‘Timothy F. Maloney
Atomey at Law
JOSEPH Jap ier ate
Ge GREENWALD Geena tb 0
& LAAKE, PA pact
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October 1, 2018
Via Electronic Mail
Jared DeMarinis, Director
Candidacy and Campaign Finance Division
Maryland State Board of Elections
51 West St., Suite 200
‘Annapolis, MD 21401 ~ 0486
RE: Floren Campaign
Dear Mr, DeMarinis:
As we previously advised the Board, the Floreen campaign initiated inquiries into the
contributions that the complainant identified as potentially over the limit. Although the
complaint indicates it was filed by a “Ken Meyers,” the Word document indicates that it was
prepared by David Mitrani is a Senior Associate at Sandler Reiff Lamb Rosenstein &
Birkenstock, P.C., which represents unions and other advocacy groups.
Our inquiry indicates the following that three of the four sets of contributions are clearly
within the limits established in § 13-226(e) of the Election Law Article, Regarding the fourth set
of contributions, we were unable to confirm that these were within the limit and have refunded
these to the contributor to avoid any possible issues involving contribution limits.
1, Lee Development Group (LDG) and related entities. We have been advised by
contributors at the Lee Development Group that none of the entities have more than 80 percent
overlapping ownership, and accordingly, the contributions are permissible under Maryland law.
2. Donohoe Companies. We have been advised by the Donohoe Companies that none
of the entities have more than 80 percent overlapping ownership, and accordingly, the
contributions are permissible under Maryland law.
3. Guardian Realty. We have been advised that the two Guardian entities have no
more than 80 percent overlapping ownership, and accordingly these contributions are permissible
under Maryland law.
4. Park Potomac Entities, We have been advised that these entities have complex
ownership structures and that there may be potential issues which may implicate (§ 13-226(e)) of
the Election Law Article, Accordingly, any aggregated contributions potentially in excess of the
individual contribution limit have been refunded.
6404 Ivy Lane | Suite 400 | Greenbelt, MD 20770
Phone: 301.220.2200 | Fax:301.220.1214 | wwwjgllawcom
‘Montgomery County Office
IN Rockville Pike | Suite 975 | Rockville. MD 20850.Jared DeMarini, Director
October 1, 2018
Page 2
Please let me know if I can provide any additional information concerning the:
contributions and if there are any additional steps we need to take.
Very truly yours,
TEMcklr