 28, 2011 through September 30,
2011.

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

aggregated with prior contributions received in the 2011 municipal election, through September
30, 2011, and for all contributions received in currency, the Respondent Candidate and Respondent
Treasurer were required to report the name and address of the contributor, the date of receipt of the
contribution, and the contribution amount, and to report for each contribution received from an
individual that was in excess of $300.00 in the aggregate, the occupation of said contributor and
the name and address of said contributor’s employer.
5. The Respondent Candidate and the Respondent Treasurer violated N.J.S.A. 19:44A-16
and N.J.A.C. 19:26-8.3, N.J.A.C. 19:25-10.2, and N.J.A.C. 19:25-10.4 by failing to certify as
correct and file with the Commission on October 17, 2011, a 2011 third quarter report (Form R-1)
for the 2011 municipal election, and to report contribution information relevant to the receipt of
seven in-kind contributions, totaling $15,800.00, as described in paragraph ten of the Proposed
Findings of Fact in this Count above. The Respondent Candidate and the Respondent Treasurer
ELEC v. Elizabeth Mason and Richard Mason
C-9 0905 14 04 M2011
Page 5
reported contribution information for the seven in-kind contributions totaling $15,800.00, on July
19, 2012, after the October 17, 2011 due date and 276 days late.
6. The Respondent Candidate and the Respondent Treasurer violated N.J.S.A. 19:44A-16
and N.J.A.C. 19:26-8.3, N.J.A.C. 19:25-10.2, and N.J.A.C. 19:25-10.4 by failing to certify as
correct and file with the Commission on October 17, 2011, a 2011 third quarter report (Form R-1)
for the 2011 municipal election, and to report contribution information relevant to the receipt of
contributions including all contributions received as loans, as described in paragraphs eleven and
twelve of the Proposed Findings of Fact in this Count above. The Respondent Candidate and the
Respondent Treasurer reported contribution information for two contributions received in the
amounts of $7,000.00 and $9,000.00 as loans, totaling $16,000.00, on July 19, 2012, after the
October 17, 2011 due date and 276 days late.
7. The Respondent Candidate and the Respondent Treasurer are each subject to imposition
by the Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et
seq., which penalties may not be more than $6,800.00 for each reporting transaction, that is, for
each contribution received which has not been reported in the manner or in the time established for
reporting by the Campaign Reporting Act or Commission Regulations.
SECOND COUNT
PROPOSED FINDINGS OF FACT:
1.

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

repeated and incorporated herein as if set forth in full below.
2. The Respondent Candidate and the Respondent Treasurer reported for the first time on
July 19, 2012, on the 2011 third quarter report described in paragraph nine of the Proposed
Findings of Fact in the First Count above on “Schedule 1 (D) – Disbursements, Campaign
Expenses,” expenditure information relevant to the making of four expenditures totaling
$19,107.50, during the 2011 third quarter report period for the 2011 municipal election.
3. The Respondent Candidate and the Respondent Treasurer reported for the first time on
July 19, 2012 on the 2011 third quarter report on “Schedule 3 (D) – Disbursements, Contributions
made to other Candidates/Committees,” expenditure information relevant to the making of one
expenditure in the amount of $500.00, during the 2011 third quarter report period for the 2011
municipal election.
ELEC v. Elizabeth Mason and Richard Mason
C-9 0905 14 04 M2011
Page 6
4. Upon information and belief, the Respondent Candidate and the Respondent Treasurer
made, incurred, or authorized the five expenditures totaling $19,607.50, described in paragraphs
two and three above during the 2011 third quarter report period for the 2011 municipal election.
5. The Respondent Candidate and the Respondent Treasurer reported for the first time on
July 19, 2012 on the 2011 third quarter report on “Table II, Expenditures, Line 6” (“In-kind
Contributions in Excess of $300”), an amount of expenditures totaling $15,800.00, relevant to the
receipt of seven in-kind contributions totaling $15,800.00, as described in paragraph ten of the
Proposed Findings of Fact in Count One above.
PROPOSED CONCLUSIONS OF LAW:
1. The Proposed Conclusions of Law contained in the First Count of this Complaint is
repeated and incorporated herein as if set forth in full below.
2. The Respondent Candidate and the Respondent Treasurer were required, pursuant to
N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3 and N.J.A.C. 19:25-12.2 to certify as correct and
report on October 17, 2011, on the 2011 third quarter report for the 2011 municipal election,
expenditure information, including the date the expenditure was made, the full name and address
of the payee, the purpose of the expenditure, the amount of the expenditure, and the number of the
check for each expenditure transaction made during the time period beginning with the first
expenditure made, incurred or authorized in the 2011 municipal election from May 28, 2011
through September 30, 2011, that is, the 2011 municipal election third quarter report period.
3. The Respondent Candidate and the Respondent Treasurer violated N.J.S.A. 19:44A-16
and N.J.A.C. 19: 25-8.3 and N.J.A.C. 19:25-12.2 by failing to certify as correct and file with the
Commission on October 17, 2011, a 2011 third quarter report (Form R-1) for the 2011 municipal
election, and to report expenditure information relevant to the making of five expenditures, totaling
$19,607.50, in the 2011 municipal election third quarter report period, as described in paragraphs
two and three in the Proposed Findings of Fact in this Count above. The Respondent Candidate
and the Respondent Treasurer reported expenditure information for the five expenditures, totaling
$19,607.50, on July 19, 2012, after the October 17, 2011 due date and 276 days late.
4. The Respondent Candidate and the Respondent Treasurer violated N.J.S.A. 19:44A-16
and N.J.A.C. 19: 25-8.3 and N.J.A.C. 19:25-12.2 by failing to certify as correct and file with the
Commission on October 17, 2011, a 2011 third quarter report (Form R-1), and to report
expenditure information relevant to the receipt of seven in-kind contributions totaling $15,800.00
ELEC v. Elizabeth Mason and Richard Mason
C-9 0905 14 04 M2011
Page 7
in the 2011 municipal election third quarter report period, as described in paragraph five in the
Proposed Findings of Fact in this Count above. The Respondent Candidate and the Respondent
Treasurer reported an amount of $15,800.00, on July 19, 2012, after the October 17, 2011 due date
and 276 days late.
5. The Respondent Candidate and the Respondent Treasurer are each subject to imposition
by the Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et
seq., which penalties may not be more than $6,800.00 for each reporting transaction, that is, for
each expenditure that is not reported in the manner or not filed on the date established for reporting
by the Campaign Reporting Act or Commission Regulations.
THIRD COUNT
PROPOSED FINDINGS OF FACT:
1. The Proposed Findings of Fact contained in the First and Second Counts of this
Complaint are repeated and incorporated herein as if set forth in full below.
2. The Respondent Candidate and the Respondent Treasurer certified as correct and filed
with the Commission on July 19, 2012, a Report of Contributions and Expenditures (Form R-1) as
a 2011 fourth quarter report for the 2011 municipal election (hereafter, 2011 fourth quarter report),
to report financial activity for the first time, for the 2011 municipal election for the time period
from October 1, 2011 through December 31, 2011 (hereafter, the 2011 fourth quarter report
period). The Respondent Candidate and the Respondent Treasurer reported on July 19, 2012,
receipts totaling $47,002.85 and expenditures totaling $53,012.85 relevant to the 2011 fourth
quarter report period for the 2011 municipal election.
3. The Respondent Candidate and the Respondent Treasurer reported on July 19, 2012
on the 2011 fourth quarter report on Schedule B (“In-Kind Contributions in Excess of $300”)
contribution information for nine in-kind contributions, totaling $47,002.85, received in amounts
greater than $300.00 in the aggregate in the 2011 municipal election as of December 31, 2011,
and relevant to the 2011 fourth quarter report period.
PROPOSED CONCLUSIONS OF LAW:
1. The Proposed Conclusions of Law contained in the First and Second Counts of this
Complaint are repeated and incorporated herein as if set forth in full below.
ELEC v. Elizabeth Mason and Richard Mason
C-9 0905 14 04 M2011
Page 8
2. The Respondent Candidate and the Respondent Treasurer were required, pursuant to
N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.1, N.J.A.C. 19:25-8.3, N.J.A.C. 19:25-10.2, and
N.J.A.C. 19:25-10.4 to certify as correct and file with the Commission on January 17, 2012, a
Report of Contributions and Expenditures (Form R-1) as a 2011 fourth quarter report for the 2011
municipal election, to report all contributions received and all expenditures made during the time
period from October 1, 2011 through December 31, 2011, that is the 2011 fourth quarter report
period for the 2011 municipal election.
3. The Respondent Candidate and the Respondent Treasurer were required pursuant to
N.J.S.A. 19:44A-16, N.J.A.C. 19:25-8.3, N.J.A.C. 19:25-10.2, N.J.A.C. 19:25-10.4, and N.J.A.C.
19:25-10.15 to report on January 17, 2012, on the 2011 fourth quarter report for the 2011
municipal election, all contributions received, including all moneys, loans, paid personal services,
or other things of value, including contributions of goods and services (in-kind contributions),
contributed to the Respondent Candidate during the time period from October 1, 2011 through
December 31, 2011. For each contribution received that was in excess of $300.00, either alone or
when aggregated with prior contributions received in the 2011 municipal election, through
December 31, 2011, and for all contributions received in currency, the Respondent Candidate and
Respondent Treasurer were required to report the name and address of the contributor, the date of
receipt of the contribution, and the contribution amount, and to report for each contribution
received from an individual that was in excess of $300.00 in the aggregate, the occupation of said
contributor and the name and address of said contributor’s employer.
4. The Respondent Candidate and the Respondent Treasurer violated N.J.S.A. 19:44A-16
and N.J.A.C. 19:26-8.3, N.J.A.C. 19:25-10.2, and N.J.A.C. 19:25-10.4 by failing to certify as
correct and file with the Commission on January 17, 2012, a 2011 fourth quarter report (Form R-1)
for the 2011 municipal election, and to report contribution information relevant to the receipt of
nine in-kind contributions, totaling $47,002.85, as described in paragraph three of the Proposed
Findings of Fact in this Count above. The Respondent Candidate and the Respondent Treasurer
reported contribution information for the nine in-kind contributions totaling $47,002.85, on July
19, 2012, after the January 17, 2012 due date and 184 days late.
5. The Respondent Candidate and the Respondent Treasurer are each subject to imposition
by the Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et
seq., which penalties may not be more than $6,800.00 for each reporting transaction, that is, for
ELEC v. Elizabeth Mason and Richard Mason
C-9 0905 14 04 M2011
Page 9
each contribution received which has not been reported in the manner or in the time established for
reporting by the Campaign Reporting Act or Commission Regulations.
FOURTH COUNT
PROPOSED FINDINGS OF FACT:
1. The Proposed Findings of Fact contained in the First through Third Counts of this
Complaint are repeated and incorporated herein as if set forth in full below.
2. The Respondent Candidate and the Respondent Treasurer reported on July 19, 2012, on
the 2011 fourth quarter report described in paragraph two of the Proposed Findings of Fact in the
Third Count above on “Schedule 1 (D) – Disbursements, Campaign Expenses,” expenditure
information relevant to the making of one expenditure in the amount of $210.00, during the 2011
fourth quarter report period for the 2011 municipal election.
3. The Respondent Candidate and the Respondent Treasurer reported on July 19, 2012, on
the 2011 fourth quarter report on “Schedule 2 (D) – Disbursements, Other,” expenditure
information relevant to the making of one expenditure in the amount of $800.00, during the 2011
fourth quarter report period for the 2011 municipal election.
4. The Respondent Candidate and the Respondent Treasurer reported on July 19, 2012 on
the 2011 fourth quarter report on “Schedule 3 (D) – Disbursements, Contributions made to other
Candidates/Committees,” expenditure information relevant to the making of one expenditure in the
amount of $5,000.00, during the 2011 fourth quarter report period for the 2011 municipal election.
5. Upon information and belief, the Respondent Candidate and the Respondent Treasurer
made, incurred, or authorized the three expenditures totaling $6,010.00, described in paragraphs
two through four above during the 2011 fourth quarter report period for the 2011 municipal
election.
6. The Respondent Candidate and the Respondent Treasurer reported on July 19, 2012 on
the 2011 fourth quarter report on “Table II, Expenditures, Line 6” (“In-kind Contributions in
Excess of $300”), an amount of expenditures totaling $47,002.85, relevant to the receipt of nine inkind contributions totaling $47,002.85, as described in Paragraph Three of the Proposed Findings
of Fact in Count Three above.
ELEC v. Elizabeth Mason and Richard Mason
C-9 0905 14 04 M2011
Page 10
PROPOSED CONCLUSIONS OF LAW:
1. The Proposed Conclusions of Law contained in the First through Third Counts of this
Complaint are repeated and incorporated herein as if set forth in full below.
2. The Respondent Candidate and the Respondent Treasurer were required, pursuant to
N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3 and N.J.A.C. 19:25-12.2 to certify as correct and
report on January 17, 2012, on the 2011 fourth quarter report for the 2011 municipal election,
expenditure information, including the date the expenditure was made, the full name and address
of the payee, the purpose of the expenditure, the amount of the expenditure, and the number of the
check for each expenditure transaction made during the time period beginning with the first
expenditure made, incurred or authorized in the 2011 municipal election from October 1, 2011
through December 31, 2011, which is the 2011 municipal election fourth quarter report period.
3. The Respondent Candidate and the Respondent Treasurer violated N.J.S.A. 19:44A-16
and N.J.A.C. 19: 25-8.3 and N.J.A.C. 19:25-12.2 by failing to certify as correct and file with the
Commission on January 17, 2012, a 2011 fourth quarter report (Form R-1) for the 2011 municipal
election, and to report expenditure information relevant to the making of three expenditures,
totaling $6,010.00, in the 2011 municipal election fourth quarter report period, as described in
paragraphs two through four in the Proposed Findings of Fact in this Count above. The
Respondent Candidate and the Respondent Treasurer reported expenditure information for the
three expenditures, totaling $6,010.00, on July 19, 2012, after the January 17, 2012 due date and
184 days late.
4. The Respondent Candidate and the Respondent Treasurer violated N.J.S.A. 19:44A-16
and N.J.A.C. 19: 25-8.3 and N.J.A.C. 19:25-12.2 by failing to certify as correct and file with the
Commission on January 17, 2012, a 2011 fourth quarter report (Form R-1), and to report
expenditure information relevant to the receipt of nine in-kind contributions totaling $47,002.85 in
the 2011 municipal election fourth quarter report period, as described in paragraph six in the
Proposed Findings of Fact in this Count above. The Respondent Candidate and the Respondent
Treasurer reported an amount of $47,002.85, on July 19, 2012, after the January 17, 2012 due date
and 184 days late.
5. The Respondent Candidate and the Respondent Treasurer are each subject to imposition
by the Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et
seq., which penalties may not be more than $6,800.00 for each reporting transaction, that is, for
ELEC v. Elizabeth Mason and Richard Mason
C-9 0905 14 04 M2011
Page 11
each expenditure that is not reported in the manner or not filed on the date established for reporting
by the Campaign Reporting Act or Commission Regulations.
FIFTH COUNT
PROPOSED FINDINGS OF FACT:
1. The Proposed Findings of Fact contained in the First through Fourth Counts of this
Complaint are repeated and incorporated herein as if set forth in full below.
2. The Respondent Candidate and the Respondent Treasurer certified as correct and filed
with the Commission on July 23, 2012, a Report of Contributions and Expenditures (Form R-1)
as a 2012 first quarter report for the 2011 municipal election (hereafter, 2012 first quarter report),
to report financial activity for the first time, for the 2011 municipal election for the time period
from January 1, 2012 through March 31, 2012 (hereafter, the 2012 first quarter report period).
The Respondent Candidate and the Respondent Treasurer reported on July 23, 2012, receipts
totaling $20,890.00 and expenditures totaling $29,197.35 relevant to the 2012 first quarter report
period for the 2011 municipal election.
3. The Respondent Candidate and the Respondent Treasurer reported on July 23, 2012
on the 2012 first quarter report on Schedule B (“In-Kind Contributions in Excess of $300”)
contribution information for eight contributions of goods or services (hereafter, in-kind
contributions), totaling $18,890.00, received in amounts greater than $300.00 in the aggregate in
the 2011 municipal election as of March 31, 2012, made by the Respondent Candidate and the
Respondent Treasurer relevant to the 2012 first quarter report period.
4. The Respondent Candidate and the Respondent Treasurer reported on July 23, 2012
on the 2012 first quarter report on Schedule C (“Loans Received in Excess of $300 and All
Currency Loans”) contribution information to report receipt of one loan as a contribution of
$2,000.00, reported as received from “Elizabeth Mason.”
5. The Respondent Candidate and the Respondent Treasurer deposited, or caused to be
deposited, into the 2011 municipal election campaign depository, one deposit of $2,000.00,
drawn on the account of “Richard and Elizabeth Mason,” in the 2012 first quarter report period
for the 2011 municipal election.
ELEC v. Elizabeth Mason and Richard Mason
C-9 0905 14 04 M2011
Page 12
PROPOSED CONCLUSIONS OF LAW:
1. The Proposed Conclusions of Law contained in the First through Fourth Counts of this
Complaint are repeated and incorporated herein as if set forth in full below.
2. The Respondent Candidate and the Respondent Treasurer were required, pursuant to
N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.1, N.J.A.C. 19:25-8.3, N.J.A.C. 19:25-10.2, and
N.J.A.C. 19:25-10.4 to certify as correct and file with the Commission on April 16, 2012, a Report
of Contributions and Expenditures (Form R-1) as a 2012 first quarter report for the 2011 municipal
election, to report all contributions received and all expenditures made during the time period from
January 1, 2012 through March 31, 2012, that is the 2012 first quarter report period for the 2011
municipal election.
3. The Respondent Candidate and the Respondent Treasurer were required pursuant to
N.J.S.A. 19:44A-16, N.J.A.C. 19:25-8.3, N.J.A.C. 19:25-10.2, N.J.A.C. 19:25-10.4, and N.J.A.C.
19:25-10.15 to report on April 16, 2012, on the 2012 first quarter report for the 2011 municipal
election, all contributions received, including all moneys, loans, paid personal services, or other
things of value, including contributions of goods and services (in-kind contributions), contributed
to the Respondent Candidate during the time period from January 1, 2012 through March 31, 2012.
For each contribution received that was in excess of $300.00, either alone or when aggregated with
prior contributions received in the 2011 municipal election, through March 31, 2012, and for all
contributions received in currency, the Respondent Candidate and Respondent Treasurer were
required to report the name and address of the contributor, the date of receipt of the contribution,
and the contribution amount, and to report for each contribution received from an individual that
was in excess of $300.00 in the aggregate, the occupation of said contributor and the name and
address of said contributor’s employer.
4. The Respondent Candidate and the Respondent Treasurer violated N.J.S.A. 19:44A-16
and N.J.A.C. 19:26-8.3, N.J.A.C. 19:25-10.2, and N.J.A.C. 19:25-10.4 by failing to certify as
correct and file with the Commission on April 16, 2012, a 2012 first quarter report (Form R-1) for
the 2011 municipal election, and to report contribution information relevant to the receipt of eight
in-kind contributions, totaling $18,890.00, as described in paragraph three of the Proposed
Findings of Fact in this Count above. The Respondent Candidate and the Respondent Treasurer
reported contribution information for the eight in-kind contributions totaling $18,890.00, on July
23, 2012, after the April 16, 2012 due date and 98 days late.
ELEC v. Elizabeth Mason and Richard Mason
C-9 0905 14 04 M2011
Page 13
5. The Respondent Candidate and the Respondent Treasurer violated N.J.S.A. 19:44A-16
and N.J.A.C. 19:26-8.3, N.J.A.C. 19:25-10.2, and N.J.A.C. 19:25-10.4 by failing to certify as
correct and file with the Commission on April 16, 2012, a 2012 first quarter report (Form R-1) for
the 2011 municipal election, and to report contribution information relevant to the receipt of
contributions including all contributions received as loans, as described in paragraphs four and five
of the Proposed Findings of Fact in this Count above. The Respondent Candidate and the
Respondent Treasurer reported contribution information for one contribution received as a loan,
totaling $2,000.00, on July 23, 2012, after the April 16, 2012 due date and 98 days late.
6. The Respondent Candidate and the Respondent Treasurer are each subject to imposition
by the Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et
seq., which penalties may not be more than $6,800.00 for each reporting transaction, that is, for
each contribution received which has not been reported in the manner or in the time established for
reporting by the Campaign Reporting Act or Commission Regulations.
SIXTH COUNT
PROPOSED FINDINGS OF FACT:
1. The Proposed Findings of Fact contained in the First through Fifth Counts of this
Complaint are repeated and incorporated herein as if set forth in full below.
2. The Respondent Candidate and the Respondent Treasurer reported on July 23, 2012, on
the 2012 first quarter report described in paragraph two of the Proposed Findings of Fact in the
Fifth Count above on “Schedule 1 (D) – Disbursements, Campaign Expenses,” expenditure
information relevant to the making of five expenditures totaling $3,807.35, during the 2012 first
quarter report period for the 2011 municipal election.
3. The Respondent Candidate and the Respondent Treasurer reported on July 23, 2012 on
the 2011 first quarter report on “Schedule 3 (D) – Disbursements, Contributions made to other
Candidates/Committees,” expenditure information relevant to the making of seven expenditures in
the amount of $6,500.00, during the 2012 first quarter report period for the 2011 municipal
election.
4. The Respondent Candidate and the Respondent Treasurer reported on July 23, 2012 on
the 2012 first quarter report on “Table II, Expenditures, Line 6” (“In-kind Contributions in Excess
of $300”), an amount of expenditures totaling $18,890.00, relevant to the receipt of eight in-kind
ELEC v. Elizabeth Mason and Richard Mason
C-9 0905 14 04 M2011
Page 14
contributions totaling $18,890.00, as described in Paragraph Three of the Proposed Findings of
Fact in Count Five above.
PROPOSED CONCLUSIONS OF LAW:
1. The Proposed Conclusions of Law contained in the First through Fifth Counts of this
Complaint are repeated and incorporated herein as if set forth in full below.
2. The Respondent Candidate and the Respondent Treasurer were required, pursuant to
N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3 and N.J.A.C. 19:25-12.2 to certify as correct and
report on April 16, 2012, on the 2012 first quarter report for the 2011 municipal election,
expenditure information, including the date the expenditure was made, the full name and address
of the payee, the purpose of the expenditure, the amount of the expenditure, and the number of the
check for each expenditure transaction made during the time period beginning with the first
expenditure made, incurred or authorized in the 2011 municipal election from January 1, 2012
through March 31, 2012, that is, the 2011 municipal election 2012 first quarter report period.
3. The Respondent Candidate and the Respondent Treasurer violated N.J.S.A. 19:44A-16
and N.J.A.C. 19: 25-8.3 and N.J.A.C. 19:25-12.2 by failing to certify as correct and file with the
Commission on April 16, 2012, a 2012 first quarter report (Form R-1) for the 2011 municipal
election, and to report expenditure information relevant to the making of twelve expenditures,
totaling $10,307.35, in the 2011 municipal election 2012 first quarter report period, as described in
paragraphs two and three in the Proposed Findings of Fact in this Count above. The Respondent
Candidate and the Respondent Treasurer reported expenditure information for the twelve
expenditures, totaling $10,307.35, on July 23, 2012, after the April 16, 2012 due date and 98 days
late.
4. The Respondent Candidate and the Respondent Treasurer violated N.J.S.A. 19:44A-16
and N.J.A.C. 19: 25-8.3 and N.J.A.C. 19:25-12.2 by failing to certify as correct and file with the
Commission on April 16, 2012, a 2012 first quarter report (Form R-1), and to report expenditure
information relevant to the receipt of eight in-kind contributions totaling $18,890.00 in the
outstanding 2011 municipal election 2012 first quarter report period, as described in paragraph
four in the Proposed Findings of Fact in this Count above. The Respondent Candidate and the
Respondent Treasurer reported an amount of $18,890.00, on July 23, 2012, after the April 16, 2012
due date and 98 days late.
ELEC v. Elizabeth Mason and Richard Mason
C-9 0905 14 04 M2011
Page 15
5. The Respondent Candidate and the Respondent Treasurer are each subject to imposition
by the Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et
seq., which penalties may not be more than $6,800.00 for each reporting transaction, that is, for
each expenditure that is not reported in the manner or not filed on the date established for reporting
by the Campaign Reporting Act or Commission Regulations.
OPPORTUNITY FOR HEARING:
Pursuant to N.J.A.C. 19:25-17.1, the Respondents and all parties shall have the opportunity
to appear personally or by attorney at a hearing pursuant to the “Administrative Procedure Act,”
N.J.S.A. 52:14B-1 et seq., and to present evidence and argument on all relevant issues. All
parties shall have the opportunity to examine and cross-examine witnesses. However, failure of
each Respondent to file with the Commission a written answer within twenty (20) days after
service of this Complaint shall constitute a default pursuant to N.J.A.C. 19:25-17.1A and
thereupon the Commission may enter a Final Decision (including imposition of a monetary
penalty).
NEW JERSEY ELECTION LAW
ENFORCEMENT COMMISSION

BY: ________________________
CAROL L. HOEKJE
Legal Director
DATE: February 26, 2014
Elizabeth Mason, Candidate
CERTIFIED MAIL NO. 7009 3410 0001 8443 4947
RETURN RECEIPT REQUESTED
Richard Mason, Treasurer
CERTIFIED MAIL NO. 7009 3410 0001 8443 4930
RETURN RECEIPT REQUESTED

More Related Content

Viewers also liked

Hoboken Claims Listing March 19 2014
Hoboken Claims Listing March 19 2014Hoboken Claims Listing March 19 2014
Hoboken Claims Listing March 19 2014Hudson TV
 
Lotus greens gurgaon
Lotus greens gurgaonLotus greens gurgaon
Lotus greens gurgaonGaurav Verma
 
Achieving learning success through tech
Achieving learning success through techAchieving learning success through tech
Achieving learning success through techRichardGlatt
 
North Bergen City Expenses for May 2015 - 1 of 2
North Bergen City Expenses for May 2015 - 1 of 2North Bergen City Expenses for May 2015 - 1 of 2
North Bergen City Expenses for May 2015 - 1 of 2Hudson TV
 
Bhalla hoboken resolution
Bhalla hoboken resolutionBhalla hoboken resolution
Bhalla hoboken resolutionHudson TV
 
UL DQS India, Global Audit, Certification & Assessment Organization, company ...
UL DQS India, Global Audit, Certification & Assessment Organization, company ...UL DQS India, Global Audit, Certification & Assessment Organization, company ...
UL DQS India, Global Audit, Certification & Assessment Organization, company ...DQS India
 
Hoboken Claims Listing March 5 2014
Hoboken Claims Listing March 5 2014Hoboken Claims Listing March 5 2014
Hoboken Claims Listing March 5 2014Hudson TV
 
MAYOR DAVIS ISSUES 100 DAY REPORT TO BAYONNE RESIDENTS
MAYOR DAVIS ISSUES 100 DAY REPORT TO  BAYONNE RESIDENTSMAYOR DAVIS ISSUES 100 DAY REPORT TO  BAYONNE RESIDENTS
MAYOR DAVIS ISSUES 100 DAY REPORT TO BAYONNE RESIDENTSHudson TV
 
Beth Mason ELEC Complain Part 1
Beth Mason ELEC Complain Part 1Beth Mason ELEC Complain Part 1
Beth Mason ELEC Complain Part 1Hudson TV
 
US Invovlement in World War I
US Invovlement in World War IUS Invovlement in World War I
US Invovlement in World War Ihistory_teacher25
 

Viewers also liked (13)

How to
How toHow to
How to
 
Hoboken Claims Listing March 19 2014
Hoboken Claims Listing March 19 2014Hoboken Claims Listing March 19 2014
Hoboken Claims Listing March 19 2014
 
Lotus greens gurgaon
Lotus greens gurgaonLotus greens gurgaon
Lotus greens gurgaon
 
Achieving learning success through tech
Achieving learning success through techAchieving learning success through tech
Achieving learning success through tech
 
Biomarkers and mediators of cardiovascular risk
 Biomarkers and mediators of cardiovascular risk Biomarkers and mediators of cardiovascular risk
Biomarkers and mediators of cardiovascular risk
 
North Bergen City Expenses for May 2015 - 1 of 2
North Bergen City Expenses for May 2015 - 1 of 2North Bergen City Expenses for May 2015 - 1 of 2
North Bergen City Expenses for May 2015 - 1 of 2
 
Bhalla hoboken resolution
Bhalla hoboken resolutionBhalla hoboken resolution
Bhalla hoboken resolution
 
UL DQS India, Global Audit, Certification & Assessment Organization, company ...
UL DQS India, Global Audit, Certification & Assessment Organization, company ...UL DQS India, Global Audit, Certification & Assessment Organization, company ...
UL DQS India, Global Audit, Certification & Assessment Organization, company ...
 
Hoboken Claims Listing March 5 2014
Hoboken Claims Listing March 5 2014Hoboken Claims Listing March 5 2014
Hoboken Claims Listing March 5 2014
 
MAYOR DAVIS ISSUES 100 DAY REPORT TO BAYONNE RESIDENTS
MAYOR DAVIS ISSUES 100 DAY REPORT TO  BAYONNE RESIDENTSMAYOR DAVIS ISSUES 100 DAY REPORT TO  BAYONNE RESIDENTS
MAYOR DAVIS ISSUES 100 DAY REPORT TO BAYONNE RESIDENTS
 
Beth Mason ELEC Complain Part 1
Beth Mason ELEC Complain Part 1Beth Mason ELEC Complain Part 1
Beth Mason ELEC Complain Part 1
 
What is the gilded age
What is the gilded ageWhat is the gilded age
What is the gilded age
 
US Invovlement in World War I
US Invovlement in World War IUS Invovlement in World War I
US Invovlement in World War I
 

Similar to Beth Mason ELEC Complain Part 2

Beth Mason Part 2
Beth Mason Part 2Beth Mason Part 2
Beth Mason Part 2Hudson TV
 
Funding request form 72214 fillable
Funding request form 72214 fillableFunding request form 72214 fillable
Funding request form 72214 fillableEmpowerLA
 
ap gov chap 10
ap gov chap 10ap gov chap 10
ap gov chap 10m15tuhw15e
 
President Uhuru Kenyatta's response to NASA's petition
President Uhuru Kenyatta's response to NASA's petitionPresident Uhuru Kenyatta's response to NASA's petition
President Uhuru Kenyatta's response to NASA's petitionThe Star Newspaper
 
2021 Emeryville Special Election Petition
2021 Emeryville Special Election Petition2021 Emeryville Special Election Petition
2021 Emeryville Special Election PetitionE'ville Eye
 
Item #1 - AH Canvass Special Election results
Item #1 - AH Canvass Special Election resultsItem #1 - AH Canvass Special Election results
Item #1 - AH Canvass Special Election resultsahcitycouncil
 
Alameda County Registrar of Voters' Report on Oakland's 2010 RCV Election
Alameda County Registrar of Voters' Report on Oakland's 2010 RCV ElectionAlameda County Registrar of Voters' Report on Oakland's 2010 RCV Election
Alameda County Registrar of Voters' Report on Oakland's 2010 RCV ElectionYehoshua7
 
Political parties come under rti act- Central Information Commission
Political parties come under rti act- Central Information CommissionPolitical parties come under rti act- Central Information Commission
Political parties come under rti act- Central Information CommissionLalith Babu
 

Similar to Beth Mason ELEC Complain Part 2 (10)

Beth Mason Part 2
Beth Mason Part 2Beth Mason Part 2
Beth Mason Part 2
 
Tapping the Power of ELEC
Tapping the Power of ELECTapping the Power of ELEC
Tapping the Power of ELEC
 
Election complaint citizens for a better huber heights final
Election complaint citizens for a better huber heights finalElection complaint citizens for a better huber heights final
Election complaint citizens for a better huber heights final
 
Funding request form 72214 fillable
Funding request form 72214 fillableFunding request form 72214 fillable
Funding request form 72214 fillable
 
ap gov chap 10
ap gov chap 10ap gov chap 10
ap gov chap 10
 
President Uhuru Kenyatta's response to NASA's petition
President Uhuru Kenyatta's response to NASA's petitionPresident Uhuru Kenyatta's response to NASA's petition
President Uhuru Kenyatta's response to NASA's petition
 
2021 Emeryville Special Election Petition
2021 Emeryville Special Election Petition2021 Emeryville Special Election Petition
2021 Emeryville Special Election Petition
 
Item #1 - AH Canvass Special Election results
Item #1 - AH Canvass Special Election resultsItem #1 - AH Canvass Special Election results
Item #1 - AH Canvass Special Election results
 
Alameda County Registrar of Voters' Report on Oakland's 2010 RCV Election
Alameda County Registrar of Voters' Report on Oakland's 2010 RCV ElectionAlameda County Registrar of Voters' Report on Oakland's 2010 RCV Election
Alameda County Registrar of Voters' Report on Oakland's 2010 RCV Election
 
Political parties come under rti act- Central Information Commission
Political parties come under rti act- Central Information CommissionPolitical parties come under rti act- Central Information Commission
Political parties come under rti act- Central Information Commission
 

More from Hudson TV

Complaint - Warrant Reynaldo Mercado West New York 2
Complaint - Warrant Reynaldo Mercado West New York 2Complaint - Warrant Reynaldo Mercado West New York 2
Complaint - Warrant Reynaldo Mercado West New York 2Hudson TV
 
Complaint - Warrant Reynaldo Mercado West New York
Complaint - Warrant Reynaldo Mercado West New YorkComplaint - Warrant Reynaldo Mercado West New York
Complaint - Warrant Reynaldo Mercado West New YorkHudson TV
 
West New York Opra Files 2017 - 2018
West New York Opra Files 2017 - 2018West New York Opra Files 2017 - 2018
West New York Opra Files 2017 - 2018Hudson TV
 
Bayonne NJ Opra Request Report November 2017
Bayonne NJ Opra Request Report November 2017Bayonne NJ Opra Request Report November 2017
Bayonne NJ Opra Request Report November 2017Hudson TV
 
Bayonne NJ Opra Request Report December 2017
Bayonne NJ Opra Request Report December 2017Bayonne NJ Opra Request Report December 2017
Bayonne NJ Opra Request Report December 2017Hudson TV
 
Bayonne NJ Opra Request Report October 2017
Bayonne NJ Opra Request Report October 2017Bayonne NJ Opra Request Report October 2017
Bayonne NJ Opra Request Report October 2017Hudson TV
 
Opra Request Reports Bayonne September 2017
Opra Request Reports Bayonne September 2017Opra Request Reports Bayonne September 2017
Opra Request Reports Bayonne September 2017Hudson TV
 
Opra Request Reports Bayonne August 2017
Opra Request Reports Bayonne August 2017Opra Request Reports Bayonne August 2017
Opra Request Reports Bayonne August 2017Hudson TV
 
Opra Request Reports Bayonne July 2017
Opra Request Reports Bayonne July 2017Opra Request Reports Bayonne July 2017
Opra Request Reports Bayonne July 2017Hudson TV
 
Opra Request Reports Bayonne June 2017
Opra Request Reports Bayonne June 2017Opra Request Reports Bayonne June 2017
Opra Request Reports Bayonne June 2017Hudson TV
 
Opra Request Reports Bayonne May 2017
Opra Request Reports Bayonne May 2017Opra Request Reports Bayonne May 2017
Opra Request Reports Bayonne May 2017Hudson TV
 
Opra Request Reports Bayonne NJ March 2017
Opra Request Reports Bayonne NJ March 2017Opra Request Reports Bayonne NJ March 2017
Opra Request Reports Bayonne NJ March 2017Hudson TV
 
Opra Request Reports Bayonne NJ April 2017
Opra Request Reports Bayonne NJ April 2017Opra Request Reports Bayonne NJ April 2017
Opra Request Reports Bayonne NJ April 2017Hudson TV
 
Opra Request Reports Bayonne NJ February 2017
Opra Request Reports Bayonne NJ February 2017Opra Request Reports Bayonne NJ February 2017
Opra Request Reports Bayonne NJ February 2017Hudson TV
 
Guttenberg Cirillo Town Administrator
Guttenberg Cirillo Town AdministratorGuttenberg Cirillo Town Administrator
Guttenberg Cirillo Town AdministratorHudson TV
 
Carmelo Garcia vs Stan Grossbard
Carmelo Garcia vs Stan GrossbardCarmelo Garcia vs Stan Grossbard
Carmelo Garcia vs Stan GrossbardHudson TV
 
Bridgegate Files
Bridgegate Files Bridgegate Files
Bridgegate Files Hudson TV
 
Bridegate Files
Bridegate FilesBridegate Files
Bridegate FilesHudson TV
 
Jersey City Under Fulop Got Huge Special State Funding And Port Authority Buc...
Jersey City Under Fulop Got Huge Special State Funding And Port Authority Buc...Jersey City Under Fulop Got Huge Special State Funding And Port Authority Buc...
Jersey City Under Fulop Got Huge Special State Funding And Port Authority Buc...Hudson TV
 
Before Bridgegate: Christie Aides Targeted Fulop And Holland Tunnel for Payback
Before Bridgegate: Christie Aides Targeted Fulop And Holland Tunnel for PaybackBefore Bridgegate: Christie Aides Targeted Fulop And Holland Tunnel for Payback
Before Bridgegate: Christie Aides Targeted Fulop And Holland Tunnel for PaybackHudson TV
 

More from Hudson TV (20)

Complaint - Warrant Reynaldo Mercado West New York 2
Complaint - Warrant Reynaldo Mercado West New York 2Complaint - Warrant Reynaldo Mercado West New York 2
Complaint - Warrant Reynaldo Mercado West New York 2
 
Complaint - Warrant Reynaldo Mercado West New York
Complaint - Warrant Reynaldo Mercado West New YorkComplaint - Warrant Reynaldo Mercado West New York
Complaint - Warrant Reynaldo Mercado West New York
 
West New York Opra Files 2017 - 2018
West New York Opra Files 2017 - 2018West New York Opra Files 2017 - 2018
West New York Opra Files 2017 - 2018
 
Bayonne NJ Opra Request Report November 2017
Bayonne NJ Opra Request Report November 2017Bayonne NJ Opra Request Report November 2017
Bayonne NJ Opra Request Report November 2017
 
Bayonne NJ Opra Request Report December 2017
Bayonne NJ Opra Request Report December 2017Bayonne NJ Opra Request Report December 2017
Bayonne NJ Opra Request Report December 2017
 
Bayonne NJ Opra Request Report October 2017
Bayonne NJ Opra Request Report October 2017Bayonne NJ Opra Request Report October 2017
Bayonne NJ Opra Request Report October 2017
 
Opra Request Reports Bayonne September 2017
Opra Request Reports Bayonne September 2017Opra Request Reports Bayonne September 2017
Opra Request Reports Bayonne September 2017
 
Opra Request Reports Bayonne August 2017
Opra Request Reports Bayonne August 2017Opra Request Reports Bayonne August 2017
Opra Request Reports Bayonne August 2017
 
Opra Request Reports Bayonne July 2017
Opra Request Reports Bayonne July 2017Opra Request Reports Bayonne July 2017
Opra Request Reports Bayonne July 2017
 
Opra Request Reports Bayonne June 2017
Opra Request Reports Bayonne June 2017Opra Request Reports Bayonne June 2017
Opra Request Reports Bayonne June 2017
 
Opra Request Reports Bayonne May 2017
Opra Request Reports Bayonne May 2017Opra Request Reports Bayonne May 2017
Opra Request Reports Bayonne May 2017
 
Opra Request Reports Bayonne NJ March 2017
Opra Request Reports Bayonne NJ March 2017Opra Request Reports Bayonne NJ March 2017
Opra Request Reports Bayonne NJ March 2017
 
Opra Request Reports Bayonne NJ April 2017
Opra Request Reports Bayonne NJ April 2017Opra Request Reports Bayonne NJ April 2017
Opra Request Reports Bayonne NJ April 2017
 
Opra Request Reports Bayonne NJ February 2017
Opra Request Reports Bayonne NJ February 2017Opra Request Reports Bayonne NJ February 2017
Opra Request Reports Bayonne NJ February 2017
 
Guttenberg Cirillo Town Administrator
Guttenberg Cirillo Town AdministratorGuttenberg Cirillo Town Administrator
Guttenberg Cirillo Town Administrator
 
Carmelo Garcia vs Stan Grossbard
Carmelo Garcia vs Stan GrossbardCarmelo Garcia vs Stan Grossbard
Carmelo Garcia vs Stan Grossbard
 
Bridgegate Files
Bridgegate Files Bridgegate Files
Bridgegate Files
 
Bridegate Files
Bridegate FilesBridegate Files
Bridegate Files
 
Jersey City Under Fulop Got Huge Special State Funding And Port Authority Buc...
Jersey City Under Fulop Got Huge Special State Funding And Port Authority Buc...Jersey City Under Fulop Got Huge Special State Funding And Port Authority Buc...
Jersey City Under Fulop Got Huge Special State Funding And Port Authority Buc...
 
Before Bridgegate: Christie Aides Targeted Fulop And Holland Tunnel for Payback
Before Bridgegate: Christie Aides Targeted Fulop And Holland Tunnel for PaybackBefore Bridgegate: Christie Aides Targeted Fulop And Holland Tunnel for Payback
Before Bridgegate: Christie Aides Targeted Fulop And Holland Tunnel for Payback
 

Recently uploaded

R$ 78 milhões: Estado aprova 593 propostas para acordos diretos de precatórios
R$ 78 milhões: Estado aprova 593 propostas para acordos diretos de precatóriosR$ 78 milhões: Estado aprova 593 propostas para acordos diretos de precatórios
R$ 78 milhões: Estado aprova 593 propostas para acordos diretos de precatóriosMaurílio Júnior
 
Embed-3-1-1.pdf The ECI direction on April 2, 2024 can be read here:
Embed-3-1-1.pdf  The ECI direction on April 2, 2024 can be read here:Embed-3-1-1.pdf  The ECI direction on April 2, 2024 can be read here:
Embed-3-1-1.pdf The ECI direction on April 2, 2024 can be read here:bhavenpr
 
Embed-4-3 (1).pdf cvxx'f['df[p'lf][l][fl][fl][][l[
Embed-4-3 (1).pdf cvxx'f['df[p'lf][l][fl][fl][][l[Embed-4-3 (1).pdf cvxx'f['df[p'lf][l][fl][fl][][l[
Embed-4-3 (1).pdf cvxx'f['df[p'lf][l][fl][fl][][l[bhavenpr
 
25052024_First India Newspaper Jaipur.pdf
25052024_First India Newspaper Jaipur.pdf25052024_First India Newspaper Jaipur.pdf
25052024_First India Newspaper Jaipur.pdfFIRST INDIA
 
Meta_AI_ads_investigation.pdfldoljjwejolejolol
Meta_AI_ads_investigation.pdfldoljjwejolejololMeta_AI_ads_investigation.pdfldoljjwejolejolol
Meta_AI_ads_investigation.pdfldoljjwejolejololbhavenpr
 
24052024_First India Newspaper Jaipur.pdf
24052024_First India Newspaper Jaipur.pdf24052024_First India Newspaper Jaipur.pdf
24052024_First India Newspaper Jaipur.pdfFIRST INDIA
 
Minnesota Timberwolves Bring Ya Ass T Shirt
Minnesota Timberwolves Bring Ya Ass T ShirtMinnesota Timberwolves Bring Ya Ass T Shirt
Minnesota Timberwolves Bring Ya Ass T Shirtniherranjansingha
 
Dominican American Coalition PAC Executive Summary
Dominican American Coalition PAC Executive SummaryDominican American Coalition PAC Executive Summary
Dominican American Coalition PAC Executive SummaryRDE GROUP CORP
 
israeil_bnetaniahou_panel_report_eng.pdf
israeil_bnetaniahou_panel_report_eng.pdfisraeil_bnetaniahou_panel_report_eng.pdf
israeil_bnetaniahou_panel_report_eng.pdfssuser5750e1
 
23052024_First India Newspaper Jaipur.pdf
23052024_First India Newspaper Jaipur.pdf23052024_First India Newspaper Jaipur.pdf
23052024_First India Newspaper Jaipur.pdfFIRST INDIA
 
Textile Waste In India | Textile Waste Management
Textile Waste In India | Textile Waste ManagementTextile Waste In India | Textile Waste Management
Textile Waste In India | Textile Waste ManagementTheUnitedIndian
 
Have A Complimentary Cheat Sheet, On Us!!!
Have A Complimentary Cheat Sheet, On Us!!!Have A Complimentary Cheat Sheet, On Us!!!
Have A Complimentary Cheat Sheet, On Us!!!Abdul-Hakim Shabazz
 
2024 - Love and Madness - a book about love, madness, heartbreak and politics
2024 - Love and Madness - a book about love, madness, heartbreak and politics2024 - Love and Madness - a book about love, madness, heartbreak and politics
2024 - Love and Madness - a book about love, madness, heartbreak and politicsConradSmit5
 
Nika Muhl Visa Approval Shirt, Nika Muhl Visa Approval T-Shirt
Nika Muhl Visa Approval Shirt, Nika Muhl Visa Approval T-ShirtNika Muhl Visa Approval Shirt, Nika Muhl Visa Approval T-Shirt
Nika Muhl Visa Approval Shirt, Nika Muhl Visa Approval T-Shirtniherranjansingha
 
21052024_First India Newspaper Jaipur.pdf
21052024_First India Newspaper Jaipur.pdf21052024_First India Newspaper Jaipur.pdf
21052024_First India Newspaper Jaipur.pdfFIRST INDIA
 
May 2024 - Crypto Market Report_FINAL.pdf
May 2024 - Crypto Market Report_FINAL.pdfMay 2024 - Crypto Market Report_FINAL.pdf
May 2024 - Crypto Market Report_FINAL.pdfmanisha194592
 
Mizzima Weekly Analysis & Insight Issue 1
Mizzima Weekly Analysis & Insight Issue 1Mizzima Weekly Analysis & Insight Issue 1
Mizzima Weekly Analysis & Insight Issue 1Mizzima Media
 
Embed-4-1-1.pdf vm ;sdkp[kdp[kpdkpodp;p;j
Embed-4-1-1.pdf vm ;sdkp[kdp[kpdkpodp;p;jEmbed-4-1-1.pdf vm ;sdkp[kdp[kpdkpodp;p;j
Embed-4-1-1.pdf vm ;sdkp[kdp[kpdkpodp;p;jbhavenpr
 
Encore portal Project PPt on live portal
Encore portal Project PPt on live portalEncore portal Project PPt on live portal
Encore portal Project PPt on live portalEshantRawat2
 
PEACE BETWEEN ISRAEL AND PALESTINE REQUIRES EXTREMISTS OUT OF POWER AND RESTR...
PEACE BETWEEN ISRAEL AND PALESTINE REQUIRES EXTREMISTS OUT OF POWER AND RESTR...PEACE BETWEEN ISRAEL AND PALESTINE REQUIRES EXTREMISTS OUT OF POWER AND RESTR...
PEACE BETWEEN ISRAEL AND PALESTINE REQUIRES EXTREMISTS OUT OF POWER AND RESTR...Faga1939
 

Recently uploaded (20)

R$ 78 milhões: Estado aprova 593 propostas para acordos diretos de precatórios
R$ 78 milhões: Estado aprova 593 propostas para acordos diretos de precatóriosR$ 78 milhões: Estado aprova 593 propostas para acordos diretos de precatórios
R$ 78 milhões: Estado aprova 593 propostas para acordos diretos de precatórios
 
Embed-3-1-1.pdf The ECI direction on April 2, 2024 can be read here:
Embed-3-1-1.pdf  The ECI direction on April 2, 2024 can be read here:Embed-3-1-1.pdf  The ECI direction on April 2, 2024 can be read here:
Embed-3-1-1.pdf The ECI direction on April 2, 2024 can be read here:
 
Embed-4-3 (1).pdf cvxx'f['df[p'lf][l][fl][fl][][l[
Embed-4-3 (1).pdf cvxx'f['df[p'lf][l][fl][fl][][l[Embed-4-3 (1).pdf cvxx'f['df[p'lf][l][fl][fl][][l[
Embed-4-3 (1).pdf cvxx'f['df[p'lf][l][fl][fl][][l[
 
25052024_First India Newspaper Jaipur.pdf
25052024_First India Newspaper Jaipur.pdf25052024_First India Newspaper Jaipur.pdf
25052024_First India Newspaper Jaipur.pdf
 
Meta_AI_ads_investigation.pdfldoljjwejolejolol
Meta_AI_ads_investigation.pdfldoljjwejolejololMeta_AI_ads_investigation.pdfldoljjwejolejolol
Meta_AI_ads_investigation.pdfldoljjwejolejolol
 
24052024_First India Newspaper Jaipur.pdf
24052024_First India Newspaper Jaipur.pdf24052024_First India Newspaper Jaipur.pdf
24052024_First India Newspaper Jaipur.pdf
 
Minnesota Timberwolves Bring Ya Ass T Shirt
Minnesota Timberwolves Bring Ya Ass T ShirtMinnesota Timberwolves Bring Ya Ass T Shirt
Minnesota Timberwolves Bring Ya Ass T Shirt
 
Dominican American Coalition PAC Executive Summary
Dominican American Coalition PAC Executive SummaryDominican American Coalition PAC Executive Summary
Dominican American Coalition PAC Executive Summary
 
israeil_bnetaniahou_panel_report_eng.pdf
israeil_bnetaniahou_panel_report_eng.pdfisraeil_bnetaniahou_panel_report_eng.pdf
israeil_bnetaniahou_panel_report_eng.pdf
 
23052024_First India Newspaper Jaipur.pdf
23052024_First India Newspaper Jaipur.pdf23052024_First India Newspaper Jaipur.pdf
23052024_First India Newspaper Jaipur.pdf
 
Textile Waste In India | Textile Waste Management
Textile Waste In India | Textile Waste ManagementTextile Waste In India | Textile Waste Management
Textile Waste In India | Textile Waste Management
 
Have A Complimentary Cheat Sheet, On Us!!!
Have A Complimentary Cheat Sheet, On Us!!!Have A Complimentary Cheat Sheet, On Us!!!
Have A Complimentary Cheat Sheet, On Us!!!
 
2024 - Love and Madness - a book about love, madness, heartbreak and politics
2024 - Love and Madness - a book about love, madness, heartbreak and politics2024 - Love and Madness - a book about love, madness, heartbreak and politics
2024 - Love and Madness - a book about love, madness, heartbreak and politics
 
Nika Muhl Visa Approval Shirt, Nika Muhl Visa Approval T-Shirt
Nika Muhl Visa Approval Shirt, Nika Muhl Visa Approval T-ShirtNika Muhl Visa Approval Shirt, Nika Muhl Visa Approval T-Shirt
Nika Muhl Visa Approval Shirt, Nika Muhl Visa Approval T-Shirt
 
21052024_First India Newspaper Jaipur.pdf
21052024_First India Newspaper Jaipur.pdf21052024_First India Newspaper Jaipur.pdf
21052024_First India Newspaper Jaipur.pdf
 
May 2024 - Crypto Market Report_FINAL.pdf
May 2024 - Crypto Market Report_FINAL.pdfMay 2024 - Crypto Market Report_FINAL.pdf
May 2024 - Crypto Market Report_FINAL.pdf
 
Mizzima Weekly Analysis & Insight Issue 1
Mizzima Weekly Analysis & Insight Issue 1Mizzima Weekly Analysis & Insight Issue 1
Mizzima Weekly Analysis & Insight Issue 1
 
Embed-4-1-1.pdf vm ;sdkp[kdp[kpdkpodp;p;j
Embed-4-1-1.pdf vm ;sdkp[kdp[kpdkpodp;p;jEmbed-4-1-1.pdf vm ;sdkp[kdp[kpdkpodp;p;j
Embed-4-1-1.pdf vm ;sdkp[kdp[kpdkpodp;p;j
 
Encore portal Project PPt on live portal
Encore portal Project PPt on live portalEncore portal Project PPt on live portal
Encore portal Project PPt on live portal
 
PEACE BETWEEN ISRAEL AND PALESTINE REQUIRES EXTREMISTS OUT OF POWER AND RESTR...
PEACE BETWEEN ISRAEL AND PALESTINE REQUIRES EXTREMISTS OUT OF POWER AND RESTR...PEACE BETWEEN ISRAEL AND PALESTINE REQUIRES EXTREMISTS OUT OF POWER AND RESTR...
PEACE BETWEEN ISRAEL AND PALESTINE REQUIRES EXTREMISTS OUT OF POWER AND RESTR...
 

Beth Mason ELEC Complain Part 2

  • 1. NEW JERSEY ELECTION LAW ENFORCEMENT COMMISSION P.O. BOX 185 Trenton, New Jersey 08625-0185 NEW JERSEY ELECTION LAW ENFORCEMENT COMMISSION COMPLAINT AND NOTICE OF OPPORTUNITY FOR A HEARING FOR Complainant LATE FILING OF REPORTS AND v. LATE FILING OF CONTRIBUTION ELIZABETH MASON, Candidate for Municipal Office, City of Hoboken, Hudson County and AND EXPENDITURE INFORMATION IN THE 2011 MUNICIPAL ELECTION C-9 0905 14 04 M2011 RICHARD MASON, Campaign Treasurer, Respondents PLEASE TAKE NOTICE that the New Jersey Election Law Enforcement Commission (hereafter, the Commission) hereby files a complaint against Elizabeth Mason (hereafter, the Respondent Candidate), and Richard Mason (hereafter, the Respondent Treasurer), and offers the Respondent Candidate and the Respondent Treasurer an opportunity for a hearing pursuant to the “Administrative Procedure Act,” N.J.S.A. 52:14B-1 et seq., to determine whether or not the Respondent Candidate and the Respondent Treasurer had the responsibility under the terms of "The New Jersey Campaign Contributions and Expenditures Reporting Act," N.J.S.A. 19:44A-1, et seq. (hereafter, the Act) for the filing of campaign reports or information required to be filed pursuant to the Act, and to determine whether or not the Respondent Candidate and the Respondent Treasurer failed, neglected or omitted to file any such report or information at the time and in the manner prescribed by law, or in any other way violated the provisions of the Act, and are therefore subject to penalties provided by the Act. The hearing will be conducted under the legal authority and jurisdiction conferred upon the Commission to impose penalties for violations of the Act, specifically Sections 6(b) and 22. The Commission by way of Complaint alleges:
  • 2. ELEC v. Elizabeth Mason and Richard Mason C-9 0905 14 04 M2011 Page 2 FIRST COUNT PROPOSED FINDINGS OF FACT: 1. Elizabeth Mason sought election to municipal office in the City of Hoboken, Hudson County, in the 2011 municipal election held on May 10, 2011. Hereafter in this Complaint, Elizabeth Mason shall be referred to as the Respondent Candidate. 2. The Respondent Candidate formed a single candidate committee for the purpose of receiving contributions and making expenditures to support her candidacy in the 2011 municipal election. 3. The Respondent Candidate designated her single candidate committee as “Friends of Beth Mason for City Council” on a Single Candidate Committee – Certificate of Organization and Designation of Campaign Treasurer and Depository” (Form D-1) filed with the Commission on April 14, 2011. 4. The Respondent Candidate designated on the Form D-1, described in paragraph three above, Richard Mason as her campaign treasurer relevant to the 2011 municipal election. The Respondent Candidate and the Respondent Treasurer Richard Mason certified the Form D-1. 5. Richard Mason was a person who acted in the capacity of campaign treasurer for the Respondent Candidate in the 2011 municipal election. In his capacity as campaign treasurer, Respondent Treasurer Richard Mason undertook activity including the certification of campaign reports filed by the Respondent Candidate in the 2011 municipal election. Hereafter in this Complaint, Richard Mason shall be referred to as the Respondent Treasurer. 6. The Respondent Candidate and the Respondent Treasurer received and deposited contributions into and made expenditures from a campaign depository account established and maintained for the 2011 municipal election at “Wells Fargo, N.A.” in Hoboken, NJ (hereafter, the 2011 municipal election campaign depository account). 7. The Respondent Candidate and the Respondent Treasurer certified as correct and filed with the Commission on June 24, 2011, a Report of Contributions and Expenditures (Form R-1) as a 20-day post election report for the 2011 municipal election (hereafter, 20-day post election report), reporting outstanding obligations and a balance in the 2011 municipal election campaign depository account. 8. The Respondent Candidate and the Respondent Treasurer also filed with the Commission on July 21, 2011, a Report of Contributions and Expenditures (Form R-1) as an amended 20-day post election report for the 2011 municipal election, and on July 11, 2012, a
  • 3. ELEC v. Elizabeth Mason and Richard Mason C-9 0905 14 04 M2011 Page 3 Report of Contributions and Expenditures (Form R-1) as a second amended 20-day post election report for the 2011 municipal election, which reported outstanding obligations and a balance in the 2011 municipal election campaign depository account. 9. The Respondent Candidate and the Respondent Treasurer certified as correct and filed with the Commission on July 19, 2012, a Report of Contributions and Expenditures (Form R-1) as a 2011 third quarter report for the 2011 municipal election (hereafter, 2011 third quarter report), to report financial activity for the first time, for the 2011 municipal election for the time period from May 28, 2011 through September 30, 2011 (hereafter, the 2011 third quarter report period). The Respondent Candidate and the Respondent Treasurer reported on July 19, 2012, receipts totaling $31,800.00 and expenditures totaling $35,407.50 relevant to the 2011 third quarter report period for the 2011 municipal election. 10. The Respondent Candidate and the Respondent Treasurer reported on July 19, 2012 on the 2011 third quarter report on Schedule B (“In-Kind Contributions in Excess of $300”) contribution information for seven contributions of goods or services (hereafter, in-kind contributions), totaling $15,800.00, received in amounts greater than $300.00 in the aggregate in the 2011 municipal election as of September 30, 2011, and relevant to the 2011 third quarter report period. 11. The Respondent Candidate and the Respondent Treasurer reported on July 19, 2012 on the 2011 third quarter report on Schedule C (“Loans Received in Excess of $300 and All Currency Loans”) contribution information to report receipt of two loans received in the amounts of $7,000.00 and $9,000.00, as contributions totaling $16,000.00, reported as received from “Elizabeth Mason.” 12. The Respondent Candidate and the Respondent Treasurer deposited, or caused to be deposited, into the 2011 municipal election campaign depository, two deposits in the amounts described in paragraph eleven above, an amount of $7,000.00 by check drawn on the account of “Elizabeth Mason” and an amount of $9,000.00 by check drawn on the account of “Richard and Elizabeth Mason,” in the 2011 third quarter report period for the 2011 municipal election. PROPOSED CONCLUSIONS OF LAW: 1. The Respondent Elizabeth Mason was a “candidate,” as the term “candidate” is defined at N.J.S.A. 19:44A-3c, for municipal office in the City of Hoboken in the 2011 municipal election held on May 10, 2011, and therefore was subject to the reporting
  • 4. ELEC v. Elizabeth Mason and Richard Mason C-9 0905 14 04 M2011 Page 4 requirements of the Act, N.J.S.A. 19:44A-1 to 47 and Commission Regulations, N.J.A.C. 19:251 to 21. 2. The Respondent Richard Mason was the Respondent Candidate’s campaign treasurer in the 2011 municipal election and was therefore subject to the requirements of the Act and Commission Regulations. 3. The Respondent Candidate and the Respondent Treasurer were required, pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.1, N.J.A.C. 19:25-8.3, N.J.A.C. 19:25-10.2, and N.J.A.C. 19:25-10.4 to certify as correct and file with the Commission on October 17, 2011, a full cumulative Report of Contributions and Expenditures (Form R-1) as a 2011 third quarter report for the 2011 municipal election, to report all contributions received and all expenditures made during the time period from May 28, 2011 through September 30, 2011, that is the 2011 third quarter report period for the 2011 municipal election. 4. The Respondent Candidate and the Respondent Treasurer were required pursuant to N.J.S.A. 19:44A-16, N.J.A.C. 19:25-8.3, N.J.A.C. 19:25-10.2, N.J.A.C. 19:25-10.4, and N.J.A.C. 19:25-10.15 to report on October 17, 2011, on the 2011 third quarter report for the 2011 municipal election, all contributions received, including all moneys, loans, paid personal services, or other things of value, including contributions of goods and services (in-kind contributions), contributed to the Respondent Candidate during the time period from May 28, 2011 through September 30, 2011. For each contribution received that was in excess of $300.00, either alone or when aggregated with prior contributions received in the 2011 municipal election, through September 30, 2011, and for all contributions received in currency, the Respondent Candidate and Respondent Treasurer were required to report the name and address of the contributor, the date of receipt of the contribution, and the contribution amount, and to report for each contribution received from an individual that was in excess of $300.00 in the aggregate, the occupation of said contributor and the name and address of said contributor’s employer. 5. The Respondent Candidate and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and N.J.A.C. 19:26-8.3, N.J.A.C. 19:25-10.2, and N.J.A.C. 19:25-10.4 by failing to certify as correct and file with the Commission on October 17, 2011, a 2011 third quarter report (Form R-1) for the 2011 municipal election, and to report contribution information relevant to the receipt of seven in-kind contributions, totaling $15,800.00, as described in paragraph ten of the Proposed Findings of Fact in this Count above. The Respondent Candidate and the Respondent Treasurer
  • 5. ELEC v. Elizabeth Mason and Richard Mason C-9 0905 14 04 M2011 Page 5 reported contribution information for the seven in-kind contributions totaling $15,800.00, on July 19, 2012, after the October 17, 2011 due date and 276 days late. 6. The Respondent Candidate and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and N.J.A.C. 19:26-8.3, N.J.A.C. 19:25-10.2, and N.J.A.C. 19:25-10.4 by failing to certify as correct and file with the Commission on October 17, 2011, a 2011 third quarter report (Form R-1) for the 2011 municipal election, and to report contribution information relevant to the receipt of contributions including all contributions received as loans, as described in paragraphs eleven and twelve of the Proposed Findings of Fact in this Count above. The Respondent Candidate and the Respondent Treasurer reported contribution information for two contributions received in the amounts of $7,000.00 and $9,000.00 as loans, totaling $16,000.00, on July 19, 2012, after the October 17, 2011 due date and 276 days late. 7. The Respondent Candidate and the Respondent Treasurer are each subject to imposition by the Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which penalties may not be more than $6,800.00 for each reporting transaction, that is, for each contribution received which has not been reported in the manner or in the time established for reporting by the Campaign Reporting Act or Commission Regulations. SECOND COUNT PROPOSED FINDINGS OF FACT: 1. The Proposed Findings of Fact contained in the First Count of this Complaint are repeated and incorporated herein as if set forth in full below. 2. The Respondent Candidate and the Respondent Treasurer reported for the first time on July 19, 2012, on the 2011 third quarter report described in paragraph nine of the Proposed Findings of Fact in the First Count above on “Schedule 1 (D) – Disbursements, Campaign Expenses,” expenditure information relevant to the making of four expenditures totaling $19,107.50, during the 2011 third quarter report period for the 2011 municipal election. 3. The Respondent Candidate and the Respondent Treasurer reported for the first time on July 19, 2012 on the 2011 third quarter report on “Schedule 3 (D) – Disbursements, Contributions made to other Candidates/Committees,” expenditure information relevant to the making of one expenditure in the amount of $500.00, during the 2011 third quarter report period for the 2011 municipal election.
  • 6. ELEC v. Elizabeth Mason and Richard Mason C-9 0905 14 04 M2011 Page 6 4. Upon information and belief, the Respondent Candidate and the Respondent Treasurer made, incurred, or authorized the five expenditures totaling $19,607.50, described in paragraphs two and three above during the 2011 third quarter report period for the 2011 municipal election. 5. The Respondent Candidate and the Respondent Treasurer reported for the first time on July 19, 2012 on the 2011 third quarter report on “Table II, Expenditures, Line 6” (“In-kind Contributions in Excess of $300”), an amount of expenditures totaling $15,800.00, relevant to the receipt of seven in-kind contributions totaling $15,800.00, as described in paragraph ten of the Proposed Findings of Fact in Count One above. PROPOSED CONCLUSIONS OF LAW: 1. The Proposed Conclusions of Law contained in the First Count of this Complaint is repeated and incorporated herein as if set forth in full below. 2. The Respondent Candidate and the Respondent Treasurer were required, pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3 and N.J.A.C. 19:25-12.2 to certify as correct and report on October 17, 2011, on the 2011 third quarter report for the 2011 municipal election, expenditure information, including the date the expenditure was made, the full name and address of the payee, the purpose of the expenditure, the amount of the expenditure, and the number of the check for each expenditure transaction made during the time period beginning with the first expenditure made, incurred or authorized in the 2011 municipal election from May 28, 2011 through September 30, 2011, that is, the 2011 municipal election third quarter report period. 3. The Respondent Candidate and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and N.J.A.C. 19: 25-8.3 and N.J.A.C. 19:25-12.2 by failing to certify as correct and file with the Commission on October 17, 2011, a 2011 third quarter report (Form R-1) for the 2011 municipal election, and to report expenditure information relevant to the making of five expenditures, totaling $19,607.50, in the 2011 municipal election third quarter report period, as described in paragraphs two and three in the Proposed Findings of Fact in this Count above. The Respondent Candidate and the Respondent Treasurer reported expenditure information for the five expenditures, totaling $19,607.50, on July 19, 2012, after the October 17, 2011 due date and 276 days late. 4. The Respondent Candidate and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and N.J.A.C. 19: 25-8.3 and N.J.A.C. 19:25-12.2 by failing to certify as correct and file with the Commission on October 17, 2011, a 2011 third quarter report (Form R-1), and to report expenditure information relevant to the receipt of seven in-kind contributions totaling $15,800.00
  • 7. ELEC v. Elizabeth Mason and Richard Mason C-9 0905 14 04 M2011 Page 7 in the 2011 municipal election third quarter report period, as described in paragraph five in the Proposed Findings of Fact in this Count above. The Respondent Candidate and the Respondent Treasurer reported an amount of $15,800.00, on July 19, 2012, after the October 17, 2011 due date and 276 days late. 5. The Respondent Candidate and the Respondent Treasurer are each subject to imposition by the Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which penalties may not be more than $6,800.00 for each reporting transaction, that is, for each expenditure that is not reported in the manner or not filed on the date established for reporting by the Campaign Reporting Act or Commission Regulations. THIRD COUNT PROPOSED FINDINGS OF FACT: 1. The Proposed Findings of Fact contained in the First and Second Counts of this Complaint are repeated and incorporated herein as if set forth in full below. 2. The Respondent Candidate and the Respondent Treasurer certified as correct and filed with the Commission on July 19, 2012, a Report of Contributions and Expenditures (Form R-1) as a 2011 fourth quarter report for the 2011 municipal election (hereafter, 2011 fourth quarter report), to report financial activity for the first time, for the 2011 municipal election for the time period from October 1, 2011 through December 31, 2011 (hereafter, the 2011 fourth quarter report period). The Respondent Candidate and the Respondent Treasurer reported on July 19, 2012, receipts totaling $47,002.85 and expenditures totaling $53,012.85 relevant to the 2011 fourth quarter report period for the 2011 municipal election. 3. The Respondent Candidate and the Respondent Treasurer reported on July 19, 2012 on the 2011 fourth quarter report on Schedule B (“In-Kind Contributions in Excess of $300”) contribution information for nine in-kind contributions, totaling $47,002.85, received in amounts greater than $300.00 in the aggregate in the 2011 municipal election as of December 31, 2011, and relevant to the 2011 fourth quarter report period. PROPOSED CONCLUSIONS OF LAW: 1. The Proposed Conclusions of Law contained in the First and Second Counts of this Complaint are repeated and incorporated herein as if set forth in full below.
  • 8. ELEC v. Elizabeth Mason and Richard Mason C-9 0905 14 04 M2011 Page 8 2. The Respondent Candidate and the Respondent Treasurer were required, pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.1, N.J.A.C. 19:25-8.3, N.J.A.C. 19:25-10.2, and N.J.A.C. 19:25-10.4 to certify as correct and file with the Commission on January 17, 2012, a Report of Contributions and Expenditures (Form R-1) as a 2011 fourth quarter report for the 2011 municipal election, to report all contributions received and all expenditures made during the time period from October 1, 2011 through December 31, 2011, that is the 2011 fourth quarter report period for the 2011 municipal election. 3. The Respondent Candidate and the Respondent Treasurer were required pursuant to N.J.S.A. 19:44A-16, N.J.A.C. 19:25-8.3, N.J.A.C. 19:25-10.2, N.J.A.C. 19:25-10.4, and N.J.A.C. 19:25-10.15 to report on January 17, 2012, on the 2011 fourth quarter report for the 2011 municipal election, all contributions received, including all moneys, loans, paid personal services, or other things of value, including contributions of goods and services (in-kind contributions), contributed to the Respondent Candidate during the time period from October 1, 2011 through December 31, 2011. For each contribution received that was in excess of $300.00, either alone or when aggregated with prior contributions received in the 2011 municipal election, through December 31, 2011, and for all contributions received in currency, the Respondent Candidate and Respondent Treasurer were required to report the name and address of the contributor, the date of receipt of the contribution, and the contribution amount, and to report for each contribution received from an individual that was in excess of $300.00 in the aggregate, the occupation of said contributor and the name and address of said contributor’s employer. 4. The Respondent Candidate and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and N.J.A.C. 19:26-8.3, N.J.A.C. 19:25-10.2, and N.J.A.C. 19:25-10.4 by failing to certify as correct and file with the Commission on January 17, 2012, a 2011 fourth quarter report (Form R-1) for the 2011 municipal election, and to report contribution information relevant to the receipt of nine in-kind contributions, totaling $47,002.85, as described in paragraph three of the Proposed Findings of Fact in this Count above. The Respondent Candidate and the Respondent Treasurer reported contribution information for the nine in-kind contributions totaling $47,002.85, on July 19, 2012, after the January 17, 2012 due date and 184 days late. 5. The Respondent Candidate and the Respondent Treasurer are each subject to imposition by the Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which penalties may not be more than $6,800.00 for each reporting transaction, that is, for
  • 9. ELEC v. Elizabeth Mason and Richard Mason C-9 0905 14 04 M2011 Page 9 each contribution received which has not been reported in the manner or in the time established for reporting by the Campaign Reporting Act or Commission Regulations. FOURTH COUNT PROPOSED FINDINGS OF FACT: 1. The Proposed Findings of Fact contained in the First through Third Counts of this Complaint are repeated and incorporated herein as if set forth in full below. 2. The Respondent Candidate and the Respondent Treasurer reported on July 19, 2012, on the 2011 fourth quarter report described in paragraph two of the Proposed Findings of Fact in the Third Count above on “Schedule 1 (D) – Disbursements, Campaign Expenses,” expenditure information relevant to the making of one expenditure in the amount of $210.00, during the 2011 fourth quarter report period for the 2011 municipal election. 3. The Respondent Candidate and the Respondent Treasurer reported on July 19, 2012, on the 2011 fourth quarter report on “Schedule 2 (D) – Disbursements, Other,” expenditure information relevant to the making of one expenditure in the amount of $800.00, during the 2011 fourth quarter report period for the 2011 municipal election. 4. The Respondent Candidate and the Respondent Treasurer reported on July 19, 2012 on the 2011 fourth quarter report on “Schedule 3 (D) – Disbursements, Contributions made to other Candidates/Committees,” expenditure information relevant to the making of one expenditure in the amount of $5,000.00, during the 2011 fourth quarter report period for the 2011 municipal election. 5. Upon information and belief, the Respondent Candidate and the Respondent Treasurer made, incurred, or authorized the three expenditures totaling $6,010.00, described in paragraphs two through four above during the 2011 fourth quarter report period for the 2011 municipal election. 6. The Respondent Candidate and the Respondent Treasurer reported on July 19, 2012 on the 2011 fourth quarter report on “Table II, Expenditures, Line 6” (“In-kind Contributions in Excess of $300”), an amount of expenditures totaling $47,002.85, relevant to the receipt of nine inkind contributions totaling $47,002.85, as described in Paragraph Three of the Proposed Findings of Fact in Count Three above.
  • 10. ELEC v. Elizabeth Mason and Richard Mason C-9 0905 14 04 M2011 Page 10 PROPOSED CONCLUSIONS OF LAW: 1. The Proposed Conclusions of Law contained in the First through Third Counts of this Complaint are repeated and incorporated herein as if set forth in full below. 2. The Respondent Candidate and the Respondent Treasurer were required, pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3 and N.J.A.C. 19:25-12.2 to certify as correct and report on January 17, 2012, on the 2011 fourth quarter report for the 2011 municipal election, expenditure information, including the date the expenditure was made, the full name and address of the payee, the purpose of the expenditure, the amount of the expenditure, and the number of the check for each expenditure transaction made during the time period beginning with the first expenditure made, incurred or authorized in the 2011 municipal election from October 1, 2011 through December 31, 2011, which is the 2011 municipal election fourth quarter report period. 3. The Respondent Candidate and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and N.J.A.C. 19: 25-8.3 and N.J.A.C. 19:25-12.2 by failing to certify as correct and file with the Commission on January 17, 2012, a 2011 fourth quarter report (Form R-1) for the 2011 municipal election, and to report expenditure information relevant to the making of three expenditures, totaling $6,010.00, in the 2011 municipal election fourth quarter report period, as described in paragraphs two through four in the Proposed Findings of Fact in this Count above. The Respondent Candidate and the Respondent Treasurer reported expenditure information for the three expenditures, totaling $6,010.00, on July 19, 2012, after the January 17, 2012 due date and 184 days late. 4. The Respondent Candidate and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and N.J.A.C. 19: 25-8.3 and N.J.A.C. 19:25-12.2 by failing to certify as correct and file with the Commission on January 17, 2012, a 2011 fourth quarter report (Form R-1), and to report expenditure information relevant to the receipt of nine in-kind contributions totaling $47,002.85 in the 2011 municipal election fourth quarter report period, as described in paragraph six in the Proposed Findings of Fact in this Count above. The Respondent Candidate and the Respondent Treasurer reported an amount of $47,002.85, on July 19, 2012, after the January 17, 2012 due date and 184 days late. 5. The Respondent Candidate and the Respondent Treasurer are each subject to imposition by the Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which penalties may not be more than $6,800.00 for each reporting transaction, that is, for
  • 11. ELEC v. Elizabeth Mason and Richard Mason C-9 0905 14 04 M2011 Page 11 each expenditure that is not reported in the manner or not filed on the date established for reporting by the Campaign Reporting Act or Commission Regulations. FIFTH COUNT PROPOSED FINDINGS OF FACT: 1. The Proposed Findings of Fact contained in the First through Fourth Counts of this Complaint are repeated and incorporated herein as if set forth in full below. 2. The Respondent Candidate and the Respondent Treasurer certified as correct and filed with the Commission on July 23, 2012, a Report of Contributions and Expenditures (Form R-1) as a 2012 first quarter report for the 2011 municipal election (hereafter, 2012 first quarter report), to report financial activity for the first time, for the 2011 municipal election for the time period from January 1, 2012 through March 31, 2012 (hereafter, the 2012 first quarter report period). The Respondent Candidate and the Respondent Treasurer reported on July 23, 2012, receipts totaling $20,890.00 and expenditures totaling $29,197.35 relevant to the 2012 first quarter report period for the 2011 municipal election. 3. The Respondent Candidate and the Respondent Treasurer reported on July 23, 2012 on the 2012 first quarter report on Schedule B (“In-Kind Contributions in Excess of $300”) contribution information for eight contributions of goods or services (hereafter, in-kind contributions), totaling $18,890.00, received in amounts greater than $300.00 in the aggregate in the 2011 municipal election as of March 31, 2012, made by the Respondent Candidate and the Respondent Treasurer relevant to the 2012 first quarter report period. 4. The Respondent Candidate and the Respondent Treasurer reported on July 23, 2012 on the 2012 first quarter report on Schedule C (“Loans Received in Excess of $300 and All Currency Loans”) contribution information to report receipt of one loan as a contribution of $2,000.00, reported as received from “Elizabeth Mason.” 5. The Respondent Candidate and the Respondent Treasurer deposited, or caused to be deposited, into the 2011 municipal election campaign depository, one deposit of $2,000.00, drawn on the account of “Richard and Elizabeth Mason,” in the 2012 first quarter report period for the 2011 municipal election.
  • 12. ELEC v. Elizabeth Mason and Richard Mason C-9 0905 14 04 M2011 Page 12 PROPOSED CONCLUSIONS OF LAW: 1. The Proposed Conclusions of Law contained in the First through Fourth Counts of this Complaint are repeated and incorporated herein as if set forth in full below. 2. The Respondent Candidate and the Respondent Treasurer were required, pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.1, N.J.A.C. 19:25-8.3, N.J.A.C. 19:25-10.2, and N.J.A.C. 19:25-10.4 to certify as correct and file with the Commission on April 16, 2012, a Report of Contributions and Expenditures (Form R-1) as a 2012 first quarter report for the 2011 municipal election, to report all contributions received and all expenditures made during the time period from January 1, 2012 through March 31, 2012, that is the 2012 first quarter report period for the 2011 municipal election. 3. The Respondent Candidate and the Respondent Treasurer were required pursuant to N.J.S.A. 19:44A-16, N.J.A.C. 19:25-8.3, N.J.A.C. 19:25-10.2, N.J.A.C. 19:25-10.4, and N.J.A.C. 19:25-10.15 to report on April 16, 2012, on the 2012 first quarter report for the 2011 municipal election, all contributions received, including all moneys, loans, paid personal services, or other things of value, including contributions of goods and services (in-kind contributions), contributed to the Respondent Candidate during the time period from January 1, 2012 through March 31, 2012. For each contribution received that was in excess of $300.00, either alone or when aggregated with prior contributions received in the 2011 municipal election, through March 31, 2012, and for all contributions received in currency, the Respondent Candidate and Respondent Treasurer were required to report the name and address of the contributor, the date of receipt of the contribution, and the contribution amount, and to report for each contribution received from an individual that was in excess of $300.00 in the aggregate, the occupation of said contributor and the name and address of said contributor’s employer. 4. The Respondent Candidate and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and N.J.A.C. 19:26-8.3, N.J.A.C. 19:25-10.2, and N.J.A.C. 19:25-10.4 by failing to certify as correct and file with the Commission on April 16, 2012, a 2012 first quarter report (Form R-1) for the 2011 municipal election, and to report contribution information relevant to the receipt of eight in-kind contributions, totaling $18,890.00, as described in paragraph three of the Proposed Findings of Fact in this Count above. The Respondent Candidate and the Respondent Treasurer reported contribution information for the eight in-kind contributions totaling $18,890.00, on July 23, 2012, after the April 16, 2012 due date and 98 days late.
  • 13. ELEC v. Elizabeth Mason and Richard Mason C-9 0905 14 04 M2011 Page 13 5. The Respondent Candidate and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and N.J.A.C. 19:26-8.3, N.J.A.C. 19:25-10.2, and N.J.A.C. 19:25-10.4 by failing to certify as correct and file with the Commission on April 16, 2012, a 2012 first quarter report (Form R-1) for the 2011 municipal election, and to report contribution information relevant to the receipt of contributions including all contributions received as loans, as described in paragraphs four and five of the Proposed Findings of Fact in this Count above. The Respondent Candidate and the Respondent Treasurer reported contribution information for one contribution received as a loan, totaling $2,000.00, on July 23, 2012, after the April 16, 2012 due date and 98 days late. 6. The Respondent Candidate and the Respondent Treasurer are each subject to imposition by the Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which penalties may not be more than $6,800.00 for each reporting transaction, that is, for each contribution received which has not been reported in the manner or in the time established for reporting by the Campaign Reporting Act or Commission Regulations. SIXTH COUNT PROPOSED FINDINGS OF FACT: 1. The Proposed Findings of Fact contained in the First through Fifth Counts of this Complaint are repeated and incorporated herein as if set forth in full below. 2. The Respondent Candidate and the Respondent Treasurer reported on July 23, 2012, on the 2012 first quarter report described in paragraph two of the Proposed Findings of Fact in the Fifth Count above on “Schedule 1 (D) – Disbursements, Campaign Expenses,” expenditure information relevant to the making of five expenditures totaling $3,807.35, during the 2012 first quarter report period for the 2011 municipal election. 3. The Respondent Candidate and the Respondent Treasurer reported on July 23, 2012 on the 2011 first quarter report on “Schedule 3 (D) – Disbursements, Contributions made to other Candidates/Committees,” expenditure information relevant to the making of seven expenditures in the amount of $6,500.00, during the 2012 first quarter report period for the 2011 municipal election. 4. The Respondent Candidate and the Respondent Treasurer reported on July 23, 2012 on the 2012 first quarter report on “Table II, Expenditures, Line 6” (“In-kind Contributions in Excess of $300”), an amount of expenditures totaling $18,890.00, relevant to the receipt of eight in-kind
  • 14. ELEC v. Elizabeth Mason and Richard Mason C-9 0905 14 04 M2011 Page 14 contributions totaling $18,890.00, as described in Paragraph Three of the Proposed Findings of Fact in Count Five above. PROPOSED CONCLUSIONS OF LAW: 1. The Proposed Conclusions of Law contained in the First through Fifth Counts of this Complaint are repeated and incorporated herein as if set forth in full below. 2. The Respondent Candidate and the Respondent Treasurer were required, pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3 and N.J.A.C. 19:25-12.2 to certify as correct and report on April 16, 2012, on the 2012 first quarter report for the 2011 municipal election, expenditure information, including the date the expenditure was made, the full name and address of the payee, the purpose of the expenditure, the amount of the expenditure, and the number of the check for each expenditure transaction made during the time period beginning with the first expenditure made, incurred or authorized in the 2011 municipal election from January 1, 2012 through March 31, 2012, that is, the 2011 municipal election 2012 first quarter report period. 3. The Respondent Candidate and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and N.J.A.C. 19: 25-8.3 and N.J.A.C. 19:25-12.2 by failing to certify as correct and file with the Commission on April 16, 2012, a 2012 first quarter report (Form R-1) for the 2011 municipal election, and to report expenditure information relevant to the making of twelve expenditures, totaling $10,307.35, in the 2011 municipal election 2012 first quarter report period, as described in paragraphs two and three in the Proposed Findings of Fact in this Count above. The Respondent Candidate and the Respondent Treasurer reported expenditure information for the twelve expenditures, totaling $10,307.35, on July 23, 2012, after the April 16, 2012 due date and 98 days late. 4. The Respondent Candidate and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and N.J.A.C. 19: 25-8.3 and N.J.A.C. 19:25-12.2 by failing to certify as correct and file with the Commission on April 16, 2012, a 2012 first quarter report (Form R-1), and to report expenditure information relevant to the receipt of eight in-kind contributions totaling $18,890.00 in the outstanding 2011 municipal election 2012 first quarter report period, as described in paragraph four in the Proposed Findings of Fact in this Count above. The Respondent Candidate and the Respondent Treasurer reported an amount of $18,890.00, on July 23, 2012, after the April 16, 2012 due date and 98 days late.
  • 15. ELEC v. Elizabeth Mason and Richard Mason C-9 0905 14 04 M2011 Page 15 5. The Respondent Candidate and the Respondent Treasurer are each subject to imposition by the Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which penalties may not be more than $6,800.00 for each reporting transaction, that is, for each expenditure that is not reported in the manner or not filed on the date established for reporting by the Campaign Reporting Act or Commission Regulations. OPPORTUNITY FOR HEARING: Pursuant to N.J.A.C. 19:25-17.1, the Respondents and all parties shall have the opportunity to appear personally or by attorney at a hearing pursuant to the “Administrative Procedure Act,” N.J.S.A. 52:14B-1 et seq., and to present evidence and argument on all relevant issues. All parties shall have the opportunity to examine and cross-examine witnesses. However, failure of each Respondent to file with the Commission a written answer within twenty (20) days after service of this Complaint shall constitute a default pursuant to N.J.A.C. 19:25-17.1A and thereupon the Commission may enter a Final Decision (including imposition of a monetary penalty). NEW JERSEY ELECTION LAW ENFORCEMENT COMMISSION BY: ________________________ CAROL L. HOEKJE Legal Director DATE: February 26, 2014 Elizabeth Mason, Candidate CERTIFIED MAIL NO. 7009 3410 0001 8443 4947 RETURN RECEIPT REQUESTED Richard Mason, Treasurer CERTIFIED MAIL NO. 7009 3410 0001 8443 4930 RETURN RECEIPT REQUESTED