FEC 14-175 Kyle Alexander Bedran

Transcription

STATE OF FLORIJ)A
FLORIDA ELECTIONS COMMISSION
In Re: Kyle Alexander Bedran
TO:
Kyle Alexande1 Bed1an
1661 Riverside Avenue, Unit 412
Jacksonville, FL 32204
Case NQ.: FEC 14-175
Division of Elections
500 S B1onough St1eet, Room 316
Tallahassee, FL 32399
NOTICE OF HEARING (INFORMAL HEARING)
A hearing will be held in this case before the Florida Elections Commission on May 20, 2015, at 8:30 am, or as soon
thereafter as the parties can be heard, at the following location: Department of Bnsiness and Professional Regnlation, 1940
North Monroe Street, Tallahassee FL 32399.
Failure to appear in accordance with this notice will constitute a waiver of your right to participate in the hearing
Continuances will be granted only upon a showing of good cause
This hearing will be conducted pursuant to Section 10625, Florida Statutes, which governs your participation as
follows:
If you are the Respondent, you may attend the hearing, and you or your attorney will have 5 minutes to present your
·
·
·
·
eeommeflclatieas fer Re prebabl~--+
cause are being considered) may be decided by an en masse vote and, unless you request to be heard or the Commission
requests that your case be considered separately on the day of the hearing, your case will not be individually heard
--""ease to the Connnission. Ilovveve1,
If you are the Complainant, you may attend the hearing, but you will not be permitted to address the Commission In
addition, some cases (including those in which consent orders or recommendations for no probable cause are being considered)
may be decided by an en masse vote and, unless the Respondent requests to be heard or the Commission requests that the case
be considered separately on the day of the hearing, the case will not be individually heard .
If you are an Appellant, and you have requested a hearing, you may attend the hearing, and you or your attorney will
have 5 minutes to present your case to the Commission.
Please be advised that both confidential and public cases are scheduled to be heard by the Florida Elections
Commission on this date As an Appellant, Respondent or Complainant in one case, you will not be permitted to attend the
hearings on other confidential cases
The Commission will electronically record the meeting. Although the Commission's recording is considered the
official record of the hearing, the Respondent may provide, at his own expense, a certified court reporter to also record the
hearing.
If you require an accommodation due to a disability, contact Donna Ann Malphurs at (850) 922-4539 or by mail at 107
West Gaines Street, The Collins Building, Suite 224, Tallahassee, Florida 32399, at least 5 days before the hearing
See further instructions on the reverse side
}I.my :MCJ(fter;er'l'oman
Executive Director
Florida Elections Commission
May 5, 2015
NOH
FEC#I4-!75
Please refor to the information below for further instructions related to your particular hearing:
If this is a hearing to consider an appeal from an automatic fine, the Filing Officer has imposed a fine
on you for your failure to file a caI11paign treasurer's report on the designated due date aJJd, by filing aJJ appeal,
you have asked the Commission to consider either (1) that the report was in fact timely filed; or (2) that there
were unusual circumstaJJces that excused the failure to file the report timely You are required to prove yow
case If the Commission finds that the report was filed timely or that there were unusual circumstaJJces that
excused the failwe, it may waive the fine, in whole or in part The Commission may reduce a fine after
considering the factors in Section 106.265, Florida Statutes.. If the Commission finds that the report was not
timely filed and there were no unusual circumstaJJces, the fine will be upheld
If this is a hearing to consider a consent order before a deter·mination of probable cause has
been made, the Commission will decide whether to accept or r"ject the consent order.. If the Commission
accepts the consent order, the case will be closed aJJd become public. If the Commission rejects the consent
order or does not make a decision to accept or deny the consent order, the case will remain confidential, unless
confidentiality has been waived .
If this is a hearing to consider a consent order after a determination of probable cause has been
made, the Commission will decide whether to accept or reject the consent order If the Commission accepts
the consent order, the case will be closed.. If the Commission r"jects the consent order or does not make a
decision to accept or deny the consent order, the Respondent will be entitled to another heaiing to determine if
the Respondent eonunitted-the-violatto·nf!>J-a~geet.-------------------------jIf this is a probable cause hearing, the Commission will decide if there is probable cause to believe that
the Respondent committed a violation of Florida's election laws.. Respondent should be prepaied to explain
how the staff in its recommendation inconectly applied the law to the facts of the case . Respondent may not
testify, call others to testify, or introduce any documentary or other evidence at the probable cause hearing
The Commission will only decide whether Respondent should be charged with a violation and, before the
Commission determines whether a violation has occuned or a fine should be imposed, Respondent will have an
opportunity for another heaiing at which evidence may be introduced
If this is aJJ informal hearing, it will be conducted pwsuaJJt Sections 120569 and 120 57(2), Florida
Statutes; Chapter 28 aJJd Commission Rule 2B-L004, Florida Administrative Code.. At the heaiing, the
Commission will decide whether the Respondent committed the violation(s) charged in the Order of Prnbable
Cause The Respondent will be permitted to testify However the Respondent may not call witnesses to testify
Respondent may argue why the established facts in the Staff Recommendation do not suppmt the violations
chaiged in the Order of Probable Cause At Respondent's request, the Commission may determine whether
Respondent's actions in the case were willful The Respondent may also address the appropriateness of the
recommended fine If Respondent claims that his limited resomces make him unable to pay the statutory fine,
he must provide the Commission with written proof of his financial resources at the hearing A financial
affidavit form is available from the Commission Clerk
STATE OF FLORIDA
In Re: Kyle Alexander· Bedrnn
Case No.: FEC 14-175
MOTION TO DISMISS
COMES NOW, Petitioner, FLORIDA ELECTIONS COMMISSION (''Commission")
by and tluough undersigned counsel, and files this Motion to Dismiss and in support thereof
states the following:
1
On Febmary 25, 2015, the Commission found probable cause that Respondent
violated Section 106 . 0703(6), Florida Statutes, on two occasions
2
Under Section 106..0703(6), Florida Statutes, the treasurer of an electioneering
communications organization is requited to file a written report with the filing officer by the
prescribed reporting date that no reportable contributions or expenditures were made during the
reporting period .
3..
Respondent violated Section 106 . 0703(6), Florida Statutes, when he failed to
timely file written reports of the electioneering communications organization's lack of activity
du1ing the 2014 M2 and M3 reporting periods
4
Pursuant to Section I 06 . 0703(7)(b ), Florida Statutes, jurisdiction over late filed
reports lies with the filing office1 fo1 the imposition of fines as set forth in the fine schedule for
the late-filing of1eports by an electioneering communications organization
5
Therefore, it appears that the Commission does not have jurisdiction over this
matter
WHEREFORE, based upon the fo1egoing, the undersigned counsel requests this matter
be dismissed
Mot006 (9/05)
/
I.
Respectfully submitted on
A~t"' \ ~I 1-0 IS' by:
stfjjctb~g~
Fla. Bar No . : 71389
Assistant General Counsel
I 07 W Gaines Street
Collins Building, Suite 224
Tallahassee, FL 32399-1050
Phone Number: (850) 922-4539
Fax Number: (850) 921-0783
Stephanie .Cunningham@myfloridalegal com;
FEC@myfloridalegaL com
Copies fi.irnished to:
Stephanie L Cunningham, Assistant General Counsel
Kyle Alexander Bedran, Respondent
Division of Elections, Complainant
Mot006 (9/05)
(
FILED
15 MAR 20 AH 3: 5~
ST/lJE Of FLORlOA
STATE OF FLORII-Ji\:ECT!ONS COMMISSION
Florida Elections Commission,
Petitioner,
v.
Kyle Alexander' Bedran,
Respondent.
ORDER OF PROBABLE CAUSE
THIS MATTER was heard by the Florida Elections Commission (Commission) at its
regularly scheduled meeting on February 25, 2015, in Tallahassee, Florida
Based on the Complaint, Report of Investigation, Staffs Recommendation, and oral
statements (if any) made at the probable cause hearing, the Commission finds that there is
probable cause to charge Respondent with the following violation(s):
Count 1:
On or about March 10, 2014, Kyle Alexander Bedran violated
Section 106 0703(6), Florida Statutes, when he failed to timely
notify the filing officer in writing on the prescribed reporting date
that he would not be filing Florida Citizens for Smart Justice's
2014 M2 Report,
Count 2:
On or about April 10, 2014, Kyle Alexander Bedran violated
Section 106,0703(6), Florida Statutes, when he failed to timely
2014 M3 Report
P:/Order of Probable Cause docx (07/14)
f'ECCase# 14-175
/
I
DONE AND ORDERED by the F101ida Elections Commission on Febmary 25, 2015
Copies fornished to:
Stephanie J Culllingham, Assistant General Counsel
Kyle Alexander Bedian, Respondent
Division of Elections, Complainant
N()TTCEOFRIGHT TOAHEARING
As the Respondent, you may elect to resolve this case in several ways . First, you may elect to
resolve this case by consent Older where you and Commission staff agree to resolve the
violation(s)s and agree to the amount of the fine The consent order is then presented to the
Commission for its approval To discuss a consent order, contact the FEC attorney identified in
the Order of Prnbable Cause
Second, you may request an informal hearing held before the Commission, if you do not dispute
any material fact in the Staff Recommendation You have 30 days from the date the Order of
Prnbable Cause is filed with the Commission to request such a hearing The date this order was
filed appears in the upper right-hand corne1 of the first page of the order. At the hearing, you
will have the right to make written or oral arguments to the Commission concerning the legal
issues related to the violation(s) and the potential fine At the request of Respondent, the
Commission will considet and determine willfolness at an infotmal hearing.. Otherwise, live
witness testimony is unnecessary.
Third, you may request a formal hearing held before an administrative law judge in the Division
of Administrative Hearings (DOAH), if you dispute any material fact in the Staff
Recommendation. You have 30 days from the date the Order of Probable Cause is filed with the
Commission to request such a hearing. The date this ordet was filed appears in the upper righthand comer of the first page of the or det At the heating, you will have the tight to present
evidence televant to the violation(s) listed in this otder, to crnss-examine opposing witnesses, to
impeach any witness, and to rebut the evidence presented against you
If you do not elect to resolve the case by consent order ot request a formal hearing at the DOAH
or an informal hearing before the Commission within 30 days of the date this Order of Probable
Cause is filed with the Commission, the case will be sent to the Commission for a fotmal ot
infotmal hearing, depending on whether the facts are in dispute.. The date this ordet was filed
appears in the upper right-hand comet of the first page of the order.
Io request a hearing, please send a written request to the Commission Clerk, Donna Ann
P:/Order of Probable Cause docx (07 /14)
FECCase# 14·175
I
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Malphurs. The address of the Commission Clerk is 107 W . Gaines Street, Collins Building,
Suite 224, Tallahassee, Florida 32399-1050 The telephone number is (850) 922-4539. The
Clerk will provide you with a copy of Chapter 28-106, Florida Administrative Code, and other
applicable rules upon request No mediation is available
P:/Order of Probable Cause docx (07/14)
FECCase# 14-175
STATE OF FLORIDA
"
FLORIDA ELECIIONS COMMISSION
In Re: Kyle Alexander Bedran
TO:
Kyle Alexander Bedian
1661 Riverside Avenue, Unit 412
500 S Bronough Street, Room 316
I allahassee, FL 32399
NOTICE OF HEARING (PROBABLE CAUSE DETERMINATION)
A hearing will be held in this case before the Florida Elections Commission on February 25, 2015, at 8:30 am, or as
soon thereafter as the parties can be heard, at the following location: Senate Office Building, Room 110-S, 404 South
Monroe Street, Tallahassee, FL .32399.
Failure to appear in accordance with this notice will constitute a waiver of your right to participate in the hearing
Continuances will be granted only upon a showing of good cause
This hearing will be conducted pursuant to Section 106 25, Flolida Statutes, which governs your participation as
follows:
If you are the Respondent, you may attend the hearing, and you or your attorney will have 5 minutes to present your
case to the Commission However, some cases (including those in which consent orders or recommendations for no probable
cause are being considered) may be decided by an en masse vote and, unless you request to be heard or the Commission
requests that your case be considered separately on the day of the hearing, your case will not be individually heard
If you are the Complainant, you may attend the hearing, but you will not be permitted to address the Commission In
addition, some cases (including those in which consent orders or recommendations for no probable cause are being considered)
may be decided by an en masse vote and, urvless the Respondent requests to be heard or the Commission requests that the case
be considered separately on the day of the hearing, the case will not be individually heard.
If you are an Appellant, and you have requested a hearing, you may attend the hearing, and you or your attorney will
have 5 minutes to present your case to the Commission
Please be advised that both confidential and public cases are scheduled to be heard by the Florida Elections
Commission on this date As an Appellant, Respondent or Complainant in one case, you will not be permitted to attend the
hearings on other confidential cases
The Commission will electronically record the meeting. Although the Commission's recording is considered the
official record of the hearing, the Respondent may provide, at his own expense, a certified court reporter to also record the
hearing
If you require an accommodation due to a disability, contact Donna Ann Malphurs at (850) 922-4539 or by mail at I 07
West Gaines Street, The Collins Building, Suite 224, Tallahassee, Florida 32399, at least 5 days before the hearing.
See further instructions on the reverse side
(!nry :MCJ(eever 'l'oman
Executive Director
February 9, 2015
NOH
fEC #14-r7S
(_
STATE OF FLORIDA
In Re: Kyle Alexander Bedrnn
Case No,: FEC 14-175
STAFF RECOMMENDATION FOLLOWING INVESTIGATION
Pursuant to Section 10625(4)(c), Florida Statutes, undersigned staff counsel files this
written recommendation fo1 disposition of the refoIIal in this case recommending that there is
probable cause to chaige Respondent with violating Section 106.0703(6), Florida Statutes, and
that there is no probable cause to chaige Respondent with violating Sections 106.19(1)(c), and
106.070.3(1)(a), Florida Statutes. Based upon a thorough 1eview of the Report oflnvestigation
submitted on December 4, 2014, the following facts and law support this staff recommendation:
On July 10, 2014, the Flolida Elections Commission ("Commission") received a
1eferral from the Department of State, Division of Elections ("Division"), alleging that Kyle
Alexande1 Bed1an, t1easure1 for Florida Citizens for Sma1t Justice ("Respondent") violated
Chapter 106, Flo1ida Statutes
2
Florida Citizens for Smart Justice, an electionee1ing communications organization
("ECO"), filed its Statement of Organization form ("DS-DE I 03") on June 7, 2012, appointing
Respondent as its treasurer.. (ROI Exhibit 1, page 2) 1
3.
By Jetter dated Septembe1 23, 2014, the Executive Di1ecto1 notified Respondent
that Commission staff would investigate the following statutory p1ovisions:
Section 106.0703(6), Florida Statutes: As alleged in the complaint,
Respondent, Kyle Alexande1 Bed1an, is the l!easure1 for Florida Citizens
for Smart Justice, an electioneering communications 01ganization (ECO)
registered with the Division of Elections Respondent failed to timely
notify the filing office1 in writing that the ECO had no reportable activity
and, therefore, would not be filing a repo1t on the prescribed repo1ting date
fo1 each of the following repo1ting pe1iods:
•
•
2014 M2
2014 M3
Section 106.19(l)(c), Florida Statutes: As alleged in the complaint,
Respondent, Kyle Alexander Bedrnn, is the treasurer fo1 Florida Citizens
for Smart Justice, an electionee1ing communications organization (ECO)
registered with the Division of Elections Respondent falsely reported 01
deliberntely failed to include information required by Chapter 106, Florida
1
The Report of Investigation is referred to herein as "ROI"
Staff Recommendation FEC 14-175
(
Statutes, when he failed to file a report on the prescribed reporting date for
each of the following repo1ting periods:
•
•
2014 M2
2014 M3
Section 106.0703(l)(a), Florida Statutes: As alleged in the
complaint, Respondent, Florida Citizens for Smart Justice, an
electioneeiing communications organization (ECO), failed to
timely file the campaign treasurer's report[s] with the Division of
Elections that were due on March I 0, 2014 (M2) and April I 0,
2014 (M3)
•
•
2014 M2
2014 M3
4..
By lette1 dated June 15, 2012, Kristi Reid B1onson, Chief; Bmeau of Election
Reco1ds, sent Respondent a letter acknowledging that the Division had received the ECO's
Application fo1 Ce1tification and that the ECO was placed on the list of active electionee1ing
communications organizations . (ROI Exhibit 2, page I)
5..
The acknowledgment lette1 advised Respondent that all ECOs filing 1epo1ts with
the Division are requiied to use the electronic filing system ("EFS"), and p1ovided Respondent
with a use1 identification numbe1 and initial passwmd to grant access to the EFS . (ROI Exhibit 2,
page 1) The letter fmther advised Respondent that all of the Division's publications and
1ep01ting forms were available on its website and directed Respondent to piint out the 2012
Calendar of Reporting Dates as well as other 1elevant documents. (ROI Exhibit 2, page 3)
6
The ECO's 2014 M2 Report was due to be filed by March 10, 2014; however,
Respondent failed to timely file the repo1t or notify the filing officer that no repo1t would be
filed (ROI Exhibit 10) By letters dated March 11, 2014, March 24, 2014, and April 11, 2014,
the Division notified Respondent that the ECO's 2014 M2 Repo1t had not been 1eceived . (ROI
Exhibits 4 & 5) The April 11, 2014 letterwas confirmed delive1ed. (ROI Exhibit 5, page 2)
7
The ECO's 2014 M3 Repmt was due to be filed by April 10, 2014; however,
Respondent failed to timely file the report or notify the filing officer that no 1ep01t would be
filed. (ROI Exhibit 10) By letters dated Ap1il 11, 2014, April 25, 2014, and May 8, 2014, the
Division notified Respondent that the ECO's 2014 M3 Report had not been received (ROI
Exhibits 6 & 7) The May 8, 2014 letter was confirmed delivered (ROI Exhibit 7, page 2)
8
A subpoena was issued to the ECO's designated depository to ascertain whethe1
any financial activity occurred during the relevant coveiage periods. The ECO's most recent
bank statement dated Novembe1 I, 2012 th10ugh Novembe1 30, 2012, shows a credit for a
monthly service charge and a ze10 balance (ROI Exhibit 8, page 2) As it appears that the ECO
had no financial activity during the relevant coveiage periods, Respondent was 1equired to notify
the filing officer in writing that he would not be filing the ECO's 2014 M2 and M3 1eports on the
Staff Recommendation FEC !4wl7S
2
(
p1esc1ibed repo1ting dates, but failed to do so (ROI Exhibit 8) The1ewith, it does not appear that
Respondent falsely repo1ted or deliberately failed to include info1mation in the ECO's 2014 M2
and M3 repo1ts nor did he fail to timely file the repo1ts as the repo1ts were waived due to a lack
of repo1table financial activity.
9
Respondent stated that he believed that he did not take any fwthe1 action with
regard to the ECO's repo1ts because he 1eceived a Notice oflntent to Revoke fiom the Division
(Attachment A, Phone Log Ent1y 2) The notice states that the Division intends to revoke the
ECO's 1egistration due to the ECO's lack of aggregate repo1ted financial activity dming the 2013
calendar year, and provides the procedure for disputing the potential revocation. (Attachment B)
10
Respondent also stated that he moved and did not receive the fail me to file notices
from the Division Respondent stated that the ECO's bank account was closed in Octobe1 2012,
despite the fact that the ECO filed repo1ts during the 2013 and 2014 calendar yea1s Respondent
stated that the ECO decided to disband in August or Septembe1 2013 but did not send the
Division a letter requesting disbandment at that time (Attachment A, Phone Log Entry 2)
11.
The Division's History Notes show that the Division called Respondent multiple
times regarding his change of address beginning in November 2011. (ROI Exhibit 11) On
December 18, 2013, the Division 1eceived an amended DS-DE 103 which updated the ECO's
mailing address . (ROI Exhibit 3, page 1) The Division emailed Respondent copies of the failure
to file notices The Division, in iesponse to Respondent's May 29, 2014 email, told Respondent
that in 01der to disband the ECO the Division would need a letter requesting disbandment The
Division also notified Respondent that all outstanding 1epo1ts, including the 2014 M2 and M3
1epo1ts, must be filed regaidless of Respondent's intent to disband the ECO (ROI Exhibit 11)
On August 21, 2014, the Division 1eceived the ECO's lette1 requesting disbandment (ROI
Exhibit 12, page 1)
12..
Respondent untimely notified the Division on Octobe1 22, 2014, 226 days afte1
the 2014 M2 Report was due, and 195 days afte1 the 2014 M3 Repo1t was due that he would not
be filing the ECO's 2014 M2 and M3 repmts . (ROI Exhibit 10)
13
"Pwbable Cause" is defined as reasonable grounds of suspicion suppo1ted by
circumstances sufficiently strong to wairant a cautious pe1son in the belief that the person has
committed the offense charged. Schmitt v State, 590 So 2d 404, 409 (Fla. 1991) P1obable
cause exists where the facts and circumstances, of which an [investigato1] has reasonably
trustwo1thy info1mation, are sufficient in themselves fo1 a reasonable man to reach the
conclusion that an offense has been committed Department of Highway Safety and Motor
Vehicles v Favino, 667 So 2d 305, 309 (Fla . I st DCA 1995)
14
The facts set forth above show that Respondent was the t1easme1 of Flmida
Citizens fo1 Smart Justice, an electioneering communications mganization registe1ed with the
Division. Respondent failed to timely file the ECO's 2014 M2 and M3 1epo1ts 01 notify the filing
office1 that no 1epo1ts would be filed. It appea1s that the ECO had no financial activity during the
2014 M2 and M3 repo1ting coverage periods, and therefore Respondent was requiied to notify
the filing officer in writing that he would not be filing the ECO's 2014 M2 and M3 1epo1ts on the
3
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prescribed reporting dates.. Therewith, it does not appear that Respondent falsely reported or
deliberately failed to include information in the ECO's 2014 M2 and M3 reports nor did he fail
to timely file the reports as the reports were waived due to a lack of reportable financial activity.
Based upon these facts and circumstances, I recommend that the Commission find no
probable cause to charge Respondent with violating Sections 106J9(1)(c), and 106.0703(1)(a),
Florida Statutes, and find probable cause to charge Respondent with violating the following:
Count 1:
On or about March 10, 2014, Kyle Alexander Bedran violated
Section 106 .0703(6), Florida Statutes, when he failed to timely
2014 M2 Report.
Count 2:
On or about April 10, 2014, Kyle Alexander Bedran violated
Section 106.0703(6), Florida Statutes, when he failed to timely
2014 M3 Report
Respectfully submitted on January
I?", 2015
Assistant General Counsel
I reviewed this Staff Recommendation
4
this~
of January 2015
PHONE LOG
CaseNo.: FECl4-175
Respondent: Kyle A . Bedran
Complainant: Division of Elections
1
Date and time: September 25, 2014; 2:36 p . m
Name: Respondent
Phone#: 904-502-3327
Summary: There was no answer; I left a voicemail asking R to return my calL I was
calling to discuss referral and ask whether R intended to submit bank documents as per his
email dated 9/10/14
Memo to File? No
Enter·ed by: ta
2
Date and time: September 25, 2014; 3:42 pm
Name: Respondent
Phone #: returned my call
Summary: I introduced myself as the investigator assigned to investigate the referral from
the Division that he failed to file the ECO's M2 and M3 reports I asked R if he intended
to submit bank records as he had indicated in his e-mail; he stated yes.. R explained that he
mistakenly thought he didn't have to do anything further when he received the notice of
intent to revoke from the Division. R further stated he recently moved and did not receive
the fuilwe to file notices from the Division R stated the ECO's bank account was closed
in October 2012; however, he kept filing waivers in 2013 because he wasn't swe they were
going to continue operating R stated it was decided in August or September 2013 to
disband the ECO . I asked R why he didn't submit a disbandment letter to the Division; he
replied he didn't know he had to. I asked R if he recalled his May e-mail to Donna Brown
in which Ms . Brown told him to send a disbandment letter and informed him that he was
still required to file the reports. R acknowledged he had communicated with Ms Brown
but stated he didn't remember the specifics of the e-mails I asked R if he had read
Chapter 106, Florida Statutes and/or the Handbook. R stated he believes he read "some"
of it R stated he was hospitalized last November and was incapacitated and back and forth
to the doctors and offered to submit doctors notes R agreed to submit bank account
records within two weeks and to file the outstanding reports within a week. R asked if he
could delay sending his medical records until he sees how the case is progressing I asked
R to contact me if he has trouble filing the outstanding reports or if he can't get the bank
records within two weeks
Memo to File? No
Entered by: ta
3.
Date and time: October 22, 2014; 4:33 p.m.
Name: Respondent
Phone #: called me
Summary: R stated he hasn't been able to get his PIN to file the reports.. I suggested R
call the Division and stated they may have a form for R to complete so he could request his
lnvOOI (10/07)
I'
PIN. I also acknowledged receiving R faxed bank documents R stated the lette1
confitming that the bank account is closed because his address is different than when he
opened the account R stated he would tiy again to get the letter and the repo1ts filed .
Memo to File? No
Entered by: ta
4
Date and time:
Name:
Phone#:
Summary:
Memo to File? No
Entered by:
5.
Date and time:
Name:
Phone#:
Summary:
Memo to File? No
Entered by:
6
Date and time:
Name:
Phone#:
Summary:
Memo to File? No
Entered by:
7
Date and time:
Name:
Phone#:
Summary:
Memo to File? No
Entered by:
8.
Date and time:
Name:
Phone#:
Summary:
Memo to File? No
Entered by:
9
Date and time:
Name:
Phone#:
Summary:
Memo to File? No
Entered by:
INVOOI (12/01)
2
I'
FloRIDA DEPARTMENT
RICK SCOTT
Governor
ofSTATE
KENDETZNER
Secretary of State
January 17, 2014
Kyle Alexander Bedian, Registered Agent
Florida Citizens for Smart Justice (59846)
1661 Riverside Avenue #412
RE: NOTICE OF INTENT TO REVOKE
Dear· Mr Bedran:
Pursuant to Section 106 03(7), Florida Statutes, you are hereby notified of the Division's intent
to revoke your committee's registration as an electioneering communications organization based
on the following:
The organization's aggregate reported financial activity during the 201.3
calendar· year was less than $5000 .
If you o~ject to this revocation you must provide documentation showing that the organization's
registration should not be revoked. Documentation must be provided within 30 days of the date
of this letter to the Department of State, Division of Elections, Bweau of Election Records, The
RA Gray Building, Room 316, 500 South Bronough Street, Tallahassee, Florida 32399·-0250 .
lfyou have any questions, please call (850) 245-·6280.
Sincerely,
-1,,(
. J--::V
·~
- . l /\.--<-:.. -::;-.\~"" '"'P-'
Kristi Reid Bronson, Chief
Bureau of Election Records
KRB/slb
Enclosure
~
VIVA flORIOA500.
R.A. Gray Bldg .., Rm. 316 • 500 S Bronaugh St.• Tallahassee, Florida 32399-0250
Telephone: 1850) 245-6240 • Facsimile: (850) 245·6259 elections.myflorida .. com
Commemorating 500 years of Florida history
www . fla500.com
)t_
VIVA flORIDA500
JS ·2..021 Revocation of Registr atlon of Political Committees and Electioncer·ing Communic·ations Organizations
(1) f)cfinition: "'Mo:;l recent address on file ... means, as applicable, the l~st addr~ss pro-.ided in a \vtitten statement ol change tl)
the Ii ling ofticcr for the registered agent pursuant to Section l06 022 .. l· S., or the last address pnlvided to the filing officcl' for lhe
committce"s chairper~on or ()rgani7ation'·s top-ranking official us contained in the statcmc.:·nt of <1rgani7.ation or in an) \\ritt~n
statement of change to the statement ol organization madi.: pursuant to Section I 06.03. 1: S.
12) Conduct \\·airanting ri;·\ocution . The 111ing otncer .shall re\.oke the registration o!' a political cnmmittee (hereinafie·r
co1nmittee) 01 an e·lectione<!ring communication5 nrganb·ation (hereinuHer organiuHit)n} for line or more of the follo\\ing reasons:
<a) The Ct1n1mittee or org.anitatinn tiiils l~l maintain a 1·eg\s1ered ~'rfice· and a registeted agent as required by Se~til)n 106 022 .
I S;
(b) 1 he committee or lHganitation IUils h) li!c the appointment o! a successor within 10 Ja)S aner the· death . resignation or
removal ot its treasurer;
(<.:) fhc commitk·c fhils to file· the appointmc·nt of' a successor \\"ithin 1() da)S afkt the death. rcsignution or n:mo\al ol its
chairperson:.
(d) l he committee or organization t'Uils to tile treasurers reports fOr more than 6 m(inths:
te) 1 he eommittee'·s uggregate report~d financial activit; during the calendar) ear is less than $500 unless the committee is onl)
re·gistered und required to repon as the sponsor ol a proposed c·onstitutional amendment hy initiative \vho intended to sc·ek the
signatures of rc::gistered \.Oters;
(f) I h~ org.~nll',a.tion 's a~g1 !.!g.1·att.: rcponcJ financial acti\ity du1·\ng, th1: caknd;.u ) ear b $5000 o\ le!is:
(g} I ht: orgttnitation Jltils to file thl.." Hppointmcnt of a succr.:ssor ""ithin 10 da;s alter the death. resignation or removal of its top ..
ranking rrindrat olfict.:r:
01'
(h) ·1 he corn1nittcc rn orgunil'ation has an 11npaid fine or dvil penah) imposc'l.l under ( h(.lpt1.:'f 106. i: S., which has becon)I! final
O)C·eining al! itppcals reg~rJing the imposition ol lhc line or civil pcnalt; hu' c bcl!ll c·;..ht\\.Jskd OJ' tht· time !hr sut:h app(.:als ha::;
pas::.cd
( l) Re' ot:ation proci!dun.:s
(a) I he· fl ling of'licer shall not it) the comrnittct:"s chairpcrson or organization ·stop-ranking principul o!fi<.:c1 and its n:·gistercd
agent of the intent to r<:\okc the registration and the tUcts ~nd conduct \vhit:h \\airant the intended revocation !o the most recent
address on file fOr both the chairperson 0r top-1anking prin<:·ipal officer, us applh:ahle and n.:gi~tt:red agenl The committee or
organi/.ation has 30 da) s from the date of lhe initial notice to pro\ ide addition~\\ d{)cumentati0n to the filing ~)('ficer showing that the
con1mittee s or organii'.ation 's registration should not he· re\oked
(b) Alier the 30-da) deadline to pro\idc additional inflHmation. the !iling ofticcr shall n!\icw all inf01mation and determine
Vlht.:thc·t th<..'· r(!gi:.tration should be l'C\Okt.:
I II the filing ol'ficcr dctc·rmincs that the registration ~hliu!d not be re\okcd. thtJn the filing of'ficcr shal! send notilil!ation to the
most rt.:i.:<.:nt address lln file tOr the comrnlncl.!'s chai1pc1son <it <Hganization's t<.,p-1anki11.g principal oflicet as. applicable, and
rcgistc;rcd agent
2 If the filing officer Jetcrn1inc5 thut the 1c·gi~u.:ition should he rc\okcd. then the filing otficcr shall send u final notice of intent
to re\{)k<! to the n10st recent address on lile foi the committee's chairperson or organiL:ation·s top .. ranldng principul officer. as
-lpptit.:ahle·. and rc·gistered agent
(C) II the ini1ial notice 0f intent ti) re·\ nke i~ returnet.I as undelivc1ahl~ fr1Hn both the l!On1n1ittee' s chairperSl)n or organization·~
t(>p~ranking plincipal o!'li<.:cr Ht1d it~ rcgisten.:d agc·nt.. us applk·able and the comn1ittcc or organization h'1s no! pr(Jddc·d an updated
<;1ddrc·ss to the filing oflit:er aflt:1 th<: Hling ofJiccr :;ent the· initial notice . then th~ Ji!ing ~)J'ficcr n1a; r~voke tht re·gistnHion ol thc
comtnittee or organii•at'ion as applic~hle The· final orde·1· of revocation shall he sent to the regi5tered agent'~ 1nost rt!·cen! address on
file, notwithstanding that !he final order u! rc-.ocation rna) again be rctun1cd as undeli\c::rablc JI the· com1nittce \)!" orgunization
pro\idcd un updattd udJrcss lo the filing olfice1 afti.!r the filing ofHccr sent the· initial notice v.hich v.·as returned undeli\Crabk.·. then
the filing of'li<.:cr v.ill pro\ i<lc an initial notice of the· intc·nt t() revoke lo the n1ost rccc·nt addr~ss un lik; thereafter the filing officer
:-;hall IOlkn., the proec·durl!s in this 1uk
(4) /\ppcals
(U) /\ con1mitle~ 01 organization may appeal a final n~nicc ol intent tu ic\okc· \\ithin 30 duys ot the date or suc:h linal notic~ I he
appe-u\ nia) he acc(1rnpanh:··d by any <locun1entation 0r evidence :;:upporting, the ~laim f h<: appeal must be filed \\ilh the filing of'ficer
!'he Ii ling olticcr \\i\l lhr\\'~rd tht· apreal to the· Florida Elections C.on1mission
{b) I ai!urc to time!; lilc an appeal as dcsc·libcd herein shtlll Cllnstitute a \vai\'Cr utan) suc·h entitlement
(c) A Cl1mn1ith:·t.• or organi1.atiun desil'ing a hearing bcH.lrc::· the flolida f:lections Commission must include in the app"al a
M:pa1atc 1equ<:st tbt h1~"r\ng.
(d) Appeals undt:-r this ruh: arc exc1npt fro1n the cont1dcntialit) provisions of Section 106 25 . I; .S
Rulemak.utg 1ut/Jorir) }lJ l0f3J 'Ji Of 2r/J 10603f7J {(16 22(<JJ fS l uw fmplt>·m~iuc·d 106 fJ.3 FS H1'~IOY)' i\rw .? .. 2S .. 9<J. Amtnded J0 ..29-03 J J•.
15-09
~ .. ]710 /(J ..lO
/3
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REPORT OF INVESTIGATION
Case No.,: FEC 14-175
Respondent: Kyle A. Bedran
Complainant: Division of Elections
Pursuant to Section 106 25, Florida Statutes, on July 10, 2014, the Florida Elections
Commission received information from the Division of Elections alleging that Respondent
violated Chapter 106, Florida Statutes The Division's referral was mandated pursuant to
Section 106 .0703(7)( d), Florida Statutes Commission staff, therefore, investigated whethe1
Respondent violated the following statutes:
Section 106 ..19(1 )(c), Florida Statutes, prohibiting a person or
organization from falsely reporting or deliberately failing to rep01t
information required by Chapte1 106, Florida Statutes; and
Section 106 .0703(6), Florida Statutes, failure of the treasure1 of an
electioneering commUI1ications organization that did not receive
any contributions or make any expenditures during a reporting
period to notify timely the filing officer, in writing, that no
reportable contributions or expenditures were made during the
reporting period
I.
Preliminary Information:
1.
Respondent was the chairpe1son and treasurer fo1 Florida Citizens for Smait
Justice, an electionee1ing communications organization that was registered with the Division of
Elections Florida Citizens for Smart Justice was disbanded on August 22, 2014.
2..
3
Records .
Complainant is the Division of Elections
Respondent's filing officer is Klisti Reid-Bronson, Chief, Bureau of Election
4
On June 7, 2012, Flo1ida Citizens for Smart Justice (ECO) filed an Electioneering
Communication Statement of Organization (DS-DE 103) form with the Division of Elections
The ECO's area, scope and jurisdiction are listed as "Organization to promote Smait Justice, as
defined by Florida Taxwatch, by suppo1ting Judicial Candidates who stand for Smart Justice."
The form also lists Respondent as treasurer and chairperson of the ECO Io view a copy of the
DS-DE 103 form, please refor to Exhibit 1.
5..
On June 15, 2012, Ms Bronson sent Respondent a letter acknowledging Florida
Citizens for Smart Justice had been placed on the active ECO list The lette1 advised Respondent
that all ECOs filing reports with the Division aie required to use the electronic filing system
(EF S). Respondent was provided a user identification number and initial password allowing him
access to the EF S
Inv002 (7 /08)
1
6
The letter also advised Respondent that all of the Division's publications and
reporting forms are available on their website, including Chapter 106, Florida Statutes, the
Electioneering Communications Organization Handbook, and the Calendar of Reporting Dates
The letter fi.uther advised Respondent that it was his responsibility to read, understand, and
follow the requirements of Flmida's election laws Io view a copy of the acknowledgement
letter, please refor to Exhibit 2
7.
On December 18, 2013, Respondent filed another DS-DE 103 form changing the
ECO's mailing address. To view a copy of the DS-DE 103 form filed on December 18, 2013,
please refer to Exhibit 3
8..
On March 11, 2014, the Division sent Respondent a letter informing him that the
ECO's report due March 10, 2014 (2014 M2) had not been received; a second failure-to-file
letter dated March 24, 2014 was also mailed to Respondent Both letters were mailed to
Respondent at the address provided on the ECO's DS-DE 103 form filed on December 18, 2013
(Exhibit 3).. Io view copies of the letters, please refer to Exhibit 4 .
9
On April 11, 2014, the Division sent Respondent a letter marked "Final Notice"
stating the ECO's 2014 M2 Report had not been filed.. Copies of the failure-to-file letters
previously provided as Exhibit 4 were included with the Final Notice.. The Final Notice was
mailed to Respondent at the address provided on the ECO's DS-DE 103 form filed on December
18, 2013 (Exhibit 3), and was delivered on April 15, 2014 Io view copies of the Final Notice,
without attachments, and delivery confirmation, please refor to Exhibit 5
10
On April 11, 2014-under separate cover-the Division sent Respondent a letter
informing him that the ECO's repmt due April 10, 2014 (2014 M3) had not been received A
second failure-to-file letter dated April 25, 2014 was also mailed to Respondent. Both letters
were mailed to Respondent at the address provided on the ECO's DS-DE 103 form filed on
December 18, 2013 (Exhibit 3) Io view copies of the letters, please refor to Exhibit 6.
1L
On May 8, 2014, the Division sent Respondent a letter marked "Final Notice"
stating the ECO's 2014 M2 Report and 2014 M3 Report had not been filed Copies of the letters
previously pwvided as Exhibits 4, 5, and 6 were included with the Final Notice The Final
Notice was mailed to Respondent at the address provided on the ECO's DS-DE 103 form filed
on December 18, 2013 (Exhibit 3), and was delivered on May 12, 2014 Io view copies of the
Final Notice without attachments, and delivery confirmation, please refer to Exhibit 7
12
On July 10, 2014, the Commission received a refonal flom the Division alleging
that Respondent failed to report campaign activity during the 2014 M2 and 2014 M3 reporting
periods, or in the alternative, failed to notify the filing officer that no reports would be filed The
allegations will be discussed in the paragraphs that follow
IL
Alleged Violation of Section 106 ..19(l)(c), Florida Statutes:
13.
I investigated whether Respondent violated this section of election laws by failing
to report campaign activity during the 2014 M2 and 2014 M3 reporting periods.
14..
On November 18, 2014, I subpoenaed the ECO's campaign account records from
Bank of America, the campaign depository listed on their DS-DE 103 form (Exhibit !). In
Inv002 (7 /08)
2
response to the subpoena, Bank of America provided the ECO's monthly bank statements which
reflect the ECO's last financial activity was a monthly service charge refund in the amount of
$29.95, which occu11ed on November 13, 2012.. The refund brought the ECO's campaign
account balance to zero Io view a copy of the 1elevant campaign account records, please refer
to Exhibit 8.
15
Based upon the ECO's monthly bank statements provided in response to the
Commission's subpoena, it appears the ECO did not have any contributions or expenditures
during the 2014 M2 and 2014 M3 report cover periods 1 Therefore, it appears there was no
campaign activity for Respondent to report during the 2014 M2 and 2014 M3 reporting periods
16
No record of Respondent having previously violated this section of law was
found
Ill.
Alleged Violation of Section 106.0703(6), Florida Statutes:
17
I investigated whether Respondent violated this section of election laws by failing
to notify the filing officer, in writing, that no report would be filed for the 2014 M2 and 2014 M3
reporting periods
18
Io review the circumstances regarding the ECO's contribution and expenditure
activity, please refer to paragraphs 14 and 15 of this report
19
Section 106 . 0703(6), Florida Statutes, states:
"Notwithstanding any other provisions of this chapter, in any reporting period
during which an electioneering communications organi~ation has not received
funds, made any contributions, or expended any reportable fonds, the treasurer
shall file a written report with the filing officer by the prescribed reporting date
that no reportable contributions 01 expenditures were made during the reporting
period . "
20.
In an e-mail dated April 2, 2014, Ms. Brnnson was asked to clarify the procedure
regarding how to notify the Division in writing on the prescribed reporting date that no report
would be filed.. In her response, Ms Bronson stated, "The notice that no report will be filed is
the waiver, which must be filed in the EFS . We do not require anything separate in writing" Io
view a copy of Ms. Bronson's e-mail, please refer to Exhibit 9
21.
Based upon the ECO's campaign account records and Ms Bronson's e-mail,
because Respondent did not have any contributions or expenditures during the 2014 M2 and
2014 M3 reporting periods, it appears Respondent was required to notify the Division in writing
on the prescribed reporting dates that no report would be filed for the 2014 M2 and 2014 M3
reporting period, by indicating on the Division's EFS that there was no activity to disclose . The
notification that no report for the 2014 M2 reporting period would be filed was due March 10,
1
The reporting periods covered the petiod Februaty 1 through February 28, 2014 and March 1 through March 31,
2014. The subpoena requested all monthly bank statements from the opening of the account through the close of the
account It appeats the ECO's last campaign financial activity occurred on November 12, 2012 (Exhibit 8)
lnv002 (7/08)
3
2014; the notification that no 1eport fo1 the 2014 M3 repo1ting period would be filed was due
April 10, 2014
22..
According to the ECO's filing histo1y, Respondent filed the notifications that no
reports would be filed for both the 2014 M2 and 2014 M3 reporting periods on October 22,
2014 I able 1 summarizes when the notifications were due, when they were filed, and the
number of days the notifications were late. Io view a copy of the ECO's filing histo1y, please
refe1 to Exhibit 10
Report
Report Cover
Period
Date Notification
Due
Date Notification
Filed
Number· of' Days
Late
2014 M2
02/01/14-02/28114
03/10/14
10/22/14
226
2014 M3
03/01/14-03/31/14
04/10/14
10/22/14
195
23
No record of Respondent having p1eviously violated this section of law was
found
Conclusion:
24
I interviewed Respondent by telephone on Septembe1 25, 2014. Respondent
stated he mistakenly thought he did not have to do anything fmther when he received a notice of
intent to 1evoke fiom the Division 2 Respondent farther stated he recently moved and did not
receive the failme to file notices from the Division
25
Respondent explained that the ECO's bank account was closed in October 2012;
howeve1, he continued to file waive1s in 2013 on behalf of the ECO because he was unsme if
they we1e going to continue operating . Respondent stated it was decided in August 01 September
2013 to disband the ECO I asked Respondent if there was a reason he did not submit a
disbandment letter to the Division; he replied he did not know he had to
26
According to history notes provided by the Division, on May 29, 2014,
Respondent sent an e-mail to Donna S Brnwn, a Division employee, stating that the ECO "was
administratively dissolved last year," and they had 1eceived a letter from the Division stating the
ECO was to be ''te1minated." In the e-mail, Respondent also inquiied whethe1 f\.uther action was
necessa1y to te1minate the ECO.. The notes 1eflect Ms Brown replied to Respondent's e-mail on
May 30, 2014; in her e-mail, Ms Brown informed Respondent that the rule regarding financial
activity was being challenged and revocations are pending until a decision is made by the court
27..
In her e-mail, Ms . Brnwn also advised Respondent that the ECO was still active
and there were three outstanding reports the ECO needed to file including the 2014 M2 Rep01t
and the 2014 M3 Report Ms . B10wn requested that Respondent send a letter disbanding the
ECO, and emphasized that disbandment would not absolve the requirement of the ECO to file
2
On January 17, 2014, the Division sent Respondent a Notice of Intent to Revoke stating that the ECO's registrntion
as a electioneering communications organization was being revoked because the ECO's financial activity during the
2013 calendar year was less than $5,000
Inv002 (7 /08)
4
(
the outstanding 1epo1ts.. Io view a copy of the histo1y notes, please refor to Exhibit 11 .
28
When asked if he recalled the e-mail exchange with Ms . Brown on May 29 and
May 30, 2014 (Histo1y Notes, Exhibit 11), in which Ms . Brown requested a disbandment lette1
and info1med Respondent that the ECO was still required to file the reports, Respondent
acknowledged that he had communicated with Ms. Brnwn but stated he could not 1ecall the
specifics of the e-mails .
29
It is noted that Respondent faxed a letter disbanding the ECO to the Division on
August 21, 2014; the Division acknowledged the disbandment in a letter dated August 27, 2014
Io view copies of the lette1 s, please refor to Exhibit 12
30
Duling the telephone interview, Respondent was asked if he 1ead Chapter 106,
Florida Statutes and/01 the Electioneering Communications Organization Handbook
Respondent replied he believes he 1ead some of the Handbook. Respondent requested that the
Commission consider that he was hospitalized in November 2013, and has had recurring doctor's
appointments. Respondent offered to submit medical documents; however, he asked that the
submission of the documents be delayed until he "sees how the case is progressing . "
3L
All additional written statements submitted by Respondent are attached as Exhibit
13
Respectfillly submitted on December 4, 2014,
Trncie Aulet
Investigation Specialist
Cunent address of Respo'ndent
Current address ofComplalnant
ML Kyle A Bedran
612 South West Stieet
Greencover Springs, FL 32043
500 South Bronough Street
Na~e and Address of Filing Officer:
Ms Klisti Reid-Bronson, Chief
Bm eau of Election Recm ds
Copy filmished to: M1 David Flagg, Investigations Manager
Inv002 (7 /08)
5
REPORT OF INVESTIGATION
Kyle A. Bedran -- FEC 14-175
fcj~ • . . , ··~a ~ 9 ? rit .\·
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E'.xhibits #s
Description of Exhibits
Exhibit I
DS-DE 103 fo1m filed 617/12
Exhibit 2
Acknowledgement letter dated 6/15/12
Exhibit 3
DS-DE 103 form filed 12/18/13
Exhibit 4
Failure-to-file letters dated 3/11/14 & 3/24/14
Exhibit 5
Final notice dated 4/11/14
Exhibit 6
Failure-to-file letters dated 4/11/14 & 4125114
Exhibit 7
Final notice dated 5/8/14
Exhibit 8
Campaign account 1ecords, relevant pages
Exhibit 9
E-mail from K Brnnson dated 4/2/14
Exhibit IO
Filing histo1y
Exhibit 11
History notes
Exhibit 12
Letters regarding disbandment dated 8/21/14 & 8/27/14
Exhibit 13
Respondent's additional written statements
lnv004 (S/08)
r::-,.,,.. I
·. '·' • .e:-D
12 JUN-7 • :...
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A/19. 46
DIV/t; 1l. •; , .
SfCRff I.it lL .
ELECTIONEERING COMMUNICATION
STATEMENT OF ORGANIZATION
•
ARy o/§TIONs
TA re
(PLEASE lYPE)
OFFICE USE ONLY
1 . Full Name of Organization
Telephone
Florida Citizens for Smart Justice
904-502-3327
-
-·
----·
--
Mailing Address (include city, state and zip code)
1650 Margaret St Ste 302 PMB #147, Jacksonville, FL 32204-3869
-
..
Street Address (include city, state and zip code)
1661 Riverside Ave Apt 412, Jacksonville, Fl 32204
2 . Affiliated or Connected Organizations
Name of Affiliated or
Connected Organization
-·
Mailing Address
---·
·-
Relationship
..
M••·----'
None
3 Area, Scope and Jurisdiction of the Organization
Organization to promote Smart Justice, as defined by Florida Taxwatch, by supporting Judicial Candidates who stand
for Smart Justice.
4 . Identify by Name, Address & Position, the Custodian of Books & Accounts for the Organization
-
Full Name
Kyle Alexander Bedran
Mailing Address
Street Address
Title or Position
..
..
·-·
1661 Riverside Ave. #412 1661 Riverside Ave. #412 Treasurer
.Jacksonville, FL 32204
--
·-
5 . This Organization was formed (check applicable box): (Calendar quarters end the last day of March, June,
September, and December.)
Iii As a newly created organization during the current calendar quarter
D From an of'ganization existing prior to the current calendar quarter.
Fonn OS-DE 103 (Rev. 08110)
(continued on reverse)
EXHIBIT
l ~· \ t>t'Z
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6, List By Name, Malling and Street Address, & Position, Other Principal Officers, Including the treasurer and
deoutv treasurer. if anv. Include the ton..rankina officer's (e.a., chalroerso!!) name and information.
Full Name
Street Address
Mailing Address
-
·-
1661 Riverside Ave. #412 1661 Riverside Ave. #412
Jacksonville. FL 32204
Title or Position
Chairman
Treasurer
7. In the Event of Dissolution, What Disposition wilt be Made of the Residual Funds?
As provided by law
8. List All Banks, Safety Deposit Boxes, or Other Depositories Used by this Organization for Electioneering
Communications
-·-·
-·
Name of Bank or Depository
Mailing Address
---
·-. ··
·-·
2011 San Marco Blvd
Jacksonville, FL 3220'7
Bank of America
9. List All Reports Required to be Filed by this Organization with Federal Officials, & the Names, Addresses,
& Positions Of Such Officials, If Any
--·Report Title
Dates Required to be Filed
Name & Position of Official
Mailing Address
..
-t--·
-----Form 8871
Upon Formation
Internal Revenue Service
Atlanta, FA 39901-0099
Form 1120-POL
March 15th Annually
Form 990
May 15th Annually
Duval
STATE OF. Florida
I,,
COUNTY
· - · - - - · certify that the information in this Statement of
-
Organization is complete, true, and correct
~~:---;;.<:~
--of Top-ranking Principal Officer of Organization
Form OS-DE 103 (Rev. 08/10)-- page 2 of 2
·-
6 - !;". 11
Date
Note: If necessary, continuation sheets should be used to complete the form ..
EXHIBIT \
Pl\· 2 t>\''2
(
FLORIDA DEPARTMENT
of STATE-.
RICK SCOTT
KENDETZNER
Governor
Secretary of State
lune ! 5, 2012
Mr Kyle Alexander Bedran, Chairperson
I 650 Margaret Street, Suite 302
Jacksonville, Florida 32204-3869
Dear Mr Bedran:
This will acknowledge receipt of the Application for Ceriification for Flor'ida Citizens for
Smart Justice, which was placed on file in our office on .June 7, 2012 This information appears
to comply with the requirements of Section 106 011and106..03, Florida Statutes, and the name
of this organization has been placed on our active list as an electioneering communication
organization
Campaign Treasur!J::'s Repor!l!
Your first campaign treasurer's report will be due on July 13, 2012 The report will cover the
period of April 1, 2012 ··July 6, 2012. Al! electioneeiing communication 01ganization that file
repmts with the Division of Elections are required to file by means of the Division's electronic
filing system (E FS).
Cr·edentials and Sign-ons
Belo\\ is the web address to access the EFS and the organizations user identification numbc1
The enclosed sealed envelope contains the organization's initial password Once you have
logged in using the initial password, you will be immediately prompted to change it to a
confidential sign-on The chairperson, treasurer, and deputy treasurers are responsible for
protecting this password from disclosure and are responsible for all lilings using these
credentials . unless the Division is notified that your credentials have been compromised.
EFS Web site Addr·ess: https://efS.dos statefl us
Identification Number: 59846
)l
R A. Gray Building • 500 South Bronough Street • Tallahassee, Florida 32399-0250
Telephone: (850) 245-6240 • Facsimile: {850) 245-6259 www.dosstate.fl.. us
Commemorating 500 year.s of Florida history
www fla500 . com
VIVA llORIDI 500
EXHIBIT
'l ?~· \ ~ 3
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VIVI llURIDA500
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Mr Kyle Alexander l3edran, Chai1person
June 15, 201?
Page Two
Pin Numbers
Pin numbers are confidential secure credentials that allow you to submit repor1s and update
personal information The enclosed sealed envelope contains your confidential pin numbers for
you
Each electioneering communication organization chairperson is required to provide the Division
of Elections with confidential personal information that may be used to allow access in the event
that the password is forgotten or lost When you enter the organization's account screen, there
will be a drop down box where you pick a question (such as What i1 your mother 1 maiden
name') and supply an answer. All passwords and answers to questions are stored as encrypted
data and cannot be viewed by Division staff and given out over the phone Please notify the
Division if your credentials have been compromised.
All reports must be completed and filed through the EFS not later than midnight, Eastern
Standard Time, of the due date. Reports not filed by midnight, Eastern Standard Time, of the
due date are late filed and subject to the penalties in Section I 06 07(8), Florida Statutes. In the
event that the EFS is inoperable on the due date, the report will be accepted as timely filed if
filed no later than midnight, Eastern Standard Time, of the first business day the EFS becomes
operable No fine will be levied during the period the EFS was inoperable
Any electioneering communication organization failing to file a 1eport on the designated due
date is subject to a fine of $50 per day for the first 3 days and, thereafter, $500 per day for each
day, not to exceed 25% of the total receipts or expenditures, whichever is greater, for the period
covered by the late report However, for the reports immediately preceding each primary and
general election, the fine shall be $500 per day, not to exceed 25% of the total receipts or
expenditures, -whichever is greater, for the period covered by the late report
Electronic Receipts
The person submitting the report on the EFS will be issued an electronic receipt indicating and
the report was tiled. Each treasurer's report filed by means of the EFS is considered to
be under oath by the chairperson and campaign treasurer and such persons are subject to the
provisions of Section 106.07(5), Florida Statute
wrif~ing
EXHIBIT
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June !5, :2012
Page Three
Instructions and Assistance
An online instruction guide is available to you on the EFS to assist with navigation, data entry,
and submission of reports. The Division of Elections will also provide assistance to all users by
contacting the EFS Help Desk at (850) 245-6280
All of the Division's publications and repor1ing forms ar·e available on the Division of
Elections' web site at http://election.dos. state. fl.us.. It is your responsibility to read,
understand, and follow the requirements of Florida's election Jaws. Therefore, please print
a copy of the following documents: Chaptns 104 and 106, Florida Statutes, 2012
Electioneering Communications Organization Handbook, 2012 Calendar of Reporti11g Dates
and Rule lS-2 . 017, Florida Administrative Code.
Please let me know if you need additional information
Sincerely,
-~Kristi Reid Bronson, Chief
c_()
KRB/!jr
Enclosures
EXHIBIT
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(PLEASE TYPE)
OFFICE USE ONL.Y
1.
Telephone
Full Name of Organization
904 502-3327
--
-----
31 West Adams Street, Unit 1206. Jacksonville FL 32202
------
3l West Adams Street, Unit 1206, Jacksonville, FL 32202
2. Affiliated or Connected Organizations
--··-···-~
---·
Relationship
Mailing Address
--
None
3
Area, Scope and Jurisdiction of the Organization
Organization to promote Smart Justice, as defined by Florida Taxwatch, by supporting Candidates who stand for Smart Justice.
4., Identify by Name, Address and Position, the Custodian of Books and Accounts for the Organization
Full Name
-
Mailing Address
31 West Adams Street
Unit 1206
Jacksonville. Fl 32202
Street Address
Unit 1206
Jacksonville, Fl 32202
Form DS-DE 103 (Rev.. 10/12) - page 1 of 2
Title or Position
Treasurer
EXHIBIT
J W· tJ '2.
5.
List by Name, Malling and Stree>t Address, and Position, Other Principal Officers, Including the Treasurer
and Deputy Treasurer, If Any (Include the Top-ranking Officer's (e..g .. , Chairperson) Name and Information)
...
---·
f-·
Street Address
Mailing Address
Full Name
---- Title or Postlion
-
-~·~
31 West Adams Stteet
Unit 1206
31 West Adams Stteet
Unit 1206
Jacksonville. FL 32202
---
Chairman
Treasurer
6. Jn the Event of Dissolution, What Disposition will be Made of the Residual Funds?
As provided by law
7.
-·
List All Banks, Safety Deposit Boxes, or Other Depositories Used by this Organization for Electioneering
Communications
·-------·---··
Mailing Address
..
n/a
nla
No current funds
8.
Lisi All Reports Required to be Filed by this Organization with Federal Officials, and the Names,
Addresses, and Positions of Such Officials, If Any
•.
Report Title
Form 8871
Upon Formation
Form 1120-POL
March 15th Annually
Fonn 990
May l Sth Annually
STATE OF
Florida
Mailing Address
Atlanta GA 39901-0099
Duval
COUNTY
I,
-
certify that the information in this Statement
---
of Or ~e and correct
;.--
x
/
---,____...---·-
~)>~ranking Principal Officer of Organization
/2
·- 3 -13
-----····
Date
...~--Form OS-DE 103 {Rev . 10/12)- page 2 of 2
Note: If necessary, continuation sheets should be used to complete the form .
EXHIBIT
3 ~~- ?.. of Z.
(.
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\
FLORIDA DEPARTMENT OF ST ATE
Ken Detzner·
Secretary of State
DIVISION OF ELECTIONS
Maich 11, 2014
Kyle Alexander Bedran, Treasurer
Apt. 1206
Jacksonville, FL 32202-2202
Re: ECO 59846
Dear Mr. Bedran:
Your campaign treasurer's report, which was due March 10, 2014, has not been teceived
Sections 106 0703(7Xb), Florida Statutes, require that the filing officer immediately
notify you of the failure to file this report and that a fine will be assessed of $50 per day for the first 3 days
late and, thereafter $500 per day, although a fine cannot exceed 25% of the total receipts or expenditures,
whichever is greater, for the period covered by the late report. However, for the report immediately
preceding each primary and general election, the fine shall be $500 per day for each late day, not to exceed
25% of the total receipts or expenditures, whichever is greater, for the period covered by the late report.
Once your report is filed, this office will notify you of the specific amount of your fine Fines must be paid
to the filing officer within 20 days of receipt of the payment due notice
Please be advised, however, that failure to file a campaign treasurer's report may constitute a violation of
Chapter I 06, Florida Statutes, independent of the automatic fine violation referenced above. Therefore, if
you fail to file a report, the division will turn the matter over to the Florida Elections Commission
Section I 06 265( I), Florida Statutes, authorizes the Florida Elections Commission, to impose a civil
penalty up to $1,000 per count for each willful violation of Chapter I 06
If you have any questions, please contact the help desk at (850) 245··6280
Sincerely,
u~D.~~----~
k-Kristi Reid Bronson, Chief
\J
EXHIBIT
4 ¥~ \ £v\>z
The RA Gray Building-Room 316 • 500 South Bronaugh Street • I allahassee FL 32399·0250 • (850) 245··6240
FAX: (850) 245··6260 •
WWW Address: http://www.. dos.state.fl.us
• E'MaiL DivE/ections@)dos.stateflus
,.1--
FLORIDA DEPARTMENT OF STATE
Ken Detzner
Secretary of State
Second Notice
March 24, 2014
Florida Citizens for Smatt Justice
Apt. 1206
Jacksonville, FL 32202 -2202
Re: ECO 59846
Dear Mr. Bedran:
Your campaign treasurer's report, due March 10, 2014, has not been received
Sections 106 .0 703(7)(b), Florida Statutes, require that the filing officer immediately notify you of
the failure to file a report.
The first notice of the failure to file the above mentioned report was mailed, via regular mail, to the
address on file with our office on March 11, 2014. As of this date, we do not show a record of
receiving this report
If the report is not filed via the Division's electronic filing system within 14 days of receipt of
this notice, this matter will be referred to the Florida Elections Commission for further action,
Section 106.265( 1), Florida Statutes, authorizes the Florida Elections Commission, upon finding
a willful violation of Chapter 106, Florida Statutes, to impose a civil penalty up to $1,000 per
If you have any questions, please contact the help desk at (850) 245-6280.
Sincerely,
EXHIBIT
t\ y~· 2of Z
The RA Gray Building-Room 316 • 500 South Bronough Street • 'Tallahassee Fl 32399-0250 • (850) 245-6240
,.
I'
I
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1-l'!!'<>Owe~
FLORIDA DEPARTMEN_T
of ST!\~~
RICK SCOTT
KENDETZNER
Governor
Secretary of State
FINAL NOTICE - &CUSTOMER
USPSTRACKING#
Delivery Confirmation:
9114 9010 7574 2751 2916 32
For Tra.ddrrg or lnqulrlH go to USPS corn
RECEIPT
or call 1-800..222·1811
April 11, 2014
Kyle Alexander Bedran, Treasurer and Chairperson for
3 I West Adams Street, Apt 1206
Dear Mr. McDonald:
According to a review of the Division's records, the organization referenced above has not filed the following
report:
Year
Report
Cover Period
2014
M2
02/0112014 - 02/28114
The organization has previously been notified of the report that is outstanding Enclosed are copies of letters
sent by the Division. If the report is not filed within 7 days of receipt of this letter, the Division will forward
this matter to the FIorida Elections Commission for further action. Section I 06265(1 ), Florida Statutes,
authorizes the Florida Elections Commission to impose civil penalties of up to $1,000 per violation.
If you have any questions, please call Donna Brown at (850) 245-6240
Sincerely,
KRB/dsb
Enclosure
~lk
VIVA FLORIDA
EXHIBIT
5 ~. \ot 2.
RA. Gmy Building, Suite 316 • 500 South Bronough Street• Tallahassee, Florida 32399
7' al
850.. 245.. 6200 • 850.245 6217 (Fax) electlon. dos.state . fl.us
flORIDA'T~
Pr·omoting Florida's History and Cultu1'e
VivaF!orida . org
Fl'EcT'iO):is ..,.
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USPS Tracking TM
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Tracking Number: 9114901075742751291632
Product & Tracking Information
Postal Product:
Available Actions
Features:
USPS Tracking TM
Aprfl 15, 2014, 11:15 am
Delivered
.JACKSONVILLE, FL 32202
April 15 2014 7:42 am
Out for Delivery
JACKSONVILLE FL 32206
April 15 2014 7:32 am
Sorting Complete
JACKSONVILLE Fl 32206
April 15 2014 6:40 am
Arrival at Post Office
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April 14 2014 8:52 pm
Processed through USPS
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April 13 2014 1:42am
Depart USPS Sort Facility
April 12 2014 10:06 pm
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April 11 2014 10:11 pm
Depart·USPS Sort Facility
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April 11 2014 7:48 pm
Sort Facility
TALLAHASSEE FL 32301
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Ken Detzner
Secretary of State
April 11, 2014
Apt. 1206
Re: ECO 59846
Dear Mr. Bedran:
Your campaign treasurer's report, which was due April 10, 2014, has not been received
Sections I 06 . 0703(7)(b), Florida Statutes, require that the filing officer immediately
notify you of the failure to file this repo1t and that a fine will be assessed of $50 per day for the first 3 days
whichever is greater, for the period covered by the late report However, for the report immediately
25% of the total receipts or expenditures, whichever is greater, for the period covered by the late report
Once your report is filed, this office will notify you of the specific amount of your fine. Fines must be paid
Chapter I 06, F Iorida Statutes, independent of the automatic fine violation referenced above T'herefore, if
you fail to file a report, the division will turn the matter over to the Florida Elections Commission.
Section 106.265(1), Florida Statutes, authorizes the Florida Elections Commission, to impose a civil
penalty up to $1,000 pe1 count for each willflll violation of Chapter 106
If you have any questions, please contact the help desk at (850) 245-6280
Sincerely,
~~~'i?--~
EXHIBIT lo \2~.
1he R A Gray Building-Room 316 •
FAX: (850) 245··6260
•
\ot 2
500 South Bronaugh Street • Tallahassee FL 32399-0250 • (850) 245-6240
WWW Address: http://www. dos.state. fl.us
• £.Mail DivE/ections(iiJdo.sstatefl.us
I'
Ken DetzneJ'
Secretary of State
Second Notice
April 25, 2014
Kyle Alexander Bedran, I reasurer
Florida Citiz.ens for Smart Justice
3 1 West Adams Street
Apt 1206
Re: ECO 59846
Dear Mr. Bedran:
Your campaign treasurer's report, due April I 0, 2014, has not been received
Sections 106. 0703(7)(b), Florida Statutes, require that the filing officer immediately notify you of
address on file with our office on April 11, 2014 As of this date, we do not show a record of
this notice, this matter will be referred to the Florida Elections Commission for forther action
Section 106265(1), Florida Statutes, authorizes the Florida Elections Commission, upon finding
Sincerely,
~~~~tv
EXHIBIT lo
N.
2 of i
The R A Gray Building-Room 316 • 500 South Bronough Street
• Tallahassee FL 32399-0250 • (850) 245··6240
.
....
----'
FLORIDA DEPARTMENT of STAT~
RICK SCOTT
Governor
FINAL NOTICE
KENDETZNER
Secretary of State
USPS TRACKING I
&CUSTOMER
RECEIPT
9114 9011 5981 8370 3038 49
For Traclllng or Inquiries go to USPS com
or can 1-soa.222.. 1a11
May 8,2014
Kyle Alexander Bedran, T'reasurer for
31 West Adams Street, Apt 1206
Dear Mr Bedran:
reports:
Year
Report
Cover Period
2014
2014
M2
M3
02/0112014 - 02/28/2014
03/0l/2014 - 03/3J/2014
The organization has previously been notified of the reports that are outstanding Enclosed are copies of letters
sent by the Division. If the reports are not filed within 7 dav§.of receipt of this letter, the Division will forward
this matter to the Florida Elections Commission for further action Section 106 265(1), Florida Statutes,
authorizes the Florida Elections Commission to impose civil penalties of up to $1,000 per violation.
If you have any questions, please call the help desk at (850) 245-6240
Sincerely,
~~_,~~o1~-·
KRB/slb
Enclosures
;~
VIVA flORIOA.
EXHIBIT
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RA. Gray Building, Suite 316 • 500 South Bronaugh Street • Tallahassee, Florida 32399
-.., a&
850.245 . 6200 • 850.245 . 6217 (Fax) election . dos.state .. fl.us
FLORIDAT~
Promoting Florida's History and Cultur·e
VivaFlorida .org
ELECTJONS f~
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Tracking Number: 9114901159818370303849
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May 12, 2014, 11:20
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Delivered
JACKSONVILLE, FL 32202
May 12 2014 8:26 am
Out for Delivery
May 12 2014 8:16 am
Sorting Complete
May 12 2014 7:42 am
Arrival at Post
Office
May 11 2014
Depart USPS Sort
Facility
May 10 2014 7:54 pm
Processed through
USPS Sort Facility
May 9 2014
Depart USPS Sort
Facility
Processed through
USPS Sort Facility
12:39 am
10:02 pm
May 9 2014 8:01 pm
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Page 1 of 3
Statement Period
11/01/12 through 11/30/12
EO P PA OA 65
Enclosures 0
Account Number
Bank of America., N A
P 0 Box 25118
lampa. Fl 33622-5118
1•• 11 ••• 1.1 •• 1.111 .... 1.. 1.1 •• 111 ..... 1.11.1 ..... 11 .. 1.1 ... 111
..
--·-·-·-···-·~-··-
.
-~.03075"''00i-SCM999
____ ----o----
FLORIDA CITIZENS FOR SMART JUSTICE, INC
1661 RIVERSIDE AVE APT 412
JACKSONVILLE, FL 32204-4029
Our Online Banking service allows you to check balances,. track account activity and more
With Online Banking you can a)so view up to 18 months of this statement online.
Enroll at www bankofamerica com/smallbusiness
This holiday season, you can make 3 times the difference in the fight against hunger. For every $1 you
give from now until .January 7, 2013, we'll give $2, up to a maximum total match of $1,500,000. Together,
we'll help provide thousands of meals to people in need through Feeding America's Give a Meal
campaign To give, visit www bankofamerica.com/give
\t>\;'3
EXHIBIT..-=::.04-~!4'·__=..;~Q
0488259
H
Page 2 of 3
Statement Period
FLORIDA CIIIZENS FOR SMARJ JUSJICE INC
11/01112 through 11130/12
EO P PA OA 65
Enclosures 0
Account Number
Business Economy Checking
FLORIDA CITIZENS FOR SMART JUSTICE, INC
Your Account at a Glance
Account Number
Statement Period
11/01/12 through 11/30/12
Number of Deposits/Credits
1
Number of Withdrawals/Debits
0
Number of Deposited Items
0
Number of Days in Cycle
Statement Beginning Balance
Amount of Deposits/Credits
Amount of Withdrawals/Debits
Statement Ending Balance
$29 ..95$29 . 95
$0.00
$0 00
Average ledger Balance
$11 98-
30
Deposits and Credits
ate
Posted
Amount
11/13
($)
an
Reference
Description
29.95 Monthly Service Charge Refund
Fdes Nmo 0006576 Nbkmj6X
Daily Ledger Balances
Date
11101
Balance ($)
29.95 -
Date
Balance ($)
11/13
0.00
EXHIBIT
6 f41·
zaf- 3
945011135769715
I
'
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Page 3 of 3
0488261
How To Balance Your Bank of America Account
FIRST,
start with your Account Register/Checkbook:
$ _ _ _ __
List your Account Register/Checkbook Balance here
2
$ _ _ _ __
Subtract any service charges or other deductions not previously recorded that are listed on this statement
········-·· $ _ _ _ __
$ _ _ _ __
3 Add any credits not previously recorded that are listed on this statement (for example interest)
This is your NEW ACCOUNT REGISTER BALANCE
NOW, with your Account Statement:
$ _ _ _ __
$ _ _ _ __
list your Statement Ending Balance here .
2
Add any deposits not shown on this statement
SUBTOTAL
3. list and total all outstanding checks, ATM, Check Card and other electronic withdrawals
Checks, ATM, Check Card,
Electronic Withdrawals
Date/Check #
Amount
$====
Date/Check #
Amount
Date/Check #
Amount
TOTAL OF OUTSTANDING CHECKS. ATM,. Check Card and other electronic withdrawals
Subtract total outstanding checks, ATM, Check Card and other electronic withdrawals from Subtotal
This Balance should match your new Account Register Balance
$ _ _ _ __
$====
Upon receipt of your statement differences if any should be reported to the bank promptly in writing and in accordance with provisions ln your deposit
agreement
IMPORTANT INFORMATION FOR BANK DEPOSIT ACCOUNTS
Change of Address
Please call us at the telephone number listed on the front of thls statement to tell us about a change of address
Deposit Agreement. When you opened your account. you received a deposit agreement and fee schedule and agreed that your account would be
governed by the terms of these documents, as we may amend them from time to time. These documents are part of the contract for your deposit account
and govern all transactions relating to your account, including all deposits and withdrawals. Copies of both the deposit agreement and fee schedule
which contain the current version of the terms and conditions of your account relationship. may be obtained at our banking centers
Electronic Transfers: In case of errors or questions about your electronic transfers
If you think your statement or receipt is wrong or if you need more information about an electronic transfer (e.g., ATM transactions, direct deposits or
withdrawals, point·Of·sale transactions} on the statement or receipt. telephone or write us at the address and number listed on the front of this statement
as soon as you can We must hear from you no later than 60 days after we sent you the FIRST statement on which the error or problem appeared
• Tell us your name and account number
• Descrlbe the error or the transfer you are unsure about and explain as clearly as you can why you believe there is an error or why you need more
information.
• Tell us the dollar amount of the suspected error
For consumer accounts used primarily for personal family or household purposes. we will investigate your complaint and will correct any error
promptly. If we take more than 10 business days (10 calender days if you are a Massachusetts customer) (20 business days if you are a new customer,
for electronic transfers occurring during the first 30 days after the first deposit is made to your account) to do this, we will recredit your account for the
amount you think is in error, so that you will have use of the money during the time it takes us to complete our investigation
For other accounts we investigate and if we find we have made an error we credit your account at the conclusion of our investigation
Reporting Other Problems. You must examine your statement carefully and promptly. You are in the best position to discover errors and unauthorized
transactions on your account If you fail to notify us in writing of suspected problems or unauthorized transactions within the time periods specified in
the deposit agreement (which periods are no more than 60 days after we make the statement available to you and in some cases are 30 days or Jess) we
are not tiabte to you for and you agree not to make a claim against us for the problems or unauthorized transactions
8 . 3d.3
Direct Deposits. If you have arranged to have direct depcsits made to your account at least once every 60 days from the same person or company you
may call us at the telephone number hsted on the front of this statement to fmd out if the deposit was made as schEXHtBIT
Bank of America, N A Member FDIC and
@
Equal Housing Lender
-----------------------·---------·------------------~-
------
-~~·-·-·--- - ' - - -
-------------------·-~·----
~~~-~---·--------~--
_
_:::..p~1~-""'-'""-""---
Page 1 of I
RE: Refo11als
Bronson, Ktisti R
to:
Tracie Aulet
04/02/2014 02:49 PM
Show Details
Secmity:
Io ensme privacy, images from remote sites were prevented frnm downloading Show Images
The notice that no report will be filed is the waiver, which must be filed in the EFS We do not require anything separate in
writing
Regar<ls,
If1bJtl Reid B1on~on, c:hiej
Divl-.ion of E/e,tio11s,
Buteau of E~leclion Recot<lfl
(.9.50) 24.5-6240
From: Tracie Au let [mailto:[email protected]]
Sent: Wednesday, April 02, 2014 12:56 PM
To: Bronson, Kristi R
Subject: Referrals
Good Afternoon Kristi,
I am investigating a referral from DOE for failure to notify the filing officer in writing on the prescribed repotting date that no report
would be filed, i e the untimely filing of waivers
Would you please inform me as to what the procedure is fOr a candidate who wants to notify the Division in writing that there will be no
report filed? Is it similar to the request for password in that they have to fax a signed letter to the Division? Does the Division
acknowledge receipt of the notification that no report will be filed? Once the letter is received is the candidate still required to file the
actual waiver of report?
Thank you for your assistance in this matter
Sincerely,
I racie L Aul et
Investigation Specialist II
The Collins Building, Suite 224
I 07 West Gaines Street
Please note that Florida has a broad public records law, and that all correspondence to me via e-mail may be subject to disclosure
ttsWorkin FL
The Department of State is committed to excellence
Please take our Customer Satisfaction Survey.
EXHIBIT_q...:..-..--file:///C:/U sers/Aulett/AppData/Local/I emp/notesFCBCEE/-web 1833 .htm
8/28/2014
Page 1 of 1
FEC - Candidate/Committer riling Histmy Repo1t
~'"m
search 1directorv1 contact us 1411 1subscribe! tour 1help
Florida Department of State - Division of Elections
Florida Election System Reports
Committee Name: Florida Citizens for Smart Justice
Account: 59846
Candidate/Committee Lookup
Name:
.... _,, ..,.,_.
Election:
Date Due Type Date Filed Status
L~~·· ~··
• n•' ••• •-'o•> • •
Acct j59846
Type
jcomri:iitt~~
Search
j
.. B
Reset
B
8/22/2014
8/15/2014
8/8/2014
8/1/2014
7/25/2014
7/18/2014
7/11/2014
7/4/2014
6/27/2014
6/10/2014
5/12/2014
4/10/2014
3/10/2014
2/10/2014
1/10/2014
12/10/2013
11/12/2013
10/10/2013
7/10/2013
4/10/2013
1/10/2013
11/2/2012
10/19/2012
10/5/2012
9/21/2012
8/10/2012
7/27/2012
7/13/2012
P7
P6
P5
P4
P3
P2A
P2
P1A
P1
M5
M4
M3
M2
M1
M12
M11
M10
03
02
01
04
G4
G3
G2
G1
F3
F2
F1
EXHIBIT
NEN
NEN
NEN
NEN
NEN
NEN
NEN
NEN
NEN
NEN
NEN
10/22/2014
10/22/2014
2/5/2014
2/5/2014
12/5/2013
12/5/2013
10/10/2013
7/10/2013
5/12/2013
1/19/2013
11/2/2012
10/24/2012
10/5/2012
9/21/2012
8/10/2012
7/31/2012
7/12/2012
Days
Late
As=~~~ed
00
00
00
00
00
00
00
00
00
00
00
00
00
Appealed
Amount Amount
Paid
Fined
$000
$0 00
$0.00
$000
$0.00
$000
$000
$000
$000
$000
$000
$000
$000
$000
$000
$000
$0.00
$0 00
$0 00
$0 00
$0 00
$0 00
$000
$0 00
$000
$0 00
CLO
CLO
0
0
0
0
0
0
0
0
0
0
0
195
226
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
$0
CLO
26
$0 00
$0 00
$000
CLO
23
$0 00
$0 00
$000
CLO
CLO
32
9
$0 00
$0 00
$0 00
$0 00
$0 00
$000
CLO
5
$0 00
$0 00
$000
CLO
4
$0 00
$000
$000
I0
12/2/2014
/
/".
I
HISTORY NOTES
Florida Citizens for Smart Justice - 59846
Unique ID
Date Recorded
38738
5/30/2014 10:06:00 AM
Last Edited Date
Orginally Recorded By
dsbrown
RE: Email from Mr. Bedran and my response
Good morning Mr Bedran
Florida Citizens for Smart Justice - ECO 59846 is still an active electioneering communication organization The Division of
Elections issued a Notice of Intent to Revoke the registration of this ECO in January 2014. However, the revocation has not
yet occurred and may be some time, if ever My understanding is that the rule regarding financial activity has been
challenged Therefore, until a decision is made by the court, revocations are pending. Should the ruling result in proceeding
with the revocations- you will receive a Final Order revoking the registration for ECO 59846
As long as this ECO is active, financial reports are required by Florida Statutes. Florida Citizen$ for Smart Justice currently
has three outstanding financial reports that must be filed: 2014 M2, M3 and M4 The 2014 M5 report will be due no later than
June 10 2014
If you would like to disband the ECO please send a letter requesting disbandment. (Disbandment does not absolve the
requirement to file financial reports Until notification that the ECO has been made inactive by the Division financial reports
will be required )
Jf you have any questions or I may be of further assistance please do not hesitate to contact me
Best regards,
Donna S Brown
From: Kyle Bedran [mailto:bedranlaw@gmail com]
Sent: Thursday, May 29, 2014 7:52 PM
To: Brown, Donna S.
Subject: Re: ECO 59846 .. Florida Citizens for Smart .Justice
Mrs. Brown,
Florida Citizens for Smart .Justice, Inc was administratively dissolved last year and we received a letter from the Division of
Elections stating the ECO was to be terminated Is further action necessary on our part to terminate the ECO?
Sincerely,
38721
dsbrown
5/29/2014 12:53:00 PM
RE: Returned FF Second Notice (M4 report)
A copy of the Seond Notice for failure to file the report due May 12 2014 was emailed to the Chairperson today:
Kyle Alexander Bedran, Chairperson and Registered Agent
Florida Citizens for Smart Justice - ECO 59846
Dear Mr Bedran,
The Second Notice for failure to file your May 12, 2014, campaign treasurer's report was returned to our office as Return to
Sender'' The Notice was mailed to your address of record as the Registered Agent for Florida Citizens for Smart Justice
To avoid further delay I have attached a copy of the Notice for your information and records
If this report is not filed via the Divisions electronic filing system within 14 days of receipt of this notice this matter will be
referred to the Florida Elections Commission for further action (See attached letter)
If you have any questions please feel free to contact me direct at (904) 245·6297
Regards
Donna S Brown
·-------·-----
EXHIBIT
Page 1 of4
I\
Pl \6\"4
717/2014
HISTORY NOTES
Unique ID
Date Recorded
38364
Last Edited Date
4/1/2014 4:05:00 PM
dsbrown
RE: Returned Mail
Email sent to Chairperson today:
Dear Mr Bedran,
The Second Notice for failure to file your March 10, 2014 campaign treasurer's report was returned to our office as "Return to
To avoid further delay I have attached a copy of the Notice for your information and records
If you have any questions please feel free to contact me direct at (904) 245-6297
36628
1/22/2014 2:01 :00 PM
ljrandolph
RE: Returned Mail
I called and left a message Mr Bedran regarding returned mail that we received I left my contact information and asked for
him to return my call
35694
12/18/2013 2:24:00 PM
1/22/2014 4:23:09 PM
lbelvin
RE Updating the address
604-502-3327
I called and spoke with Mr Bedran because when I was processing the mail it was given to me stamped as incomplete
Looking over the form there were a few errors, however this committee was already in the system and the only thing he was
doing was trying to change the address for our records He said that he had already went into the EFS sytem to make
changes and the only reason he sent the forms were to create a paper trail
35762
elalexander
12/12/2013 11 :22:00 AM
Re: Return of Mail
Re-mailed to Mr Bedran on 12/12/2013
-·-------·--~-------------
35761
elalexander
12/12/201311 :20:00 AM
Re: Return of Mai!
Called Mr Bedran and left a detailed voice message in regards to change of address
Noticed the following:
- Address has been updated in EFS with a valid email address and linked into CanCom with the new mailing address
EXHIBIT \)
Page 2 of 4
~- 2of4
71712014
HISTORY NOTES
Florida Citizens for Smart Justice ·· 59846
Unique ID
Date Recorded
35409
121212013 9:38:00 AM
Or·ginally Recorded By
Last Edited Date
elalexander
Re: Return of Mail
The following email was sent to Mr Bedran (BedranLaw@gmail com) in regards to return mail:
Dear Mr Bedran
This is a follow-up email to a return of mail that was received in our office on November 25 2013 for the following ECO
(Florida Citizens for Smart .Justice) We just need to verify that we have the proper address for you If we do not we will need
the following to ensure that we keep your information updated within our office:
1.A signed written notification verifying a change of address This may be scanned and emailed to our office or faxed to our
office at (850) 245-6259 or (850) 245-6260
2 Please update your contact information in EFS as well as providing a valid email address for future notifications
Below is the following address that we have on file for you:
1650 Margaret Street, Suite 302 PMB 147
Jacksonville Florida 32204
If the information listed above is incorrect please follow the instructions provided so that we may update our system with your
most recent contact information If you have any questions, please call our office at (850) 245-6240
Sincerely
Erica Leondria Alexander
Regulatory Specialist I
Florida Department of State
R.A Gray Building
500 S Bronough Street
Tallahassee FL 32399
Note: This response ls provided for reference only and does not constitute a formal legal opinion or representation from the
Department of State or the Division of Elections As applied to a particular set of facts or circumstances, interested parties
should refer to the Florida Statutes and applicable case law, and/or consult an attorney to represent their interests before
drawing any legal conclusions or relying upon the information provided
35407
elalexander
1212/2013 9:20:00 AM
Re: Return of Mail
Searched in BER Imaging found the following email address for Mr Bedran: BedranLaw@gmaiJ com
35403
elalexander
121212013 9:00:00 AM
Re: Return of Mail
Called for Mr Bedran left a detailed voice message:
-
Need to verify change of address
Please update your current address and other contact information on EFS
Please send in a signed written notification to our office notifying us of the change of address
Please call our office at (850) 245-6240
35371
elalexander
11127/201312:0100 PM
Re: Return of Mail
Called the number on file for Mr Bed ran and left a detailed voice message. Below are the details from the message:
- Calling to verify current mailing address
- Advise Mr. Bedran to update his information in the EFS System for future notifications in reagrds
- Please call our office at (850) 245-6240
EXHIBIT I\
Page 3 of 4
to
reporting deadlines, etc
?'J 3 & 4
7/712014
HISTORY NOTES
Unique ID
35298
Date Recorded
Last Edited Date
11/26/2013 8:23:00 AM
ELAlexander
Re: Return of Mail
Called and left a voice message for the treasurer, below are the details from the message:
- .Just calling to obtain your new mailing address to send the following mail that has returned to our office to you
- Also calling to remind you that we would still need a letter and the forms showing any changes of address or other changes
of information for the ECO (Florida Citizens for Smart .Justice)
- If you have any questions, please call our office at (850) 245-6240 or my direct line (850) 245-6170
35297
elalexander
11/25/2013 4:48:00 PM
Re: Return of Mail
Called and spoke with treasurer below are the following details from our conversation:
- Need a verification of address
- Has been meaning to send in the information stating a change of address to our office
- Will send in a letter and the forms showing a change of address
29267
6/18/201211:45:00AM
ljrandolph
Past notes pertaining to incomplete paperwork:
Not Processed because box 3 isnt specific enough I called and spoke to Mr bedran and explained to him that he need to be
more specific because box 3 need to state what type of candidates the committee is supporting He said that he will submit
the corrected paperwork asap LJR 6/4/2012
EXHIBIT \ \
Page 4 of 4
Pl 4 ~4
7/7/2014
I
Aug 2' n14 :l'.)7AV
~'
'ubl1c De'1"~''' C'·'-,
322l
F
2
'
""'
Kyle A Bed!an, Esq.
Floiida Citizens for Smart Justice
612 S West Street
Green Cove Springs, Flo1ida 32043
,~,
.~
-
I II'- ' )
t '
........
,.,
'
io
14 AUG 21 AH I I: 04
August 21, 2014
iJIVLc. : . ,:..E.CTJONS
SECRE IAHY OF STATE
Florida Divis.ion of Elections
Room316
RA Gray Building
lallahassee, Florida 32399-0250
'Io Whom It May Concern:
Please accept this letter as notice that Florida Citizens for Smrut Justice, an
Electioneering Communication Organization, has been decommissioned and is no longer
an active ECO
As of October 17, 2012, the bank account fo1 the ECO was balanced, zeroed out
and reported, concluding its financial activity. An Annual Repo1t was filed in 2013,
continuing the nonprofil's life to the end of year . After receiving your letter dated
Janua1y 17, 2014 and titled Notice oflntent to Revoke, I was under the impression that
after the
:~O
day period lapsed, the organization would not be 1ecognized as an active
ECO. No Annual Report was filed for the year2014 and the nonprofit is cunently set to
administratively dissolve within the next month. To further compound my confosion, my
address has changed twice in the past year, leading to several miscommunications
Jn summation, I apologize for my misunde1 standing and lack of communication in
resolving this matter . I hope the timeline set out above sheds light on the problem. If
anything fu1the1 is needed please feel free to contact me at any time at 904-502-3327 or
Bed1 anLaw@gmaiL2Qffi
EXHIBIT_J 2
p;j. \tf 2
>
I
I
'
FLORIDA DEPARTMENT o!STATE
RICK SCOTT
Governor
KENDETZNER
Secretary of State
August 27, 2014
Kyle Alexander Bedran, Chairperson
Florida Citizens fot Smart Justice (59846)
3 l West Adams Street
Jacksonville, Florida 32202
Dear Mr Bedran:
This will acknowledge receipt of your committee's letter informing us of the disbandment of
Florida Citizens for Smart Justice as an electioneering communications organization This
information was placed on file in our office on August 21, 2014. Yom final report may be filed at
any time but is due no later than August 22, 2014 This report must be filed via the Division's
Electronic Filing System (EFS).. If you have no activity to report, you are still required to file a
waiver. Should you need to file amendments after the final report has been filed, please contact
our office to have your account activated
If you have any questions, or if we may be of further assistance to you at any time, please do not
hesitate to call (850) 245-6280
Since1ely,
~~~+~13~
KRB/ljr
EXHIBIT I 2
~
VIVA ftORrnA500.
PJ 2 af'2
RA. Gray Building, Suite 316 • 500 South Bronough Street • Tallahassee, Florida 32399
850 .. 245 . 6200 • 850. 245.6217 (Fax) election.dos.. state . fl,us
Pr·omoting Florida's History and Cultur·e
VivaFlor!da.org
/1
*Confidential: Re: Confidential Case No.: FEC 14-175- Response due by
close of business on September 4, 2014 ~
Florida Elections Commission to: Kyle Bedran
From:
To:
09/10/2014 05:02 PM
Florida Elections Commission/OAG
Kyle Bedran <[email protected]>
Please direct them to Erin Riley or Amy Toman Thank you
Kyle Bedran
From:
To:
Date:
Subject:
Kyle Bedran <bedranlaw@gmail com>
Florida Elections Commission <[email protected]>
09/10/2014 03:29 PM
Re: •confidential: Confidential Case No : FEC 14-175 - Response due by close of business on
September~, 2014
··-·-------------
Mrs . Malphurs,
I apologize for not submitting a response within the allotted time . Work became quite
buidensome last week I would like to let the Commission know that I want to cooperate fully to
resolve this issue quickly. If! may, I want to provide complete bank records for the ECO in
hopes that this will expedite the process Who can I direct those records to?
Thank you,
KyleBedran
On Thu, Aug 21, 2014 at 11:45 AM, Florida Elections Commission <[email protected]>
wrote:
Dear Mr Bedran,
Thank you for confirming receipt of the referral for your alleged failure to file reports, after
notice. Please keep in mind that ALL outstanding reports are required to be filed, even if you
disband the ECO
You may also wish to notify Donna Brown with the Division of Elections at 850-245-6297 of
your new address for theiI records (or you may be able to update your address through the
electronic filing system (EFS) database
Please submit your initial response to the complaint/referral by the close of business on
September 4, 2014 If you have any questions, please let me know
Sincerely,
D~AIM'V/\ll~y
Agency Clerk
EXHIBIT_i 3
pj. \ o+' 2
850-922-4539
""Kyle Bedran---08/21/2014 10:47:00 AM---Mrs Malphurs, I am in receipt of the complaint
and will issue a response within the
From: Kyle Bedran <[email protected]>
Io: Florida Elections Commission <[email protected]>
Date: 08/2112014 10:47 AM
Subject: Re: Confidential Case No.: FEC 14-175 -- Please respond
Mrs Malphurs,
I am in receipt of the complaint and will issue a response within the allotted time.
Thank you,
Kyle A Bcdran, Esq.
[email protected]
904-502-3327
This email may contain PRlVlLEGf'D AND CONFIDENTIAL information intended only for
the use of the addressee(s) named above If you are not the intended recipient of this
email, or an authorized employee or agent responsible for delivering it to the intended
recipient, you are hereby notified that any dissemination or copying of this email is
strictly prohibited 1f you have received this em,1il in error, please notify sender by reply
email and delete this email from your records. Thank you for your cooperation .
Kyle A Bedran, Esq.
[email protected]
904-502-3327
This email may contain PRIVILEGED AND CONFIDENTIAL information intended only for the use of the addressee(s)
named above. If you are not the intended recipient of this email, or an authorized employee or agent responsible for
delivering it to the intended recipient, you are hereby notified that any dissemination or copying of this email is strictly
prohibited. If you have received this email in error, please notify sender by reply email and delete this email from your
records Thank you for your cooperation
EXHIBIT
I3
pj · '2 of 2
107 W. Gaines Street,
Suite 224 Collins Building
Tallahassee, Florida 32399-1050
Telephone: (850) 922-4539
Fax: (850) 921-0783
Septembe1 23, 2014
612 South West Street
Greencove1 Springs, FL 32043
RE:
Case No.: FEC 14-175; Respondent: Kyle A. Bedran, Treasurer· and Florida
Citizens for Smart Justice
Dear M1 Bedran:
On July 10, 2014, the Flo1ida Elections Commission received a complaint alleging that you
violated Florida's election laws I have reviewed the complaint and find that it contains one or
more legally sufficient allegations.. The Commission staff will investigate the following alleged
violations:
Section 106.070.3(6), Florida Statutes: As alleged in the complaint,
Respondent, Kyle Alexander Bedran, is the treasurer for Florida Citizens
for Smart Justice, an electioneering communications organization (ECO)
registered with the Division of Elections Respondent failed to timely
notify the filing officer in writing that the ECO had no reportable activity
and, the1efore, would not be filing a report on the presc1ibed reporting date
fo1 each of the following reporting periods:
•
•
2014M2
2014 M3
Section 106 . 19(1)(c), Florida Statutes: As alleged in the complaint,
Respondent, Kyle Alexander Beman, is the treasurer for Florida Citizens
for Smart Justice, an electioneering communications 01ganization (ECO)
registered with the Division of Elections . Respondent falsely repo1ted or
deliberately failed to include information required by Chapter 106, Florida
Statutes, when he failed to file a 1epo1t on the prescribed repo1ting date for
each of the following reporting pe1iods:
•
ComOl l (10/07)
2014 M2
•
2014 M3
Section 106.070.3(l)(a), Florida Statutes: As alleged in the
complaint, Respondent, Florida Citizens for Smart Justice,. an
electioneering communications 01ganization (ECO), failed to
timely file the campaign treasurer's report with the Division of
Elections that were due on March 10, 2014 (M2) and April 10,
2014 (M3)
•
•
2014 M2
2014 M3
You may respond to the allegations above by filing a notarized statement prqviding any
information regarding the facts and circumstances surrounding the allegations.. Your response
will be included as an attachment to the investigator's report
When we conclude the investigation, a copy of the Report of Investigation will be mailed to you
at the above address You may file a response to the report within 14 days from the date the
report is mailed to you. Based on the results of the investigation, legal staff will make a written
recommendation to the Commission on whether there is probable cause to believe you have
violated Chapter 104 or 106, Floiida Statutes . A copy of the Staff Recommendation will be
mailed to you and you may file a 1esponse within 14 days ft om the date the recommendation is
mailed to you. Your timely filed response(s) will be considered by the Commission when
dete1mining probable cause.
The Commission will then hold a heaiing to determine whether there is p1obable cause to believe
you have violated Chapters 104 or 106, Florida Statutes You and the complainant will receive a
notice of hea1ing at least 14 days before the heaiing The notice of heaiing will indicate the
location, date, and time of your heaiing. You will have the opportunity to make a brief oral
statement to the Commission, but you will not be permitted to testify or call others to testify, or
introduce any docUinentaiy or other evidence .
At any time before a p1obable cause finding, you may notify us in writing that you want to enter
into negotiations directed towards reaching a settlement via consent agreement
The Report of Investigation, Staff Recommendation, and Notice of Hearing will be mailed
to the above addr·ess as this letter. Therefore, if your address changes, you must noti(y this
office of your new address. Otherwise, you may not receive these important documents.
Failure to receive the documents will not delay the probable cause hearing.
Under section 10625, F101ida Statutes, complaints, Commission investigations, investigative
reports, and other documents 1elating to an alleged violation of Chapters 104 and 106, Florida
Statutes, are confidential until the Commission finds p10bable cause or no p10bable cause.. The
confidentiality provision does not apply to the pe1son filing the complaint Howeve1, it does
apply to you unless you waive confidentiality in writing· The confidentiality provision does not
preclude you from seeking legal counsel.. Howeve1, if you retain counsel, your attorney must file
a notice of appearance with the Commission befo1e any member of the Commission staff can
discuss this case with him 01 her.
ComOl 1 (8/08)
I
'
I
'
If you have any questions or need additional information, please contact Cedric Oliver, the
investigator assigned to this case
AMII
Como 11 (8/08)
/
*Confidential: Re: Confidential Case No.: FEC 14-175- Response due by
close of business on September 4, 2014 0
From:
To:
09/10/2014 05:02 PM
Please direct them to Erin Riley or Amy Toman. Thank you
Mrs. Malphurs, I apologize for not submitting a r .··
Kyle Bedran
From:
To:
Date:
Subject:
O§fi0/2014 03:29:37 PM
Kyle Bed ran <[email protected]>
09/10/2014 03:29 PM
Re: •confidential: Confidential Case No : FEC 14-175 - Response due by close of business on
September 4, 2014
Mrs . Malphurs,
I apologize for not submitting a response within the allotted time Work became quite
burdensome last week I would like to let the Commission know that I want to cooperate fully to
resolve this issue quickly. If I may, I want to provide complete bank records for the ECO in
hopes that this will expedite the process . Who can I direct those records to?
Thank you,
Kyle Bedran
On Thu, Aug 21, 2014 at 11 :45 AM, Florida Elections Commission <[email protected]>
wrote:
Dear Mr. Bedran,
Thank you for confoming receipt of the referral for your alleged failure to file reports, after
notice . Please keep in mind that ALL outstanding reports are required to be filed, even if you
disband the ECO
You may also wish to notify Donna Brown with the Division of Elections at 850-245-6297 of
your new address for their records (or you may be able to update your address through the
electronic filing system (EFS) database.
Please submit your initial response to the complaint/referral by the close of business on
September 4, 2014 If you have any questions, please let me know.
Sincerely,
D~
AIM'V /V1~s-
Agency Clerk
/
(
850-922-4539
"'"Kyle Bedran ---·08/21/2014 10:47:00 AM---Mrs Malphurs, I am in receipt of the complaint
and will issue a response within the
From: Kyle Bedran <[email protected]>
Io: Florida Elections Commission <fec@myf!01idalegal.com>
Date: 08/2112014 10:47 AM
Subject: Re: Confidential Case No . : FEC 14-175 -- Please respond
Mrs Malphurs,
I am in receipt of the complaint and will issue a response within the allotted time
Thank you,
Kyle A Bcdran, Fsq
[email protected]
904-502-3327
This email may contain PRIVII. FGLD AND CONr lDENl !AL information intended only for
the use of the addressce(s) named above . lf'you arc not the intended recipient of this
email, or an authorized employee or agent responsible for delivering it to the intended
recipient, you arc hereby notified that any dissemination or copying of this email is
strictly prohibited lt you have received this email in error, please notify sender by reply
email and delete this email frorn your records. Thank you for your cooperation.
Kyle A Bedran, Esq.
[email protected]
904-502-3327
named above If you are not the intended recipient of this email, or an authorized employee or agent responsible for
records. Thank you for your cooperation
Page I of2
/
I
'
Re: *Confidential: Confidential Case No . : FEC 14-175 - Response due by close ofbusiness
on September 4, 2014
Kyle Bedran
to:
09/10/2014 03:29 PM
Show Details
I Attachment
l~I
graycoLgif
Mrs Malphurs,
I apologize for not submitting a response within the allotted time Work became quite burdensome last
week I would like to let the Commission know that I want to cooperate fully to resolve this issue
quickly. If I may, I want to provide complete bank records for the ECO in hopes that this will expedite
the process . Who can I direct those records to?
Thank you,
Kyle Bedran
On Thu, Aug 21, 2014 at 11 :45 AM, Florida Elections Commission <[email protected]> wrote:
Dear Mr Bedran,
Thank you for confirming receipt of the refeHal for your alleged failure to file reports, after notice
Please keep in mind that ALL outstanding reports are required to be filed, even if you disband the
ECO
You may also wish to notify Donna Brown with the Division of Elections at 850-245-6297 of your
new address for their records (or you may be able to update your address through the electronic filing
system (EF S) database
Please submit your initial response to the complaint/refenal by the close of business on September 4,
2014. If you have any questions, please let me know
Sincerely,
D~
AIM'\; /lll~y
Agency Clerk
850-922-4539
Kyle Bed1an ---08/21/2014 10:47:00 AM---Mrs Malphws, I am in receipt of the complaint and
will issue a response within the
from: Kyle Bedran <bcdranlav,,(mgmail.com>
To: Florida Elections Commission <fec(ii)mvt101idalegal.com>
· Date: 08/21/2014 10:47 AM
file:///C:/Users/Malphwsd/AppData/1 ocal/1 emp/notesF CBCEE/.-web4202 htm
9110/2014
Page 2 of2
Subject: Re: Confidential Case No.: FEC 14-175 -- Please respond
Mrs Malphurs,
I am in receipt of the complaint and will issue a response within the allotted time .
Thank you,
1
Kyle A Bedran, vsq
[email protected]
904-502-3327
i This email may contain PRIVILEGED AND CONFIDENTIAL information intended only for the use
of the addressee(s) named above. If you are not the intended recipient of this email, or an
authorized employee or agent responsible for delivering it to the intended recipient, you are
' hereby notified that any dissemination or copying of this email is strictly prohibited. If you have
received this email in error, please notify sender by reply email and delete this email from your
Kyle A Bedran, Esq
Bcdranl ,a\V(aigrnail.con1
904-502-3327
This email may contain PRIVILEGED AND CONFIDENIIAL information intended only for the use of the addressee(s) named above
If you are not the intended recipient of this email, or an authorized employee or agent responsible for delivering it to the intended
recipient, you are hereby notified that any dissemination or copying of this email is strictly prohibited. If you have received this
email in error, please notify sender by reply email and delete this email from your records Thank you for your cooperation
file:///C:/Users/Malphmsd/AppDatall ocal/Temp/notesFCBCEE/-web4202 httn
9/10/2014
*Confidential: Confidential Case No.: FEC 14-175- Response due by close of
business on September 4, 2014 @)
From:
To:
08/21/2014 11 :45 AM
Dear Mr Bedran,
Thank you for confirming receipt of the referral for your alleged failure to file reports, after notice. Please
keep in mind that ALL outstanding reports are required to be filed, even if you disband the ECO.
You may also wish to notify Donna Brown with the Division of Elections at 850-245-6297 of your new
address for their records (or you may be able to update your address through the electronic filing system
(EFS) database
Please submit your initial response to the complainVreferral by the close of business on September 4,
2014. If you have any questions, please let me know
Sincerely,
D~,
A"""'
fVl~y
Agency Clerk
850-922-4539
Mrs . Malphurs, I am in r~Ceipt of the complaint a
Kyle Bedran
From:
To:
Date:
Subject:
• 081iii2014'10:47:00.AM
08/21/2014 10:47 AM
Re: Confidential Case No.: FEC 14-175 -- Please respond
Mrs . Malphurs,
I am in receipt of the complaint and will issue a response within the allotted time
Thank you,
Kyle A Bedran, Esq
[email protected]
904-502-3327
named above If you are not the intended recipient of this email, or an authorized employee or agent responsible for
Page I of I
Re: Confidential Case No.: FEC 14-175 -- Please respond
Kyle Bedran
to:
08/2112014 10:47 AM
Show Details
History: This message has been replied to .
Mrs . MalphUis,
I am in receipt of the complaint and will issue a response within the allotted time .
Thank you,
Kyle A Bedran, Esq .
BedranLaw(ii),gmail.com
904-502-3327
lhis email may contain PRIVILEGED AND CONFIDENIIAL information intended only for the use of the addressee(s) named above
If you are not the intended recipient of this email, or an authorized employee or agent responsible for delivering it to the intended
recipient, you are hereby notified that any dissemination or copying of this email is strictly prohibited If you have received this
email in error, please notify sender by reply email and delete this email from your records Thank you for your cooperation.
file:///C:/Users/Malphursd/AppData/L.ocal/Temp/notesFCBCEE/-web6904 htm
8/21/2014
/
I
'
107 W. Gaines Street,
Suite 224 Collins Building
Tallahassee, Florida 32399-1050
Telephone: (850) 922-4539
Fax: (850) 921-0783
August 21, 2014
Green Cove Springs, FL 32043
RE:
Case No.: FEC 14-175, Respondent: Kyle Alexander Bedran as treasurer, and
.Florida Citizens for Sma1t Justice, an electioneering communications organization
Deai Mr. Bedian:
On July 10, 2014, the Florida Elections Commission mailed notification to you that the Division
of Elections refo11ed you and yoUl organization for failure to file required 1epo1ts (2014 M2 and
M3).. However, our notification was retUlned to us "unclaimed"
Pursuant to OUl telephone conversation today, I am enclosing a copy of the refonal/complaint
documents for your review and action Fot your convenience, I have also emailed them to you at
[email protected] Please take a moment to confirm receipt via email at
fec@m yfl 01idal egal. com
Thank you for your cooperation If you have any questions, please contact me
Sincerely,
L~'IYL~--
Donna Ann Malphurs
Agency Clerk
/dam
Enclosure: Complaint/Refonal w/attachments
cc: Kyle Alexander Bedran, Treasurer, Florida Citizens for Smart Justice (ECO) via
[email protected]
Confidential Case No . : FEC 14-175 -- Please respond
Florida Elections Commission to: bedranlaw
From:
To:
08/21/2014 10:26 AM
[email protected]
Kyle Alexander Bed1an
Green Cove Springs, FL 32043
RE:
Case No.: FEC 14-175, Respondent: Kyle Alexander Bedran as treasurer, and
Florida Citizens for Smart Justice, an electioneering communications organization
Dear Mr Bedran:
On July 10, 2014, the Florida Elections Commission mailed notification to you that the Division
of Elections refened you and your 01ganization for failure to file required reports (2014 M2 and
M3) However, out notification was returned to us "unclaimed."
Pursuant to our telephone conversation today, I am enclosing a copy of the refenal/complaint
documents for your review and action For your convenience, I have also emailed them to you at
[email protected]. Please take a moment to confitm receipt via email at
[email protected] .
14-175 Referral from DOE .pdf
Thank you for your cooperation If you have any questions, please contact me.
Since1ely,
D~ A""""" /\ll~y
Agency Clerk
/dam
Enclosure: Complaint/Referral w/attachments
cc: Kyle Alexande1 Bedran, Treasuret, Flotida Citizens for Smatt Justice (ECO) via
[email protected]
Page I of I
I
•
Re: Please call 850-922-4539
Kyle Bechan
to:
Donna Malphws
08/21/2014 09:54 AM
Show Details
612 S . West St
Green Cove Spring, FL 32043
On Thu, Aug 21, 2014 at 9:42 AM, Donna Malphws <[email protected]> wrote:
Dear M1 Bedran,
Please call me to discuss an important confidential matter
Thank you,
D~AIMV/\11~$/
Agency Clerk
F loiida Elections Commission
donna.malphu1 s(almyfloridalegal.com
850-922-4539; Fax 850-921-0783
Kyle A. Bedran, Esq .
Bed1anLaw@l)gmail.com
904-502-3327
This email may contain PRIVILEGED AND CONFIDENTIAL information intended only for the use of the addressee(s) named above
If you are not the intended recipient of this email, or an authorized employee or agent r·esponsible for delivering it to the intended
recipient, you are hereby notified that any dissemination or copying of this email is strictly prohibited. If you have received this
email in error, please notify sender by reply email and delete this email from your records Thank you for your cooperation
file:///C:/Users/Malphursd/AppData/Local/Temp/notesFCBCEE/-web9739.httn
8/21/2014
Please call 850-922-4539
Donna Malphurs to: bedranlaw
Cc: kab
From:
To:
Cc:
Donna Malphurs/OAG
bedranlaw@gmait com
[email protected]
Dear Mr Bedran,
Please call me to discuss an important confidential matter
Thank you,
D~
Al'IA-V /Vt~_s,
Agency Clerk
[email protected]
850-922-4539; Fax 850-921-0783
08/21/2014 09:42 AM
The Florida Bar. MemberProfile
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FOR THE PUBLIC
THE FLORIDA BAR I Find A Lawyer f MemberProfile
Member in Good Standing
Bar Number:
94864
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I
'
FEC REFERRAL FORM
,
2014 JUL 10 p 1: 38
To FEC from Division of Elections
Name:
Account Number:
59846
Chairperson:
Treasurer:
Registered Agent: Kyle Alexander Bedran
The Division of Elections is referring this issue to the Florida Elections Commission
pursuant to Sections 106 ..25, Section 106 . 0703(6), and 106 .19(1 )(c), Florida Statutes
Section 106 . 0703(6) Florida Statutes, requires the filing officer to notify the FEC of a
oo.litical-eommittees-alleged failure to file reports as set forth in the notification .
cc·c
In the alternative, Florida Citizens for Smart Justice failed to notify the filing officer on
Jhe prescribed reporting dates that no reports were to be filed. Late filing of the
required waiver notice(s) reflects a deliberate failure to provide information to the filing
officer as required by Section 106.0703(7)(d), Florida Statutes.
Report(s):
2014 M2 Report
2014 M3 Report
Sent By:
Date:
slb
Kristi Reid Bronson
July 9, 2014
i;.,ef.J
OUOUU1
/
i
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AFFIDAVIT
STATE OF FLORIDA
County of Leon
Kristi Reid Bronson, being duly sworn, says:
1
I am the Chief of the Bmeau of Election Records of the Division of Elections (Division). In
that capacity, I oversee the Division's duties related to the filing of campaign finance reports.
2
This affidavit is made upon my personal knowledge, including information obtained from
review of the attached records, of which I am the custodian .
3..
I am oflegal age and competent to testify to the matters stated herein.
4
Florida Citizens for Smart Justice (59846) is an electioneering communications organization
registered with the Division. On June 7, 2012 , Kyle Alexander Bedran filed the DSDE
41 and 103 with the Division of Elections indicating that he was the chairperson and treasurer
for the 01ganization (See attached documents and acknowledgment letter )
5
The 2014 M2 campaign treasurer's report was due on March 10, 2014 At the time the
rep01t was due, Mr.. Bedran was the treasurer.
6
On March 11, 2014, the Division mailed Mr Bedran notifications that the 2014 M2 campaign
treasurer's report had not been filed. (See attached letter) .
7
On March 24, 2014, the Division mailed Mr.. Bedran notifications thatthe 2014 M2 campaign
treasurer's report had not been filed (See attached letter).
8.
On April 11, 2014, the Division mailed Mr . Bedrnn final notification with delivery
confirmation that the 2014 M2 report had not been filed . (See attached letter with delivery
confirmation}.
9
The 2014 M3 campaign treasurer's report was due on April 10, 2014. At the time the
rep01t was due, Mr Bedr an was the treasurer
10
On April 11, 2014, the Division mailed Mr.. Bedran notifications that the 2014 M3 campaign
rNV035 (S/00)
OOOOu2
treasurer's report had not been filed..
(See attached letter)
11
On April 25, 2014, the Division mailed Mr. Bedran notifications that the 2014 M3 campaign
treasurer's report had not been filed (See attached letter).
12..
On May 8, 2014, the Division mailed Mr . Bedran final notification with delivery
confirmation that the 2014 M3 report had not been filed . (See attached letter with delivery
confirmation).
13
As of July 9, 2014, Florida Citizens for Smait Justice has failed to file the 2014 M2 and
2014 M3 reports.
I hereby swear or affirm that the foregoing information is true and correct to the best
of my knowledge.
Sworn to or affirmed) and subscribed before me this 9th day
of July, 0
Print, Type, or S t a
Com
7p
ssioned Name of Notary
Public
Personally Known
JOELMYNAAD
I.ff COMMISSION # ff 115'14!6
EXPIRES: May 16, 2018
Bonded 'l1wll NollfyP,bllc Unde-.s
INV035 (5/00)
i
____
REGISTERED AGENT
STATEMENT OF APPOINTMENT
(Section 106 022, F.S . )
liJ
D
Change of Mailing Address
--·····~
Name
..., ,... ,... :: j \~ifB@. USE ONLY
12 JUN-4 PH \2: 58
DIV\:;iG;l G.' ELE CTlONS
SECRETARY OF STATE
D
D
Original Appointment
.._
..,_
Change of Appointment
Change of Physical Address
Registered Agent and Office Information
...----·--- ·-··---Telephone
Street Address
1661 Riverside Ave. #412
City
Jacksonville
904-502-3327
·--
--=~·--------·---Rf----
- - - ---:=-
1f~ig~~~
----·--
-~·--
Mailing Address
I State
City
Jacksonville
---------·-
Zip Code
FL
32204
---·-·---••n""""
I accept this appointment and confirm that I am familiar with and accept the obligations of the position as set
forih in Section 106.022, F.S. I also understand that I may resign this appointment by executing a written
statement of resignation and filing it with the applicable filing officer
~---~
' - l. 12 ------Date
~dAgenl
-··
Former Registered Agent and Office Information (for changes only)
·----··--w·--••n-··--·-•-•·-·-----•-••-·--
Name
I Telephone
------·-
Street Address
-------··--''H•--'"''''''--'"
City
----•Rm
•.
-·-
I State
I Zip Cod.e
Committee or Organization Information
--
----~---
Name of Committee or Organization
Street Address
City
Jacksonville
-
Telephone
904-502-3327
,
___,, __
--f~~ate
Zip Code
32204
~=""
~~:=---fule Alexander Bed ran
Printed Name of Chairperson
Form DS·DE 41(revised6111)
6,l-12.
Date
-
r
r
I
Kyle Alexander Bed ran, Esq .
1661 Riverside Ave . #412
12 JUN -4 PH /2: 58
~¥bWt~~~·yt0LFESCT1011s
TATE
904-502··3327
[email protected]
Re: Florida Citizens for Smart Justice
Department of State
Room 316 RA Gray Building
500 S. Bro no ugh Street
Tallahassee, FL 32399·-0250
To Whom It May Concern:
Attached please find the required DS-DE 41 Appointment of Registered Agent and the DS .. DE
103 Electioneering Communication Statement of Organization forms for filing Please let me know when
the Division has certified the above entity or if further information is needed
Thank you very much for your attention to this matter.
Kyle Alexander Bed ran, Esq
Enclosures
I
I
I
I,
'
"'I.''''!'
.I
. n
.,- l'.'." ,.., c" I., '1 F
. .
~·
'
12 JUN-4 PM \2: 58
5
o~~~~~ifA~RY 2~f~~hDfE
(PLEASE TYPE)
OFFICE USE ONLY
1. Full Name of Organization
Telephone
·-
-
·--------·------
-·
904-502-3327
1650 Margaret St. Ste. 302 PMB #147, Jacksonville, FL 32204-3869
Street Address (include city state and zip code)
1661 Riverside Ave Apt 412, Jacksonville, FL 32204
2. Affiliated or Conne<:ted Organizations
Mailing Address
Relationship
None
3. Area, Scope and Jurisdiction of the Organization
Statewide organization to promote the common good and welfare of the citizens of the State of Florida
-
4 . Identify by Name, Address & Position, the Custodian of Books & Accounts for the Organization
--·
Full Name
Mailing Address
Street Address
--- ···-
Title or Position
....
Jacksonville FL 32204
5. This Organization was formed (check applicable box): (Calendar quarters end the last day of March, June,
September, and December. )
ii As a newly created organization during the current calendar quarter.
0 From an organization existing prior to the current calendar quarter.
fH'nn<'h
Form DS··DE 103 (Rev. 08/10)
I
~
(
6,, List By Name, Mailing and Street Address, & Position, Other Principal Officers, including the treasurer and
deeu~ treasurer, if anv. Include the top-ranking officer's (e.Q., chairperson) name and information.
-·-·
Full Name
Street Address
Mailing Address
Title or Position
--··
1661 Riverside Ave. #412 1661 Riverside Ave. #412
Chairman
Treasurer
7. In the Event of Dissolution, What Disposition will be Made of the Residual Funds?
As Provided by law
8 . List All Banks, Safety Deposit Boxes, or Other Depositories Used by this Organization for Electioneering
Communications
·---------..
--·Mailing Address
-
-
-.. ----•'""
Bank of America
2011 San Marco Blvd
9. List All Reports Required to be Filed by this Organization with Federal Officials, & the Names, Addresses,
& Positions of Such Officials, If Any
-~---
Report Title
Form 8871
Form 1120-POL
Form 990
Upon Formation
March 15th Annually
May 15th Annually
__ ____
STATE OF Florida
I,
Name & Position of Dfficial
--·
Mailing Address
Atlanta, GA 39901 .. 0099
Duval
,..
COUNTY
... certify that the information in this Statement of
~·
)(,./~ ~-,,~\lilrO~
1 op-ranking
o-{-IZ
Principal Officer of Organization .
OCD0>1'-;:
Date
··--·-·--·--
':~
":'>r::-..,.,...
. ·... ;.1,
. , 'I
12 JUN~7
DIVJ5
.
.t:-D
'
• :....
AH 9.·' 46
SfCR~f U1 lL ··c .
ARy o/sflONs
:4rt
(PLEASE TYPE)
OFFICE USE ONLY
1 . Fun Name of Organization
Telephone
_.. -
-
904-502-3327
1650 Margaret St Ste 302 PMB #147, Jacksonville, FL 32204-3869
.
----
·-
·---·
1661 Riverside Ave. Apt 412, Jacksonville, FL 32204
2 . Affiliated or Connected Organizations
·-
.
.•.
·-
Mailing Address
Relationship
····----
None
3. Area, Scope and Jurisdiction of the Organization
Organization to promote Smart Justice, as defined by Florida Taxwatch, by supporting Judicial Candidates who stand
for Smart Justice .
4 . Identify by Name, Address & Position, the Custodian of Books & Accounts for the Organl:zation
.
-
.•.
Full Name
Mailing Address
··--·
Street Address
Title or Position
·--
Jacksonville FL 32204
5 . This Organization was formed (check applicable box): (Calendar quarters end the last day of March, June,
September, and December.)
Ii] As a newly created organization during the current calendar quarter.
0 From an organization existing prior to the current calendar quarter.
Form OS-DE 103 (Rev. 08110)
(
6. List By Name, Mailing and Street Address, & Position, Other Principal Officers, including the treasurer and
deoutv treasurer, if any. Include the too-rankinQ officer's /e.Q., chair·personl name and information.
-
Full Name
Mailing Address
Street Address
...
Title or Position
-
Chairman
Treasurer
7. In the Event of Dissolution, What Disposition will be Made of the Residual Funds?
As provided by law
8. List All Banks, Safety Deposit Boxes, or other Depositories Used by this Organization for Electioneering
Communications
..
Mailing Address
---··
··-·
·-
2011 San Marco Blvd
Bank of America
9 List All Reports Required to be Filed by this Organization with Federal Officials, & the Names, Addresses,
& Positions of Such Officials, If Any
,_.__.
--
--
Report Title
Form 8871
Form 1120-POL
Form 990
-----
Upon Formation
March 15th Annually
May 15th Annually
Mailing Address
---··-
--~--~·-
Atlanta, FA 39901-0099
Duval
STATE OF Florida
I,
..
COUNTY
·--..- - - ' certify that the information in this Statement of
~---~
~---~-~
~---------·
--~
--··
,,.... ~
---
,_y-- ~f Top-ranking Principal Officer ~f Organizati~C OO•.,•S
Form OS-OE 103 (Rev. 08/10)-· page 2 of 2
•..
6 --·
~
.
12
Date
Note: If necessary, continuation sheets should be used to complete the form.
('
Kyle Alexander Bedran, Esq.
1661 Riverside Ave #412
904-502-3327
[email protected]
Re: Florida Citizens for Smart Justice
Department of State
Room 316 RA Gray Building
Tallahassee, FL 32399-0250
To Whom It May Concern:
Attached please find the revised DS-DE 103 Electioneering Communication Statement of
Organization for filing . Please let me know when the Division has certified the above entity or if further
information is needed.
Thank you
very much for your attention to this matter
Sincerely,
Kyle Alexander Bed ran, Esq
Enclosures
RICK SCOTT
Governor
KENDETZNER
Secretary of State
June 15, 2012
Florida Citi:.wns for Smar1 .Justice
l 650 Margaret Street, Suite 302
Jacksonville, Florida 32204-3869
Dear Mr Bedran:
This will acknowledge receipt of the Application for Certification for Flodda Citizens for
Smart Justice, which was placed on file in our office on .June 7, 2012 This information appears
to comply with the requirements of Section 106 011 and 106.03, Florida Statutes, and the name
of this organization has been placed on our active list as an electioneering communication
organization
Campaign Treasurer's Reports
Your fhst campaign treasurer's report will be due on July 1.3, 2012 The report will cove1 the
period of April 1, 2012 ··July 6, 2012 . All electioneering communication organization that file
reports with the Division of Elections are required to file by means of the Division's electronic
filing system (E FS).
Credentials and Sign-ons
Belo\' is the web address to access the EFS and the organization s user identification nurnbc1
The enclosed sealed envelope contains the organization's initial passwo1d Once you have
logged in using the initial password, you will be immediate!} prompted to change it to a
confidcntiul sign-on.. The chairperson, treasurer, and deputy treasurers are responsible J01
protecting this password from disclosure and are responsible for all filings using these
credentials . unless the Division is notified that your credentials have been comprnmised
EFS Web site Addr·ess: https://efs . dos state 0 .us
Identification Number: 59846
)l
VIVA flORIDA 50ll
R A. Gray Building • 500 South Bronough St,.eet • Tallahassee, Florida 32399·0250
Telephone: (850) 245-6240 • Facsimile: (850) 245 .. 6259 www.dos . state.fl.us
Commemor·ating 500 years of F'lorida htstory
www fiaSOO .. com
0 1 ·'v"O' ·~ -41
'-·
__..... )f
)
VIVA frnRID
(
I
Mr Kyle Alcxande1 l3edran, Chairperson
June 15, 20 l:2
Page Two
Pin Number·s
Pin numbers are confidential secure credentials that allow you to submit repons and update
personal information The enclosed sealed envelope contains your confidential pin numbers for
you
Each electioneering communication organization chairpernon is required to provide the Division
of Elections with confidential personal information that may be used to allow access in the event
that the password is fo1gotten or lost When you enter the organization's account screen, there
will be a drop down box where you pick a question (such as Whal 11 yow mother s maiden
name?) and supply an answer. All passwords and answers to questions are stored as encrypted
data and cannot be viewed by Division staff and given out over the phone.. Please notify the
Division if your credentials have been compromised.
All reports must be completed and filed through the EFS not later than midnight, Eastern
Standard Time, of the due date. Reports not filed by midnight, Eastern Standard Time, of the
due date are late filed and subject to the penalties in Section 106 07(8), Florida Statutes Jn the
event that the EFS is inoperable on the due date, the repon will be accepted as timely filed if
filed no later than midnight, Eastern Standard Time, of the first business day the EFS becomes
operable No fine will be levied during the peliod the EFS was inoperable
Any electioneering communication organization foiling to file a report on the designated dL1e
date is subject to a fine of $50 per day for the first 3 days and, thereafter, $500 per day for each
day, not to exceed 25% of the total receipts or expenditures, whichever is greater, for the period
covered by the late report However, for the reports immediately preceding each primary and
general election, the fine shall be $500 pe1 day, not to exceed 25% of the total receipts ot
expenditures, whichever is greater, for the peiiod cove1ed by the late report
.Electronic Receipts
The person submitting the report on the EFS will be issued an electronic receipt indicating and
veritYing the report was filed . Each treasurer's report Jiled by means of the EFS is considered to
be under oath by the chairperson and campaign treasurer and such persons are subject to the
provisions of Section l 06 .07(5), Florida Statute
Ol00~L2
June l5, 2012
Page Three
Instructions and Assistance
An Qnline instruction guide is available to you on the EFS to assist with navigation, data entry,
and submission of reports. The Division of Elections will also provide assistance to all usc1s by
contacting the EFS Help Desk at (850) 245-6280
All of the Division's publications and repor1ing forms are available on the Division of
Elections' web site at http://election.dos . state.fl.us, It is your responsibility to read,
understand, and follow the requir'cments of Florida's election laws. Thcr·efore, please print
a copy of' the following documents: Chapters 104 and 106, Florida Statutes, 2012
E/ectio11eeri11g Communications Organization Ha11dbook, 20 I 2 Calendar of Reporting Dates·
and Rule JS-2.017, Florida Administrntive Code.
Please let rne know if you need additional information
Sincerely,
b
C ,/Bureau of Election Records
KRB/ljr
Endosures
)
I
'
Ken Detzner·
Secretary of State
Ma1ch 11, 2014
Kyle Alexande1 Bed1an, Treasurer
Florida Citizens for Sma1t Justice
Apt 1206
Re: ECO 59846
Dea1 Mr. Bedran:
Your campaign treasurer's report, which was due March 10, 2014, has not been received
Sections 106 0703(7)(b ), Florida Statutes, require that the filing officer immediately
Once your report is filed, this office will notify you of the specific amount of your fine. Fines must be paid
Please be advised, however, that failure to file a campaign treasurer's report may constirute a violation of
Chapter 106, Florida Statutes, independent of the automatic fine violation referenced above Therefore, if
you fail to file a report, the division will turn the matter over to the Florida Elections Commission.
Section I 06 265(1 ), FIorida Statutes, authorizes the Florida Elections Commission, to impose a civil
penalty up to $1,000 per count for each willful violation of Chapter 106
If you have any questions, please contact the help desk at (850) 245 .. 6280
Sincerely,
u~¥Ut~·----L r i s t i Reid Bronson, Chief
\l
The RA Gray Building-Room 316 • 500 South Bronough Street
• TalJahassee Fl 32399-0250 • (850) 245··6240
(
Ken Detzner
Secretary of State
Second Notice
March 24, 2014
Apt 1206
Re: ECO 59846
Dear Mr. Bedran:
Your campaign ueasurer's report, due March l 0, 2014, has not been received,
Sections l06,0703(7)(b), Florida Statutes, require that the filing officer immediately notify you of
the failure to file a report
The first notice of the failure to file the above mentioned repoct was mailed, via regulac mail, to the
address on file with our office on March 11, 2014 As of this date, we do not show a record of
receiving this rcpott
If the report is not filed via the Division's electronic filing system within 14 days of receipt of'
this notice, this matter will be referred to the Florida Elections Commission for further action,
Section 106265(1), Florida Statutes, authorizes the Florida Elections Commission, upon finding
a will fol violation of Chapter l 06, Florida Statutes, to impose a civil penalty up to $1,000 per
lfyou have any questions, please contact the help desk at (850) 245-6280
Sincerely,
5
f nn ........
:'
o'-.,.v\J~
lhe RA Gray Building-Room 316 • 500 South Bronaugh Street
• Tallahassee FL 32399 .. 0250 • (850) 245-6240
/
I
I
FioruoA DEPARTMENT of S:rf\:i:~
RICK SCOTT
KENDETZNER
Governor
Secretary of State
FINAL ~OTICE
- &CUSTOMER
USPSTRACKlflG•
9114 9010 7574 2751291632
FOi' TradOng or Inquiries go to USPS com
or call 1-800-222.. 181 t
RECEIPT
April 11, 2014
Florida Citizens for Smart Justice ( 59846)
Dear Mr McDonald:
report:
Year
Report
Cover' Period
2014
M2
0210I/2014 - 02/28/ 14
The organization has previously been notified of the repon that is outstanding Enclosed are copies of letters
sent by the Division, If the report is not filed within 7 dan of.receipt of this letter, the Division will forward
this matter to the Florida Elections Commission for further action, Section I 06265(1 ), Florida Statutes,
authorizes the Florida Elections Commission to impose civil penalties of up to $1,000 per violation
Sincerely,
~ ~-' ~1.L~~ -~.
Bureau of Elec1ion Records
KRB/dsb
Enclosure
OCOOJ.. 6
R,,A,,
11111 I
P'I IU\I .. l
Gray Building, Suite 316 • 500 South Bronough Street• Tallahassee, Florida 32399
..........
850,245.6200 • 850,,245.6217 (Fax) election.dos.state,fl.us
FLORIDA
VivaFlorida,,org
ff'Ec1'i0Nl
I
I
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'
FLOR1DA DEPARTMENT OF STATE
Ken Detzner
Secretary of State
March 11, 2014
.3 l West Adams Street
Apt 1206
Jacksonville, Fl 12202-2202
Re: ECO 59846
Dear Mr Bedran:
Your campaign treasurer's report, whicn was due March 10, 20\4, has not been received
Sections I 06.0703(7)(b), Florida Statutes, require that the filing officer immediately
notify you of the failure to file this report and that a fine will be assessed of $50 per day for the first ] days
lo the filing officer within 20 days of receipt of the payment due notice
Please be advised, however, that failure to file a campaign treasurer's report may constirute a violation of
Chapter \ 06, Florida Statutes, independent of the automatic fine violation referenced above Therefore, if
you fail lo file a report, the division will turn the matter over to the Florida Elections Commission
S~ction 106 265(1), Florida Statutes, authorizes the Florida Elections Commission, to impose a civil
penalty up to $1,000 per count for each willfUI violation of Chapter I 06
If you have any questions, please contact the help desk at (850) 245··6280
Sincerely,
.!2. •
(\ n ~ > 'J __
U»4...)t.t.U~~--__.J
' I\• • •..Q
L
\S
L
risti Reid Bronson, Chief
0(,00.L?
Ken Detzncr·
Secretary of State
DIVJSION OF ELECTIONS
Second Notice
March 24, 2014
Florida Citizens fot Smart Justice
Apt 1206
Re: ECO 59846
Dear Mr Bedran:
Your campaign treasurer's report, due March 10, 2014, has not been received
Sections 106.0703(7)(b), Florida Statutes, require that the filing officer immediately notify you of
address on file with our office on March I I, 2014 As of this date, we do not show a record of
this notice, this matter will be referred to the Florida Elections Commission for further action.
Section 106265(1 ), Florida Statutes, authorizes the Florida Elections Commission, upon finding
a willful violation of Chapter \06, Florida Statutes, to impose a civil penalty up to $1,000 per
Sincerely,
ocoo_~s
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hnps://tools. usps com/go/J rackConfinnAction! input action?tRef=qt&tL.c..O&tLabels"'9 l l 490 I07574 275 l29NjE~~J~l}:l4
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Jo
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'
FLORJDA DEPARTMENT OF STATE
KenDetzner
Secretary of State
April 11, 2014
Apt 1206
Re: ECO 59846
Dear Mr. Bedran:
Your campaign treasurer's report, which was due April JO, 2014, has not been received
Sections 106. 0703(1)(b), Florida Statutes, require that the filing officer immediately
notify you of the failure to file this report and that a fine will be assessed of$50 per day for the first 3 days
Once your report is filed, this office will notify you of the specific amount ofyour fine Fines must be paid
Chapter 106, Florida Statutes, independent of the automatic fine violation reforenced above Therefore, ii
you fail to file a report, the division will tum the matter over to the Florida Elections Commission
Section I 06265(1 ), Florida Statutes, authorizes the FJorida Elections Commission, to impose a civil
penalty up to $1,000 per count for each willfol violation of Chapter I 06
Sincerely,
AJ /U·~.e-~o<~--Kristi Reid Bronson, Chief
ocoozo
lhe RA Gray BuildinR-Room 316 • 500 South Bronough Street
• Tallahassee FL 32399-0250 • (850) 245-6240
(
I,_
Ken Detzner
Secretary of State
Second Notice
April 25, 2014
Florida Citiz.ens for Smart Justice
Apt 1206
Re: ECO 59846
Dear Mr Bedran:
Your campaign treasurer's report, due April I 0, 2014, has not been received
Sections 106. 0703(7)(b), Florida Statutes, require that the filing officer immediately notify you of
The fast notice of the failure to file the above mentioned report was mailed, via regular mail, to the
address on file with our office on April 11, 2014 As of this date, we do not show a record of
receiving this report.
this notice, this matter will be reftmed to the Florida Elections Commission for fi.Jrther action
Section I 06.265( 1), Florida Statutes, authorizes the Florida Elections Commission, upon finding
a willful violation of Chapter 106, Florida Starutes, to impose a civil penalty up to $1,000 per
Sincerely,
~~-£-~~~;
OC0021
The R A Gr•v Ruildino-Room 316
• 500 South Bronoueh Street
• Tallahassee Fl 32399-0250 • (850) 245--6240
/
"
(
FLORIDA DEPARTMENT of STAT~
RICK SCOTT
KENDETZNER
Governor
Secretary of State
FINAL NOTICE
USPS TRACKlNG f.
&CUSTOMER
RECEIPT
9114 9011 5981 8370 3038 49
ForTra~~r Inquiries go to USPS com
or ¢iii! 1..aaa.222.. 1s11
May 8, 2014
Kyle Alexander Bedran, I reasurer for
Dear Mr . Bedran:
According 10 a review of the Division's records, the organization reforenced above has not filed the following
1eports:
2014
2014
Report
Cover Period
M2
M3
02/01/2014 - 02/28/2014
03/01/2014 - 03/31/2014
The organization has previously been notified of the reports that are outstanding Enclosed are copies of letters
sent by the Division If the reports are not filed within 7.dan of receipt of this letter, the Division will forward
this matter to the Florida Elections Commission for further action Section I 06 .265( I), Florida Statutes,
authorizes the Florida Elections Commission to impose civil penalties of up to $1,000 per violation
If you have any questions, please call the help desk at ( 850) 245-6240
Sincerely,
di~~~k,q 'iS-.
KRB/slb
Enclosures
OCD022
)k
11111• r1
nn1n1
RA. Gray Building, Suite 316 • 500 South Bronaugh Street• Tallahassee, Florida 32399
,.....,,
850.245.6200 • 850.245.6217 (Fax) election dos.state .. 11.,us
FLORIDA
*l)l\l~UJ,11111
VivaFlorlda . org
ELECTION!
.I
I
Ken Det.t;ner
Secretary of State
March 11, 2014
Kyle Alexander Bedran, I reasurer
3 J West Adams Street
Apt 1206
Re: ECO 59846
Dear Mr Bedran:
Your campaign treasurer's report, which was due March 10, 2014, has not been rcceiwd
Sections I 06 . 070.3(7Xb), Florida Statutes, require that the filing officer immediately
Please be advised. however, that failure to file a campaign treasurer's report may constitute a violation of
Chapter 106, Florida Statutes, independent of the automatic fine violation referenced above Th~ieforc, if
you fail to file a report, the division will turn the maner over 10 the Florida Elections Commission
Section 106.265(1), l'lorida Statutes, authorizes the Florida Elections Commission, to impose a civil
Sincerely,
Ken Detzner
Secretary of State
Second Notice
March 24, 2014
Florida Citizens for Smmt Justice
Apt 1206
Jacksonville, Fl 32202-2202
Re: ECO 59846
Dear Mr. Bedran:
Your campaign treasurer's report, due March I 0, 20 I4, has not been received.
Sections 106 0 703(7)(b), Florida Statutes, require !hat the filing officer immediately notify you of
address on file with our oflice on March 11, 2014 As of this date, we do not show a record of
this notice, this matter will be reforred to the Florida Elections Commission for further action..
Section 106.265{1 ), Florida Statutes, authorizes the Florida Elections Commission, upon finding
a willful violation of Chapter l 06, Florida Statutes, to impose a civil penalty up to $1,000 per
If you have any questions, please contact the help desk al (850) 245-6280
Sincerely,
~A.-~7L--R~~~
000024
/
I
I
(
I
Ken Detzner
Secretary of State
April 11, 2014
3 l West Adams Street
Apt 1206
Jacksonville, FL 32202.. 2202
Re: ECO 59846
Dear Mr Bedran:
Your campaign treasurer's report, which was due April 10, 2014, has not been recci ved
Sections I 06 . 0703(7)(b), Florida Statutes, require that the filing officer immediately
notify you ofthe failure to file this report and that a fine will be assessed of $50 per day for the first .3 days
to the filing oflicer within 20 days of receipt of the payment due notice
Chapter 106, Florida Statutes, independent ofthe automatic fine violation referenced above Thereforu, if
you fail to file a report, the division will turn the matter over to the Florida Elections Commission
Section I 06.265(1 ), Florida Statutes, authorizes the Florida Elections Commission, to impose a civil
lfyou have any questions, please contact the help desk at (850) 245-6280
Sincerely,
~~"~;~.....
0(0025
(
RICK SCOTT
KENDETZNER
Secretary of State
Governor
FINAL NOTICE - USPHRACKll<G•
Delivery Conllr·mation:
&OJSTOME~
9114 9010 7674 2761 2916 32
For Ttacking
RECEIPT
or lnqulritt ~o to USPS oom
or e:tll l-&OD-222 .. 11111
April 11, 2014
Florida Citizens fot· Smar1 Justice (59846)
Dear Mr McDonald:
According 10 a review of the Division's recorus, the organization referenced above has not filed the followin:
report
Year
Report
Cover Pcrio!!.
2014
M2
0210I/2014 - 02/2&/ 14
The organization has previously been notifiexl of the repon that is outstanding Enclosed are copies of letter
sent by the Division If the repor1 is not tiled within 7 days of~ceipt of this lctt.£.!., the Division will forwan
this matter to the Florida E,lections Commission for further action Section I06 265( I), Florida Statutes
authorizes lhe Florida Elections Commission to impose civil penalties of up to $1,000 per violation
Sincerely,
~ ;1-~?l.- ~ ..~~fl..
KRB/dsh
Enclosure
'i..... V
..... u
O''"O':?'-'
I'
'
I
I
I
Ken Detzner
Secretary of Stale
Secoud Notice
April 25, 2014
Apt 1206
Jacksonville, FL '32202-2202
Re: ECO 59846
Dear Mr . Bedran:
Your campaign
treasur~r's
report, due April J0, 2014, has not been received
Sections 106.0703(7)(b), Florida Statutes, require that the filing officer immediately notify you of
address on file with our office on April 11, 2014 . As of this date, we do not show a record of
this notice, this matter will be referred to the Florida Elections Commission for forthcr action .
Section 106 265( J), Florida Statutes, authorizes the Florida Elections Commission, upon finding
Sincerely,
~Mt;;{~~-~~·
I'
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May 12_ 2014, 11:20
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Arrival at Post
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May 11 2014 12:39 am
Depart USPS Sort
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Processed through
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What"s your tracking (or receipt} number'?
https://tools usps com/gofl rackConfinnAction action?tRef=fullpage&tLc""l&text28777=&tl abels=91I49011e~100B@12014 10:40:24 AM]
fCJ
'
,.
1
1
/.
HISTORY NOTES
Unique ID
38738
Date Recorded
Last Edited Date
5/30/201410:06:00 AM
dsbrown
RE: Email from Mr Bedran and my response
Good morning Mr Bedran
Florida Citizens for Smart Justice - ECO 59846 is still an active electioneering communication organization The Division of
Elections issued a Notice of Intent to Revoke the registration of this ECO in .January 2014. However, the revocation has not
yet occurred and may be some time. if ever My understanding is that the rule regarding financial activity has been
challenged. Therefore, until a decision is made by the court, revocations are pending, Should the ruling result in proceeding
with the revocations you will receive a Final Order revoking the registration for ECO 59846
As long as this ECO is active, financial reports are required by Florida Statutes. Florida Citizens for Smart .Justice currently
has three outstanding financial reports that must be filed: 2014 M2 M3 and M4 The 2014 MS report will be due no later than
June 10 2014
If you would like to disband the ECO, please send a letter requesting disbandment (Disbandment does not absolve the
requirement to file financial reports Until notification that the ECO has been made inactive by the Division financial reports
will be required )
If you have any questions or I may be of further assistance please do not hesitate to contact me
Best regards,
Donna S Brown
From: KyleBedran[mailto:bedranlaw@gmail com]
Sent: Thursday May 29, 2014 7:52 PM
To: Brown, Donna S.
Subject: Re: ECO 59846 - Florida Citizens for Smart Justice
Mrs. Brown,
Florida Citizens for Smart Justice Inc. was administratively dissolved last year and we received a letter from the Division of
Elections stating the ECO was to be terminated Is further action necessary on our part to terminate the ECO?
Sincerely,
38721
5/2912014 12:53:00 PM
dsbrown
RE: Returned FF Second Notice (M4 report)
A copy of the Seond Notice for failure to file the report due May 12 2014 was emailed to the Chairperson today:
Florida Citizens for Smart .Justice - ECO 59846
Dear Mr Bedran
The Second Notice for failure to file your May 12, 2014 campaign treasurer's report was returned to our office as Return to
Sender'' The Notice was mailed to your address of record as the Registered Agent for Florida Citizens for Smart .Justice
To avoid further delay_ I have attached a copy of the Notice for your information and records
If this report is not filed via the Divisions electronic filing system within 14 days of receipt of this notice this matter will be
referred to the Florida Elections Commission for further action (See attached letter)
If you have any questions please feel free to contact me direct at (904) 245-6297
Regards
Donna S Brown
Page 1 of4
71712014
HISTORY NOTES
Unique ID
Date Recorded
38364
Last Edited Date
dsbrown
4/1/2014 4:05:00 PM
RE: Returned Mail
Email sent to Chairperson today:
Dear Mr Bedran
The Second Notice for failure to file your March 10, 2014 campaign treasurer's report was returned to our office as Return to
To avoid further delay, I have attached a copy of the Notice for your information and records
If you have any questions_ please feel free to contact me direct at (904) 245-6297
36628
ljrandolph
1/22/2014 2:01 :00 PM
RE: Returned Mail
I called and left a message Mr Bedran regarding returned mail that we received I left my contact information and asked for
him to return my call
35894
12/18/2013 2:24:00 PM
1/22/2014 4:23:09 PM
lbelvin
RE Updating the address
604-502-3327
I called and spoke with Mr Bedran because when I was processing the mail it was given to me stamped as incomplete
Looking over the form there were a few errors, however, this committee was already in the system and the only thing he was
doing was trying to change the address for our records He said that he had already went into the EFS sytem to make
changes and the only reason he sent the forms were to create a paper trail
35762
12/12/201311:22:00 AM
elalexander
Re: Return of Mall
Re-mailed to Mr Bedran on 12/12/2013
35761
12/12/2013 11 :20:00 AM
elalexander
Re: Return of Mail
Called Mr Bedran and left a detailed voice message in regards to change of address
Noticed the following:
- Address has been updated in EFS with a valid email address and linked into CanCom with the new mailing address
Page2 of4
7/7/2014
HISTORY NOTES
Unique ID
Date Recorded
35409
12/2/2013 9:38:00 AM
Last Edited Date
elatexander
Re: Return of Mail
The following email was sent to Mr. Bedran (Bedranlaw@gmail com) in regards to return mail:
Dear Mr Bedran
This is a follow-up email to a return of mail that was received in our office on November 25 2013 for the following ECO
(Florida Citizens for Smart Justice) We just need to verify that we have the proper address for you If we do not we will need
the following to ensure that we keep your information updated within our office:
1.A signed written notification verifying a change of address This may be scanned and emailed to our office or faxed to our
office at (850) 245-6259 or (850) 245-6260
2 Please update your contact information in EFS, as well as providing a valid email address for future notifications
Below is the following address that we have on file for you:
1650 Margaret Street, Suite 302, PMB 147
Jacksonville Florida 32204
If the information listed above is incorrect, please follow the instructions provided so that we may update our system with your
most recent contact information If you have any questions please call our office at (850) 245-6240
Sincerely,
Erica Leondria Alexander
Regulatory Specialist 1
Florida Department of State
R.A Gray Building
Tallahassee FL 32399
Note: This response is provided for reference only and does not constitute a formal legal opinion or representation from the
Department of State or the Division of Elections As applied to a particular set of facts or circumstances, interested parties
should refer to the Florida Statutes and applicable case law, and/or consult an attorney to represent their interests before
drawing any legal conclusions or relying upon the information provided
35407
elalexander
12/2/2013 9:20:00 AM
Re: Return of Mail
Searched in BER Imaging found the following email address for Mr Bedran: Bedranlaw@gmail com
35403
elalexander
12/2/2013 9:00:00 AM
Re: Return of Mail
Called for Mr Bedran, left a detailed voice message:
-
Need to verify change of address
Please update your current address and other contact information on EFS
Please send in a signed written notification to our office notifying us of the change of address
Please call our office at (850) 245-6240
35371
11/27/2013 12:01 :00 PM
elalexander
Re: Return of Mail
Called the number on file for Mr Bedran and left a detailed voice message Below are the details from the message:
- Calling to verify current mailing address
-Advise Mr. Bedran to update his information in the EFS System for future notifications in reagrds to reporting deadlines etc
- Please call our office at (850) 245-6240
0t0031
Page 3 of4
7/7/2014
HISTORY NOTES
Unique ID
Date Recorded
35298
11/26/2013 8:23:00 AM
Last Edited Date
ELAlexander
Re: Return of Mail
Called and left a voice message for the treasurer, below are the details from the message:
- Just calling to obtain your new mailing address to send the following mail that has returned to our office to you
- Also. calling to remind you that we would still need a letter and the forms showing any changes of address or other changes
of information for the ECO (Florida Citizens for Smart .Justice)
- If you have any questions please call our office at (850) 245-6240 or my direct line (850) 245-6170
--------··-------------35297
elalexander
11/25/2013 4:48:00 PM
Re: Return of Mail
Called and spoke with treasurer, below are the following details from our conversation:
- Need a verification of address
- Has been meaning to send in the information stating a change of address to our office
- Will send in a letter and the forms showing a change of address
29267
ljrandolph
6/18/2012 11 :45:00 AM
Past notes pertaining to incomplete paperwork:
Not Processed because box 3 isnt specific enough I called and spoke to Mr bedran and explained to him that he need to be
more specific because box 3 need to state what type of candidates the committee is supporting He said that he will submit
the corrected paperwork asap LJR 6/4/2012
OlG032
Page 4 of 4
71712014

FEC 14-175 Kyle Alexander Bedran

Transcription

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