Peter Cammarano ELEC Complaint

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NEW JERSEY ELECTION LAW ENFORCEMENT COMMISSION P.O. BOX 185 Trenton, New Jersey 08625-0185 NEW JERSEY ELECTION LAW ENFORCEMENT COMMISSION Complainant v. PETER CAMMARANO, Candidate for Office of Mayor, City of Hoboken, Hudson County, and VINCENT ADDEO, ANGEL ALICIA, and RAUL MORALES II, Candidates for Municipal Office, City of Hoboken, Hudson County, and LUCY TRUGLIO, Campaign Treasurer, Respondents COMPLAINT AND NOTICE OF OPPORTUNITY FOR A HEARING FOR LATE AND NON-FILING OF CONTRIBUTION AND EXPENDITURE INFORMATION, FAILURE TO CERTIFY REPORTS, RECEIPT OF EXCESSIVE CONTRIBUTIONS, RECEIPT OF EXCESSIVE CURRENCY CONTRIBUTIONS, AND FAILURE TO FILE 48-HOUR NOTICES OF CONTRIBUTIONS IN THE 2009 MUNICIPAL RUNOFF ELECTION C-G 0905 04 04 R2009 C-9 0905 01 04 R2009 C-9 0905 02 04 R2009 C-9 0905 07 04 R2009 PLEASE TAKE NOTICE that the New Jersey Election Law Enforcement Commission (hereafter, the Commission) hereby files a complaint against Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, (hereafter, the Respondent Candidates), and Lucy Truglio, (hereafter, the Respondent Treasurer), and offers the Respondent Candidates and the Respondent Treasurer an opportunity for a hearing pursuant to the “Administrative Procedure Act,” N.J.S.A. 52:14B-1 et seq., to determine whether or not the Respondent Candidates and the Respondent Treasurer had the responsibility under the terms of "The New Jersey Campaign Contributions and Expenditures Reporting Act," N.J.S.A. 19:44A-1, et seq. (hereafter, the Act) for the filing of campaign reports or information required to be filed pursuant to the Act, and to determine whether or not the Respondent Candidates and the Respondent Treasurer failed, neglected or omitted to file any such report or information at the time and in the manner prescribed by law, or in any other way violated the provisions of the Act, and are therefore subject to penalties provided by the Act. The hearing will be conducted under the legal authority and jurisdiction conferred upon the Commission to impose penalties for violations of the Act, specifically Sections 6(b) and 22. The Commission by way of Complaint alleges:

description

15 NJ election violations filed by NJ ELEC against Peter Cammarano and his campaign including running mates Angel Alicea. Peter Cammarano is the former mayor of Hoboken and a convicted felon arrested and convicted for taking $25,000 in bribes from FBI informant Solomon Dwek.

Transcript of Peter Cammarano ELEC Complaint

Page 1: Peter Cammarano ELEC Complaint

NEW JERSEY ELECTION LAW ENFORCEMENT COMMISSION P.O. BOX 185

Trenton, New Jersey 08625-0185

NEW JERSEY ELECTION LAW ENFORCEMENT COMMISSION Complainant v. PETER CAMMARANO, Candidate for Office of Mayor, City of Hoboken, Hudson County, and VINCENT ADDEO, ANGEL ALICIA, and RAUL MORALES II, Candidates for Municipal Office, City of Hoboken, Hudson County, and LUCY TRUGLIO, Campaign Treasurer, Respondents

COMPLAINT AND NOTICE OF OPPORTUNITY FOR A HEARING FOR LATE AND NON-FILING OF CONTRIBUTION AND EXPENDITURE INFORMATION, FAILURE TO CERTIFY REPORTS, RECEIPT OF EXCESSIVE CONTRIBUTIONS, RECEIPT OF EXCESSIVE CURRENCY CONTRIBUTIONS, AND FAILURE TO FILE 48-HOUR NOTICES OF CONTRIBUTIONS IN THE 2009 MUNICIPAL RUNOFF ELECTION C-G 0905 04 04 R2009 C-9 0905 01 04 R2009 C-9 0905 02 04 R2009 C-9 0905 07 04 R2009

PLEASE TAKE NOTICE that the New Jersey Election Law Enforcement Commission (hereafter,

the Commission) hereby files a complaint against Peter Cammarano, Vincent Addeo, Angel Alicia, and

Raul Morales II, (hereafter, the Respondent Candidates), and Lucy Truglio, (hereafter, the Respondent

Treasurer), and offers the Respondent Candidates and the Respondent Treasurer an opportunity for a

hearing pursuant to the “Administrative Procedure Act,” N.J.S.A. 52:14B-1 et seq., to determine whether or

not the Respondent Candidates and the Respondent Treasurer had the responsibility under the terms of "The

New Jersey Campaign Contributions and Expenditures Reporting Act," N.J.S.A. 19:44A-1, et seq.

(hereafter, the Act) for the filing of campaign reports or information required to be filed pursuant to the Act,

and to determine whether or not the Respondent Candidates and the Respondent Treasurer failed, neglected

or omitted to file any such report or information at the time and in the manner prescribed by law, or in any

other way violated the provisions of the Act, and are therefore subject to penalties provided by the Act. The

hearing will be conducted under the legal authority and jurisdiction conferred upon the Commission to

impose penalties for violations of the Act, specifically Sections 6(b) and 22.

The Commission by way of Complaint alleges:

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 2 FIRST COUNT

PROPOSED FINDINGS OF FACT:

1. The Respondent Candidate, Peter Cammarano, sought election to the office of Mayor and the

Respondent Candidates, Vincent Addeo, Angel Alicia, and Raul Morales II, sought election to municipal

office in the City of Hoboken in the 2009 municipal runoff election (hereafter, the “2009 runoff election”)

held on June 9, 2009 in the City of Hoboken (Hudson County). Hereafter in this Complaint, Peter

Cammarano shall be referred to as Respondent Candidate Cammarano, Vincent Addeo shall be referred to

as Respondent Candidate Addeo, Angel Alicia shall be referred to as Respondent Candidate Alicia, and

Raul Morales II shall be referred to as Respondent Candidate Morales. The four candidates shall

collectively be called the Respondent Candidates.

2. The Respondent Candidates established a joint candidates committee for the purpose of

receiving contributions and making expenditures to support their candidacies in the 2009 runoff election.

3. The Respondent Candidates received and deposited contributions into and made expenditures

from a campaign depository account established and maintained for the 2009 runoff election at “TD Bank

NA” at 47 Newark Street in Hoboken, New Jersey (hereafter, the 2009 runoff election campaign

depository).

4. The Respondent Candidates, certified as correct and filed with the Commission on May 28,

2009, a Joint Candidates Committee – Certificate of Organization and Designation of Campaign Treasurer

and Depository (Form D-2), to report that they had established a joint candidates committee in the 2009

runoff election entitled “Cammarano for Mayor” and designating the 2009 runoff election campaign

depository, described in paragraph 3 above, as the campaign depository of their joint candidates committee.

5. The Respondent Lucy Truglio was a person who acted in the capacity of campaign treasurer and

undertook activity relating to receiving contributions and making expenditures on behalf of the Respondent

Candidates’ 2009 runoff election candidacies. The Respondent Candidates designated Lucy Truglio as their

campaign treasurer for the 2009 runoff election on the Form D-2 described in paragraph 4 above, and Lucy

Truglio certified the Form-D-2 as Treasurer. Hereafter in this Complaint, Lucy Truglio shall be referred to

as the Respondent Treasurer.

6. The Respondent Candidates and the Respondent Treasurer certified as correct and filed for the

first time on June 8, 2009, a Form R-1 (Report of Contributions and Expenditures) relevant to the time

period from April 29, 2009 (the 13th day preceding May 12, 2009, the date of the municipal election)

through May 26, 2009 (the 14th day preceding June 9, 2009, the date of the municipal runoff election), that

is, the 11-day preelection report period for the 2009 runoff election (hereafter, 11-day preelection report

period), which Form R-1 was designated as their 11-day preelection report for the 2009 runoff election

(hereafter, 11-day preelection report).

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 3 7. The Respondent Candidates and the Respondent Treasurer filed with the Commission on

October 8, 2010, a Form R-1 (Report of Contributions and Expenditures) relevant to the 11-day preelection

report period for the 2009 runoff election, as an amendment to the Form R-1 described in paragraph 6 above

(hereafter, amended 11-day preelection report), which report was certified as correct by Respondent

Candidate Cammarano. The amended 11-day preelection report was unsigned and not certified as correct

by Respondent Candidate Addeo, Respondent Candidate Alicia, Respondent Candidate Morales, and

Respondent Treasurer Truglio.

8. The Respondent Candidates and the Respondent Treasurer reported for the first time, on October

8, 2010, on the amended 11-day preelection report described in paragraph 7 above, contribution information

for 35 contributions, totaling $55,850.00, received in amounts greater than $300.00 in the aggregate

relevant to the time period from April 29, 2009 through May 26, 2009, that is, the 11-day preelection report

period for the 2009 runoff election as follows:

a. for 33 contributions totaling $45,850.00;

b. for a currency contribution of $5,000.00 reported received on May 8, 2009, from

“Solomon Dwek – David Essenbach;” and

c. for a currency contribution of $5,000.00 reported received on May 19, 2009, from

“Solomon Dwek – David Essenbach.”

9. The Respondent Candidates and the Respondent Treasurer did not report on the 11-day

preelection report described in paragraph 6 above, or on the amended 11-day preelection report described in

paragraph 7 above, and have not reported, as of the date of this Complaint, contribution information for an

additional 34 contributions, totaling $38,350.00, received in amounts greater than $300.00 in the aggregate,

or in currency, during the 11-day preelection report period for the 2009 runoff election as follows:

a. receipt of 6 contributions, totaling $12,000.00, as set forth in Exhibit A, which is

attached to and hereby incorporated into this Complaint;

b. the occupation, and the employer name and address or the name and address under

which the contributor does business, for 21 contributions from individuals, totaling

$19,400.00, as set forth in Exhibit B, which is attached to and hereby incorporated into this

Complaint; and

c. the name and address of the individual contributing partner or member, and the

occupation of the individual contributor and the name and address of the individual

contributor’s employer, for 7 contributions totaling $6,950.00, each received by check

drawn on the account of a limited liability company (LLC), as set forth in Exhibit C, which

is attached to and hereby incorporated into this Complaint.

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 4 10. The Respondent Candidates and the Respondent Treasurer received and deposited, or caused to

be deposited, the contributions in excess of $300.00 in the aggregate, or in currency, described above in

paragraphs 8 and 9, into the 2009 runoff campaign depository in the time period from April 29, 2009,

through May 26, 2009, that is, the 11-day preelection report period for the 2009 runoff election.

PROPOSED CONCLUSIONS OF LAW:

1. The Respondent Candidate, Peter Cammarano, was at all times relevant to this Complaint a

“candidate,” as the term “candidate” is defined at N.J.S.A. 19:44A-3c, for office of Mayor in the City of

Hoboken, Hudson County, in the 2009 run-off election held on June 9, 2009, and therefore was subject to

the requirements of the Act, N.J.S.A. 19:44A-1 to -47 and Commission Regulations, N.J.A.C. 19:25-1 to

21.

2. The Respondent Candidates, Vincent Addeo, Angel Alicia, and Raul Morales II, were at all

times relevant to this Complaint “candidates,” as the term “candidate” is defined at N.J.S.A. 19:44A-3c, for

municipal office in the City of Hoboken, Hudson County, in the 2009 run-off election held on June 9, 2009,

and therefore were subject to the requirements of the Act and Commission Regulations.

3. The Respondent Treasurer, Lucy Truglio, was at all times relevant to this Complaint, the

Respondent Candidates’ campaign treasurer in the 2009 run-off election held on June 9, 2009, and therefore

was subject to the requirements of the Act and Commission Regulations.

4. The Respondent Candidates and the Respondent Treasurer were required, pursuant to N.J.S.A.

19:44A-16 and N.J.A.C. 19:25-8.1, N.J.A.C. 19:25-8.2(c) and N.J.A.C. 19:25-10.2 to certify as correct and

file with the Commission on May 29, 2009, a full cumulative Report of Contributions and Expenditures

(Form R-1) as an 11-day preelection report for the 2009 runoff election, to report all contributions received

and all expenditures made during the time period from April 29, 2009 (the 13th day preceding May 12,

2009, the date of the municipal election) through May 26, 2009 (the 14th day preceding June 9, 2009, the

date of the municipal runoff election), that is, the 11-day preelection report period for the 2009 runoff

election.

5. The Respondent Candidates and the Respondent Treasurer were required pursuant to N.J.S.A.

19:44A-16, N.J.A.C. 19:25-8.2, N.J.A.C. 19:25-10.2, and N.J.A.C. 19:25-10.15 to report on May 29, 2009,

on the 2009 runoff election 11-day preelection report, all contributions received, including all moneys,

loans, paid personal services, or other things of value, including contributions of goods and services (in-

kind contributions), contributed to the Respondent Candidates during the time period from April 29, 2009

through May 26, 2009. For each contribution received that was in excess of $300.00, either alone or when

aggregated with prior contributions received from the same contributor in the 11-day preelection report

period for the 2009 runoff election, and for all contributions received in currency, the Respondent

Page 5: Peter Cammarano ELEC Complaint

ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 5 Candidates and the Respondent Treasurer were required to report the name and address of the contributor,

the date of receipt of the contribution, and the contribution amount, and to report for each contribution

received from an individual that was either in excess of $300.00 in the aggregate or in currency, the

occupation of said contributor and the name and address of said contributor’s employer. For any

contributor reported as self-employed, the Respondent Candidates and the Respondent Treasurer were

required pursuant to N.J.A.C. 19:25-10.2A to report a description of the individual’s source of livelihood,

the trade name under which the contributor does business, and the business address even it is the same as

the contributor address.

6. For each contribution received by means of a check drawn on the account of a partnership or a

limited liability company (LLC), the Respondent Candidates and the Respondent Treasurer were required

pursuant to N.J.A.C. 19:25-10.15 and N.J.A.C. 19:25-11.10 to report on May 29, 2009, on the 2009 runoff

election 11-day preelection report, contribution information for the partner or partners or member or

members who signed the check, or where any portion of the contribution is to be attributed or allocated to a

partner or partners or member or members who have not signed the check, contribution information for the

partner or partners or member or members who signed a written acknowledgement of the contribution.

7. For each contribution received in excess of $300.00 in the aggregate in the 11-day preelection

report period for the 2009 runoff election, from a contributing partner or member, as described in paragraph

6 above, the Respondent Candidates and the Respondent Treasurer were required pursuant to N.J.S.A.

19:44A-16 and N.J.A.C. 19:25-10.2 and N.J.A.C. 19:25-11.10 to report on May 29, 2009, on the 11-day

preelection report the following information: the name and address of the individual contributor; the

contribution amount; the date of receipt of the contribution; and the occupation of the individual contributor

and the name and mailing address of the individual contributor’s employer.

8. The Respondent Candidates and Respondent Treasurer were prohibited, pursuant to N.J.S.A.

19:44A-11 and N.J.A.C. 19:25-10.6, from accepting any contribution in the form of currency in excess of

$200.00, in the aggregate from one source, in the 2009 runoff election.

9. For each contribution received in the form of currency, not in excess of $200.00 in the aggregate

from one source, the Respondent Candidates and Respondent Treasurer were required, pursuant to N.J.S.A.

19:44A-11 and N.J.A.C. 19:25-10.6, to obtain from the contributor a written record containing the name,

mailing address and signature of the contributor, the date the contribution was made, the amount of the

contribution, and where the contributor was an individual, the individual’s occupation and the name and

mailing address of the individual’s employer.

10. The Respondent Candidates and Respondent Treasurer violated N.J.S.A. 19:44A-11 and

N.J.A.C. 19:25-10.6 by receiving and depositing into the municipal election campaign depository account

during the 11-day preelection report period, two currency contributions, each in the amount of $5,000.00

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 6 and totaling $10,000.00, described in paragraphs 8b and 8c of the Proposed Findings of Fact in this Count,

above, which two contribution amounts each exceeded, by $4,800.00, the $200.00 currency contribution

amount, per election, the Respondent Candidates and Respondent Treasurer were permitted to accept, in the

aggregate, from an individual contributor in the 2009 runoff election.

11. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.2 and 19:25-10.2, by failing to certify as correct and file with the Commission on May 29,

2009, on an 11-day preelection report for the 2009 runoff election, contribution information for 33

contributions, totaling $45,850.00, each received in an amount greater than $300.00 as of May 26, 2009, as

described in paragraph 8a of the Proposed Findings of Fact in this Count above. The Respondent

Candidates and the Respondent Treasurer filed contribution information for the 33 contributions, totaling

$45,850.00, on October 8, 2010, 497 days late.

12. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.2 and 19:25-10.2, by failing to certify as correct and file with the Commission on May 29,

2009, on an 11-day preelection report for the 2009 runoff election, contribution information for six

contributions totaling $12,000.00, each received in an amount greater than $300.00 as of May 26, 2009, as

described in paragraph 9a of the Proposed Findings of Fact in this Count above. The Respondent

Candidates and the Respondent Treasurer continue to violate N.J.S.A. 19:44A-16 and N.J.A.C. 19:26-8.2

and N.J.A.C. 19:25-10.2, as of the date of this Complaint, by failing to file contribution information for the

six contributions totaling $12,000.00.

13. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.2 and 19:25-10.2, by failing to certify as correct and file with the Commission on May 29,

2009, on an 11-day preelection report for the 2009 runoff election, contribution information including the

occupation, and the employer name and address or the name and address under which the contributor does

business, for 21 contributions from individuals, totaling $19,400.00, each received in an amount greater

than $300.00 in the aggregate, or in currency, as of May 26, 2009, as described in paragraph 9b of the

Proposed Findings of Fact in this Count above. The Respondent Candidates and Respondent Treasurer

continue to violate N.J.S.A. 19:44A-16 and N.J.A.C. 19:26-8.2 and N.J.A.C. 19:25-10.2 by failing to certify

as correct and file with the Commission as of the date of this Complaint occupation and employer

information for 21 contributions from individuals, totaling $19,400.00.

14. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:26-8.2, N.J.A.C. 19:25-10.2, and N.J.A.C. 19:25-11.10 by failing to certify as correct and file

with the Commission on May 29, 2009, on an 11-day preelection report for the 2009 runoff election, the

name and address of the individual partner or member, and the occupation of the individual partner or

member for seven contributions totaling $6,950.00, each received by check drawn on the account of a

Page 7: Peter Cammarano ELEC Complaint

ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 7 limited liability company (LLC), as described in paragraph 9c of the Proposed Findings of Fact in this

Count above. The Respondent Candidates and the Respondent Treasurer continue to violate N.J.S.A.

19:44A-16 and N.J.A.C. 19:26-8.2, N.J.A.C. 19:25-10.2, and N.J.A.C. 19:25-11.10, as of the date of this

Complaint, by failing to file contributor information for these seven contributions totaling $6,950.00, each

reported on the amended 11-day preelection report as received from a LLC.

15. Respondent Candidates Vincent Addeo, Angel Alicia, and Raul Morales II, and the

Respondent Treasurer, violated and continue to violate, as of the date of this Complaint, N.J.S.A. 19:44A-

16 and N.J.A.C. 19:25-8.2(e), by failing to certify the correctness of the contribution information reported

on the amended 11-day preelection report.

16. The Respondent Candidates and the Respondent Treasurer are each subject each subject to

imposition by the Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1

et seq. which penalties may not be more than $6,800.00 for accepting two currency contributions, each in

the amount of $5,000.00 and totaling $10,000.00 in the aggregate from one individual contributor,

described in paragraphs 8b and 8c of the Proposed Findings of Fact in this Count, above, which exceeded

by $9,800.00 the $200.00 aggregate limit on currency contributions in effect during the 2009 runoff

election.

17. The Respondent Candidates and the Respondent Treasurer are each subject to imposition by

the Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which

penalties may not be more than $6,800.00 for each reporting transaction, that is, for each contribution

received which has not been reported in the manner or in the time established for reporting by the

Campaign Reporting Act or Commission Regulations.

SECOND COUNT

PROPOSED FINDINGS OF FACT:

1. The Proposed Findings of Fact contained in the First Count of this Complaint are repeated and

incorporated herein as if set forth in full below.

2. The Respondent Candidates and the Respondent Treasurer reported for the first time on October

8, 2010, on the amended 11-day preelection report, described in paragraph 7 of the Proposed Findings of

Fact in the First Count above, expenditure information to report 220 expenditures totaling $80,344.76, with

transaction dates in the time period from April 29, 2009 through May 26, 2009, that is, the 11-day

preelection report period for the 2009 runoff election.

3. The Respondent Candidates and the Respondent Treasurer did not report on the 11-day

preelection report, described in paragraph 6 of the Proposed Findings of Fact in the First Count above, or on

the amended 11-day preelection report, described in paragraph 7 of the Proposed Findings of Fact in the

Page 8: Peter Cammarano ELEC Complaint

ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 8 First Count above, and have not reported, as of the date of this Complaint, expenditure information to report

payee addresses for an additional 74 expenditures, totaling $8,829.81, with transaction dates in the 11-day

preelection report period for the 2009 runoff election, as set forth in Exhibit D, which is attached to and

hereby incorporated into this Complaint.

4. The Respondent Candidates and the Respondent Treasurer made, incurred, or authorized the

expenditures described in paragraphs 2 and 3 above, during the 11-day preelection report period for the

2009 runoff election.

PROPOSED CONCLUSIONS OF LAW:

1. The Proposed Conclusions of Law contained in the First Count of this Complaint are repeated

and incorporated herein as if set forth in full below.

2. The Respondent Candidates and the Respondent Treasurer were required, pursuant to N.J.S.A.

19:44A-16 and N.J.A.C. 19: 25-8.2 and N.J.A.C. 19:25-12.2 to certify as correct and report on May 29,

2009, on an 11-day preelection report (Form R-1) for the 2009 runoff election, expenditure information,

including the date the expenditure was made, the full name and address of the payee, the purpose of the

expenditure, the amount of the expenditure, and the number of the check for each expenditure transaction

made during the time period from April 29, 2009 through May 26, 2009, that is, the 11-day preelection

report period for the 2009 runoff election.

3. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.2 and N.J.A.C. 19:25-12.2 by failing to certify as correct and file with the Commission on

May 29, 2009, on an 11-day preelection report (Form R-1) for the 2009 runoff election, expenditure

information for 220 expenditures totaling $80,344.76, as described in paragraph 2 of the Proposed Findings

of Fact in this Count above. The Respondent Candidates and the Respondent Treasurer reported the 220

expenditures, totaling $80,344.76, on an amended 11-day preelection report, on October 8, 2010, as

described in paragraph 2 of the Proposed Findings of Fact in this Count above, after the May 29, 2009 filing

date and 497 days late.

4. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.2 and N.J.A.C. 19:25-12.2 by failing to certify as correct and file with the Commission on

May 29, 2009, on an 11-day preelection report (Form R-1) for the 2009 runoff election, expenditure

information including payee addresses for 74 expenditures, totaling $8,829.81. The Respondent Candidates

and the Respondent Treasurer continue to violate N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.2 and N.J.A.C.

19:25-12.2, as of the date of this Complaint, by failing to file payee addresses for 74 expenditures totaling

$8,829.81.

Page 9: Peter Cammarano ELEC Complaint

ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 9 5. Respondent Candidates Vincent Addeo, Angel Alicia, and Raul Morales II, and the Respondent

Treasurer, violated and continue to violate, as of the date of this Complaint, N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.2(e), by failing to certify the correctness of the expenditure information reported on the

amended 11-day preelection report.

6. The Respondent Candidates and the Respondent Treasurer are each subject to imposition by the

Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which

penalties may not be more than $6,800.00 for each reporting transaction, that is, for each expenditure that is

not reported in the manner or not filed on the date established for reporting by the Campaign Reporting Act

or Commission Regulations.

THIRD COUNT

PROPOSED FINDINGS OF FACT:

1. The Proposed Findings of Fact contained in the First and Second Counts of this Complaint are

repeated and incorporated herein as if set forth in full below.

2. The Respondent Candidates and the Respondent Treasurer filed with the Commission on

October 8, 2010, a Report of Contributions and Expenditures (Form R-1) relevant to the time period from

May 27, 2009 through June 26, 2009, that is, the 20-day postelection report period, as a 20-day postelection

report for the 2009 runoff election, which report was certified as correct by Respondent Candidate

Cammarano. The 20-day postelection report was unsigned and not certified as correct by Respondent

Candidate Addeo, Respondent Candidate Alicia, Respondent Candidate Morales, and Respondent Treasurer

Truglio.

3. The Respondent Candidates and the Respondent Treasurer reported for the first time, on October

8, 2010, on the 20-day postelection report described in paragraph 2 above, contribution information as

described below for 52 contributions, totaling $173,335.58, received in amounts greater than $300.00 in the

aggregate as of June 26, 2009 in the 2009 runoff election as follows:

a. for 45 contributions totaling $125,300.00;

b. for an in-kind contribution of $9,035.58; and

c. for 6 loans totaling $39,000.00.

4. The Respondent Candidates and the Respondent Treasurer did not report on the 20-day

postelection report described in paragraph 2 above, and have not reported, as of the date of this Complaint,

contribution information for an additional 26 contributions totaling $58,340.00, received in amounts greater

than $300.00 in the aggregate, or in currency, as of June 26, 2009 in the 2009 runoff election as follows:

a. for receipt of 7 contributions, totaling $10,840.00, as set forth in Exhibit E, which is

attached to and hereby incorporated into this Complaint;

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 10

b. the occupation, and the employer name and address or the name and address under

which the contributor does business, for 13 contributions from individuals, totaling

$43,500.00, as set forth in Exhibit F, which is attached to and hereby incorporated into this

Complaint; and

c. the name and address of the individual contributing partner or member, and the

occupation of the individual contributor and the name and address of the individual

contributor’s employer, for 6 contributions, totaling $4,000.00, each received by check

drawn on the account of a limited liability company (LLC), as set forth in Exhibit G, which

is attached to and hereby incorporated into this Complaint.

5. The Respondent Candidates and the Respondent Treasurer received and deposited, or caused to

be deposited, the contributions in excess of $300.00 in the aggregate, or in currency, described above in

paragraphs 3 and 4 above, into the 2009 runoff campaign depository in the time period from May 27, 2009

through June 26, 2009, that is, the 20-day postelection report period for the 2009 runoff election.

PROPOSED CONCLUSIONS OF LAW:

1. The Proposed Conclusions of Law contained in the First and Second Counts of this Complaint

are repeated and incorporated herein as if set forth in full below.

2. The Respondent Candidates and the Respondent Treasurer were required, pursuant to N.J.S.A.

19:44A-16 and N.J.A.C. 19:25-8.1, N.J.A.C. 19:25-8.2 and N.J.A.C. 19:25-10.2 to certify as correct and file

with the Commission on June 29, 2009, a full cumulative Report of Contributions and Expenditures (Form

R-1) as an 20-day postelection report for the 2009 runoff election, to report all contributions received and

all expenditures made during the time period from May 27, 2009 through June 26, 2009, that is, the 20-day

postelection report period for the 2009 runoff election.

3. The Respondent Candidates and the Respondent Treasurer were required pursuant to N.J.S.A.

19:44A-16, N.J.A.C. 19:25-8.2, N.J.A.C. 19:25-10.2, and N.J.A.C. 19:25-10.15 to report on June 29, 2009,

on the 2009 runoff election 20-day postelection report, all contributions received, including all moneys,

loans, paid personal services, or other things of value, including contributions of goods and services (in-

kind contributions), contributed to the Respondent Candidates during the time period from May 27, 2009

through June 26, 2009. For each contribution received that was in excess of $300.00, either alone or when

aggregated with prior contributions received from the same contributor in the 2009 runoff election, through

June 26, 2009, and for all contributions received in currency, the Respondent Candidates and the

Respondent Treasurer were required to report the name and address of the contributor, the date of receipt of

the contribution, and the contribution amount, and to report for each contribution received from an

individual that was either in excess of $300.00 in the aggregate or in currency, the occupation of said

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 11 contributor and the name and address of said contributor’s employer. For any contributor reported as self-

employed, the Respondent Candidates and the Respondent Treasurer were required pursuant to N.J.A.C.

19:25-10.2A to report a description of the individual’s source of livelihood, the trade name under which the

contributor does business, and the business address even it is the same as the contributor address.

4. For each contribution received by means of a check drawn on the account of a partnership or a

limited liability company (LLC), the Respondent Candidates and the Respondent Treasurer were required

pursuant to N.J.A.C. 19:25-10.15 and N.J.A.C. 19:25-11.10 to report on June 29, 2009, on the 2009 runoff

election 20-day postelection report, contribution information for the partner or partners or member or

members who signed the check, or where any portion of the contribution is to be attributed or allocated to a

partner or partners or member or members who have not signed the check, contribution information for the

partner or partners or member or members who signed a written acknowledgement of the contribution.

5. For each contribution received in excess of $300.00 in the aggregate in the 20-day postelection

report period for the 2009 runoff election, from a contributing partner or member, as described in paragraph

4 above, the Respondent Candidates and the Respondent Treasurer were required pursuant to N.J.S.A.

19:44A-16 and N.J.A.C. 19:25-10.2 and N.J.A.C. 19:25-11.10 to report on June 29, 2009, on the 20-day

postelection report the following information: the name and address of the individual contributor; the

contribution amount; the date of receipt of the contribution; and the occupation of the individual contributor

and the name and mailing address of the individual contributor’s employer.

6. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.2 and 19:25-10.2, by failing to certify as correct and file with the Commission on June 29,

2009, on an 20-day postelection report for the 2009 runoff election, contribution information for 45

contributions totaling $125,300.00, each received in an amount greater than $300.00 as of June 26, 2009, as

described in paragraph 3a of the Proposed Findings of Fact in this Count above. The Respondent

Candidates and the Respondent Treasurer filed contribution information for the 45 contributions totaling

$125,300.00, on October 8, 2010, 466 days late.

7. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.2 and 19:25-10.2, by failing to certify as correct and file with the Commission on June 29,

2009, on an 20-day postelection report for the 2009 runoff election, contribution information for an in-kind

contribution of $9,035.58, as described in paragraph 3b of the Proposed Findings of Fact in this Count

above. The Respondent Candidates and the Respondent Treasurer filed contribution information for the in-

kind contribution of $9,035.58, on October 8, 2010, 466 days late.

8. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.2 and 19:25-10.2, by failing to certify as correct and file with the Commission on June 29,

2009, on an 20-day postelection report for the 2009 runoff election, contribution information for 6

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 12 contributions received as loans, totaling $39,000.00, each received in an amount greater than $300.00 as of

June 26, 2009, as described in paragraph 3c of the Proposed Findings of Fact in this Count above. The

Respondent Candidates and the Respondent Treasurer filed contribution information for the 6 contributions

received as loans, totaling $39,000.00, on October 8, 2010, 466 days late.

9. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.2 and 19:25-10.2, by failing to certify as correct and file with the Commission on June 29,

2009, on an 20-day postelection report for the 2009 runoff election, contribution information for 7

contributions, totaling $10,840.00, each received in an amount greater than $300.00 in the aggregate as of

June 26, 2009, as described in paragraph 4a of the Proposed Findings of Fact in this Count above. The

Respondent Candidates and the Respondent Treasurer continue to violate N.J.S.A. 19:44A-16 and N.J.A.C.

19:26-8.2 and N.J.A.C. 19:25-10.2, as of the date of this Complaint, by failing to file contribution

information for the 7 contributions, totaling $10,840.00.

10. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.2 and 19:25-10.2, by failing to certify as correct and file with the Commission on June 29,

2009, on an 20-day postelection report for the 2009 runoff election, contribution information including the

occupation, and the employer name and address or the name and address under which the contributor does

business, for 13 contributions from individuals, totaling $43,500.00, each received in an amount greater

than $300.00, or in currency, as of June 26, 2009, as described in paragraph 4b of the Proposed Findings of

Fact in this Count above. The Respondent Candidates and Respondent Treasurer continue to violate

N.J.S.A. 19:44A-16 and N.J.A.C. 19:26-8.2 and N.J.A.C. 19:25-10.2 by failing to certify as correct and file

with the Commission as of the date of this Complaint occupation and employer information for 13

contributions from individuals, totaling $43,500.00.

11. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:26-8.2, N.J.A.C. 19:25-10.2, and N.J.A.C. 19:25-11.10 by failing to certify as correct and file

with the Commission on June 29, 2009, on an 20-day postelection report for the 2009 runoff election, the

name and address of the individual partner or member, and the occupation of the individual partner or

member for 6 contributions, totaling $4,000.00, each received by check drawn on the account of a limited

liability company (LLC), as described in paragraph 4c of the Proposed Findings of Fact in this Count above.

The Respondent Candidates and the Respondent Treasurer continue to violate N.J.S.A. 19:44A-16 and

N.J.A.C. 19:26-8.2, N.J.A.C. 19:25-10.2, and N.J.A.C. 19:25-11.10, as of the date of this Complaint, by

failing to file contributor information for these 6 contributions, totaling $4,000.00, each reported on the

amended 20-day postelection report as received from a LLC.

12. Respondent Candidates Vincent Addeo, Angel Alicia, and Raul Morales II, and the Respondent

Treasurer, violated and continue to violate, as of the date of this Complaint, N.J.S.A. 19:44A-16 and

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 13 N.J.A.C. 19:25-8.2(e), by failing to certify the correctness of the contribution information reported on the

20-day postelection report for the 2009 runoff election.

13. The Respondent Candidates and the Respondent Treasurer are each subject to imposition by

the Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which

penalties may not be more than $6,800.00 for each reporting transaction, that is, for each contribution

received which has not been reported in the manner or in the time established for reporting by the

Campaign Reporting Act or Commission Regulations.

FOURTH COUNT

PROPOSED FINDINGS OF FACT:

1. The Proposed Findings of Fact contained in the First through Third Counts of this Complaint

are repeated and incorporated herein as if set forth in full below.

2. During the time period from May 27, 2009 through June 9, 2009, the Respondent Candidates

and the Respondent Treasurer received and deposited into the 2009 runoff election campaign depository

account, 5 contributions, totaling $14,550.00, received from 5 contributors as follows:

a. from “Ryan D. Graham,” received by check in the amount of $2,600.00, deposited on or

around May 27, 2009;

b. from “Jeffrey White,” received by check in the amount of $1,950.00, deposited on or

around May 29, 2009;

c. from “N.J. Citizens Rights Initiative,” received by check in the amount of $5,000.00,

deposited on or around June 1, 2009;

d. from “Residential Automation,” received by check in the amount of $2,500.00,

deposited on or around June 4, 2009; and

e. from “Maher Khalil,” received by check in the amount of $2,500.00, deposited on or

around June 5, 2009.

3. The Respondent Candidates and the Respondent Treasurer did not file with the Commission

within 48-hours of receipt, or on any date up to and including June 9, 2009, the date of the 2009 runoff

election, any written notice of receipt of the five 48-hour notice reporting transactions, totaling $14,550.00,

described in paragraph two above.

PROPOSED CONCLUSIONS OF LAW:

1. The Proposed Conclusions of Law contained in the First through Third Counts of this Complaint

are repeated and incorporated herein as if set forth in full below.

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 14 2. The Respondent Candidates and the Respondent Treasurer were required, pursuant to N.J.S.A.

19:44A-16i and N.J.A.C. 19:25-8.6, to file with the Commission a written notice within 48 hours of receipt

of each 48-hour notice reporting transaction. As used in this Complaint, the term, “48-hour notice reporting

transaction” shall mean the receipt by the Respondent Candidates and Respondent Treasurer of a

contribution or aggregate contributions from a single source during the period of time from May 27, 2009

(the 13th day preceding the 2009 runoff election) through June 9, 2009 (the date of the 2009 runoff

election), which contribution was in excess of $1,200.00, or which aggregate contributions from a

contributor were in excess of $1,200.00. The 48-hour written notice was required to include for each

contribution or aggregate contributions in excess of $1,200.00, the name of the recipient candidate

committee, the name and address of the contributor, the contribution amount, the date of receipt, and where

the contributor is an individual, the occupation of said individual contributor and the name and mailing

address of said individual contributor’s employer.

3. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16i and

N.J.A.C. 19:25-8.6 by failing to file with the Commission either within 48 hours of receipt or on any date

up to and including June 9, 2009, the date of the 2009 runoff election in the City of Hoboken, any written

notice of receipt of the five 48-hour notice reporting transactions, totaling $14,550.00, described in

paragraph two of the Proposed Findings of Fact in this Count above.

4. The Respondent Candidates and Respondent Treasurer are each subject to imposition by the

Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which

penalties may not be more than $6,800.00 for each 48-hour notice reporting transaction, that is, for each

contribution or aggregate contributions from a single source received in an amount greater than $1,200.00

by the Respondent Candidate and Respondent Treasurer during the period of time from May 27, 2009

through June 9, 2009, for which a written notice of receipt was not filed with the Commission within 48-

hours of receipt, as required by N.J.S.A. 19:44A-16i and N.J.A.C. 19:25-8.6.

FIFTH COUNT

PROPOSED FINDINGS OF FACT:

1. The Proposed Findings of Fact contained in the First through Fourth Counts of this Complaint

are repeated and incorporated herein as if set forth in full below.

2. The Respondent Candidates and the Respondent Treasurer reported for the first time, on October

8, 2010, on the 20-day postelection report described in paragraph 2 of the Proposed Findings of Fact in the

Third Count above, on “Table I. Receipts, Line 1” (“Monetary Contributions of $300.00 or Less”), receipt

of an amount of $77,444.34 as a sum of contributions of $300.00 or less received in the time period from

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 15 May 27, 2009 through June 26, 2009, that is, the 20-day postelection report period for the 2009 runoff

election.

3. The Respondent Candidates and the Respondent Treasurer received and deposited, or caused to

be deposited, into the 2009 runoff election campaign depository account, an amount of $77,444.34

described in paragraph 2 above, received from contributors, each of whose contributions to the Respondent

Candidates in the 2009 runoff election did not exceed $300.00 in the aggregate as of June 26, 2009

(hereafter sum of contributions of $300.00 or less), in the 20-day postelection report period for the 2009

runoff election.

PROPOSED CONCLUSIONS OF LAW:

1. The Proposed Conclusions of Law contained in the First through Fourth Counts of this

Complaint are repeated and incorporated herein as if set forth in full below.

2. The Respondent Candidates and the Respondent Treasurer were required, pursuant to N.J.S.A.

19:44A-16 and N.J.A.C. 19:25-8.2 and N.J.A.C. 19:25-10.3, to certify as correct and report on June 29,

2009, on the 20-day postelection report for the 2009 runoff election, the sum of contributions of $300.00 or

less received during the time period from May 27, 2009 through June 26, 2009, that is, the 20-day

postelection report period for the 2009 runoff election.

3. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.2 and N.J.A.C. 19:25-10.3 by failing to certify as correct and file with the Commission on

June 29, 2009, the 20-day postelection report (Form R-1) for the 2009 runoff election and to report the

amount of contributions of $300.00 or less, totaling $77,444.34, received during the 20-day postelection

report period, as described in paragraph two of the Proposed Findings of Fact in this Count above. The

Respondent Candidates and the Respondent Treasurer reported an amount of $77,444.34, as a sum of

contributions of $300.00 or less, on the 20-day postelection report for the 2009 runoff election filed on

October 8, 2010, which date was after the June 29, 2009 filing due date and 466 days late.

4. Respondent Candidates Vincent Addeo, Angel Alicia, and Raul Morales II, and the Respondent

Treasurer, violated and continue to violate, as of the date of this Complaint, N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.2(e), by failing to certify the correctness of the contribution information reported on the

20-day postelection report for the 2009 runoff election.

5. The Respondent Candidates and the Respondent Treasurer are each subject to imposition by the

Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which

penalties may not be more than $6,800.00 for each reporting transaction, that is, for each contribution

amount which has not been reported in the manner or in the time prescribed by the Campaign Reporting Act

or Commission Regulations.

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 16

SIXTH COUNT

PROPOSED FINDINGS OF FACT:

1. The Proposed Findings of Fact contained in the First through Fifth Counts of this Complaint are

repeated and incorporated herein as if set forth in full below.

2. The Respondent Candidates and the Respondent Treasurer reported for the first time on October

8, 2010, on the 20-day postelection report, described in paragraph 2 of the Proposed Findings of Fact in the

Third Count above, expenditure information to report 517 expenditures totaling $117,171.43, with

transaction dates in the time period from May 27, 2009 through June 26, 2009, that is, the 20-day

postelection report period for the 2009 runoff election.

3. The Respondent Candidates and the Respondent Treasurer did not report on the 20-day

postelection report, described in paragraph 2 of the Proposed Findings of Fact in the Third Count above,

and have not reported, as of the date of this Complaint, expenditure information to report payee addresses

for an additional 241 expenditures, totaling $38,423.04, with transaction dates in the 20-day postelection

report period for the 2009 runoff election, as set forth in Exhibit H, which is attached to and hereby

incorporated into this Complaint.

4. The Respondent Candidates and the Respondent Treasurer did not report on the 20-day

postelection report described in paragraph 2 of the Proposed Findings of Fact in the Third Count above, and

have not reported, as of the date of this Complaint, expenditure information to report 541 expenditures

totaling $51,633.00, with transaction dates in the 20-day postelection report period for the 2009 runoff

election, as set forth in Exhibit I, which is attached to and hereby incorporated into this Complaint.

5. The Respondent Candidates and the Respondent Treasurer made, incurred, or authorized the

expenditures described in paragraphs 2, 3, and 4 above, during the 20-day postelection report period for the

2009 runoff election.

PROPOSED CONCLUSIONS OF LAW:

1. The Proposed Conclusions of Law contained in the First through Fifth Counts of this Complaint

are repeated and incorporated herein as if set forth in full below.

2. The Respondent Candidates and the Respondent Treasurer were required, pursuant to N.J.S.A.

19:44A-16 and N.J.A.C. 19: 25-8.2 and N.J.A.C. 19:25-12.2 to certify as correct and report on June 29,

2009, on a 20-day postelection report (Form R-1) for the 2009 runoff election, expenditure information,

including the date the expenditure was made, the full name and address of the payee, the purpose of the

expenditure, the amount of the expenditure, and the number of the check for each expenditure transaction

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 17 made during the time period from May 27, 2009 through June 26, 2009, that is, the 20-day postelection

report period for the 2009 runoff election.

3. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.2 and N.J.A.C. 19:25-12.2 by failing to certify as correct and file with the Commission on

June 29, 2009, on a 20-day postelection report (Form R-1) for the 2009 runoff election, expenditure

information for 517 expenditures totaling $117,171.43, as described in paragraph 2 of the Proposed

Findings of Fact in this Count above. The Respondent Candidates and the Respondent Treasurer reported

the 517 expenditures totaling $117,171.43, on the 20-day postelection report on October 8, 2010, as

described in paragraph 2 of the Proposed Findings of Fact in this Count above, after the June 29, 2009 filing

date and 466 days late.

4. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.2 and N.J.A.C. 19:25-12.2 by failing to certify as correct and file with the Commission on

June 29, 2009, on a 20-day postelection report (Form R-1) for the 2009 runoff election, expenditure

information including payee addresses for 241 expenditures, totaling $38,423.04, as described in paragraph

3 of the Proposed Findings of Fact in this Count above. The Respondent Candidates and the Respondent

Treasurer continue to violate N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.2 and N.J.A.C. 19:25-12.2, as of the

date of this Complaint, by failing to file payee addresses for 241 expenditures totaling $38,423.04.

5. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.2 and N.J.A.C. 19:25-12.2 by failing to certify as correct and file with the Commission on

June 29, 2009, on a 20-day postelection report (Form R-1) for the 2009 runoff election, expenditure

information for 541 expenditures totaling $51,663.00, as described in paragraph 4 of the Proposed Findings

of Fact in this Count above. The Respondent Candidates and the Respondent Treasurer continue to violate

N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.2 and N.J.A.C. 19:25-12.2, as of the date of this Complaint, by

failing to file expenditure information for the 541 expenditures totaling $51,663.00.

6. Respondent Candidates Vincent Addeo, Angel Alicia, and Raul Morales II, and the Respondent

Treasurer, violated and continue to violate, as of the date of this Complaint, N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.2(e), by failing to certify the correctness of the expenditure information reported on the

20-day postelection report.

7. The Respondent Candidates and the Respondent Treasurer are each subject to imposition by the

Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which

penalties may not be more than $6,800.00 for each reporting transaction, that is, for each expenditure that is

not reported in the manner or not filed on the date established for reporting by the Campaign Reporting Act

or Commission Regulations.

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 18

SEVENTH COUNT

PROPOSED FINDINGS OF FACT:

1. The Proposed Findings of Fact contained in the First through Sixth Counts of this Complaint are

repeated and incorporated herein as if set forth in full below.

2. The Respondent Candidates and the Respondent Treasurer filed with the Commission on

October 8, 2010, a Form R-1 (Report of Contributions and Expenditures) relevant to the period of time from

June 27, 2009 through September 30, 2009 (hereafter, the 2009 third quarter report period for the 2009

runoff election), which report (hereafter, the 2009 third quarter report) was certified as correct by

Respondent Candidate Cammarano. The 2009 third quarter report was unsigned and not certified as correct

by Respondent Candidate Addeo, Respondent Candidate Alicia, Respondent Candidate Morales, and

Respondent Treasurer Truglio.

3. The Respondent Candidates and the Respondent Treasurer reported for the first time, on October

8, 2010, on the 2009 third quarter report described in paragraph 2 above, contribution information for 4

contributions totaling $15,000.00, received in amounts greater than $300.00 in the aggregate, relevant to the

time period from June 27, 2009 through September 30, 2009, that is, the 2009 third quarter report period for

the 2009 runoff election as follows:

a. for 3 contributions totaling $5,000.00;

b. for a currency contribution of $10,000.00 reported received on July 16, 2009, from

“Solomon Dwek – David Essenbach;”

4. The Respondent Candidates and the Respondent Treasurer did not report on the 2009 third

quarter report described in paragraph 2 above, and have not reported, as of the date of this Complaint,

contribution information for 13 contributions, totaling $12,000.00, received in amounts greater than

$300.00 in the aggregate, or in currency, during the 2009 third quarter report period for the 2009 runoff

election, as set forth in Exhibit J, which is attached to and hereby incorporated into this Complaint.

5. The Respondent Candidates and the Respondent Treasurer received and deposited, or caused to

be deposited, the contributions in excess of $300.00 in the aggregate, or in currency, described above in

paragraphs 3 and 4, into the 2009 runoff campaign depository in the time period from June 27, 2009

through September 30, 2009, that is, the 2009 third quarter report period for the 2009 runoff election.

PROPOSED CONCLUSIONS OF LAW:

1. The Proposed Conclusions of Law contained in the First through Sixth Counts of this

Complaint are repeated and incorporated herein as if set forth in full below.

2. The Respondent Candidates and the Respondent Treasurer were required pursuant to N.J.S.A.

19:44A-16 and N.J.A.C. 19:25-8.3, 10.2, 10.3, and 12.2, to certify as correct and file with the Commission

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 19 on October 15, 2009, a full cumulative Report of Contributions and Expenditures (Form R-1) as a 2009

third quarter report for the 2009 runoff election, to report all contributions received and all expenditures

made during the time period from June 27, 2009 through September 30, 2009, that is, the 2009 third quarter

report period for the 2009 runoff election.

3. The Respondent Candidates and the Respondent Treasurer were required pursuant to N.J.S.A.

19:44A-16 and N.J.A.C. 19:25-8.3, 10.2, and 10.15 to report on October 15, 2009 on the 2009 third quarter

report for the 2009 runoff election, all contributions received, including all moneys, loans, paid personal

services, or other things of value, including contributions of goods and services (in-kind contributions),

contributed to the Respondent Candidates during the time period from June 27, 2009 through September 30,

2009. For each contribution received that was in excess of $300.00, either alone or when aggregated with

prior contributions received from the same contributor in the 2009 runoff election, through September 30,

2009, and for all contributions received in currency, the Respondent Candidates and the Respondent

Treasurer were required to report the name and address of the contributor, the date of receipt of the

contribution, and the contribution amount, and to report for each contribution received from an individual

that was either in excess of $300.00 in the aggregate or in currency, the occupation of said contributor and

the name and address of said contributor’s employer. For any contributor reported as self-employed, the

Respondent Candidates and the Respondent Treasurer were required pursuant to N.J.A.C. 19:25-10.2A to

report a description of the individual’s source of livelihood, the trade name under which the contributor

does business, and the business address even it is the same as the contributor address.

4. For each contribution received by means of a check drawn on the account of a partnership or a

limited liability company (LLC), the Respondent Candidates and the Respondent Treasurer were required

pursuant to N.J.A.C. 19:25-10.15 and N.J.A.C. 19:25-11.10 to report on October 15, 2009, on a 2009 third

quarter report for the 2009 runoff election, contribution information for the partner or partners or member or

members who signed the check, or where any portion of the contribution is to be attributed or allocated to a

partner or partners or member or members who have not signed the check, contribution information for the

partner or partners or member or members who signed a written acknowledgement of the contribution.

5. For each contribution received in excess of $300.00, either alone or when aggregated with prior

contributions received from the same contributor in the 2009 runoff election through September 30, 2009,

from a contributing partner or member, as described in paragraph 4 above, the Respondent Candidates and

the Respondent Treasurer were required pursuant to N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-10.2 and

N.J.A.C. 19:25-11.10 to report on October 15, 2009, on a 2009 third quarter report for the 2009 runoff

election, the following information: the name and address of the individual contributor; the contribution

amount; the date of receipt of the contribution; and the occupation of the individual contributor and the

name and mailing address of the individual contributor’s employer.

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 20 6. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.3 and 10.2, by failing to certify as correct and file with the Commission on October 15,

2009, on a 2009 third quarter report for the 2009 runoff election, contribution information for 3

contributions totaling $5,000.00, each received in an amount greater than $300.00, or in currency, as of

September 30, 2009, as described in paragraph 3a of the Proposed Findings of Fact in this Count above.

The Respondent Candidates and the Respondent Treasurer filed contribution information for the 3

contributions totaling $5,000.00, on October 8, 2010, 358 days late.

7. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.3 and 19:25-10.2 by failing to certify as correct and file with the Commission on October

15, 2009, on a 2009 third quarter report for the 2009 runoff election, contribution information relevant to

one contribution amount of $10,000.00 received as a currency contribution and described in paragraph 3b of

the Proposed Findings of Fact in this Count above. The Respondent Candidates and the Respondent

Treasurer filed contribution information for the one contribution, received as a currency contribution, in the

amount of $10,000.00, on October 8, 2010, 358 days late.

8. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.3 and 19:25-10.2 by failing to certify as correct and file with the Commission on October

15, 2009, on a 2009 third quarter report for the 2009 runoff election, contribution information for 13

contributions, totaling $12,000.00, each received in an amount greater than $300.00 in the aggregate as of

September 30, 2009, as described in paragraph 4 of the Proposed Findings of Fact in this Count above. The

Respondent Candidates and the Respondent Treasurer continue to violate N.J.S.A. 19:44A-16 and N.J.A.C.

19:26-8.3 and 19:25-10.2, as of the date of this Complaint, by failing to file contribution information for the

13 contributions, totaling $12,000.00.

9. Respondent Candidates Vincent Addeo, Angel Alicia, and Raul Morales II, and the Respondent

Treasurer, violated and continue to violate, as of the date of this Complaint, N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.3(e), by failing to certify the correctness of the contribution information reported on the

2009 third quarter report for the 2009 runoff election.

10. The Respondent Candidates and the Respondent Treasurer are each subject to imposition by

the Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which

penalties may not be more than $6,800.00 for each reporting transaction, that is for each contribution

received that is not reported in the manner or not filed on the date established for reporting by the Act or

Commission Regulations.

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 21

EIGHTH COUNT

PROPOSED FINDINGS OF FACT:

1. The Proposed Findings of Fact contained in the First through Seventh Counts of this Complaint

are repeated and incorporated herein as if set forth in full below.

2. The Respondent Candidates and the Respondent Treasurer reported for the first time, on October

8, 2010, on the 2009 third quarter report for the 2009 runoff election described in paragraph 2 of the

Proposed Findings of Fact in the Seventh Count above, on “Table I. Receipts, Line 1” (“Monetary

Contributions of $300.00 or Less”), receipt of an amount of $675.00 as a sum of contributions of $300.00 or

less received in the time period from June 27, 2009 through September 30, 2009, that is, the 2009 third

quarter report period for the 2009 runoff election.

3. The Respondent Candidates and the Respondent Treasurer received and deposited, or caused to

be deposited, into the 2009 runoff election campaign depository account, an amount of $675.00 described in

paragraph 2 above, received from contributors, each of whose contributions to the Respondent Candidates

in the 2009 runoff election did not exceed $300.00 in the aggregate as of September 30, 2009 (hereafter

sum of contributions of $300.00 or less), in the 2009 third quarter report period for the 2009 runoff election.

PROPOSED CONCLUSIONS OF LAW:

1. The Proposed Conclusions of Law contained in the First through Seventh Counts of this

Complaint are repeated and incorporated herein as if set forth in full below.

2. The Respondent Candidates and the Respondent Treasurer were required, pursuant to N.J.S.A.

19:44A-16 and N.J.A.C. 19:25-8.3 and N.J.A.C. 19:25-10.3, to certify as correct and report on October 15,

2009, on a 2009 third quarter report for the 2009 runoff election, the sum of contributions of $300.00 or less

received during the time period from June 27, 2009 through September 30, 2009, that is, the 2009 third

quarter report period for the 2009 runoff election.

3. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.3 and N.J.A.C. 19:25-10.3 by failing to certify as correct and file with the Commission on

October 15, 2009, the 2009 third quarter report (Form R-1) for the 2009 runoff election and to report the

amount of contributions of $300.00 or less, totaling $675.00, received during the 2009 third quarter report

period, as described in paragraph two of the Proposed Findings of Fact in this Count above. The

Respondent Candidates and the Respondent Treasurer reported an amount of $675.00 as a sum of

contributions of $300.00 or less, on the 2009 third quarter report for the 2009 runoff election filed on

October 8, 2010, which date was after the October 15, 2009 filing due date and 358 days late.

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 22 4. Respondent Candidates Vincent Addeo, Angel Alicia, and Raul Morales II, and the Respondent

Treasurer, violated and continue to violate, as of the date of this Complaint, N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.3(e), by failing to certify the correctness of the contribution information reported on the

2009 third quarter report for the 2009 runoff election.

5. The Respondent Candidates and the Respondent Treasurer are each subject to imposition by the

Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which

penalties may not be more than $6,800.00 for each reporting transaction, that is, for each contribution

amount which has not been reported in the manner or in the time prescribed by the Campaign Reporting Act

or Commission Regulations.

NINTH COUNT

PROPOSED FINDINGS OF FACT:

1. The Proposed Findings of Fact contained in the First through Eighth Counts of this Complaint

are repeated and incorporated herein as if set forth in full below.

2. The Respondent Candidates and the Respondent Treasurer reported for the first time on the 2009

third quarter report for the 2009 runoff election, described in paragraph 2 of the Proposed Findings of Fact

in the Seventh Count above, expenditure information to report 15 expenditures totaling $9,537.00, with

transaction dates in the time period from June 27, 2009 through September 30, 2009, that is, the 2009 third

quarter report period for the 2009 runoff election.

3. The Respondent Candidates and the Respondent Treasurer did not report on the 2009 third

quarter report for the 2009 runoff election, described in paragraph 2 of the Proposed Findings of Fact in the

Seventh Count above, and have not reported, as of the date of this Complaint, expenditure information to

report payee addresses for an additional 7 expenditures, totaling $650.00, with transaction dates in the 2009

third quarter report period for the 2009 runoff election, as set forth in Exhibit K, which is attached to and

hereby incorporated into this Complaint.

4. The Respondent Candidates and the Respondent Treasurer did not report on the 2009 third

quarter report described in paragraph 2 of the Proposed Findings of Fact in the Seventh Count above, and

have not reported, as of the date of this Complaint, expenditure information to report 12 expenditures

totaling $640.00, with transaction dates in the time period from June 27, 2009 through September 30, 2009,

that is, the 2009 third quarter report period for the 2009 runoff election, as set forth in Exhibit L, which is

attached to and hereby incorporated into this Complaint.

5. The Respondent Candidates and the Respondent Treasurer made, incurred, or authorized the

expenditures described in paragraphs 2, 3, and 4 above, during the 2009 third quarter report period for the

2009 runoff election.

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 23

PROPOSED CONCLUSIONS OF LAW:

1. The Proposed Conclusions of Law contained in the First through Eighth Counts of this

Complaint are repeated and incorporated herein as if set forth in full below.

2. The Respondent Candidates and the Respondent Treasurer were required, pursuant to N.J.S.A.

19:44A-16 and N.J.A.C. 19: 25-8.3 and N.J.A.C. 19:25-12.2 to certify as correct and report on October 15,

2009, on a 2009 third quarter report (Form R-1) for the 2009 runoff election, expenditure information,

including the date the expenditure was made, the full name and address of the payee, the purpose of the

expenditure, the amount of the expenditure, and the number of the check for each expenditure transaction

made during the time period from June 27, 2009 through September 30, 2009, that is, the 2009 third quarter

report period for the 2009 runoff election.

3. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.3 and N.J.A.C. 19:25-12.2 by failing to certify as correct and file with the Commission on

October 15, 2009, on a 2009 third quarter report (Form R-1) for the 2009 runoff election, expenditure

information for 15 expenditures totaling $9,537.00, as described in paragraph 2 of the Proposed Findings of

Fact in this Count above. The Respondent Candidates and the Respondent Treasurer reported the 15

expenditures totaling $9,537.00, on the 2009 third quarter report on October 8, 2010, as described in

paragraph 2 of the Proposed Findings of Fact in this Count above, after the October 15, 2009 filing date and

358 days late.

4. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.3 and N.J.A.C. 19:25-12.2 by failing to certify as correct and file with the Commission on

October 15, 2009, on a 2009 third quarter report (Form R-1) for the 2009 runoff election, expenditure

information including payee addresses for 7 expenditures totaling $650.00, as described in paragraph 3 of

the Proposed Findings of Fact in this Count above. The Respondent Candidates and the Respondent

Treasurer continue to violate N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3 and N.J.A.C. 19:25-12.2, as of the

date of this Complaint, by failing to file payee addresses for 7 expenditures totaling $650.00.

5. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.3 and N.J.A.C. 19:25-12.2 by failing to certify as correct and file with the Commission on

October 15, 2009, on a 2009 third quarter report (Form R-1) for the 2009 runoff election, expenditure

information for 12 expenditures totaling $640.00, as described in paragraph 4 of the Proposed Findings of

Fact in this Count above. The Respondent Candidates and the Respondent Treasurer continue to violate

N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.3 and N.J.A.C. 19:25-12.2, as of the date of this Complaint, by

failing to file expenditure information for the 12 expenditures totaling $640.00.

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 24 6. Respondent Candidates Vincent Addeo, Angel Alicia, and Raul Morales II, and the Respondent

Treasurer, violated and continue to violate, as of the date of this Complaint, N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.3(e), by failing to certify the correctness of the expenditure information reported on the

2009 third quarter report.

7. The Respondent Candidates and the Respondent Treasurer are each subject to imposition by the

Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which

penalties may not be more than $6,800.00 for each reporting transaction, that is, for each expenditure that is

not reported in the manner or not filed on the date established for reporting by the Campaign Reporting Act

or Commission Regulations.

TENTH COUNT

PROPOSED FINDINGS OF FACT:

1. The Proposed Findings of Fact contained in the First through Ninth Counts of this Complaint are

repeated and incorporated herein as if set forth in full below.

2. The Respondent Candidates and the Respondent Treasurer received and deposited, or caused to

be deposited, the following contribution check into the 2009 runoff election campaign depository account:

check number 195 drawn on the account of “Florence Amato” in the amount of $20,000.00, deposited on or

around June 22, 2009.

3. The Respondent Candidates and the Respondent Treasurer reported on October 8, 2010, on

Schedule C (“Loans Received in Excess of $300”) of the 20-day postelection report for the 2009 runoff

election, described in paragraph two of the Proposed Findings of Fact in the Third Count above,

contribution information to report receipt of the contribution in the amount of $20,000.00, described in

paragraph two above.

4. The contributor described in paragraph two above, “Florence Amato,” was at all times relevant

to this Complaint an individual contributor.

5. The $20,000.00 contribution, described in paragraph two above, is an amount in excess of

$10,400.00 by $9,600.00.

6. The Respondent Candidates and the Respondent Treasurer did not refund or return to “Florence

Amato” within 48 hours of receipt, an amount of $9,600.00, or any amount of the $20,000.00 contribution

amount described in paragraphs two and five above.

7. The Respondent Candidates and the Respondent Treasurer refunded or returned to “Florence

Amato” on or around July 22, 2009, an amount of $4,000.00, of the $20,000.00 loan contribution amount

described in paragraphs two and five above.

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 25 8. The Respondent Candidates and the Respondent Treasurer refunded or returned to “Florence

Amato” on or around September 2, 2009, an amount of $2,198.55, of the $20,000.00 contribution amount

described in paragraphs two and five above.

9. The Respondent Candidates and the Respondent Treasurer reported on October 8, 2010, on the

2009 third quarter report for the 2009 runoff election, described in paragraph 2 of the Proposed Findings of

Fact in the Seventh Count above, on “Schedule 1 (D) – Disbursements, Campaign Expenses,” expenditure

information for two expenditures, totaling $6,198.55, described in paragraphs seven and eight above, each

made payable to “Florence Amato” for the reported purpose of “partial payment of loan” as follows:

a. an expenditure in the amount of $4,000.00, by check number 5006 on July 22, 2009; and

b. an expenditure in the amount of $2,198.55, by check number DB108 on September 2,

2009.

10. The Respondent Candidates and the Respondent Treasurer have not as of the date of this

Complaint refunded or returned to “Florence Amato” an amount of $3,401.45, or any amount of the

$20,000.00 contribution amount described in paragraph two above, other than the $6,198.55 total amount

described in paragraph nine above.

PROPOSED CONCLUSIONS OF LAW:

1. The Proposed Conclusions of Law contained in the First through Ninth Counts of this

Complaint are repeated and incorporated herein as if set forth in full below.

2. The Respondent Candidates and the Respondent Treasurer were at all times relevant to this

Count subject to the provisions of N.J.S.A. 19:44A-11.3 and N.J.A.C. 19:25-11.1 and 19:25-11.2, which

statutes and regulations prohibited the Respondent Candidates and the Respondent Treasurer from

knowingly accepting any contribution of money, including loans, from any individual, corporation, union,

association, or group contributor, which alone or when aggregated with prior contributions from that

contributor received in the 2009 runoff election, exceeded a contribution limit of $10,400.00.

3. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-11.3 and

N.J.A.C. 19:25-11.1 and 19:25-11.2 by knowingly accepting a contribution in the amount of $20,000.00 in

the 2009 runoff election, from a single contributor, “Florence Amato,” as described in paragraphs two

through six in the Proposed Findings of Fact in this Count above, and knowingly depositing, or causing to

be deposited, this contribution amount into the campaign depository for the 2009 runoff election. The

contribution from “Florence Amato” in the amount of $20,000.00, exceeded by $9,600.00 the $10,400.00

contribution limit per election the Respondent Candidates and the Respondent Treasurer were permitted to

accept pursuant to N.J.S.A. 19:44A-11.3 and N.J.A.C. 19:25-11.1 and 19:25-11.2.

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 26 4. The Respondent Candidates and the Respondent Treasurer violated N.J.A.C. 19:25-11.8, by

failing to refund or return to the contributor, “Florence Amato,” within 48 hours of receipt, the amount of

$9,600.00, which represents the difference between the $20,000.00 contribution amount from this

contributor and the $10,400.00 contribution limit the Respondent Candidates and the Respondent Treasurer

were permitted to accept in the 2009 runoff election from an individual, corporation, union, association or

group contributor pursuant to N.J.S.A. 19:44A-11.3 and N.J.A.C. 19:25-11.1 and 19:25-11.2. The

Respondent Candidates and the Respondent Treasurer refunded or returned to the contributor, “Florence

Amato,” the total amount of $6,198.55, as described in paragraphs seven through nine in the Proposed

Findings of Fact in this Count above.

5. The Respondent Candidates and the Respondent Treasurer violated and continue to violate

N.J.A.C. 19:25-11.8, as of the date of this Complaint, by failing to refund or return to the contributor,

“Florence Amato,” the amount of $3,401.45, which represents the difference between the $9,600.00

excessive amount of the $20,000.00 contribution from this contributor and the refunded amounts, totaling

$6,198.55, described in paragraphs seven through nine in the Proposed Findings of Fact in this Count

above.

6. The Respondent Candidates and the Respondent Treasurer are each subject to imposition by the

Commission of the penalties prescribed by N.J.S.A. 19:44A-22e and N.J.A.C. 19:25-17.1 et seq., which

penalty may be not more than $150,000.00 for willfully and intentionally accepting, retaining and not

returning or refunding within 48 hours of receipt, the $9,600.00 amount of the $20,000.00 contribution from

“Florence Amato,” which exceeded the $10,400.00 contribution limit in the 2009 runoff election.

ELEVENTH COUNT

PROPOSED FINDINGS OF FACT:

1. The Proposed Findings of Fact contained in the First through Tenth Counts of this Complaint are

repeated and incorporated herein as if set forth in full below.

2. The Respondent Candidates and the Respondent Treasurer received and deposited, or caused to

be deposited, three currency contributions, totaling $20,000.00, into the 2009 runoff election campaign

depository account as follows:

a. a currency contribution of $5,000.00, reported received on May 8, 2009, from

“Solomon Dwek – David Essenbach;”

b. a currency contribution of $5,000.00, reported received on May 19, 2009, from

“Solomon Dwek – David Essenbach;” and

c. a currency contribution of $10,000.00, reported received on July 16, 2009, from

“Solomon Dwek – David Essenbach.”

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 27 3. The Respondent Candidates and the Respondent Treasurer reported on October 8, 2010, on the

amended 11-day preelection report for the 2009 runoff election, described in paragraph 7 of the Proposed

Findings of Fact in the First Count above, contribution information to report receipt of the two contributions

totaling $10,000.00, described in paragraphs 2a and 2b above.

4. The Respondent Candidates and the Respondent Treasurer reported on October 8, 2010, on the

2009 third quarter report for the 2009 runoff election, described in paragraph 2 of the Proposed Findings of

Fact in the Seventh Count above, contribution information to report receipt of the one contribution in the

amount of $10,000.00, described in paragraph 2c above.

5. The contributor described in paragraph two above, “Solomon Dwek – David Essenbach,” was at

all times relevant to this Complaint an individual contributor.

6. The $20,000.00 aggregate contribution from “Solomon Dwek – David Essenbach” described in

paragraph two above, is an amount in excess of $10,400.00 by $9,600.00.

7. The Respondent Candidates and the Respondent Treasurer did not refund or return to “Solomon

Dwek – David Essenbach” within 48 hours of receipt, an amount of $9,600.00, or any amount of the

$20,000.00 aggregate contribution amount described in paragraphs two and six above.

8. The Respondent Candidates and the Respondent Treasurer have not as of the date of this

Complaint refunded or returned to “Solomon Dwek – David Essenbach” an amount of $9,600.00, or any

amount of the $20,000.00 aggregate contribution amount described in paragraph two above.

PROPOSED CONCLUSIONS OF LAW:

1. The Proposed Conclusions of Law contained in the First through Tenth Counts of this

Complaint are repeated and incorporated herein as if set forth in full below.

2. The Respondent Candidates and the Respondent Treasurer were at all times relevant to this

Count subject to the provisions of N.J.S.A. 19:44A-11.3 and N.J.A.C. 19:25-11.1 and 19:25-11.2, which

statutes and regulations prohibited the Respondent Candidates and the Respondent Treasurer from

knowingly accepting any contribution of money, including loans, from any individual, corporation, union,

association, or group contributor, which alone or when aggregated with prior contributions from that

contributor received in the 2009 runoff election, exceeded a contribution limit of $10,400.00.

3. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-11.3 and

N.J.A.C. 19:25-11.1 and 19:25-11.2 by knowingly accepting an aggregate contribution totaling $20,000.00

in the 2009 runoff election, from a single contributor, “Solomon Dwek – David Essenbach,” as described in

paragraphs two through six in the Proposed Findings of Fact in this Count above, and knowingly

depositing, or causing to be deposited, this aggregate contribution amount into the campaign depository for

the 2009 runoff election. The aggregate contribution from “Solomon Dwek – David Essenbach” totaling

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 28 $20,000.00, exceeded by $9,600.00 the $10,400.00 contribution limit per election the Respondent

Candidates and the Respondent Treasurer were permitted to accept pursuant to N.J.S.A. 19:44A-11.3 and

N.J.A.C. 19:25-11.1 and 19:25-11.2.

4. The Respondent Candidates and the Respondent Treasurer violated N.J.A.C. 19:25-11.8, by

failing to refund or return to the contributor, “Solomon Dwek – David Essenbach,” within 48 hours of

receipt, the amount of $9,600.00, which represents the difference between the $20,000.00 aggregate

contribution amount from this contributor and the $10,400.00 contribution limit the Respondent Candidates

and the Respondent Treasurer were permitted to accept in the 2009 runoff election from an individual,

corporation, union, association or group contributor pursuant to N.J.S.A. 19:44A-11.3 and N.J.A.C. 19:25-

11.1 and 19:25-11.2.

5. The Respondent Candidates and the Respondent Treasurer violated and continue to violate

N.J.A.C. 19:25-11.8, as of the date of this Complaint, by failing to refund or return to the contributor,

“Solomon Dwek – David Essenbach,” the amount of $9,600.00, which represents the difference between

the $20,000.00 aggregate contribution amount from this contributor and the $10,400.00 contribution limit

the Respondent Candidates and the Respondent Treasurer were permitted to accept in the 2009 runoff

election from an individual, corporation, union, association or group contributor pursuant to N.J.S.A.

19:44A-11.3 and N.J.A.C. 19:25-11.1 and 19:25-11.2.

6. The Respondent Candidates and the Respondent Treasurer are each subject to imposition by the

Commission of the penalties prescribed by N.J.S.A. 19:44A-22e and N.J.A.C. 19:25-17.1 et seq., which

penalty may be not more than $150,000.00 for willfully and intentionally accepting, retaining and not

returning or refunding within 48 hours of receipt, the $9,600.00 amount of the $20,000.00 aggregate

contribution from “Solomon Dwek – David Essenbach,” which exceeded the $10,400.00 contribution limit

in the 2009 runoff election.

TWELFTH COUNT

PROPOSED FINDINGS OF FACT:

1. The Proposed Findings of Fact contained in the First through Eleventh Counts of this Complaint

are repeated and incorporated herein as if set forth in full below.

2. The Respondent Candidates and the Respondent Treasurer reported on October 8, 2010, on the

2009 third quarter report for the 2009 runoff election, described in paragraph 2 of the Proposed Findings of

Fact in the Seventh Count above, on “Schedule E – Outstanding Obligations,” outstanding obligations

totaling $78,797.47.

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 29 3. The 2009 runoff election campaign depository maintained by the Respondent Candidates and the

Respondent Treasurer in the 2009 runoff election had a zero balance as of September 30, 2009, the last day

of the 2009 third quarter report period.

4. The Respondent Candidates and the Respondent Treasurer filed with the Commission on

October 8, 2010, a Form R-1 (Report of Contributions and Expenditures) relevant to the period of time from

October 1, 2009 through December 31, 2009 (hereafter, the 2009 fourth quarter report period for the 2009

runoff election), which report (hereafter, the 2009 fourth quarter report) was certified as correct by

Respondent Candidate Cammarano. The 2009 fourth quarter report was unsigned and not certified as

correct by Respondent Candidate Addeo, Respondent Candidate Alicia, Respondent Candidate Morales,

and Respondent Treasurer Truglio.

5. The Respondent Candidates and the Respondent Treasurer reported for the first time, on the

2009 fourth quarter report described in paragraph four above, no financial activity during that quarter and

on “Schedule E – Outstanding Obligations,” outstanding obligations totaling $78,797.47.

PROPOSED CONCLUSIONS OF LAW:

1. The Proposed Conclusions of Law contained in the First through Eleventh Counts of this

Complaint are repeated and incorporated herein as if set forth in full below.

2. The Respondent Candidates and Respondent Treasurer were required, pursuant to N.J.S.A.

19:44A-16 and N.J.A.C. 19:25-8.7 to certify as correct and file with the Commission, a full cumulative

Report of Contributions and Expenditures (Form R-1) for the 2009 runoff election to certify that there is no

remaining balance in any depository opened or maintained in the 2009 runoff election, that there are no

remaining 2009 runoff election outstanding obligations, and that the 2009 runoff election candidate

committee has been dissolved and wound-up its business, or to continue to file quarterly reports thereafter

until a final report is certified as correct and filed with the Commission.

3. The Respondent Candidates and the Respondent Treasurer were required pursuant to N.J.S.A.

19:44A-16 and N.J.A.C. 19:25-8.3, 10.2, 10.3, and 12.2, to certify as correct and file with the Commission

on January 15, 2010, a full cumulative Report of Contributions and Expenditures (Form R-1) as a 2009

fourth quarter report for the 2009 runoff election, to report all contributions received and all expenditures

made during the time period from October 1, 2009 through December 31, 2009, that is, the 2009 fourth

quarter report period for the 2009 runoff election.

4. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.3 by failing to certify as correct and file with the Commission on January 15, 2010, a 2009

fourth quarter report for the 2009 runoff election, and by failing to report on January 15, 2010, information

described in paragraph five of the Proposed Findings of Fact in this Count above. The Respondent

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 30 Candidates and the Respondent Treasurer filed the 2009 fourth quarter report and reported this information

on October 8, 2010, 266 days late.

5. Respondent Candidates Vincent Addeo, Angel Alicia, and Raul Morales II, and the Respondent

Treasurer, violated and continue to violate, as of the date of this Complaint, N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.3(e), by failing to certify the correctness of the information reported on the 2009 fourth

quarter report for the 2009 runoff election.

6. The Respondent Candidates and the Respondent Treasurer are subject to imposition by the

Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which

penalties may not be more than $6,800.00 for each reporting transaction, that is, for each reporting

transaction which has not been reported in the manner or in the time prescribed by the Act or Commission

Regulations.

THIRTEENTH COUNT

PROPOSED FINDINGS OF FACT:

1. The Proposed Findings of Fact contained in the First through Twelfth Counts of this Complaint

are repeated and incorporated herein as if set forth in full below.

2. The Respondent Candidates and the Respondent Treasurer filed with the Commission on

October 8, 2010, a Form R-1 (Report of Contributions and Expenditures) relevant to the period of time from

January 1, 2010 through March 31, 2010 (hereafter, the 2010 first quarter report period for the 2009 runoff

election), which report (hereafter, the 2010 first quarter report) was certified as correct by Respondent

Candidate Cammarano. The 2010 first quarter report was unsigned and not certified as correct by

Respondent Candidate Addeo, Respondent Candidate Alicia, Respondent Candidate Morales, and

Respondent Treasurer Truglio.

3. The Respondent Candidates and the Respondent Treasurer reported for the first time, on the

2010 first quarter report described in paragraph two above, no financial activity during that quarter and on

“Schedule E – Outstanding Obligations,” outstanding obligations totaling $78,797.47.

PROPOSED CONCLUSIONS OF LAW:

1. The Proposed Conclusions of Law contained in the First through Twelfth Counts of this

Complaint are repeated and incorporated herein as if set forth in full below.

2. The Respondent Candidates and Respondent Treasurer were required, pursuant to N.J.S.A.

19:44A-16 and N.J.A.C. 19:25-8.7 to certify as correct and file with the Commission, a full cumulative

Report of Contributions and Expenditures (Form R-1) for the 2009 runoff election to certify that there is no

remaining balance in any depository opened or maintained in the 2009 runoff election, that there are no

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 31 remaining 2009 runoff election outstanding obligations, and that the 2009 runoff election candidate

committee has been dissolved and wound-up its business, or to continue to file quarterly reports thereafter

until a final report is certified as correct and filed with the Commission.

3. The Respondent Candidates and the Respondent Treasurer were required pursuant to N.J.S.A.

19:44A-16 and N.J.A.C. 19:25-8.3, 10.2, 10.3, and 12.2, to certify as correct and file with the Commission

on April 15, 2010, a full cumulative Report of Contributions and Expenditures (Form R-1) as a 2010 first

quarter report for the 2009 runoff election, to report all contributions received and all expenditures made

during the time period from January 1, 2010 through March 31, 2010, that is, the 2010 first quarter report

period for the 2009 runoff election.

4. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.3 by failing to certify as correct and file with the Commission on April 15, 2010, a 2010

first quarter report for the 2009 runoff election, and by failing to report on April 15, 2010, information

described in paragraph three of the Proposed Findings of Fact in this Count above. The Respondent

Candidates and the Respondent Treasurer filed the 2010 first quarter report and reported this information on

October 8, 2010, 176 days late.

5. Respondent Candidates Vincent Addeo, Angel Alicia, and Raul Morales II, and the Respondent

Treasurer, violated and continue to violate, as of the date of this Complaint, N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.3(e), by failing to certify the correctness of the information reported on the 2010 first

quarter report for the 2009 runoff election.

6. The Respondent Candidates and the Respondent Treasurer are subject to imposition by the

Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which

penalties may not be more than $6,800.00 for each reporting transaction, that is, for each reporting

transaction which has not been reported in the manner or in the time prescribed by the Act or Commission

Regulations.

FOURTEENTH COUNT

PROPOSED FINDINGS OF FACT:

1. The Proposed Findings of Fact contained in the First through Thirteenth Counts of this

Complaint are repeated and incorporated herein as if set forth in full below.

2. The Respondent Candidates and the Respondent Treasurer filed with the Commission on

October 8, 2010, a Form R-1 (Report of Contributions and Expenditures) relevant to the period of time from

April 1, 2010 through June 30, 2010 (hereafter, the 2010 second quarter report period for the 2009 runoff

election), which report (hereafter, the 2010 second quarter report) was certified as correct by Respondent

Candidate Cammarano. The 2010 second quarter report was unsigned and not certified as correct by

Page 32: Peter Cammarano ELEC Complaint

ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 32 Respondent Candidate Addeo, Respondent Candidate Alicia, Respondent Candidate Morales, and

Respondent Treasurer Truglio.

3. The Respondent Candidates and the Respondent Treasurer reported for the first time, on the

2010 second quarter report described in paragraph two above, no financial activity during that quarter and

on “Schedule E – Outstanding Obligations,” outstanding obligations totaling $78,797.47.

PROPOSED CONCLUSIONS OF LAW:

1. The Proposed Conclusions of Law contained in the First through Thirteenth Counts of this

Complaint are repeated and incorporated herein as if set forth in full below.

2. The Respondent Candidates and Respondent Treasurer were required, pursuant to N.J.S.A.

19:44A-16 and N.J.A.C. 19:25-8.7 to certify as correct and file with the Commission, a full cumulative

Report of Contributions and Expenditures (Form R-1) for the 2009 runoff election to certify that there is no

remaining balance in any depository opened or maintained in the 2009 runoff election, that there are no

remaining 2009 runoff election outstanding obligations, and that the 2009 runoff election candidate

committee has been dissolved and wound-up its business, or to continue to file quarterly reports thereafter

until a final report is certified as correct and filed with the Commission.

3. The Respondent Candidates and the Respondent Treasurer were required pursuant to N.J.S.A.

19:44A-16 and N.J.A.C. 19:25-8.3, 10.2, 10.3, and 12.2, to certify as correct and file with the Commission

on July 15, 2010, a full cumulative Report of Contributions and Expenditures (Form R-1) as a 2010 second

quarter report for the 2009 runoff election, to report all contributions received and all expenditures made

during the time period from April 1, 2010 through June 30, 2010, that is, the 2010 second quarter report

period for the 2009 runoff election.

4. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.3 by failing to certify as correct and file with the Commission on July 15, 2010, a 2010

second quarter report for the 2009 runoff election, and by failing to report on July 15, 2010, information

described in paragraph three of the Proposed Findings of Fact in this Count above. The Respondent

Candidates and the Respondent Treasurer filed the 2010 second quarter report and reported this information

on October 8, 2010, 85 days late.

5. Respondent Candidates Vincent Addeo, Angel Alicia, and Raul Morales II, and the Respondent

Treasurer, violated and continue to violate, as of the date of this Complaint, N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.3(e), by failing to certify the correctness of the information reported on the 2010 second

quarter report for the 2009 runoff election.

6. The Respondent Candidates and the Respondent Treasurer are subject to imposition by the

Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 33 penalties may not be more than $6,800.00 for each reporting transaction, that is, for each reporting

transaction which has not been reported in the manner or in the time prescribed by the Act or Commission

Regulations.

FIFTEENTH COUNT

PROPOSED FINDINGS OF FACT:

1. The Proposed Findings of Fact contained in the First through Fourteenth Counts of this

Complaint are repeated and incorporated herein as if set forth in full below.

2. The Respondent Candidates and the Respondent Treasurer have not certified as correct and filed

with the Commission a Form R-1 (Report of Contributions and Expenditures) relevant to the period of time

from July 1, 2010 through September 30, 2010 (hereafter, the 2010 third quarter report period for the 2009

runoff election).

3. The Respondent Candidates and the Respondent Treasurer have not, as of the date of this

Complaint, certified as correct and filed with the Commission, a postelection quarterly report or any other

Report of Contributions and Expenditures (Form R-1), as a final election fund report for the 2009 runoff

election.

PROPOSED CONCLUSIONS OF LAW:

1. The Proposed Conclusions of Law contained in the First through Fourteenth Counts of this

Complaint are repeated and incorporated herein as if set forth in full below.

2. The Respondent Candidates and Respondent Treasurer were required, pursuant to N.J.S.A.

19:44A-16 and N.J.A.C. 19:25-8.7 to certify as correct and file with the Commission, a full cumulative

Report of Contributions and Expenditures (Form R-1) for the 2009 runoff election to certify that there is no

remaining balance in any depository opened or maintained in the 2009 runoff election, that there are no

remaining 2009 runoff election outstanding obligations, and that the 2009 runoff election candidate

committee has been dissolved and wound-up its business, or to continue to file quarterly reports thereafter

until a final report is certified as correct and filed with the Commission.

3. The Respondent Candidates and the Respondent Treasurer were required pursuant to N.J.S.A.

19:44A-16 and N.J.A.C. 19:25-8.3, 10.2, 10.3, and 12.2, to certify as correct and file with the Commission

on October 15, 2010, a full cumulative Report of Contributions and Expenditures (Form R-1) as a 2010

third quarter report for the 2009 runoff election, to report all contributions received and all expenditures

made during the time period from July 1, 2010 through September 30, 2010, that is, the 2010 third quarter

report period for the 2009 runoff election.

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 34 4. The Respondent Candidates and the Respondent Treasurer violated N.J.S.A. 19:44A-16 and

N.J.A.C. 19:25-8.3 by failing to certify as correct and file with the Commission on October 15, 2010, a

2010 third quarter report for the 2009 runoff election.

5. The Respondent Candidates and the Respondent Treasurer violated and continue to violate, as

of the date of this Complaint, N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.7 by failing to certify as correct and

file with the Commission a final report in the 2009 runoff election as prescribed by the Campaign Reporting

Act and Commission Regulations.

6. The Respondent Candidates and the Respondent Treasurer are subject to imposition by the

Commission of the penalties prescribed by N.J.S.A. 19:44A-22 and N.J.A.C. 19:25-17.1 et seq., which

penalties may not be more than $6,800.00 for each reporting transaction, that is, for each reporting

transaction which has not been reported in the manner or in the time prescribed by the Act or Commission

Regulations.

OPPORTUNITY FOR HEARING:

Pursuant to N.J.A.C. 19:25-17.1, the Respondents and all parties shall have the opportunity to

appear personally or by attorney at a hearing pursuant to the “Administrative Procedure Act,” N.J.S.A.

52:14B-1 et seq., and to present evidence and argument on all relevant issues. All parties shall have the

opportunity to examine and cross-examine witnesses. However, failure of each Respondent to file with

the Commission a written answer within twenty (20) days after service of this Complaint shall constitute

a default pursuant to N.J.A.C. 19:25-17.1A and thereupon the Commission may enter a Final Decision

(including imposition of a monetary penalty).

NEW JERSEY ELECTION LAW ENFORCEMENT COMMISSION BY: ________________________ CAROL L. HOEKJE Legal Director DATE: September 11, 2013 Peter Cammarano CERTIFIED MAIL NO. 7009 3410 0001 8443 4251 RETURN RECEIPT REQUESTED Vincent Addeo CERTIFIED MAIL NO. 7009 3410 0001 8443 4268 RETURN RECEIPT REQUESTED

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 35 Angel Alicia CERTIFIED MAIL NO. 7009 3410 0001 8443 4275 RETURN RECEIPT REQUESTED Raul Morales II CERTIFIED MAIL NO. 7009 3410 0001 8443 4282 RETURN RECEIPT REQUESTED Lucy Truglio CERTIFIED MAIL NO. 7009 3410 0001 8443 4299 RETURN RECEIPT REQUESTED

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 36

EXHIBIT A Count 1

(A) Item No. (B) Date of Deposit (C) Amount

(D) Name on Contributor Check or

Currency Contribution

1 05/08/09 $5,000

Mary E. Bellotti

2 05/11/09 $500 U.A. Local Union 322 Plumbers & Pipefitters

Political Action Committee

3 05/12/09 $500

Tonio Burgos & Associates of New Jersey LLC

4 05/13/09 $2,000

Artesian Design Group Inc

5 05/19/09 $1,500

Crydon Corp DBA McSwiggan’s

6 05/19/09 $2,500

Jack M. Shaw

Total: $12,000

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 37

EXHIBIT B Count 1

(A) Item No. (B) Date (C) Amount

(D) Contributor Name (E) Occupation (F) Employer Name (G) Employer Address

1 05/19/09 $2,500 Robert Capelli, Jr. None reported Actor None reported 2 05/20/09 $500 Jim B. Clugston self None reported None reported 3 05/01/09 $2,000 Dina Ali None reported None reported None reported 4 05/01/09 $500 Anthony M. Delmastro None reported None reported None reported 5 05/01/09 $500 Brian J. Mazzei None reported None reported None reported 6 05/01/09 $500 Michael Nirchio None reported None reported None reported 7 05/04/09 $1,500 Lori Zaksewski None reported None reported None reported 8 05/07/09 $80 Daris Birto None reported None reported None reported 9 05/07/09 $80 Michael De Fusco None reported None reported None reported

10 05/07/09 $40 Nicole De Fusco None reported None reported None reported 11 05/07/09 $150 Bill Freil None reported None reported None reported 12 05/07/09 $30 Owen Henry None reported None reported None reported 13 05/07/09 $40 Edward La Pierre None reported None reported None reported 14 05/07/09 $80 Tito Rodriguez None reported None reported None reported 15 05/08/09 $3,000 Joseph Addonizio None reported None reported None reported 16 05/08/09 $1,000 Robert Debeer None reported None reported None reported 17 05/08/09 $1,000 TJ Rooney None reported None reported None reported 18 05/12/09 $400 BB None reported None reported None reported 19 05/16/09 $2,500 Saturnina Mojica None reported None reported None reported 20 05/17/09 $1,000 Benny Tudinos None reported None reported None reported 21 05/19/09 $2,500 Suzanne Forbes None reported None reported None reported

Total: $19,400

Page 38: Peter Cammarano ELEC Complaint

ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 38

EXHIBIT C Count 1

(A) Item No. (B) Date (C) Amount (D) Account Name on

Contributor Check (E) Name(s) of Individual

Contributors 1 05/01/09 $1,000 Riverview Historical Plaza II LLC None reported 2 05/04/09 $750 Homebuilders Group LLC None reported

3 05/06/09 $1,200 Premier Business Management

Group LLC None reported 4 05/09/09 $1,000 JN Associates, LLC None reported 5 05/11/09 $500 Lopiano & Kenny LLC None reported 6 05/12/09 $500 627 Willow Ave LLC None reported 7 05/19/09 $2,000 Anthony L&S LLC None reported

Total: $6,950

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 39

EXHIBIT D Count 2

(A) Item No. (B) Date (C) Check No. (D) Amount (E) Payee Name (F) Payee Address

1 05/12/09 3009 $100 Maria Viaux Hoboken, NJ 2 05/12/09 3134 $50 Carmen Ortiz Hoboken NJ 07030 3 05/12/09 3135 $50 Agripina Panet Hoboken NJ 07030 4 05/12/09 3176 $50 Margaret Romeoletti Hoboken, NJ 07030 5 05/12/09 3272 $100 J Lopez Hoboken NJ 07030 6 05/12/09 3273 $100 Creg Delguelo Hoboken, NJ 07030 7 05/12/09 3277 $100 Nenida Colon Hoboken, NJ 07030 8 05/12/09 3293 $50 Nicolas M Hoboken, NJ 07030 9 05/12/09 3295 $50 Miguel Vargas Hoboen, NJ 07030

10 05/12/09 3331 $50 Jazelina Avila Hoboken NJ 07030 11 05/12/09 3398 $50 Jalisa Pressley Hoboken, NJ 12 05/12/09 3443 $50 Jerald Dixon Hoboken, NJ 07030 13 05/12/09 3444 $50 Shawnette Owusu-Ansah Hoboken, NJ 07030 14 05/12/09 3474 $35 Marshall Lemanowicz Hoboken NJ 07030 15 05/12/09 3475 $35 Jordan Luglio Hoboken, NJ 07030 16 05/12/09 3478 $35 Virginia Moore Hoboken, NJ 07030 17 04/30/09 1041 $900 Christino Diaz None reported 18 05/08/09 debit $2,419.81 Progressive None reported 19 05/03/09 1071 $32 Justin Rubro None reported 20 05/03/09 1072 $64 Marcelo De Lima None reported 21 05/03/09 1074 $40 Victor Kwak None reported 22 05/03/09 1075 $40 Daniel Jung None reported 23 05/03/09 1076 $40 Willy Seo None reported 24 05/09/09 1111 $400 Alixa Christopher None reported 25 05/09/09 1113 $150 Natalia Fucilli None reported 26 05/09/09 1136 $36 Matthew Spano None reported 27 05/09/09 1137 $40 Franco Danielle None reported 28 05/09/09 1138 $40 Corrado Minervini None reported 29 05/09/09 1143 $80 Ricardo Cruz None reported 30 05/09/09 1152 $64 Justin Rubro None reported 31 05/09/09 1154 $144 Marcelo De Lima None reported 32 05/09/09 1156 $40 Victor Kwak None reported 33 05/09/09 1157 $40 Daniel Jung None reported 34 05/09/09 1158 $40 Willy Seo None reported 35 05/09/09 1161 $100 Adam Kraemer None reported 36 05/09/09 1163 $330 John Pimental None reported 37 05/09/09 1164 $64 Kayla Delgado None reported 38 05/09/09 1165 $32 Ricky Trippner None reported 39 05/09/09 1166 $36 Steven Medina None reported 40 05/09/09 1172 $104 Marcos Espinoza None reported 41 05/09/09 1173 $300 Alex Lesiak None reported 42 05/20/09 1179 $40 Marcelo De Lima None reported 43 05/20/09 1181 $48 Natalia Fucilli None reported 44 05/20/09 1185 $48 Bill Meyer None reported 45 05/20/09 1191 $50 Zoraido Montanez None reported 46 05/20/09 1192 $20 Wilfredo Rodriguez None reported 47 05/09/09 1226 $200 Jasmine Durham None reported 48 05/09/09 1229 $24 Ryan Lopez None reported 49 05/12/09 1232 $100 Alixa Christopher None reported 50 05/12/09 3027 $50 Charlie Hanberry None reported 51 05/12/09 3081 $100 Martin Peralta None reported 52 05/12/09 3082 $50 Miguel Gonzalez None reported 53 05/12/09 3083 $50 Adaberto Matos None reported 54 05/12/09 3084 $50 Santos Alvarez None reported 55 05/12/09 3095 $50 Martin Peralta None reported

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 40

56 05/12/09 3104 $50 Michael Stevens None reported 57 05/12/09 3154 $50 Emilio Cintron None reported 58 05/12/09 3173 $50 Dean Guderson None reported 59 05/12/09 3217 $150 William Meyer None reported 60 05/12/09 3269 $50 De Ja Lawrence None reported 61 05/12/09 3280 $50 Irene Mestres None reported 62 05/12/09 3281 $50 Maria Laviera None reported 63 05/12/09 3314 $50 Luz Ithier None reported 64 05/12/09 3363 $50 Angela Matias None reported 65 05/12/09 3368 $35 Antoinette Ambrosini None reported 66 05/12/09 3403 $100 Deborah Barnes None reported 67 05/12/09 3409 $50 Walter Dickerson None reported 68 05/12/09 3430 $50 Jarell Lee None reported 69 05/12/09 3484 $200 John Pimental None reported 70 05/12/09 3487 $50 Christine Ripeile None reported 71 05/12/09 3492 $50 Juan Alvarado None reported 72 05/12/09 3494 $80 Mike Di Tullio None reported 73 05/12/09 3496 $100 Divina Herrera None reported 74 05/12/09 3498 $162 Melina Skarantonakis None reported

Total: $8,829.81

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 41

EXHIBIT E Count 3

(A) Item No. (B) Date of Deposit (C) Amount

(D) Name on Contributor Check

or Currency Contribution

1 06/05/09 $5,000

“Cash”

2 06/08/09 $500 “Bank check issued from Haven

Savings Bank”

3 06/12/09 $3,000

“Cash”

4 06/18/09 $500

Jeffrey E. Peckham

5 06/23/09 $340

Robert W. Sheridan

6 06/26/09 $1,000

Anton C. Peskens

7 06/26/09 $500

Patricia A. Pope

Total: $10,840

Page 42: Peter Cammarano ELEC Complaint

ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 42

EXHIBIT F Count 3

(A) Item No. (B) Date (C) Amount

(D) Contributor Name

(E) Occupation (F) Employer Name (G) Employer Address

1 06/03/09 $1,000

Edward Salmon

None reported Salmon Ventures

Ltd 7 Easterwood St Suite D

Millville, NJ 08332 2 06/01/09 $500 Richard England, Jr. None reported None reported None reported 3 06/01/09 $500 Paul Hanak None reported None reported None reported 4 06/01/09 $500 Justin M. Silverman None reported None reported None reported 5 06/03/09 $1,000 James M. Canino None reported None reported None reported 6 06/05/09 $2,500 Maher Khalil None reported None reported None reported 7 06/08/09 $500 Edward Dolan None reported None reported None reported 8 06/08/09 $500 Walter McMahon None reported None reported None reported 9 06/09/09 $5,000 Angel L. Alicea None reported None reported None reported

10 06/12/09 $5,000 Jacqueline Klausner None reported None reported None reported 11 06/12/09 $4,000 Michael Schaffer None reported None reported None reported 12 06/12/09 $2,500 Mario Steriti None reported None reported None reported 13 06/22/09 $20,000 Florence Amato None reported None reported None reported

Total: $43,500

Page 43: Peter Cammarano ELEC Complaint

ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 43

EXHIBIT G Count 3

(A) Item No. (B) Date (C) Amount (D) Account Name on

Contributor Check (E) Name(s) of Individual

Contributors 1 05/27/09 $500 M&M Development LLC None reported 2 05/27/09 $500 R&R Golf Management LLC None reported 3 06/01/09 $1,000 80 River Street LLC None reported 4 06/01/09 $500 Elysian Café, LLC None reported

5 06/01/09 $500 Premier Business Management

Group LLC None reported

6 06/04/09 $1,000 Premier Business Management

Group LLC None reported Total: $4,000

Page 44: Peter Cammarano ELEC Complaint

ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 44

EXHIBIT H Count 6

(A) Item No. (B) Date (C) Check No. (D) Amount (E) Payee Name (F) Payee Address

1 06/08/09 1307 $150 Hoboken Parking Authority Hoboken NJ 07030 2 06/09/09 1316 $1,500 Anthony Romano Hoboken, NJ 07030 3 06/09/09 1324 $420 Wilbur Huggins Hoboken NJ 07030 4 06/12/09 3664 $50 Jazelina Avila Hoboken NJ 07030 5 06/12/09 3944 $50 Isla Montano Hoboken, NJ 07030 6 06/12/09 3970 $50 Carmen Ortiz Hoboken, NJ 07030 7 06/12/09 3980 $50 Agripina Panet Hoboken, NJ 07030 8 06/12/09 4065 $50 Margaret Romeole Hoboken, NJ 07030 9 05/29/09 1211 $420 John Pimental None reported

10 05/29/09 1212 $150 Alex Lesiak None reported 11 05/29/09 1214 $500 Alixa Christopher None reported 12 05/29/09 1221 $40 Lyla Ribot None reported 13 06/02/09 1635048 $2,500 RC Solutions None reported 14 06/04/09 1251 $1,900 All-In-One Entertainment None reported 15 06/04/09 1252 $560 Benny Love None reported 16 06/04/09 1261 $8 Stefano Bassanini None reported 17 06/04/09 3500 $200 Lisa Okragly None reported 18 06/04/09 3501 $400 Romina Pascual None reported 19 06/04/09 3502 $420 John Pimental None reported 20 06/04/09 3503 $32 Elida Theresa Port None reported 21 06/04/09 3507 $115 Lyla Ribot None reported 22 06/04/09 3518 $50 Tirone Carmella None reported 23 06/04/09 3521 $40 Mike Trost None reported 24 06/04/09 3522 $32 Kevin Valdez None reported 25 06/04/09 3524 $40 Maxwell Yu None reported 26 06/04/09 3531 $64 Ronald Garcia None reported 27 06/04/09 3534 $96 Steven Gaeta None reported 28 06/04/09 3539 $40 Gabriel Gomzez None reported 29 06/04/09 3540 $32 Miguel Gonzalez None reported 30 06/04/09 3543 $32 Matthew Trontz None reported 31 06/04/09 3544 $128 Max Tyutyunik None reported 32 06/04/09 3545 $96 Andrew Valdez None reported 33 06/04/09 1268 $35 Maria Aldecoa None reported 34 06/04/09 1269 $35 Rosendo Aldecoa None reported 35 06/05/09 1275 $35 Thomas Walenta None reported 36 06/05/09 1277 $60 Divina Herrera None reported 37 06/05/09 1280 $190 Adam Kraemer None reported 38 06/05/09 1282 $400 Alex Lesiak None reported 39 06/05/09 1284 $32 Michael Lipowski None reported 40 06/05/09 1290 $96 Nixidia Martinez None reported 41 06/05/09 1292 $32 William Meyer None reported 42 06/05/09 1293 $32 Samantha Morales None reported 43 06/05/09 1296 $216 Melina Skarantonakis None reported 44 06/05/09 1298 $50 Aixa Christopher None reported 45 06/05/09 1305 $413.96 Ryan Yacco None reported 46 06/08/09 1310 $1,090.08 Joseph Branco None reported 47 06/08/09 1315 $2,750 Bluestate Technologies None reported 48 06/09/09 1318 $4,900 All-In-One Entertainment None reported 49 06/09/09 1319 $1,000 Benny Love None reported 50 06/09/09 1323 $500 Daniel Matos None reported 51 06/09/09 3546 $128 Kleber Vera None reported 52 06/09/09 3549 $350 Barbara Walensky None reported 53 06/09/09 3550 $210 Vicki Webber None reported 54 06/09/09 3552 $64 Jasmin Zikri None reported 55 06/09/09 3555 $220 Angie Aly None reported

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 45

56 06/09/09 3563 $200 Aixa Christopher None reported 57 06/09/09 3566 $64 Julissa Correa None reported 58 06/09/09 3568 $32 Ricardo Cruz None reported 59 06/09/09 3571 $150 Mike Di Tullio None reported 60 06/09/09 3574 $40 Natalia Fucilli None reported 61 06/09/09 3576 $96 Ronald Garcia None reported 62 06/09/09 3589 $400 Alex Lesiak None reported 63 06/09/09 3597 $96 Bianca Silva None reported 64 06/09/09 3599 $225 Melina Skarantona None reported 65 06/09/09 3600 $32 Matthew Spano None reported 66 06/09/09 3601 $150 Danny Spatucci None reported 67 06/09/09 3610 $64 Tiffany Martinez None reported 68 06/09/09 3611 $32 Melissa Mendez None reported 69 06/09/09 3612 $200 William Meyer None reported 70 06/09/09 3613 $68 Milton Moss None reported 71 06/09/09 3614 $32 David Muntzer None reported 72 06/09/09 3616 $400 Lisa Okragly None reported 73 06/09/09 3617 $480 Romina Pascual None reported 74 06/09/09 3619 $540 John Pimental None reported 75 06/09/09 3621 $64 Samata Steel None reported 76 06/09/09 3625 $320 Lyla Ribot None reported 77 06/09/09 3635 $50 Jocelyn Agosta None reported 78 06/09/09 3643 $50 Maria Alicea None reported 79 06/09/09 3644 $50 Marquita Allen None reported 80 06/12/09 3647 $50 Radiah Alston None reported 81 06/12/09 3649 $50 Santos Alvarez None reported 82 06/12/09 3650 $50 Antoinette Ambrosi None reported 83 06/12/09 3657 $50 Edna Aponte None reported 84 06/12/09 3658 $50 Debeniese Aponte None reported 85 06/12/09 3667 $50 Leondel Ayuso None reported 86 06/12/09 3701 $50 Veronique Campbell None reported 87 06/12/09 3711 $50 Tabitha Castellanos None reported 88 06/12/09 3722 $50 Emilio Cintron None reported 89 06/12/09 3734 $50 Jerry Crandeal None reported 90 06/12/09 3745 $50 Rafael Cruz None reported 91 06/12/09 3747 $50 Wilfredo Cruzado None reported 92 06/12/09 3770 $50 Walter Dickerson None reported 93 06/12/09 3785 $50 Ada Estrella None reported 94 06/12/09 3799 $50 Sasha Ferrer None reported 95 06/12/09 3817 $50 Mayi Fonseca None reported 96 06/12/09 3820 $50 Taisha Fragosa None reported 97 06/12/09 3824 $50 Migna Franco None reported 98 06/12/09 3827 $50 Gloria Freire None reported 99 06/12/09 3833 $50 Maria Garcia None reported

100 06/12/09 3856 $50 Hydir Ladson None reported 101 06/12/09 3860 $50 Zoan Lardy None reported 102 06/12/09 3866 $50 De Jesus Leanor None reported 103 06/12/09 3867 $50 Henry Lobo None reported 104 06/12/09 3869 $50 Thomas Lopez None reported 105 06/12/09 3876 $50 Samuel Lopez None reported 106 06/12/09 3892 $50 Piedad Marcos None reported 107 06/12/09 3907 $50 Alberto Matos None reported 108 06/12/09 3909 $50 Charol Matos None reported 109 06/12/09 3910 $50 Thomas McInerney None reported 110 06/12/09 3913 $50 Israel Melendez None reported 111 06/12/09 3914 $50 Aixa Melendez None reported 112 06/12/09 3921 $50 Irene Mestres None reported 113 06/12/09 3922 $50 Justine Miles None reported 114 06/12/09 3923 $50 Tyrone Miles None reported

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 46

115 06/12/09 3947 $50 Carmelo Morales None reported 116 06/12/09 3952 $50 Thomas Morel None reported 117 06/12/09 3953 $50 Nicholas Moreno None reported 118 06/12/09 3983 $50 Segundo Parrales None reported 119 06/12/09 3986 $50 Martin Peralta None reported 120 06/12/09 3987 $50 Dayna Peralta None reported 121 06/12/09 3988 $50 Ireina Peralta None reported 122 06/12/09 3989 $50 Melissa Perez None reported 123 06/12/09 4021 $50 Stephen Rhone None reported 124 06/12/09 4033 $50 Cardidad Rivera None reported 125 06/12/09 4043 $50 Venetta Rivera None reported 126 06/12/09 4066 $50 Julia Rosa None reported 127 06/12/09 4083 $50 Mirran Rosiro None reported 128 06/12/09 4092 $50 Valenta Santiago None reported 129 06/12/09 4098 $50 Vincente Santiago None reported 130 06/12/09 4103 $50 Osvaddo Sepulveda None reported 131 06/12/09 4105 $50 Eliezer Sepulvedo None reported 132 06/12/09 4135 $50 Migdalia Torres None reported 133 06/12/09 4139 $50 Rafael Triunfel None reported 134 06/12/09 4158 $50 Ursula Vidal None reported 135 06/12/09 4165 $50 Shireasha Walker None reported 136 06/12/09 4185 $50 Tara Weyouche None reported 137 06/12/09 4223 $100 Joan Mincica None reported 138 06/12/09 4226 $100 Martin Peralta None reported 139 06/12/09 4241 $35 Alexandra Richard None reported 140 06/12/09 4252 $50 Miguel Gonzalez None reported 141 06/12/09 4258 $50 Thomas Gorham None reported 142 06/12/09 4265 $50 Chantee Hanberry None reported 143 06/12/09 4328 $50 Julissa Correa None reported 144 06/12/09 4333 $50 Sara Drishti None reported 145 06/12/09 4337 $50 Christopher Ferna None reported 146 06/12/09 4341 $50 Rafael Flores None reported 147 06/12/09 4344 $50 Ronald Garcia None reported 148 06/12/09 4348 $50 Cindi Gentry None reported 149 06/12/09 4359 $50 Jason Guzman None reported 150 06/12/09 4363 $50 Walter Hernandez None reported 151 06/12/09 4364 $50 William Hernandez None reported 152 06/12/09 4373 $50 Patricia Ingles None reported 153 06/12/09 4376 $50 Victor Kwak None reported 154 06/12/09 4385 $50 Kenneth Maccagna None reported 155 06/12/09 4395 $50 Sarita Mehta None reported 156 06/12/09 4397 $50 Latoya Miller None reported 157 06/12/09 4400 $50 Kim Mincica None reported 158 06/12/09 4404 $50 Leslie Moreno None reported 159 06/12/09 4409 $50 Brittany O’Keefe None reported 160 06/12/09 4420 $50 Frank Quiroz None reported 161 06/12/09 4436 $50 Naveed Siddque None reported 162 06/12/09 4439 $50 Samata Steel None reported 163 06/12/09 4441 $50 Stacy Sweeny None reported 164 06/12/09 4447 $50 Brian Valente None reported 165 06/12/09 4461 $90 Robert Brennan None reported 166 06/12/09 4464 $90 Ronald Cassesa None reported 167 06/12/09 4468 $90 David Muntzer None reported 168 06/12/09 4474 $90 Danny Spatucci None reported 169 06/12/09 4484 $125 Alex Lesiak None reported 170 06/12/09 4505 $50 Otero Idgalia None reported 171 06/12/09 4511 $50 Silfredo Genao None reported 172 06/12/09 4514 $50 Jasmin Briggs None reported 173 06/12/09 4516 $150 John McGinley None reported

Page 47: Peter Cammarano ELEC Complaint

ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 47

174 06/12/09 4517 $150 Joanne Kemp None reported 175 06/12/09 4531 $90 Joseph Casella None reported 176 06/12/09 4534 $50 Ellen Molina None reported 177 06/12/09 4548 $50 Melissa Mendez None reported 178 06/12/09 4550 $80 Zac Zaforski None reported 179 06/12/09 4572 $50 Edward Triosi None reported 180 06/12/09 4605 $50 Stephen Rhone None reported 181 06/12/09 4613 $50 Thomas Lopez None reported 182 06/12/09 4633 $100 John Markle None reported 183 06/12/09 4637 $100 Steven O’Connor None reported 184 06/12/09 4649 $150 Danny Spatucci None reported 185 06/12/09 4657 $32 Julissa Correa None reported 186 06/12/09 4659 $75 Jake Durham None reported 187 06/12/09 4660 $50 Christopher Ferna None reported 188 06/12/09 4665 $128 Miguel Gonzalez None reported 189 06/12/09 4669 $240 Alex Lesiak None reported 190 06/12/09 4670 $50 Michael Gruich None reported 191 06/12/09 4671 $90 Emmanuel Munoz None reported 192 06/12/09 4672 $50 Bianca Silva None reported 193 06/12/09 4673 $100 Anthony Simbana None reported 194 06/12/09 4680 $32 William Meyer None reported 195 06/12/09 4683 $280 Lisa Okragly None reported 196 06/12/09 4685 $240 John Pimental None reported 197 06/12/09 4690 $32 Samata Steel None reported 198 06/12/09 4692 $100 Barbara Walensky None reported 199 06/12/09 4693 $50 Sadiel Rodriguez None reported 200 06/12/09 4697 $50 Nilsa Robertson None reported 201 06/12/09 4703 $50 Michael Lombardo None reported 202 06/12/09 4704 $40 Latoya Miller None reported 203 06/12/09 4705 $50 Manny Bermudez None reported 204 06/12/09 4706 $50 Preston Whiete None reported 205 06/12/09 4707 $50 Jeffrey Thompson None reported 206 06/12/09 4709 $50 Mario Medina None reported 207 06/12/09 4710 $90 Mildred Perez None reported 208 06/12/09 4714 $90 Douglas Salters None reported 209 06/12/09 4716 $50 Alex Teller None reported 210 06/12/09 4717 $50 Cory Aponte None reported 211 06/12/09 4721 $220 Chris Orbe None reported 212 06/12/09 4746 $300 Karen Kelly None reported 213 06/12/09 4750 $50 Tamika Bracey Domi None reported 214 06/12/09 3186 $40 Megan Brown None reported 215 06/12/09 4248 $50 Sulema Gonzalez None reported 216 06/12/09 4347 $50 Matthew Gelmetti None reported 217 06/12/09 4435 $50 Kelly Shami None reported 218 06/12/09 4684 $240 Romina Pascual None reported 219 06/12/09 4797 $80 Yamilet Naterea None reported 220 06/12/09 4801 $300 Lisa Okragly None reported 221 06/12/09 3661 $50 Kathy Asorio None reported 222 06/12/09 4575 $50 Mildred Auriemma None reported 223 06/12/09 4724 $250 Romina Pascual None reported 224 06/13/09 4751 $50 Edith O’Keefe None reported 225 06/13/09 4770 $50 Ryan Wurth None reported 226 06/13/09 4784 $50 Christopher Ferna None reported 227 06/13/09 4785 $50 Ditjona Drishati None reported 228 06/13/09 4791 $80 Nancy Betancourt None reported 229 06/13/09 4795 $40 Hakeem Gordon None reported 230 06/13/09 4799 $100 Melina Skarantona None reported 231 06/13/09 4817 $75 Nawal Taha None reported 232 06/13/09 4827 $50 Larry Kolpping None reported

Page 48: Peter Cammarano ELEC Complaint

ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 48

233 06/13/09 4832 $50 Rosanne Jacoby None reported 234 06/13/09 4838 $50 Aida Ferrer None reported 235 06/13/09 4803 $50 Divina Herrera None reported 236 06/15/09 4879 $150 Migdalia Cabrera None reported 237 06/15/09 4900 $50 Jonathan Cummings None reported 238 06/15/09 4958 $100 James Wynn None reported 239 06/15/09 4968 $50 Teresa Branda None reported 240 06/15/09 4978 $300 John Pimental None reported 241 06/15/09 4981 $250 John Eifert None reported

Total: $38,423.04

Page 49: Peter Cammarano ELEC Complaint

ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 49

EXHIBIT I Count 6

(A) Item No. (B) Date (C) Check No. (D) Amount (E) Payee Name

1 05/29/09 1648668 $6,400 Bluewater Operations LLC 2 05/09/09 1229 $24 Ryan Lopes 3 06/04/09 1272 $35 Kevin Phillips 4 06/04/09 1294 $32 Randall Blaine Morris 5 06/09/09 1328 $13,000 Bluewater Operations LLC 6 06/25/09 3118 $40 Gabrielle Musella 7 06/04/09 3191 $60 Dana Duffy 8 05/29/09 3493 $155 Alejandra Vasquez 9 05/29/09 3494 $80 Mike Di Tullio

10 05/29/09 3496 $100 Divina Herrera 11 05/29/09 3497 $40 Luz Marrero 12 05/29/09 3498 $162 Melina Skarantonakis 13 06/04/09 3535 $32 Anthony Gilyard 14 06/04/09 3536 $32 Christopher Gilyard 15 06/12/09 3551 $30 Maxwell Yu 16 06/09/09 3575 $32 Mayra Garcia 17 06/09/09 3579 $24 Anthony Gilyard 18 06/09/09 3580 $136 Christopher Gilyard 19 06/09/09 3582 $96 Anibal Gonzalez 20 06/09/09 3584 $80 Divina Herrera 21 06/09/09 3598 $32 Tatiana Silva 22 06/16/09 3628 $35 Feliciano Jimenez 23 06/18/09 3639 $50 Flores Alesy 24 06/19/09 3651 $50 Raven Andrews 25 06/11/09 3652 $50 Fannie Andrews 26 06/17/09 3654 $50 Joseph Andrews 27 06/17/09 3655 $50 Michelle Andrews 28 06/11/09 3662 $50 Ernestine Ausby 29 06/18/09 3668 $50 Matthew Azzoline 30 06/17/09 3669 $50 Carlos Baez 31 06/17/09 3670 $50 Judith Baez 32 06/17/09 3673 $50 Anna Bates 33 06/17/09 3674 $50 Melody Bates 34 06/17/09 3675 $50 Zelda Bell 35 06/16/09 3676 $50 Morales Bienvenido 36 06/17/09 3677 $50 Benjamin Blanks 37 06/17/09 3679 $50 Irma Bolano 38 06/17/09 3683 $50 Maria Borrero 39 06/17/09 3684 $50 Lateka Boyd 40 06/17/09 3685 $50 Alvenia Boyd 41 06/17/09 3686 $50 Justin Boyd 42 06/17/09 3687 $50 Charles Boyd 43 06/18/09 3691 $50 Lucilla Burgos 44 06/18/09 3692 $50 Jayanna Burrell 45 06/18/09 3695 $50 Ariel Calle 46 06/15/09 3697 $50 Mildred Camacho 47 06/18/09 3713 $50 Nora Cedeno 48 06/18/09 3723 $50 Lillian Colon 49 06/18/09 3728 $50 Alberto Colon 50 06/18/09 3729 $50 Efrain Colon 51 06/18/09 3732 $50 Aurea Colon 52 06/18/09 3733 $50 Angela Correa 53 06/18/09 3748 $50 Giebent Cuevas 54 06/18/09 3754 $50 Latasha Davis 55 06/18/09 3756 $50 Cindy Davis

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 50

56 06/18/09 3760 $50 Crystal Davis 57 06/16/09 3762 $50 Carolyn DeJarnette 58 06/16/09 3763 $50 Nancy Dejesus 59 06/18/09 3766 $50 Daniel Demeo 60 06/19/09 3767 $50 Mary Demeo 61 06/18/09 3777 $50 Hector Duran 62 06/16/09 3778 $50 Javier Duran 63 06/16/09 3783 $50 Enedine Espinal 64 06/16/09 3786 $50 Austria Eusebio 65 06/17/09 3788 $50 Chasity Feliciano 66 06/18/09 3793 $50 Jeffery Ferguson 67 06/18/09 3796 $50 Carmen Fernandez 68 06/18/09 3808 $50 Elizabeth Figueroa 69 06/18/09 3815 $50 Margarita Fonseca 70 06/18/09 3828 $50 Jeanette Fresse 71 06/16/09 3835 $50 America Garcia 72 06/18/09 3846 $50 Tawana Jones 73 06/16/09 3851 $50 Francine Ladson 74 06/18/09 3853 $50 Nancy Ladson 75 06/18/09 3859 $50 Maeia Lanera 76 06/18/09 3863 $50 Kimani Lawrence 77 06/18/09 3864 $50 Deja Lawrence 78 06/18/09 3871 $50 Josefina Lopez 79 06/18/09 3872 $50 Alfredo Lopez 80 06/18/09 3877 $50 Barna Lopez 81 06/18/09 3878 $50 Flora Lopez 82 06/18/09 3882 $50 Kristian Lyons 83 06/17/09 3886 $50 Kalifah Lyons 84 06/17/09 3890 $50 Carmen Maldonado 85 06/17/09 3899 $50 Afonso Martinez 86 06/16/09 3904 $50 Angela Matia 87 06/18/09 3905 $50 Franciska Matias 88 06/18/09 3906 $50 Angela Matias 89 06/17/09 3911 $50 Josue Medina 90 06/18/09 3912 $50 Jameliz Mejias 91 06/17/09 3916 $50 Joshua Mendoza 92 06/17/09 3917 $50 Carmen Menendez 93 06/17/09 3919 $50 Diego Mercado 94 06/18/09 3926 $50 Lawanda Miller 95 06/17/09 3927 $50 Andrielle Miller 96 06/18/09 3928 $50 Irma Mineros 97 06/18/09 3935 $50 Chris Mongon 98 06/17/09 3946 $50 Lora Moone 99 06/17/09 3948 $50 Aida Morales

100 06/17/09 3949 $50 Jorge Morales 101 06/19/09 3950 $50 Carmen Morales 102 06/17/09 3958 $50 Ines Neves 103 06/17/09 3962 $50 Crystal Nelson 104 06/17/09 3963 $50 Crusita Nieves 105 06/17/09 3967 $50 Jamal Oliver 106 06/16/09 3968 $50 Hector Ortega 107 06/18/09 3976 $50 Igdalia Otero 108 06/17/09 3977 $50 Alejandra Padilla 109 06/17/09 3978 $50 Lucila Padilla 110 06/17/09 3979 $50 Martina Padillo 111 06/17/09 3982 $50 Letha Parker 112 06/18/09 3991 $50 Noella Perez 113 06/17/09 3998 $50 Chadita Pineiro 114 06/22/09 4001 $50 Mary Potter

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 51

115 06/18/09 4003 $50 Gina Praylow 116 06/18/09 4005 $50 Rudy Praylow 117 06/17/09 4007 $50 Anthony Purvis 118 06/17/09 4008 $50 Valerie Purvis 119 06/18/09 4009 $50 Michele Purvis 120 06/17/09 4011 $50 Anthony Purvis 121 06/17/09 4012 $50 Amber Purvis 122 06/18/09 4016 $50 Brenda Ramos 123 06/17/09 4019 $50 Melissa Reyes 124 06/16/09 4022 $50 Tynell Rice 125 06/17/09 4023 $50 Tracy Richardson 126 06/17/09 4029 $50 Angelica Rivera 127 06/16/09 4031 $50 Mary Ann Rivera 128 06/26/09 4040 $50 Santiago Rivera 129 06/26/09 4041 $50 Milagros Rivera 130 06/17/09 4044 $50 Josefina Rivera 131 06/17/09 4045 $50 Juan Rivera 132 06/17/09 4047 $50 Jose Rivera 133 06/18/09 4048 $50 Aixa Rivera 134 06/18/09 4053 $50 Maria Rodriguez 135 06/18/09 4054 $50 Linmary Rodriguez 136 06/17/09 4060 $50 Wilfredo Rodriguez 137 06/19/09 4061 $50 Jillian Rodriguez 138 06/18/09 4067 $50 Juana Rosa 139 06/18/09 4068 $50 Reny Rosada 140 06/17/09 4070 $50 Saul Rosada 141 06/18/09 4073 $50 Alexis Rosario 142 06/18/09 4079 $50 Angel Rosario 143 06/18/09 4085 $50 Tanya Rugar 144 06/22/09 4086 $50 Jacqueline Sanabia 145 06/18/09 4088 $50 Adelina Sanchez 146 06/17/09 4094 $50 Sylvia Santiago 147 06/17/09 4095 $50 Stephanie Santiago 148 06/15/09 4102 $50 Milly Segarra 149 06/15/09 4107 $50 Crystal Serrano 150 06/19/09 4108 $50 Pablo Serrano 151 06/18/09 4109 $50 Jimmy Serrano 152 06/17/09 4110 $50 Leroy Sherrill 153 06/23/09 4115 $50 Shaleka Smith 154 06/17/09 4116 $50 Violetti Smolic 155 06/18/09 4117 $50 Rebecca Soto 156 06/16/09 4118 $50 Josephine Spears 157 06/17/09 4120 $50 Juleen Steed 158 06/15/09 4121 $50 David Steed 159 06/15/09 4122 $50 Alice Steed 160 06/15/09 4123 $50 Ageria Stephen 161 06/15/09 4124 $50 Ruby Stephens 162 06/15/09 4125 $50 Michael Stephens 163 06/15/09 4126 $50 Diane Steward 164 06/15/09 4128 $50 Sharron Stone 165 06/18/09 4129 $50 Jenny Suazo 166 06/18/09 4130 $50 Sara Tavares 167 06/15/09 4131 $50 Zuleyma Tavares 168 06/17/09 4132 $50 Arleen Thomas 169 06/25/09 4133 $50 Latrenda Thomas 170 06/17/09 4134 $50 Ethel Thomas 171 06/15/09 4138 $50 Kimberly Torres 172 06/18/09 4141 $50 Maximina Vargas 173 06/15/09 4142 $50 Minerva Vargas

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 52

174 06/15/09 4143 $50 Miguel Vargas 175 06/17/09 4144 $50 Elsie Vargas 176 06/16/09 4146 $50 Barbarita Vasquez 177 06/15/09 4149 $50 Nilda Vega 178 06/15/09 4150 $50 America Velasquez 179 06/18/09 4152 $50 Ana Velazquez 180 06/15/09 4153 $50 William Velez 181 06/19/09 4155 $50 Jimmy Velez 182 06/15/09 4156 $50 Juan Velez 183 06/15/09 4157 $50 Maria Viaux 184 06/18/09 4159 $50 Ana Villafane 185 06/16/09 4160 $50 Ana Villafane 186 06/15/09 4162 $50 Ricky Walker 187 06/15/09 4163 $50 Kalisa Walker 188 06/15/09 4166 $50 Jonathan Walker 189 06/15/09 4167 $50 Melinda Walker 190 06/15/09 4168 $50 David Walker 191 06/17/09 4170 $50 Obneak Walker 192 06/15/09 4171 $50 David Jr. Walker 193 06/15/09 4172 $50 Ross Walker 194 06/17/09 4174 $50 Ernest Walker 195 06/18/09 4175 $50 Melissa Walker 196 06/15/09 4176 $50 Deeon Walker 197 06/17/09 4178 $50 Iyianta Walker 198 06/15/09 4179 $50 Joyce Walker 199 06/17/09 4182 $50 Alan Watson 200 06/15/09 4183 $50 Michael Watts 201 06/19/09 4184 $50 Debra Welch 202 06/17/09 4186 $50 Mae Wheeler 203 06/15/09 4187 $50 Britany Wheeler 204 06/18/09 4188 $50 Alice Wheeler 205 06/15/09 4189 $50 Jermaine Wheeler 206 06/18/09 4190 $50 Annie Wheeler 207 06/17/09 4191 $50 Regis Wheeler 208 06/18/09 4192 $50 Betty Whiting 209 06/10/09 4193 $50 Jamal William 210 06/17/09 4195 $50 Annette Wright 211 06/17/09 4196 $50 Doris Yidal 212 06/17/09 4197 $50 Iris Zabaleta 213 06/18/09 4199 $50 Evelin Zaragoza 214 06/15/09 4200 $50 Carmen Zayas 215 06/15/09 4202 $100 Marcelina Biart 216 06/15/09 4203 $100 Carmen Camacho 217 06/17/09 4206 $100 Carlla Chapman 218 06/12/09 4207 $100 Dominga Colon 219 06/15/09 4208 $100 Concepcion Colon 220 06/17/09 4209 $100 Karen Ferguson 221 06/15/09 4212 $100 Toleda Hicks 222 06/17/09 4213 $100 Pamela Huggins 223 06/15/09 4214 $100 Orlando Johnson 224 06/15/09 4215 $100 Robyn Johnson 225 06/15/09 4217 $100 Jannette Lopez 226 06/15/09 4220 $100 Luz Marrero 227 06/15/09 4221 $100 Nexida Martinez 228 06/15/09 4222 $100 Kelly McInerney 229 06/17/09 4224 $100 Shawna Oliver 230 06/15/09 4225 $100 Odessa Patterson 231 06/16/09 4228 $100 Bernardo Rodriguez 232 06/15/09 4231 $100 Luz Sanchez

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 53

233 06/15/09 4232 $100 Julio Segarra 234 06/17/09 4233 $100 Geovany Sepulveda 235 06/17/09 4234 $100 Sabrina Serrano 236 06/15/09 4235 $100 Gregory White 237 06/15/09 4239 $125 Angel Rivera 238 06/15/09 4240 $125 Marcelino Rodriguez 239 06/15/09 4245 $50 Jose Gonzalez 240 06/15/09 4247 $50 Carlos Gonzalez 241 06/17/09 4249 $50 Margarita Gonzalez 242 06/18/09 4250 $50 Anibal Gonzalez 243 06/22/09 4253 $50 Yudelka Gonzalez 244 06/23/09 4254 $50 Eufemia Gonzalez 245 06/17/09 4259 $50 Turleatta Gorham 246 06/17/09 4260 $50 John Grauso 247 06/15/09 4261 $50 Linda Grullon 248 06/15/09 4262 $50 Jimmy Hampton 249 06/15/09 4264 $50 Renee Hanberry 250 06/18/09 4267 $50 Donitha Hicks 251 06/18/09 4268 $50 Shanta Hicks 252 06/15/09 4269 $50 Marquis High 253 06/15/09 4270 $50 Barry High 254 06/15/09 4271 $50 Margaret High 255 06/15/09 4272 $50 Hakeem High 256 06/18/09 4273 $50 Van Hines 257 06/18/09 4274 $50 Sadie Huggins 258 06/18/09 4275 $50 Yusanna Huggins 259 06/17/09 4276 $50 Demetria Huggins 260 06/17/09 4277 $50 Vivian Huggins 261 06/17/09 4278 $50 Malika Huggins 262 06/17/09 4279 $50 Natlie Huggins 263 06/17/09 4280 $50 Eldride Huggins 264 06/18/09 4281 $50 John Huggins 265 06/18/09 4283 $50 Angel Irizarry 266 06/15/09 4284 $50 Luz Ithier 267 06/17/09 4285 $50 Tyisha Jackson 268 06/17/09 4286 $50 Rudy Jackson 269 06/17/09 4290 $50 Taneisha Jeffery 270 06/15/09 4291 $50 Luz Jiminez 271 06/17/09 4293 $50 Davina Johnson 272 06/15/09 4294 $50 Donald Johnson 273 06/15/09 4295 $50 Corinthia Johnson 274 06/15/09 4297 $50 Mario Johnson 275 06/15/09 4301 $50 James Johnson 276 06/15/09 4302 $50 Daryl Johnson 277 06/18/09 4303 $50 Neomi Johnson 278 06/15/09 4304 $50 Hineefa Johnson 279 06/15/09 4306 $50 Stephanie Johnson 280 06/15/09 4307 $50 Paula Johnson 281 06/15/09 4308 $50 Ava Johnson 282 06/15/09 4309 $50 Mario Johnson 283 06/15/09 4312 $50 Spencer Jones 284 06/18/09 4313 $50 Debra Jones 285 06/17/09 4314 $50 Ernestine Jones 286 06/18/09 4315 $50 Terina Jones 287 06/16/09 4318 $50 Sophia Antonopoulos 288 06/12/09 4324 $50 Rob Chewning 289 06/15/09 4327 $50 Hector Concepcion 290 06/15/09 4335 $50 Ali Elgayar 291 06/22/09 4338 $50 Nicholas Fernandez

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 54

292 06/18/09 4343 $50 Michael Fuccilli 293 06/18/09 4349 $50 Kishaun Gilyard 294 06/12/09 4351 $50 Gabriel Gomez 295 06/25/09 4361 $50 Benu Hall 296 06/17/09 4365 $50 Divina Herrera 297 06/19/09 4367 $50 Jennifer Holmes 298 06/17/09 4369 $50 Patrick Howitt 299 06/11/09 4374 $50 Mateusz Kolano 300 06/23/09 4375 $50 Mateusz Kvawiec 301 06/15/09 4377 $50 Tia LaBruno 302 06/15/09 4379 $50 Hakeem Lawrence 303 06/15/09 4380 $50 Jeffrey Lazu 304 06/17/09 4388 $50 Mike Marciona 305 06/15/09 4390 $50 Marissa Marrero 306 06/15/09 4393 $50 Maurine McGinley 307 06/12/09 4398 $50 Kyungcheon Min 308 06/12/09 4399 $50 Kyungsun Min 309 06/16/09 4406 $50 Blaine Morris 310 06/16/09 4407 $50 Randall Blaine Morris 311 06/16/09 4412 $50 Mariusz Palka 312 06/17/09 4416 $50 Nancy Petrone 313 06/17/09 4417 $50 Amanda Pollifrone 314 06/23/09 4422 $50 Kristina Rivera 315 06/15/09 4424 $50 Estrella Rojas 316 06/12/09 4433 $50 Willy Seo 317 06/18/09 4450 $50 Krystian Wrobel 318 06/18/09 4452 $75 Kayla Goris 319 06/16/09 4456 $80 Jonathan Potoczak 320 06/16/09 4457 $80 Jason Tinoco 321 06/15/09 4480 $100 Lisa Okragly 322 06/18/09 4494 $50 Tara Stone 323 06/15/09 4496 $50 Lavone Ferguson 324 06/17/09 4497 $50 Tyease Chiaolan 325 06/17/09 4499 $90 Rose Anderson 326 06/16/09 4502 $50 Carmen Fernandez 327 06/15/09 4504 $50 Cumba Daniel 328 06/18/09 4506 $100 Cruz Delgado 329 06/17/09 4507 $50 Felipa Flores 330 06/15/09 4508 $50 Juan Mejias 331 06/18/09 4510 $50 Elena M. Pagan 332 06/15/09 4512 $50 Nancy Sosa 333 06/17/09 4519 $50 Gregory Johnson 334 06/17/09 4520 $50 Julio Fermaim 335 06/17/09 4521 $50 Victor Diaz 336 06/15/09 4522 $50 Princess Gonzales 337 06/18/09 4523 $50 Michael Santos 338 06/15/09 4524 $100 Lucy Gonzalez 339 06/18/09 4526 $90 Nicole Barcus 340 06/18/09 4527 $90 Lori Chiles 341 06/18/09 4529 $50 Carlos Rivera 342 06/17/09 4530 $100 Jose Ferrer 343 06/17/09 4535 $50 Noelia Fernandez 344 06/18/09 4539 $50 Tracey Lyons 345 06/18/09 4540 $50 Khalifah Lyons 346 06/15/09 4541 $50 Melissa Reyes 347 06/15/09 4542 $50 Jose Reyes 348 06/15/09 4543 $50 Chris Lyons 349 06/17/09 4544 $50 Bashawan Darden 350 06/15/09 4547 $200 Luz Sanchez

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 55

351 06/17/09 4558 $50 Irene Mestres 352 06/18/09 4560 $50 Debra Stone 353 06/18/09 4566 $50 Keith Montague 354 06/17/09 4567 $50 Anthony Henriquez 355 06/18/09 4568 $50 Luz Adriana Padilla 356 06/18/09 4569 $50 Frederick Ladson 357 06/17/09 4570 $30 Marilyn Jacoby 358 06/17/09 4571 $30 Maureen Auriemma 359 06/17/09 4574 $50 Dennis Auriemma 360 06/17/09 4576 $30 Gwenolyn Robertson-Gray 361 06/17/09 4577 $50 Carmelo Ramos 362 06/17/09 4578 $50 Angel Sanabria 363 06/18/09 4580 $100 Rafael Santiago 364 06/17/09 4581 $50 Hyaida Ladson 365 06/18/09 4583 $50 Monica Rodriguez 366 06/17/09 4584 $50 Christine Riepil 367 06/17/09 4590 $50 Debra Marotta 368 06/18/09 4591 $50 Dorka Rodriguez 369 06/18/09 4592 $50 Katrina DeJesus 370 06/17/09 4593 $50 Delores Mongon 371 06/17/09 4594 $50 Jose Esquiuel 372 06/17/09 4595 $50 Miguel Mongon 373 06/17/09 4597 $50 Jose Braxton 374 06/19/09 4600 $50 Jackie Rodriguez 375 06/17/09 4601 $50 Ana Bates 376 06/17/09 4603 $50 Darrell Bates 377 06/18/09 4604 $50 Farra Mongon 378 06/17/09 4614 $50 Desmond Bates 379 06/23/09 4616 $50 Robert Braxton 380 06/26/09 4617 $50 Charmain Tarawally 381 06/19/09 4618 $50 Mariah Tarawally 382 06/22/09 4620 $50 Joel A. Prins 383 06/17/09 4621 $50 Xiomara A. Cruz 384 06/17/09 4622 $50 Elizabeth V. Cruz 385 06/17/09 4623 $50 Jason Wheeler 386 06/18/09 4629 $50 Dolores Scott 387 06/22/09 4630 $50 Larry Scott 388 06/18/09 4635 $50 Dion Casey 389 06/17/09 4638 $50 Margarita Fonseca 390 06/17/09 4639 $50 Alonzo Williams 391 06/15/09 4640 $50 Josephine Henderson 392 06/18/09 4647 $50 Justin Boyd 393 06/17/09 4648 $50 Alonzo Jefferies 394 06/10/09 4654 $64 Margarita Canini 395 06/10/09 4655 $64 Migdalia Canini 396 06/10/09 4661 $50 Nicholas Fernandez 397 06/10/09 4662 $200 Freddie Frazier 398 06/10/09 4664 $96 Christopher Gilyard 399 06/19/09 4666 $32 Kayla Goris 400 06/10/09 4667 $50 Divina Herrera 401 06/10/09 4668 $80 Veronica Huggins 402 06/15/09 4674 $90 Moises Villafane 403 06/10/09 4681 $96 Milton Moss 404 06/10/09 4682 $75 Lauren Murphy 405 06/10/09 4686 $64 Elizabeth Rivera 406 06/10/09 4687 $54 Ed Rosado 407 06/10/09 4688 $105 Irma Santiago 408 06/10/09 4689 $126 Nick Stanton 409 06/17/09 4694 $100 Violetta Smolic

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 56

410 06/17/09 4696 $50 Felicia Feliciano 411 06/17/09 4699 $50 Luis Rivera 412 06/17/09 4700 $50 Milagras Quinones 413 06/15/09 4711 $50 Juliana Ochoa 414 06/15/09 4712 $50 Carlos Ochoa 415 06/17/09 4713 $50 Kelly Hogan 416 06/17/09 4718 $75 Ruben Gonzalez 417 06/18/09 4719 $50 Jacqueline Algarin 418 06/11/09 4722 $150 Lauren Rubitz 419 06/12/09 4725 $325 Lyla Ribot 420 06/12/09 4726 $350 Angie Aly 421 06/17/09 4728 $200 Milton Moss 422 06/17/09 4729 $200 Chris Gilyard 423 06/19/09 4732 $50 Hilda Rivera 424 06/18/09 4733 $50 John Maratta Jr. 425 06/18/09 4735 $50 Valencia Huggins 426 06/17/09 4740 $50 Kathaleen T. O’Connor 427 06/17/09 4741 $50 Jasmin Santos 428 06/17/09 4742 $50 Yolanda Oliver 429 06/10/09 4747 $50 Maria Araquez 430 06/10/09 4749 $200 Dio Braxton 431 06/13/09 4755 $50 Theresa Mongon 432 06/13/09 4756 $50 Justin Torres 433 06/13/09 4757 $50 Lasheena J. Lopez 434 06/13/09 4758 $50 Edwin Rivera 435 06/13/09 4759 $50 Devonique Pride 436 06/13/09 4764 $50 Tyrone Andrews 437 06/13/09 4766 $50 B.A. Stead 438 06/13/09 4768 $50 Pamela Torres 439 06/13/09 4769 $50 Milton Vargas 440 06/13/09 4772 $50 Lonnie Richardson 441 06/13/09 4773 $50 Mary Mellado 442 06/13/09 4775 $50 Bertha Garcia 443 06/13/09 4778 $50 Nicole Bucato 444 06/13/09 4781 $50 Miguel Irizarry 445 06/13/09 4782 $50 Mayra Garcia 446 06/13/09 4783 $50 Nick Fernandez 447 06/13/09 4786 $50 Lasalle Davis 448 06/13/09 4796 $60 Tim Kane 449 06/13/09 4800 $80 Bennett Tran 450 06/15/09 4806 $50 Victor Lucatarto 451 06/13/09 4808 $100 Joseph Davis 452 06/13/09 4809 $90 Kevin Scott 453 06/13/09 4812 $35 Michelle Cordero 454 06/13/09 4813 $50 Nona Walker 455 06/13/09 4814 $50 Taya Mitchell 456 06/13/09 4815 $100 Katherine Torres 457 06/12/09 4816 $50 Adam Campbell 458 06/13/09 4818 $50 Cristal Rivera 459 06/13/09 4820 $50 Dadan Soto 460 06/13/09 4821 $50 Robert Pride 461 06/13/09 4822 $50 Drucilla Parker 462 06/13/09 4823 $50 Irisha Rivera 463 06/13/09 4826 $50 Renee Johnson 464 06/13/09 4828 $100 Kelly McInerney 465 06/13/09 4830 $50 Lily Colon 466 06/13/09 4831 $50 Mark Jacoby 467 06/13/09 4833 $50 Tonya Chapman 468 06/13/09 4834 $50 Tyrone Montague Jr.

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 57

469 06/13/09 4836 $50 Yammel Cancel 470 06/13/09 4837 $50 Maria Sanchez 471 06/15/09 4839 $50 Olga Hernandez 472 06/15/09 4840 $50 Carlos Torres 473 06/15/09 4841 $50 Daisy Colon 474 06/15/09 4843 $50 Shaila Bonilla 475 06/15/09 4844 $50 Hector Rivera 476 06/15/09 4845 $50 Edwin Rodriguez 477 06/15/09 4846 $100 Migdalia Cancel 478 06/15/09 4847 $100 Anthony Peralta 479 06/15/09 4851 $50 Richie Francolino 480 06/13/09 4853 $50 Norma Gonzalez 481 06/15/09 4854 $50 Belki Cueto 482 06/15/09 4855 $50 William Velez 483 06/15/09 4856 $50 Carmen Vazquez 484 06/15/09 4857 $50 Yolanda Torres 485 06/15/09 4858 $50 Alvin Rivera 486 06/15/09 4860 $50 Nidia Colon 487 06/15/09 4862 $50 Blanca Luciano 488 06/15/09 4863 $50 Juan Alvarado 489 06/15/09 4865 $50 Blanca Cantuna 490 06/16/09 4866 $50 Claudio Cantuna 491 06/15/09 4867 $50 Luz Martinez 492 06/13/09 4870 $50 Miguel Cruz 493 06/13/09 4872 $50 Jorge Millan 494 06/13/09 4880 $50 Reinaldo Cruzado 495 06/15/09 4884 $50 Madeline Gonzalez 496 06/15/09 4885 $50 Samantha Gonzalez 497 06/15/09 4887 $350 Margarita Canini 498 06/15/09 4888 $50 Osvaldo Garcia 499 06/15/09 4889 $50 Migdalia Canini 500 06/15/09 4890 $50 Jose Verdejo 501 06/15/09 4891 $50 Nelly Escobar 502 06/15/09 4893 $50 Jorge Canini 503 06/15/09 4894 $50 Ramon Quinonez 504 06/15/09 4895 $50 Carmen Quinonez 505 06/15/09 4897 $50 Maria Ramirez 506 06/15/09 4898 $50 Pedro Canini 507 06/15/09 4901 $100 Yolanda Morales 508 06/15/09 4903 $50 Wilde Trinidad 509 06/15/09 4904 $50 Luis Morales 510 06/15/09 4905 $50 Denise Fresse 511 06/15/09 4906 $50 Miriam Rodriguez 512 06/15/09 4907 $50 Luz Calderon 513 06/15/09 4908 $50 Maria Rodriguez 514 06/13/09 4910 $150 Dina Petrozelli 515 06/15/09 4911 $50 Maria Araquez 516 06/15/09 4912 $50 Jose Canini 517 06/15/09 4913 $50 Barbara Cassaj 518 06/15/09 4914 $50 Maria Pratt 519 06/15/09 4915 $50 Debora Gilyard 520 06/15/09 4916 $50 Bashawn Darden 521 06/15/09 4919 $100 Kaushik Majmudar 522 06/15/09 4920 $100 Dipiku Majmudar 523 06/15/09 4929 $100 Julia Purvis 524 06/15/09 4930 $100 Gregory White 525 06/15/09 4931 $50 Rebecca Gonzalez 526 06/15/09 4932 $50 Antonia Gilyard 527 06/15/09 4933 $100 Debbie Jones

Page 58: Peter Cammarano ELEC Complaint

ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 58

528 06/15/09 4950 $50 Deisha Moreno 529 06/15/09 4951 $50 Neionii Johnson 530 06/15/09 4953 $50 Sabrina Serrano 531 06/15/09 4954 $50 Crystal Serrano 532 06/15/09 4955 $75 Angel Maldonado 533 06/15/09 4956 $75 Gabriel Garcia 534 06/15/09 4961 $50 Rafael Irizarry 535 06/15/09 4962 $100 Luz Marrero 536 06/12/09 4963 $50 Crystal Serrano 537 06/15/09 4966 $50 Francesca Matias 538 06/15/09 4969 $150 Joan Falco 539 06/15/09 4970 $300 Nick Stanton 540 06/15/09 4976 $50 Sheila Panzarelli 541 06/15/09 4980 $150 Mohammad Abboud

Total: $51,663

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 59

EXHIBIT J Count 7

(A) Item No. (B) Date of Deposit (C) Amount (D) Name on Contributor Check

or Currency Contribution 1 06/30/09 $500 John Corea 2 06/30/09 $1,000 Harvey A. Holzberg

3 06/30/09 $1,000 Pat Cappello Payroll Account

80 River St. LLC

4 06/30/09 $1,000 Mario Fini Payroll Account

80 River St. LLC 5 06/30/09 $400 Peter Johnston, Architect, PC 6 06/30/09 $1,000 Fred M. Bado 7 06/30/09 $1,000 John P. Pope 8 06/30/09 $1,000 S. Hatiras 9 06/30/09 $2,000 Frank J. Palmisano

10 06/30/09 $400 Richard Blohm 11 06/30/09 $1,000 James D. Vance 12 06/30/09 $1,000 76 River St. Investment Corp. 13 06/30/09 $700 “Cash”

Total: $12,000

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 60

EXHIBIT K Count 9

(A) Item No. (B) Date (C) Check No. (D) Amount (E) Payee Name (F) Payee Address

1 07/02/09 4982 $100 Beverly Pascale None reported 2 07/02/09 4983 $110 Helen De Stefano None reported 3 07/07/09 4987 $150 Miguel Irizarry None reported 4 07/07/09 4988 $100 Ivette Vargas None reported 5 07/22/09 5001 $70 Miguel Cruz None reported 6 07/22/09 5002 $70 Norma Gonzalez None reported 7 07/22/09 5003 $50 Yudelka Gonzalez None reported

Total: $650

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ELEC v. Peter Cammarano, Vincent Addeo, Angel Alicia, and Raul Morales II, and Lucy Truglio, Treasurer C-G 0905 04 04 R2009; C-9 0905 01 04 R2009; C-9 0905 02 04 R2009; C-9 0905 07 04 R2009 Page 61

EXHIBIT L Count 9

(A) Item No. (B) Date (C) Check No. (D) Amount (E) Payee Name

1 07/08/09 3186 $40 Megan Brown 2 07/08/09 3666 $50 Mercedes Ayala 3 07/08/09 3749 $50 Daniel Cumba 4 07/16/09 3791 $50 Melody Ferguson 5 07/15/09 4025 $50 Phanta Richardson 6 07/06/09 4028 $50 Florence Rivera 7 07/17/09 4074 $50 Robert Rosario 8 07/02/09 4198 $50 Belkins Zapata 9 07/17/09 4229 $100 Angela Rosario

10 07/24/09 4347 $50 Matthew Gelmetti 11 08/19/09 4565 $50 Damien Bates 12 07/01/09 4619 $50 Liman Tarawally

Total: $640