Ocasio Cortez Complaint
Ocasio Cortez Complaint
)
COOLIDGE-REAGAN FOUNDATION )
1629 K Street, N.W., Suite 300 )
Washington, D.C. 20006 )
)
Complainant, )
)
v. )
)
ALEXANDRIA OCASIO-CORTEZ )
FEC ID Number H8NY15148 )
P.O. Box 680080 )
Corona, NY 11368, )
)
ALEXANDRIA OCASIO-CORTEZ )
FOR CONGRESS )
P.O. Box 680080 )
Corona, NY 11368 )
Frank Llewellyn, Treasurer )
)
BRAND NEW CONGRESS )
2930 Wesley Avenue )
Charlotte, NC 28205 )
Isra Allison, Treasurer )
)
Respondents. )
_______________________________________)
VERIFIED COMPLAINT
Introduction
campaign funds through Brand New Congress—a limited liability corporation and affiliated
PAC—to her boyfriend. Reason to believe exists both the transaction, as well as the involved
PARTIES
1
2. Respondent ALEXANDRIA OCASIO-CORTEZ was a candidate for Congress in
2018, and currently serves as a Member of Congress from New York’s 14th Congressional
District.
and address of each person who has received any disbursement not disclosed” as an expenditure,
Congresswoman Loves the Swamp. Her Wealthy Chief of Staff Used a PAC to Pay Her
Boyfriend,” on Medium, which parses FEC records to reveal evidence Ocasio-Cortez funneled
money from her official campaign account to her boyfriend, Riley Roberts.
https://medium.com/@ltthompso/the-congresswoman-loves-the-swamp-d33296ec251e.
founded Brand New Congress PAC and Brand New Congress LLC in 2016. He operated Brand
New Congress PAC through approximately August 2017. It appears he no longer operates Brand
2
9. On August 9, 2017, Brand New Congress PAC paid Ocasio-Cortez’s boyfriend,
Riley Roberts, $3,000. The description of the payment specifies only “marketing consultant.”
10. Less than three weeks later, on August 27th, 2017, Cortez’s campaign committee
Ocasio-Cortez 2018 at the time—reported the transaction on Page 20 of its October Quarterly 2017
report to the FEC, filed on October 14, 2017 and amended on April 13, 2018. It is available at:
http://docquery.fec.gov/pdf/150/201804139108015150/201804139108015150.pdf.
12. The following month, Brand New Congress PAC paid Cortez’s boyfriend, Roberts,
13. Brand New Congress PAC reported both of its payments to Roberts on Page 1,211
of its Year-End 2017 report to the FEC, filed on January 31, 2018. It is available at
http://docquery.fec.gov/pdf/370/201801319091223370/201801319091223370.pdf.
14. Thus, over the span of a little more than a month, Cortez’s campaign committee
paid just over $6,000 to Brand New Congress PAC, while its affiliated LLC turned around and
15. Ocasio-Cortez subsequently hired Chakrabarti, who created the entities which
conducted these transactions and facilitated the transfer of Ocasio-Cortez’s official campaign
16. The timing and amounts of these transactions, the use of two affiliated entities as
intermediaries, the vague and amorphous nature of the services Riley ostensibly provided, the
magnitude of these transactions compared to both the limited funds the campaign had raised at the
time and the total amount of its expenditures, and the romantic relationship between Ocasio-Cortez
3
and Riley collectively establish reason to believe these transactions may have violated campaign
finance law.
CAUSES OF ACTION
candidate committee to personal use by transferring a total of $6,191.32 from her campaign
committee to Brand New Congress PAC in late August and September 2017, which
contemporaneously had its affiliated LLC pay $6,000 to her boyfriend, Riley.
19. On information and belief, the amount paid to Riley was either not provided as
consideration for bona fide services or exceeded the fair market value of any legitimate services
Riley provided. On information and belief, the true intent of the payment to Riley was to provide
personal benefit to a boyfriend, rather than defray bona fide campaign expenses.
21. In an attempt to mask the payment of official campaign funds to her boyfriend,
Ocasio-Cortez instead laundered them through intermediaries Brand New Congress PAC and
4
22. Ocasio-Cortez incorrectly reported a payment of $6,191.32 to Brand New Congress
LLC on August 27, 2017, for strategic consulting, rather than correctly characterizing the
CONCLUSION