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IN THE OHIO ELECTIONS COMMISSIONDANNY R. BUBP307 North Market StreetWest Union, Ohio 45693

Complainant,v s .

TED STRICKLAND,YVETTE McGEE BROWN,STRICKLAND FOR GOVERNOR,JOHN P. BRODY, TREASURER65 East State Street, Suite 1800Columbus, Ohio 43215

Respondents.

Case No .

COMPLAINTState of O hioCounty of Franldin

R E C E I V E DO C T 2 5 2 U 1 0

O H I O E L E C T IO N S C O M l V l i S S

ss.Darmy Bubp, being first duly sworn, deposes and says as follows:1. I am a registered Ohio voter and make this Complaint based upon my personal

knowledge.2 . I am a life m ember of the National Rifle Association (N RA ). I currently serve in

the Ohio Ho use of Representatives. I have an A+ rating from the NR A and was endorsed by theNR A in my current campaign for reelection to the Ohio House. As a proud NRA m ember, I am

outraged that Ted Strickland is lying about John Kasic h's NRA rating.3 . John Kasich and Mary Taylor are the Republican candidates for Governor and

Lieutenant Governor in the general election to be decided on Nov emb er 2, 2010. Respondents

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Ted Strickland and Yvette McGee Brown are the Democrat candidates for Governor andLieutenant Governor in the general election to be decided on Novem ber 2, 2010.

4. Under R.C. 3517.01(B)(3), the joint candidates for Governor and LieutenantGovernor are a single "candidate" for certain purposes, including for the purpose of having asingle campaign comm ittee. Respondent Strickland for Governor is the campaign comm itteethat has been duly authorized by Respondents Ted Strickland and Yvette McGee B rown to act ontheir behalf Respo ndent John P. Brody is the Treasurer of the Strickland for GovernorCommittee.

5. Attached hereto as Exhibit A is a true copy of a "Media Advisory" press releasethat has been sent out by Respondents to the various news media in an effort to influence theresults of the election. This press release falsely refers to:

"John Kasich's . . . 'F' rating from the National RifleAssociation.6. In fact, John Kasich does not have an 'F' rating from the National Rifle

Association. As can readily be verified from the NRA website [at ww w.nrapvf org/upcoming-elections/Ohio.aspx ] John Kasich has a 'B ' rating from the Nation al Rifle A ssociation. A truecopy of this portion o f the NRA website is attached hereto as Exhibit B .

7. In fact, the NRA website shows that the only member of either gubernatorialticket with an 'F' rating from the NRA is Ted Strickland's chosen candidate for LieutenantGovernor, Yvette McGee Brown.

8. Respo ndents either knew that John Kasich has a 'B ' rating from the NR A or haverecklessly refused to c heck his true rating. Non etheless Respo nden ts have chosen to falselyrepresent that John Kasich has an ' F ' rating.

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9. R.C. 3517 .21(B)(1 0) makes it unlawful to "[p]ost, pub lish, circulate, distribute, orotherwise disseminate a false statement concerning a candidate, either knowing the same to befalse or with reckless disregard of whether it was false or not, if the statement is designed topromote the election, nomination, or defeat of the candidate."

10. Respondents made the above false statement either knowing it to be false or withreckless disregard of i ts truth or falsity and in an attempt to influence the resu lts of the election.

WHEREFORE, Complainant requests that Respondents be found in violation of R.C.3517.21(B)(10) and that they be appropriately sanctioned.

Further Affiant sayeth nough t.

Danny Bub^Sworn to before me and subscribed in i w presence, this 24"^ day of October, 2010.

& n A ^ J L : / C u ^ ^ ,Notary Public

MNALDCARLBREY.A t to rney^AtLaw^ W O T M I Y P U B U C , S T A T E O F O H I Ol i O i I l l s n o e x p i r a ti o n d a t e .

N D : 4825-9438-2087, V . 1

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StricklandLFor Im med iat e Release:October 22, 2010

Contact:Allison Kolodziej, Press Secretary(514) 558-8120 (cell)iLis Smith, Communications Director(6 14 ) 545 -6 84 0 ext 12 2 (office)(22 4) 5 67 -9 06 2 (cell)

* * *Med i a Advisory***SATURDAY: Governor Stricl

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To unsubscribe, go to : h ttp : / /ww w.tedstr ic k land.com /unsubs cribePaid for by Strickland for Governor, John P. Brody, Treasurer,55 E. State St. , Suite 1800, Columbus, Ohio 43215.

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National Rifle Association | Political Victory Fu nd | Local Grades Page 2 of 9

Sta tewideGOVERNOR

John Kasich (R)status: Candidatei^ Ted Strickland (D)status: Incumbent

WH Y WE ENDOR SE THIS CANDIDATE

Grade: B

Grade: A +

W HAT THE GRADES MEAN

LIEUTENANT GOVERNORMary Taylor (R)status: CandidateYvette McGee Brown (D)status: Candidate

Grade: A

Grade: F

W HAT THE GRADES MEAN

http://www.m-apvf.org/grades-endorsements/local-grades.aspx?state=Ohio&county=Fran... 10/22/2010