Friday, September 16, 2016

Donald Trump contributed more than $40,000 of ''in-kind" services to Florida AG Pam Bondi's campaign, violating state election laws, according to complaint

Donald Trump and Pam Bondi
Donald Trump violated election law by giving a campaign contribution of more than $3,000 to Florida Attorney General Pam Bondi, according to a Boston attorney's complaint.

J. Whitfield Larrabee also alleges that Bondi violated the law by failing to certify and publicly disclose Trump's illegal contribution to the Florida Division of Elections. (See full complaint at the end of this post.)

What are the possible implications for Trump, the Republican Party's 2016 presidential nominee? The answer is not immediately clear, but Larrabee already has filed complaints alleging a donation to Bondi's campaign constituted bribery and involved tax evasion and political corruption.

Is Trump withholding his income-tax information because it would reveal criminal activity related to the Bondi donation? Did Bondi withdraw from an investigation of Trump University after receiving a $25,000 campaign donation? Based on Larrabee's complaints, and reporting from a number of Florida news outlets, the answers appear to be yes. Heck, even The New York Times is starting to treat it as a real story.

Now, Larrabee is addressing possible election-law violations, and they go well beyond the $25,000 campaign contribution. Here is how Larrabee describes them in his complaint:

On March 14, 2014, Bondi held an event at the Mar-a-Lago Club in Palm Beach, Florida, in which she solicited campaign contributions in support of her campaign to be re-elected to be the Florida Attorney General.

[Fifty] or more individuals attended this event, including Trump. The minimum contribution to attend the event was $3,000 per person.

The Mar-a-Lago Club is a private club in Palm Beach located on 20 acres of gardens with ocean views. In includes an enormous mansion, beach, pool facility, spa and fine dining.

Space at the resort is expensive to rent. Trump has charged his own presidential campaign roughly $140,000 per event for use of the mansion.

The value of using the Mar-a-Lago Club for Bondi’s fundraising event was approximately $15,000 or more. The value of the use of the venue, the service of drinks and other amenities could not reasonably be less than $300.00 per person. The value of Trump’s attendance at this event was a service that further increased the value of the in-kind gift above $15,000.

In light of the $140,000 that Trump paid for use of the venue for his own events, it is highly likely that the value of the in-kind gift was far in excess of $15,000. As a professional entertainer, the value of Trump’s attendance was at least $25,000. The total value of the in-kind services provided to Bondi was over $40,000.

How do the numbers add up, and what do they mean? Larrabee sums it up:

Donald J. Trump and The Trump Organization made an in-kind contribution to Bondi by allowing her to use the club, its liquor and dining services, and its other amenities for the fundraising event. In-kind contributions are gifts of goods or services, other than monetary gifts.

The Republican Party of Florida paid only $4,855.65 for use of the Mar-a-Lago Club on March 14, 2014.

Bondi received an in-kind contribution from Donald J. Trump and The Trump Organization of approximately $35,144.35 or more. This is the difference between the $4,855.65 paid by the Republican Party for use of the facility and the $15,000 minimum actual value of the use of Mar-a-Lago resort together with the $25,000 entertainment value for Trump’s attendance.

In filings with the Florida Division of Election, Bondi failed to report the $35,144.35 in-kind contribution from Trump and The Trump Organization.

How does this edge toward unlawful activity? Larrabee explains:

In-kind contributions are subject to the same limits as are cash contributions under Florida law.

Florida Statute, 106.08, provides in relevant part:
Contributions; limitations on.—
(1)(a) Except for political parties or affiliated party committees, no person or political committee may, in any election, make contributions in excess of the following amounts: 
1. To a candidate for statewide office or for retention as a justice of the Supreme Court, $3,000.

By contributing more than $35,000 to Bondi, Donald J. Trump and The Trump Organization violated Florida Statute, 106.08(1)(a)(1) and other applicable provisions of Florida Statute 106.08.

Aside from its obvious national implications, this story has special ties to Alabama, as we noted in an earlier post:

How do Alabama and Jessica M. Garrison enter the picture? Until January of this year, the Birmingham-based Garrison was senior advisor to the Republican Attorneys General Association (RAGA) and the affiliated Rule of Law Defense Fund (RLDF). Before that, she was executive director of RAGA and President of (RLDF). Why has Garrison backed away from RAGA and its affiliated groups? That's a post for another day, but it's curious that Bondi is a major figure in RAGA -- and she has been at the heart of several controversies.

In fact, a major part of Garrison's job at RAGA apparently was to defend Bondi, who serves on the organization's executive committee as immediate past chair.

When Bondi was criticized in the Florida press for her cozy relationship with out-of-state lobbyists and corporate lawyers, Garrison came to her defense. . . .

Did Garrison break ties with RAGA earlier this year because she knew the Trump-Bondi story was a bombshell that could explode at any moment? If someone heeds calls for an investigation of the matter, perhaps we will find out.

Whitfield Larrabee, of Massachusetts, might be just the guy to do it.

Larrabee is pushing for prompt action, based on these words from his complaint:

The complainant requests the Florida Elections Commission expedite the investigation of this complaint. Said investigation is urgent because this complaint concerns the corruption of the elected and presently serving Florida Attorney General by the candidate nominated by the Republican Party to be President of the United States. Corruption of this nature interferes with the functioning of the governments of Florida and of the United States and undermines the public’s confidence in our democratic institutions.


Anonymous said...

Thanks for staying on top of this story, Mr. Schnauzer. Pretty impressive for a "little Alabama blog."

Anonymous said...

I don't think Trump gives a damn about the law. He's totally ignorant about it.

Anonymous said...

Jessica Garrison considers it a "ridiculous little blog," @12:25. No wonder. It could bring her young ass down.

Anonymous said...

How could the Bondi Trump thing be a one off? Trump was planning to run for years.

Here is another example of the RAGA possibilities:

Additional research:

Search "RAGA" and "David Rivkin"

Anonymous said...

Anonymous said...

Bill Pryor founded RAGA, so it's no surprise that it's tied to sleaze.

legalschnauzer said...

Thanks for sharing that URL, @1:11. The article seems to give plenty of reasons why it is best not to elect ideological ding-a-lings like Pam Bondi and Luther Strange as state AGs. These positions come with the power to affect national policies, and we need to elect capable, intelligent people, not knuckle-draggers.

Also Jessica M. Garrison, with her limited intellect and sub-zero ethics, has no business being involved at all.

legalschnauzer said...

This is from another URL provided by @1:11 (many thanks):

"Fossil fuel giants Murray Energy and Southern Company paid for meetings with Republican attorneys general to discuss their opposition to the Clean Power Plan less than two weeks before the same GOP officials petitioned federal courts to block the Obama administration's signature climate proposal, according to private emails (see below) from state attorneys general obtained by the Center for Media and Democracy. The meetings took place at an August 2015 summit hosted by the Republican Attorneys General Association (RAGA) in West Virginia, where attendees were offered the opportunity to meet with GOP attorneys general in exchange for financial donations to help reelect the Republican state prosecutors.

Confidential documents also reveal that some of the GOP attorneys general again discussed "the future of the fight to stop the Clean Power Plan" at a meeting of the Republican Attorneys General Association's 501(c)(4) organization, the Rule of Law Defense Fund, this past April. . . .

An attendee list for the 2015 summer conference also included representatives from Koch Industries, American Fuel & Petrochemical Manufacturers (AFPM), American Coalition for Clean Coal Electricity (ACCCE), American Chemistry Council, America's Natural Gas Alliance (ANGA), Devon Energy, Edison Electric Institute, Georgia Power, National Mining Association, NextEra Energy, Nuclear Energy Institute, Troutman Sanders, U.S. Chamber for Legal Reform, the State Policy Network and Peabody Energy.

According to materials reviewed by CMD, since 2015 RAGA has received at least $100,000 from ExxonMobil, $350,000 from Koch Industries, $85,000 from Southern Company, $378,250 from the American Coalition for Clean Coal Electricity (ACCCE), and $250,000 from Murray Energy. In total, fossil fuel interests, utilities and their trade groups have given more than $2.25 million to RAGA since 2015."

Anonymous said...

Looks pretty clear that RAGA exists only to serve as corporate whores.

Anonymous said...

What role might Pam Bondi play in a Trump admin?

e.a.f. said...

electing A.G.s as a separate position just opens the position up to things as described in this article. In my opinion an A.G. ought to be non political. It might be better if each legislature appointed an A.G. from amongst those elected to the legislature, with specific qualifications for the job and then operate outside of the political quagmire. It might be best if it were an independent arm of the legislature. How can the law be applied if it is politically influenced.

Nice coverage by your blog on the subject. There may not be enough time for this to have an impact on the federal election, but one can hope. Trump as President would not be a good thing for those of us sitting on either side of the American borders.

legalschnauzer said...

Agreed, e.a.f. In the U.S. you have the Democratic Attorneys General Association (DAGA), Republican Attorneys General Association (RAGA), something like Western States Attorneys General Association (WSAFA, not sure I have that name exactly right), and National Attorneys General Association (NAGA). Ridiculous.

Anonymous said...

A Drummond is national committee woman for Republicans & the Democrats screwed Bernie over to have Clinton & the trail of bodies that follows her as their nominee. Can't imagine much scarier.

Anonymous said...

The cartoon of Governor "I put my hands on your married to someone else breasts" Bentley is a classic!

Alabama has a serious creepy clown issue. But it's not the ones hanging around in the woods scaring the kids that are the problem. It's the ones we elect into office.

Anonymous said...

"What role might Pam Bondi play in a Trump admin?"

Bimbo eruption... (apologies, it was just too great a temptation)!

Buddy said...

Check out "The Guardian" "BCAUAUSE SCOTT WALKER ASKED FOR IT" Your frvorite person is going down down down.😁

legalschnauzer said...

Thanks for sharing re: the Guardian's Scott Walker series of articles. Had not heard about them, but working my way through them now. Are you thinking Karl Rove could go down in this? For others who are clueless I was on this, here are a couple of key URLs to the stories:

Buddy said...

Yes I'm hoping he will go down. Digging through anything

Anonymous said...


The NY AG may force governance changes and may well seek to remove Trump and his family members from the board or require a majority of independent board members. The AG may also uncover other issues,” said Marcus Owens, a lawyer who once served as the director of the IRS’ Exempt Organizations Divisions, which oversees the nation’s charities and foundations.

"Other issues?" With a bunch of Trumps running things? Could be they've stumbled into a target rich environment with their warrants and subpoenas!

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