Parties: Jefferson County Republican Central Committee (JCRCC) MEC ID: C000983 Voters for Good Government (VGG)

MEC ID: C021020 Janet Engelbach 3489 LINHORST RD HILLSBORO MO 63050 (636) 475-6328 George Engelbach 3489 LINHORST RD HILLSBORO MO 63050 (636) 475-6328 Leslie Hanson Treasurer of JCRCC PO BOX 284 HIGH RIDGE MO 63049 Hm (636) 376-3378 Wk (314) 605-9894 William Hardin IV -- Treasurer of VGG 3396 Cottonwood Dr St Charles Mo 63301 (636) 578-3496 Facts: 1. George and Janet Engelbach were both candidates on the 2012 Republican Primary Ballot. Janet as candidate in August 7th primary for committeewoman. George as candidate on August 7th primary for committeeman and for county council. 2. In the days leading up to this election, Voters for Good Government paid for a mailing that supported George, Janet and other candidates for the 2012 Republican Primary. (A scanned copy of the mailing is provided) 3. George and Janet Engelbach are both members of the JCRCC. 4. Janet Engelbach is, and was, the Chairman of the JCRCC at the time of the financial transactions which are the subject of this complaint. Timeline of known facts:

1. July 10, 2012- Jefferson County Republican Central Committee authorizes the transfer of $5,000 to a newly created PAC which they also control called Jefferson County Organization to Reinforce Citizen Awareness (JCORCA) PAC MEC ID: C121401 2. July 26, 2012 George Engelbach makes a reported contribution to Voters for Good Government (VGG) in the amount of $3,400 3. July 28, 2012 VGG makes two reported expenditures ($2,594.75 for design and printing and $756.50 for postage) totaling $3,351.25 4. August 16, 2012 The Jefferson County Republican Central Committee (JCRCC) makes a reported expenditure to Janet Engelbach for an election mailing in the amount of $3,400

Allegations: George and Janet Engelbach colluded to receive and make contributions in a manner as to conceal the identity of the actual source of the contribution in violation of Section 130.031, and attempted and actually did control and direct two continuing committees to the benefit of their own campaigns as is described and prohibited in MEC Opinion No. 2003.07.104. If the JCRCC intended to pay for political mailings for candidates, then the JCRCC should have done so directly rather than try to juggle funds between accounts and individuals calling them contributions,

however, had they not concealed the origin of the funds, they would be in clear violation of MEC Opinion No. 2003.07.104 which prohibits the JCRCC from using Committee funds in support or opposition of Committee candidates, as well as prohibits current candidates who are voting members of the committee from directing committee funds in support of their candidacies. The fact exists, while Janet Engelbach was reimbursed well after the fact for Mailings there were no mailers which were ever mailed which denoted that they were paid for by Janet Engelbach and/or the Central Committee. These funds were in fact disbursed to Janet Engelbach by her own direction, without a vote of the Committee, then liquidated, and transferred to her husband George Engelbach, also a Central Committee member, who then contributed them to Voters for Good Government PAC, representing that the funds were his own personal funds. If VGG knew the origin of these funds, and yet reported them as personally coming from George Engelbach, and in collusion with the Engelbachs worked to conceal the origin of the funds, Voters for Good Government would be complicit and likely in violation of Missouri Statutes regarding Civil Conspiracy, Money Laundering, as well as Campaign Finance Reporting Requirements contained within Chapter 130 RSMo, however, to what extent William Hardin IV was aware of the actual source of the funds and intent to conceal cannot be discerned without investigation by the necessary legal authorities. Law: Section 130.031 3 requires that No contribution shall be made or accepted and no expenditure shall be made or incurred, directly or indirectly, in a fictitious name, in the name of another person, or by or through another person in such a manner as to conceal the identity of the actual source of the contribution or the actual recipient and purpose of the expenditure. In addition, George and Janet Engelbach attempted and actually did control and direct two continuing committees, namely the Jefferson County Republican Central Committee and Voters for Good Government Political Action Committees, to make expenditures for a political campaign mailing in support of their, and other, campaigns. Law: MEC Opinion No. 2003.07.104 states, in pertinent part, that If a person has the potential to have his/her direction or ideas exercised by the committee, he or she would appear to have the ability to direct or control the committee even if these duties are out-voted. George and Janet Engelbach are both members of the JCRCC. In fact, Janet Engelbach is, and was, the Chairman of the JCRCC at the time of the financial transactions which are the subject of this complaint. As such, they were in a position to have their direction exercised by the JCRCC, which did in fact happen on August 16, 2012 when the JCRCC recorded a contribution to Mrs. Engelbach for the mailing that was previously made. When the funds were actually disbursed to Mrs. Engelbach, and whether the dates were misrepresented in the attached Campaign Finance Report filed by the JCRCC is a matter which requires investigation. It seems the recording of this expense was specifically orchestrated to avoid being reported prior to the election, a period during which the JCRCC failed to file a 40 Day Report, and 8 Day Report, and by Missouri Statute should therefore be subject to late reporting penalties and sanction for the failure to report. In addition, although George and Janet Engelbach do not appear to be members of the VGG, the fact that the expenditures for the mailing by VGG occurred merely two days after George Engelbachs contribution in substantially the same amount as the VGG mailing expenditure is evidence that the VGG acted under the direction of Mr. Engelbach. The funds, in the amount of $5,000, were approved by the JCRCC on 7/10 to establish the Jefferson County Organization to Reinforce Citizen Awareness (JCORCA) PAC. Instead of transferring the

$5,000 to the approved Committee, Chairwoman Janet Engelbach and member and husband George Engelbach then colluded to "disburse and launder the funds without the consent of the full body, to VGG, by issuance of a check drafted from the JCRCC Account payable to Janet Engelbach, who then liquidated those funds, transferred them to George, who then contributed them to Voters for Good Government in his own name, with the intent of concealing their origin. These funds were then expended, as seen on the 24 hour expenditure report on 7/29, by the VGG in support of the candidacies of George Engelbach, Janet Engelbach, John Gebel, Dwight Vermette, Diane Bast Berberich, Ken Hollenberg, Linda VanDeRiet, David Courtway, Teresa Kreitler, Gerald Bollinger, Janet Bollinger, and Angela Alter-Wren who are all voting members of the JCRCC. As such, the use of the funds for such an expenditure by the JCRCC would be a gross blatant violation of Missouri Ethics Law per MEC Opinion No. 2003.07.104, so instead, they chose to intentionally conceal the origin of the funds, in violation of RSMO Section 130.031, in order to attempt to circumvent the letter and spirit of the law. Due to there being no record of the body of the JCRCC approving the expense or disbursement of a check directly to Janet Engelbach for the purpose of reimbursing George Engelbach for the funds he provided to Voters for Good Government PAC , this would seem to constitute theft from the JCRCC. And as such, combined with the fact that the funds misappropriated were in the amount of $3400 and the check was cashed and then the cash was transferred to George Engelbach to shield and conceal the origin of the funds, this would seem to meet the statutory requirement for "criminal activity", and as such violates RSMO 574.105.2(2), as the proceeds from a criminal act were then laundered with the intent to conceal their origin,ultimately in an attempt to make an expenditure which would otherwise have been illegal had the actual source of the funds been known. Conclusion George and Janet Engelbach coerced, controlled and directed the VGG and JCRCC Political Action Committees for the benefit of their own personal campaigns and colluded to receive and make contributions in such a manner as to launder the money and conceal the identity of the actual source of the contribution to allow for a use of the funds (support of select JCRCC candidates) which would have otherwise been prohibited by law per MEC Opinion No. 2003.07.104. had the funds been expended by JCRCC PAC. These actions are clearly in violation of Section 130.031 3 RSMO, Section 574.105.2(2) RSMO and MEC Opinion No. 2003.07.104.