Ventimiglia V Whitmer File 744163 7

Complaint Against:
Gretchen Whitmer for Governor

Committee Identification No. 518014
325 S. Walnut
Lansing, MI 48933
Telephone No. 517.763.2955
Gretchen Whitmer
2520 Oxford Road
Lansing, Ml 48911
Complainant:
Eric Ventimiglia
123 W Allegan, Suite 770
Lansing, Ml 48933
Telephone No. 586.216.4940
Dated: July 26, 2021
Filed Pursuant to MCL 169.215

and the Administrative Rules of the
Michigan Department ofState
Bureau ofElections
Richard H. Austin Building, 1st Floor
430 W. Allegan
Lansing, Michigan 48918
Christopher M. Trebilcock Clark Hill
T (313) 965-8575 500 Woodward Ave., Suite 3500
F (313) 309-6910 Detroit, MI 48226
Email:[email protected] T (313) 965-8300
F (313) 965-8252
August 20, 2021
Via Email, only
Adam Fracassi
Michigan Department of State
Bureau of Elections
Richard H. Austin Building – 1st Floor
430 W. Allegan St.
Lansing, MI 48918
[email protected]; [email protected]
Re: Response to Complaint in Ventimiglia v Whitmer

No. 2021-07-17-21
Dear Mr. Fracassi:
I serve as legal counsel to Governor Gretchen Whitmer, the Gretchen Whitmer for
Governor candidate committee, and Michigan Transition 2019. I am in receipt of the complaint
filed by Eric Ventimiglia against Governor Whitmer (the “Complaint”) alleging violations of the
Michigan Campaign Finance Act (“MCFA” or the “Act”). Specifically, the Complaint alleges that
the Act does not permit the Gretchen Whitmer for Governor candidate committee to pay for the
cost of a private flight for the Governor to travel to Florida in March of 2021. As detailed in the
Complaint, the cost of the flight at issue was initially paid for by Michigan Transition 2019. The
Complaint is meritless and should be dismissed for the reasons stated below.
A. Michigan Transition 2019
Michigan Transition 2019 is organized as a Michigan nonprofit corporation. Exhibit 1,

LARA Filings. It is recognized as a tax-exempt social welfare organization under Internal
Revenue Code Section 501(c)(4). It also has registered assumed names of “Michigan Inaugural
2019” and “Executive Office Account.” Contributions to Michigan Transition 2019 are not
deductible as charitable contributions. Thus, any expenditures from Michigan Transition 2019
have not been subsidized by charitable contributions.
Article II of the Articles of Incorporation of Michigan Transition 2019 describes the

purposes for which Michigan Transition 2019 is established. Exhibit 2, Article of Incorporation.
Those purposes relevant to the current situation include:
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Response to Ventimiglia Complaint
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Page 2
 To operate for the promotion of civic action and social welfare by

promoting the common good and general welfare of the residents of, and
visitors to, the State of Michigan.
 To educate legislators, state officers, and the general public on issues facing
Michigan and the United States.
 To advocate citizen participation and obtain support for public policies in

Michigan. [Id.]
The exempt activities of Michigan Transition 2019 are not limited to its original purpose of
supporting the transition of Governor Whitmer and her inaugural ceremony. As such, the
expenditures made by Michigan Transition 2019 since its inception were made consistently with
its purposes by, in many cases, lessening the use of taxpayers’ dollars and the burden on
government. This includes expenses for travel, staff, food, postage, and research when those
activities are related to the exempt activities of Michigan Transition 2019.
B. The March 2021 Florida Trip
Upon learning of the need for Governor Whitmer to need to travel to Florida in March 2020
to visit her ailing father, her office consulted with Governor Whitmer’s security detail regarding
the timing, methods, and mode of transportation available for Governor Whitmer to travel to
Florida. The conclusion was that travel by private aircraft would significantly reduce the security
risks associated with Governor Whitmer’s travel to Florida.
On or around March 8, 2021, an aide to Governor Whitmer’s office contacted PVS to ask
whether PVS had an aircraft that could fly her on a trip to Florida. As stated by the Governor’s
office, this was a two-day weekend trip to visit her ailing father, with a travel day on each side of
the visit.1
PVS responded to the outreach the next day and indicated that it did have an aircraft. On
March 10, 2021, PVS was provided with an itinerary for the flight and arranged for a flight to
depart on March 12 and return on March 15, 2021. The flight to Florida included Governor
Whitmer and her security detail. The return flight from Florida to Michigan added Governor
Whitmer’s two daughters, who had been helping manage their grandfather’s health issues for
several weeks while maintaining their college and high school virtual schedules. No other people
were on the flights besides the Governor, her children on the return flight, her security detail, and
the flight crew.
1
I have been informed that leading up to and during this trip, the Michigan State Police adhered
to all protocols at all times. The Governor’s office has also indicated that during the trip, Governor
Whitmer followed all MDHHS epidemic orders. Michigan has not had any limitations on travel
for nearly a year. The State does not typically provide details regarding security for the Governor,
especially given the very real and ever-present threats to her life.
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On March 19, 2021, an aide to Governor Whitmer’s office contacted PVS to determine the
cost of the flight. PVS responded to the request but did not issue an invoice or request payment at
that time. The value of the flight was $27,521. PVS later received payment in the amount of
$27,521.00 (the “Payment”) from Michigan Transition 2019.
At the time the Payment was issued, both PVS and Michigan Transition 2019 believed that
the Payment was being made in compliance with all applicable laws. PVS assumed that the
Payment was made pursuant to 14 C.F.R. § 91.321 (Carriage of Candidates in Elections). Under
federal tax laws and state nonprofit law, Michigan Transition 2019 may pay expenses related to
the carrying out of its exempt purposes. It was determined that the expense of the non-commercial
flight was reasonable and necessary given the serious and varied threats to the personal safety of
the Governor as advised by security experts. Only because of media reports on these issues did
PVS and Michigan Transition 2019 learn that a miscommunication occurred between them with
respect to the source of the payment for the flight.
Notwithstanding that the payment of the trip was a proper expense of Michigan Transition
2019 under tax and nonprofit law, legal counsel for PVS advised Michigan Transition 2019 on
May 17 that because of PVS’ status as a Part 91 operator, FAA rules do not allow the operator to
accept any flight reimbursements except from a candidate campaign committee. Based on this
new understanding, the cost of the flight was then paid from the Gretchen Whitmer for Governor
campaign fund consistent with FAA rules and in compliance with the MCFA as an incidental
office expense. Although not required by law, Governor Whitmer voluntarily reimbursed the
Gretchen Whitmer for Governor candidate committee for an amount equivalent to the cost of a
first-class commercial airline ticket for herself and her daughters.
C. The Significant and Continuing Threats to Governor Whitmer’s Life
Governor Whitmer has been the subject of extraordinary threats to her life. As this office
is aware, in October 2020, the Federal Bureau of Investigation thwarted a plot by more than a
dozen militia members who were plotting to kidnap Governor Whitmer and take her to a remote
location in Wisconsin, hold a “trial” against her for alleged “treasonous” conduct, and likely
execute her. Indeed, these militia members had gone so far as to conduct surveillance at Governor
Whitmer’s personal vacation home in northern Michigan on at least two occasions. See Snell and
Naan Burke, Plans to kidnap Whitmer, overthrow government spoiled, officials say, THE DETROIT
NEWS (Oct. 8, 2020) (Exhibit 3).
The threats do not just stop there. The Detroit Metro Times reported on numerous threats
made against Governor Whitmer in private Facebook groups, which were “promoting violence
and mobilizing armed rallies against Gov. Gretchen Whitmer.” See Neaviling, Gov. Whitmer
becomes target of dozens of threats on private Facebook groups ahead of armed rally in Lansing,
THE DETROIT METRO TIMES (May 11, 2020) (Exhibit 4).2 According to the Detroit Metro Times,
2
As The Detroit News reported, the militia members who sought to kidnap Governor Whitmer
“allegedly met starting in June, including at a Second Amendment rally in Lansing.” See Exhibit
3.
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“[a]ssassinating Whitmer [was] a common theme among members of the groups. Dozens of
people have called for her to be hanged.” Id. (citing to posts stating that a “good old fashioned
lynch mob [needed] to storm the Capitol, drag [Governor Whitmer’s] tyrannical a** out onto the
street and string her up as our forefathers would have,” that “Plain and simple [Governor Whitmer]
needs to eat lead and send a statement to the rest of the democrats that they are next.”). Others
suggested that they “[d]rag that tyrant governor out to the front lawn,” and “[f]it her for a noose,”
while another man wondered “[h]ow long till she’s hit with a shotgun blast.” Id. Finally, one man
asked to “[t]ake up a collection for an assassin to put that woman from Michigan down.” Id.
Such dangerous individuals did not just hide behind computer screens. Armed protestors
– some of whom were militia members – came to the Capitol to protest shelter-in-place orders and
carried signs calling Governor Whitmer a “Tyrant B****” and threatening that “Tyrants get the
Rope.” A reporter for the Michigan Advance even headed up being hit in the head with a
protestor’s rifle. See Nichols, ‘Tyrants Get The Rope’: Small anti-Whitmer protest rocks Capitol,
reporter hit by gun, MICHIGAN ADVANCE (April 30, 2020) (Exhibit 5).
[Twitter, @CraigDMauger, 4/30/20]
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Some protestors demanded entry into the House of Representatives’ chamber, and some were
dressed in camouflage fatigues carrying semiautomatic rifles, and watched from the gallery for the
Senate chamber as elected officials attempted to carry out their work. See Gray, In Michigan, a
Dress Rehearsal for the Chaos at the Capitol on Wednesday, The New York Times (Jan. 9, 2021)
(Exhibit 6).
A Republican candidate for 21st state House district – James Chapman – attended a protest where
he hung a brunette doll from a noose at the end of his 13-star Betsy Ross flag and fishing rod, and
explained that the noose was “one size fits all” for anyone not standing up to Governor Whitmer
and her tyranny. See Dodge, Protester explains doll, noose demonstration at Capitol, wants to gift
props to Trump, MLIVE (May 18, 2020) (Exhibit 7). Chapman had a long and violent criminal
history, including a 1990 conviction for assault with intent to do great bodily harm less than murder
and a firearms charge, for which he was sentenced to three to 10 years in prison and a stalking
charge, for which was placed on probation in 2015. More recently, Chapman was sentenced to six
months in jail in 2018 after being found guilty of resisting a police officer. Id.
According to the Michigan Court of Appeals, during his latest run in with the law, Chapman argued
with and attempted to stab an acquaintance and then drove into Belleville Lake in an attempt to
evade police. People v Chapman, Docket No. 345090, 2019 WL 6340929 (Mich Ct App Nov 26,
2019).
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In yet another threat, a Michigan man was charged with threatening to kill both Governor
Whitmer and Attorney General Nessel in the spring of 2020. See Mele, Man Faces Terrorism
Charge After Threatening to Kill Michigan’s Governor, Officials Say, THE NEW YORK TIMES (May
15, 2020; updated Oct. 9, 2020) (Exhibit 8). As with the numerous and persistent threats against
Governor Whitmer and other statewide public officials, Wayne County Prosecutor Kym Worthy
stated that the facts of the case “lay out a very disturbing scenario.” Id.
The threats continued into 2021. In March of 2021, right around the time of the trip at
issue, Attorney General Nessel charged a 21-year-old West Michigan man with threatening
terrorism and using a computer to commit a crime for making death threats against President
Biden, Speaker Pelosi, and Governor Whitmer. See Michigan man charged with threatening to
kill Biden, Pelosi, and Whitmer, REUTERS (Mar. 16, 2021) (Exhibit 9). Officials stated that the
man stated he would use a gun to shoot and kill the elected officials and had information on how
to make a bomb, including where to find the necessary materials. Id.
Numerous individuals also sent threatening messages directly to Governor Whitmer’s

social media accounts. See Exhibit 10, Social Media Direct Message Threats. Some of the more
egregious examples follow:
 While referring to Governor Whitmer by numerous vulgar and misogynistic names over
the course of several days, a man threatened that President Trump was “GOING 2 BE
COMING AFTER” her. Id. at 1–4.
 A woman wished that Governor Whitmer and other Democrats would “die horrible
deaths.” Id. at 5.
 A Michigan man who allegedly worked at a restaurant stated the following to Governor
Whitmer: “I would like to sincerely hope you get some type of mixed super AIDS Ebola
that makes you die slowly and painfully while your organs leak from your rectum. I
sincerely hope I am working at the next restaurant that you try to eat at so if they don’t
outright refuse to serve you I can personally walk to your table, b**** slap your cuck
husband, s*** on your dinner plate and shove it down your cold heartless throat.” Id.
at 6 (emphasis added).
 Another man told Governor Whitmer she “should watch out” and referred to her in
misogynistic language. Id. at 12.
 Another man stated his wish that “WE THE PEOPLE REMOVE YOU FROM OFFICE
ONE WAY OR ANOTHER VERY SOON.” Id. at 14.
 One man sent a message to Governor Whitmer’s account stating: “Remove her from office.
Do it by force if she won’t leave willingly.” Id. at 15.
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 One man extended to the threat to Governor Whitmer’s husband and stated: “F*** your
husband. Better hope I never catch you to him on the streets.” Id. at 16.
 A Florida man expressed his desire to kidnap Governor Whitmer and that he was going to
kill her, “cut [her] head off,” that she could “get one of [his] cars,”3 that she could “get
stabbed,” that he was “going to knock [her] head off,” and that he was going to “shoot [her]
in the head.” Id. at 17–23.
 On January 6, 2021 – the same day as the Washington D.C. insurrection – one man told
Governor Whitmer “[t]he People of Michigan will take care of that for you,” and told her
“[w]e’ve got you” and referenced her hiding in one of her two houses, and sent a bomb
emoji, followed by an hourglass emoji and a person in a wheelchair emoji. Id. at 24.
 On March 7, 2021 – right before the trip at issue – a man sent Governor Whitmer a message
blaming her for the suicide of his niece and told her that while he did not live in Michigan,
he would be “back to visit” and that he hoped her “protection detail is good and sharp.” Id.
at 25.
 One woman told Governor Whitmer that she hoped “they drag you out and pound your
head on the pavement,” and that she “would knock [her] teeth down [her] throat.” Id. at
26.
More recently, the Ronald Weiser, co-chair of the Michigan Republican Party, when speaking
about Governor Whitmer, Secretary Benson, and Attorney General Nessel, stated that the
Republican Party’s “job now is to soften up those three witches and make sure that when we have
good candidates to run against them, that they are ready for burning at the stake.” Stracqualursi,
Michigan GOP chair calls top Democratic women 'witches' and quips about assassination of
Republican congressmen, CNN (March 29, 2021) (Exhibit 11).
These are just the threats that are known and have been made public. Given these threats,
a non-commercial flight was necessary in March 2021 to ensure the safety of Governor Whitmer
and her family, and the safety of the traveling public. Moreover, the threats to Governor Whitmer
are ever present when she travels, whether the travel is for state business, campaign-related, or
personal. The job of a governor does not have a time clock and neither do the threats to the
Governor.
D. Candidate Committees May Use Funds To Pay For Security Related Expenses Under
Interpretive Guidance Issued by the Bureau of Elections.
Payment for the flight by the Gretchen Whitmer for Governor candidate committee was
permissible under the MCFA. MCL 169.209 permits candidate committees to make expenditures
for incidental expenses “paid or incurred in carrying out the business of an elective office.” Under
3
Presumably, this referred to him threatening to run Governor Whitmer over with his car given
the context of the rest of the messages.
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the law, these expenses include but are not limited to “unreimbursed [expenses] for travel, lodging,
meals, or other expenses incurred by the public official, a member of the public official’s
immediate family, or a member of the public official’s staff in carrying out the business of the
elective office.”
Recently, in response to a request by Representative Kevin Hertel, the Bureau of Elections

issued an interpretative statement on April 15, 2021 that is squarely on point and dispositive of the
Complaint. See Exhibit 12, Hertel Interpretative Statement. Given that heavily armed protestors
had attempted to gain access to the floor of the House of Representatives on April 30, 2020, and
the death threats that Representative Hertel and his family had received, Representative Hertel
wanted to know “[w]hether the purchase of a ballistics vest or home security system in response
to threats of violence constitutes a personal expense.” Id. at 2. As the Bureau of Elections put it,
“[a]t the heart of these questions is whether the requested items [] are considered personal expenses
or incidental office expenses.” Id.
In unequivocal language, the Bureau of Elections determined that a candidate committee

could purchase a home security system as an incidental office expense:
The Department agrees with these conclusions and determines that

a committee may purchase home security system as an
incidental office expense so long as the expenditure is not being
made for personal use. If an office holder determines it necessary
to purchase a home security system due to increased threats incurred
as a result of their elected office, such purchase may be done using
committee funds. For example, if the committee elects to purchase
a home security system as a direct result of threats motived by the
office holder’s status, such as supporting/opposing legislation, such
a disbursement may be a lawful incidental office expense.
However, the disbursement must be done as a result of their

status as an office holder, otherwise it will constitute a personal
expense. For example, a disbursement for home security system
may not increase the value of the residence or constitute a structural
improvement (e.g. installation of bullet proof glass or privacy
fence), and must be motived by the office holder’s status as an office
holder. [Id. at 6 (emphases added).]
The Bureau of Elections arrived at this conclusion after a detailed and thorough analysis of facts
applicable to all officeholders in Michigan, the MCFA, and identical and persuasive Federal law
and guidance from the Federal Election Commission (“FEC”).
First, as to the facts and the reality of the situation on the ground, the Bureau of Elections
recognized that “[i]n 2020, elected and appointed officials in Michigan [and nationwide] have seen
an unprecedented number of threats of physical harm against them and their families,” and
specifically cited the plot to kidnap Governor Whitmer as an example. Id. at 4 and n 7–8. The
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Bureau of Elections also referenced the fact that, in the wake of the riot at the United States Capitol
on January 6, the Massachusetts Office of Campaign and Political Finance issued an advisory
opinion on March 1, 2021 concluding that committee funds may be used to purchase bullet-proof
vests/body armor, pepper spray, gas masks, or other similar personal protective equipment so long
as it was not being purchased for personal use, in addition to authorizing committee funds to pay
for security detail and the purchase of a home security system. Id. at n 5 (citations omitted).
Second, in reaching its conclusion, the Bureau of Elections analyzed several advisory
opinions issued by the FEC interpreting the Federal Election Campaign Act of 1971 (“FECA”).
Id. at 5. As the Bureau of Elections recognized, while not binding, it may rely upon administrative
opinions of the FEC, and other states, as persuasive in its interpretation of similar provisions of
the MCFA. Id. at 6 (citing Interpretative Statement to David Lambert, issued October 31, 1984
and Chiles v. Machine Shop, Inc., 238 Mich App 462, 472 (1999) (stating that analogous federal
precedents of similar legal provisions are persuasive so long as they do not conflict with Michigan
law). The Bureau of Elections concluded that “[t]he MCFA’s provisions echo its FECA
counterparts,” recognizing the similarities between the two statutes. Id.4
Having determined the similarities between the statutes, the Bureau of Elections analyzed
FEC Advisory Opinion 2021-03. 5 Id. at 5. There, the National Republican Senatorial Committee
and the National Republican Congressional Committee asked the FEC whether committee funds
could be used to pay for personal security personnel of members of Congress and their families.
Id. In analyzing and interpreting the relevant provisions of the FECA, the FEC held that committee
funds could be used for hiring security personnel for members of Congress and their families due
to threats arising from their status as office holders. Id.; see also FEC Advisory Opinion 2021-03.
The Bureau of Elections analyzed other advisory opinions issued by the FEC regarding the
use of campaign funds to protect against threats to officeholders’ physical safety on the grounds
that the need for such security expenses would not have been incurred but-for the officeholder’s
activities or duties. Exhibit 12, at 5. For example, following the shootings targeting
4
Under FECA, federal committees may use campaign funds for “ordinary and necessary expenses
incurred in connection with duties of the individual as a holder of Federal office.” 52 U.S.C. §
30114(a). A contribution or donation may not be converted for personal use. 52 U.S.C. §
30114(b)(1). The FEC’s regulations define personal use as the “use of funds in a campaign account
of a present or former candidate to fulfill a commitment, obligation or expense of any person that
would exist irrespective of the candidate’s campaign or duties as a Federal officeholder.” 11 CFR
§ 113.1.
Similarly, the MCFA allows incumbent officeholders the ability to make incidental office expenses
defined as “an expenditure that is an ordinary and necessary expense, paid or incurred in carrying
out the business of an elective office.” MCL 169.209(1). Expenditures are defined as any of
ascertainable monetary value made in assistance of or opposition to the election of a candidate.
MCL 169.206(1).
5
All FEC Advisory Opinions are attached as Exhibit 13 and appear in the order in which they are
referenced in this Response.
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Representatives Gabby Giffords and Steve Scalise, the FEC authorized candidate committee funds
to be used to purchase home security system installation and upgrades due to the “current
heightened threat environment” and anonymous nature of many of the threats. Id. at 5 (citing FEC
Advisory Opinions 2011-17 and 2017-07). In 2021, the FEC issued another Advisory Opinion in
response to a request submitted by Representative Veronica Escobar wherein the FEC expanded
its guidance to include upgrades to wiring and lighting as part of a residential security system so
long as it did not include a structural improvement. Id. at 5 (citing FEC Advisory Opinion 2020-
06).
As shown above and as previously recognized by the Bureau of Elections, the threats
against Governor Whitmer’s life are well-documented. A private flight was used because this
method of travel significantly reduced the security risks to Governor Whitmer’s life based on the
security assessment at that time. Moreover, as Governor Whitmer’s office has stated, while
outside the state the Governor maintained her official schedule and conducted scheduled meetings.
The payment for the additional security costs by an entity other than the State lessened the burden
on taxpayers. But for her elected office and the threats that she has received against her life because
she holds elected office, Governor Whitmer would not have incurred the security expenses for
travel to see her ailing father on short notice.
This legal conclusion is consistent with MCL 169.209 and the April 15, 2021 interpretive
statement of the Bureau of Elections to Representative Hertel, which confirmed that security
expenses necessary to protect the health and welfare of an elected official that would not otherwise
have been incurred but for the person’s status as an elected official can be considered a necessary
and reasonable expense under the Michigan Campaign Finance Act.
Accordingly, the Complaint is meritless and should be dismissed without any further action
taken by the Bureau of Elections.
Sincerely,
CLARK HILL PLC
Christopher M. Trebilcock
CMT:vcs
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EXHIBIT 1
8/20/2021 Search Summary State of Michigan Corporations Division
LARA Home Contact LARA Online Services News MI.gov
ID Number: 802253099 Request certificate Return to Results New search

Summary for: MICHIGAN TRANSITION 2019

The name of the DOMESTIC NONPROFIT CORPORATION: MICHIGAN TRANSITION 2019

Entity type: DOMESTIC NONPROFIT CORPORATION

Identification Number: 802253099

Date of Incorporation in Michigan: 11/05/2018

Purpose: Other
Term: Perpetual

Most Recent Annual Report: 2021 Most Recent Annual Report with Officers & Directors: 2021

The name and address of the Resident Agent:
Resident Agent Name: CSC-LAWYERS INCORPORATING SERVICE (COMPANY)
Street Address: 2900 WEST ROAD STE 500
Apt/Suite/Other:
City: EAST LANSING State: MI Zip Code: 48823

https://cofs.lara.state.mi.us/CorpWeb/CorpSearch/CorpSummary.aspx?ID=802253099&SEARCH_TYPE=3&CanReturn=True 1/3
Registered Office Mailing address:

P.O. Box or Street Address: 151 S. OLD WOODWARD AVE
Apt/Suite/Other: SUITE 200
City: BIRMINGHAM State: MI Zip Code: 48009

The Officers and Directors of the Corporation:
Title Name Address

PRESIDENT S. MARTIN TAYLOR 222 N WASHINGTON SQUARE, SUITE 400 LANSING, MI
48933 USA
TREASURER KRISTEN CASWELL 222 N WASHINGTON SQUARE, SUITE 400 LANSING, MI
48933 USA
SECRETARY MICHAEL PRUSI 222 N WASHINGTON SQUARE, SUITE 400 LANSING, MI
48933 USA
DIRECTOR KRISTEN CASWELL 222 N WASHINGTON SQUARE, SUITE 400 LANSING, MI
48933 USA
DIRECTOR MICHAEL PRUSI 222 N WASHINGTON SQUARE, SUITE 400 LANSING, MI
48933 USA
DIRECTOR S. MARTIN TAYLOR 222 N WASHINGTON SQUARE, SUITE 400 LANSING, MI
48933 USA

Act Formed Under: 162-1982 Nonprofit Corporation Act

Acts Subject To: 162-1982 Nonprofit Corporation Act

The corporation is formed on a Directorship basis.

Written Consent

View Assumed Names for this Business Entity

View filings for this business entity:
ALL FILINGS
ANNUAL REPORT/ANNUAL STATEMENTS
ARTICLES OF INCORPORATION
ARTICLES OF INCORPORATION
RESTATED ARTICLES OF INCORPORATION
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Comments or notes associated with this business entity:

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EXHIBIT 2
EXHIBIT 3
8/20/2021 Feds say they thwarted militia plot to kidnap Whitmer
MICHIGAN
Plans to kidnap Whitmer, overthrow government

spoiled, officials say
Robert Snell and Melissa Nann Burke The Detroit News
Published 11:27 a.m. ET Oct. 8, 2020 Updated 5:18 p.m. ET Oct. 9, 2020
Federal agents said Thursday they thwarted a plot to violently overthrow the government as well as kidnap and harm

Michigan Gov. Gretchen Whitmer — a conspiracy that included visits to her home in northern Michigan and training

with firearms and explosive devices.

The alleged plot mainly involved six conspirators unhappy in part about Whitmer's coronavirus restrictions, calling her a

"tyrant." They wanted to create a "self-sufficient" society free from what they called unconstitutional state
governments and discussed plans to storm the Capitol and take hostages, according to FBI documents filed in court.

Organizers allegedly met starting in June, including at a Second Amendment rally in Lansing and in a Grand Rapids shop
basement accessed through a secret door hidden under a rug.

The plot also included at least seven members of a Michigan militia known as the Wolverine Watchmen accused by state

officials on Thursday of targeting police, making threats to "instigate civil war" and helping to plan Whitmer's kidnapping,
according to state and federal officials.

►Read the filing: FBI affidavit: Conspirators wanted to kidnap gov to remote Wisconsin location

The federal court filing alleges the conspirators twice conducted surveillance at Whitmer's personal vacation home in
northern Michigan and discussed kidnapping her to a "secure location" in Wisconsin to stand "trial" for treason prior to the
https://www.detroitnews.com/story/news/local/michigan/2020/10/08/feds-thwart-militia-plot-kidnap-michigan-gov-gretchen-whitmer/5922301002/ 1/9
Nov. 3 election.
"Several members talked about murdering 'tyrants' or 'taking' a sitting governor," an FBI agent wrote in the affidavit. "The
group decided they needed to increase their numbers and encouraged each other to talk to their neighbors and spread their
message."
After the charges were revealed, Whitmer slammed President Donald Trump for failing to condemn in strong enough terms
hate groups, such as the far-right Proud Boys, whom he told to "stand back and stand by" during the debate last week.
"Hate groups heard the president's words not as a rebuke, but as a rallying cry, a call to action," the Democratic
governor said.
She also warned those who threatened violence: "We will find you, we will hold you accountable and we will bring you to
justice.”
The federal affidavit first reported by The Detroit News was filed hours after a team of FBI agents raided a Hartland
Township home Wednesday and comes amid an investigation into the death of a Metro Detroit man killed during a
shootout with FBI agents.
Michigan Attorney General Dana Nessel, federal and state officers on Thursday detailed charges against the 13 people and
what they described as "elaborate plans" to kidnap Whitmer.
The nature of the case is “rather unprecedented,” Michigan State Police Col. Joe Gasper said at the news conference.
“But it does send a very vivid reminder that while we may be in a period of discourse, possibly even divisiveness and
fighting across the nation, law enforcement stands united,” Gasper said.
The investigation is the result of months of work that culminated Wednesday night in the execution of a series of search
warrants and arrest warrants — both in-state and out-of-state — related to acts of terrorism under Michigan state law.
The conspiracy described by the FBI specifically involved six people, including Ty Garbin, 24, whose home was raided by
agents in Hartland Township late Wednesday.
The affidavit filed in federal court details probable cause to charge the six men with conspiring to kidnap Whitmer. Those
identified by name include:
Adam Fox, 37, of Potterville

Barry Croft, 44, of Bear, Delaware
Ty Garbin, 24, of Hartland
Kaleb Franks, 26, of Waterford
Daniel Harris, 23, of Lake Orion
Brandon Caserta, 32, of Canton Township
Fox, Garbin, Franks, Harris and Caserta made initial appearances in federal court Thursday and are being held without
bond pending detention hearings. The conspiracy charge each is facing is punishable by up to life in federal prison.
"All of us standing here today want the public to know that federal and state law enforcement are committed to working
together to make sure violent extremists never succeed with their plans, particularly when they target our duly elected
leaders," said U.S. Attorney Andrew Birge of the Western District of Michigan.
'Wake ... up'

Through confidential sources, undercover agents and "clandestine" recordings, federal agents tracked the six men during
their planning to kidnap Whitmer as they communicated over encrypted messaging platforms using code words
and phrases in an attempt to avoid detection by law enforcement, Birge said.
The group also allegedly participated in field exercises that included detonating an improvised explosive wrapped in
shrapnel to test its capabilities, he said.
Caserta, 32, of Canton Township, posted several videos on TikTok, including one in which he is wearing a Hawaiian shirt,
the trademark clothing of members of the antigovernment boogaloo movement.
“The price of freedom is eternal vigilance,” Caserta said in one video. “And indifference to this notion is the means by which
the people can and will secure their own oppression. Wake the f--- up.”
Former U.S. Rep. Mike Rogers, a former FBI agent who chaired the House Intelligence Committee, said the conspirators
had taken “really extensive steps” to put their plan into action, which was “obviously very, very troubling.”
“I feel for the governor and her family. Politics is bad enough these days. To have to put up with somebody threatening to
kidnap and probably kill you for some deranged political cause is over the top for sure. My heart goes out to her and her
family,” said Rogers, a Howell Republican.
He said it seems the authorities appear to have a solid case against the accused.
“They got a level of evidence inside the organization that is going to be hard to deny,” said Rogers, noting information from
an undercover agent, informants, as well as bugged phone and intercepted data conversations.
“It looks like the evidence was overwhelming, and they got to a point where they said, OK, we don’t want to take the chance
that they actually flip the switch here, and went in and did it.
"We should all be concerned," he added. "We really need to talk about how this stuff needs to be tamped down."
The criminal charges were filed six days after another so-called boogaloo boy, Madison Heights resident Eric Allport, 43,
was killed during a shootout with FBI agents at a Madison Heights restaurant.
Allport is not believed to have been involved with any of the people accused of conspiring to kidnap Whitmer or violently
overthrow the government, a law enforcement source told The News.
Allport died of multiple gunshot wounds during a shootout with FBI agents in the parking lot of a Texas Roadhouse
at about 4:30 p.m. Friday near John R and 12 Mile.
He had a violent, turbulent life. Allport served an 11-year prison sentence for shooting at two police officers, was a
boogaloo adherent and played a minor role in the infamous Ruby Ridge standoff in 1992, one of the darkest chapters in
federal law enforcement history.
The 'Watchmen'
Separately, Nessel on Thursday announced state charges against the seven other individuals pursuant to the state's anti-
terrorism act, "all of whom are in custody and linked to the militia group Wolverine Watchmen."
In total, 19 state felony charges for firearms and terror-related acts were filed by Nessel against seven individuals known to
be members or associates of the Wolverine Watchmen.
The individuals include Paul Bellar, 21, of Milford; Shawn Fix, 38, of Belleville; Eric Molitor, 36, of Cadillac; Michael Null,
38, of Plainwell; William Null, 38, of Shelbyville; Pete Musico, 42; and Joseph Morrison, 26, who live together in Munith.
The suspects are alleged to have called on the groups’ members to identify the home addresses of law enforcement officers
in order to target them; made threats of violence to instigate a civil war leading to societal collapse; and engaged in the
planning and training for an operation to attack the state Capitol building and kidnap government officials,
including Whitmer, according to a statement from Nessel's office.
“There has been a disturbing increase in anti-government rhetoric and the re-emergence of groups that embrace extremist
ideologies,” Nessel said.
“These groups often seek to recruit new members by seizing on a moment of civil unrest and using it to advance their
agenda of self-reliance and armed resistance. This is more than just political disagreement or passionate advocacy, some of
these groups’ mission is simply to create chaos and inflict harm upon others.”
Musico and Morrison live in Munith in a rural area of Jackson County. Signs saying “private property” and “no trespassing”
were in their home’s front yard Thursday evening. What appeared to be a Confederate flag could also be seen near the
home, which was located along a wooded roadway and a river.
Pam Karshnock of Munith lives next door to the property. She said she regularly hears the sound of gunfire that disrupt her
quiet evenings in the country.
“For months, there’s been gunfire almost daily,” Karshnock said.

“I’m still shaking, knowing that it was that close to me,” she added, “just thinking back to the times I almost approached
them to ask them to stop.”
A group of individuals was visible Thursday outside of the home. They appeared to be moving things from the residence
into a trailer that was parked outside. A stack of tires, cars and an RV were all located near the home.
The federal investigation dates to early this year when the FBI learned through social media that individuals were
discussing the violent overthrow of several state governments and law enforcement.
In June, Croft, Fox and 13 others from multiple states held a meeting in Dublin, Ohio, near Columbus, according to the
government.
Those present included an FBI confidential source who recorded the meetings. The source has been paid $8,600.
“The group talked about creating a society that followed the U.S. Bill of Rights and where they could be self-sufficient,” the
FBI agent wrote.
“They discussed different ways of achieving this goal from peaceful endeavors to violent actions. At one point, several
members talked about state governments they believed were violating the U.S. Constitution, including the government of
Michigan and Whitmer.
“As part of that recruitment effort, Fox reached out to a Michigan-based militia group,” the agent added.
'We gotta do something'

The militia group is not identified in the court filing, but members periodically meet in remote areas of the state for
firearms training and tactical drills.
The FBI was already tracking the militia in March after a local police department learned members were trying to obtain
addresses of local law-enforcement officers, the FBI agent wrote.
“At the time, the FBI interviewed a member of the militia group who was concerned about the group’s plans to target and
kill police officers, and that person agreed to become a (confidential source),” the agent wrote
In late June, Fox posted on Facebook a video in which he complained about the state’s judicial system and COVID-19
restrictions on gyms operating in Michigan.
“Fox referred to Governor Whitmer as ‘this tyrant b----,’ and stated, ‘I don’t know, boys, we gotta do something,” according
to the court affidavit. “You guys link with me on our other location system, give me some ideas of what we can do.”
The affidavit describing the thwarted plot reports two occasions when the alleged conspirators conducted surveillance on
Whitmer's vacation home — during the day on Aug. 29 and at night over the weekend of Sept. 12-13.
Fox and two other individuals located Whitmer's home and shot video and took photos of it as they drove by on Aug. 29.
One of the individuals then calculated how long it would take local and state police to respond to an incident at the
property.
"We ain't going to let 'em burn our f---in' state down. I don't give a f--- if there's only 20 or 30 of us, dude, we'll go out there
and use deadly force," said Fox during the surveillance operation, according to an audio recording quoted in the affidavit.
In an encrypted group chat, Garbin later suggested that demolishing a nearby bridge would hamper a response by police to
the governor's home, according to the court filing.
The September surveillance followed a field exercise at Garbin's property in Luther, Michigan, where the conspirators
allegedly detonated an improvised explosive device made from a commercial firework wrapped in shrapnel "to test its anti-
personnel effectiveness."
After a briefing on the plan to kidnap Whitmer, a larger group of the men drive from Luther to the vacation home in three
separate vehicles while armed.
They stopped to check the underside of a highway bridge to check for places to attach an explosive charge, and discussed
detonating explosive devices to divert law enforcement officers from the area of the governor's home.
“She f---ing goddamn loves the power she has right now,” Fox said during the surveillance operation, according to the
affidavit. “I can see several states takin’ their f---in’ tyrants. Everybody takes their tyrants.”
The group later returned to Garbin's property, where they discussed destroying Whitmer's vacation home. "Kidnapping,
arson, death, I don't care," Franks said, according to the affidavit.
The group made plans to conduct a final training exercise in late October but then decided that was too close to the
November election, so they moved forward with raising money to procure explosives and other supplies including an
800,000-volt taser. It's unclear when the kidnapping was planned for.
The 'lightning rod'

FBI and state police executed the arrests of several of the conspirators when they were meeting on the east side of the state
to pool funds for explosives and exchange tactical gear, Birge said Thursday.
Garbin and Franks appeared in federal court shortly after Thursday's news conference announcing the charges in the
alleged kidnapping plot.
In a brief court hearing in Grand Rapids that took about five minutes, Garbin, 24, and Franks told a judge that they would
need court-appointed attorneys based on their financial status. The two also were given their next court date of Oct. 13 for a
bond hearing. The pair will remain in the custody of the U.S. Marshals.
The criminal case comes after months of state restrictions on travel and business during the COVID-19 pandemic.
“The lockdown has been a lightning rod for anti-government extremists in this country, and Gov. Whitmer has been on the
forefront of their targeting,” said Seamus Hughes, deputy director of George Washington University’s Program on
Extremism.
Senate Majority Leader Mike Shirkey, R-Clarklake, tweeted Thursday afternoon: "A threat against our Governor is a threat
against us all."
"We condemn those who plotted against her and our government," he said. "They are not patriots. There is no honor in
their actions. They are criminals and traitors, and they should be prosecuted to the fullest extent of the law."
House Speaker Lee Chatfield tweeted that violence "has no place in politics."
"Ever. It’s never a solution to disagreements. The people who targeted @GovWhitmer and police officers are un-American.
Justice should be swift and severe. It’s time to send a message that violence will not be tolerated," he wrote.
U.S. Rep. Paul Mitchell, a Republican and Whitmer critic, also condemned the threats against her and praised law
enforcement. "I wish Governor Whitmer and her family well."
In recent weeks, the state-owned Michigan governor's residence received security upgrades, including the construction of a
new perimeter fence.
The "perimeter security and other safety upgrades" were planned out last year, Whitmer spokeswoman Tiffany Brown said
in early September. They were scheduled to start in the early spring but were delayed until recently because of the
pandemic, she said.
The cost for the "maintenance" projects at the Lansing residence, which was recommended by the Michigan State Police
and the state Department of Technology, Management and Budget, was about $1.1 million, Brown said.
"As a matter of practice, we’re constantly reviewing security protocols and adjusting as needed," said Shanon Banner,
spokeswoman for the Michigan State Police, in early September.
"We don’t comment on specific threats against the governor nor do we provide information about security measures."
Staff Writers Craig Mauger, Beth LeBlanc, Francis X. Donnelly and Christine Ferretti contributed.
EXHIBIT 4
NEWS HITS
Gov. Whitmer becomes target of

dozens of threats on private
Facebook groups ahead of armed
rally in Lansing
Posted
By Steve Neavling
on Mon, May 11, 2020 at 9:38 am
Shutterstock
Dozens of angry Michiganders, fueled by conspiracy theories and

disinformation about the coronavirus, are promoting violence and mobilizing
armed rallies against Gov. Gretchen Whitmer on Facebook, in violation of the
social media company’s policies.
Metro Times gained access to four private Facebook groups that can only be
seen by approved members. The pages, which have a combined 400,000
members, are filled with paranoid, sexist, and grammar-challenged rants, with
members encouraging violence and flouting the governor’s social-distancing
orders.
On Sunday, after being contacted by Metro Times, Facebook removed one of
the groups, Michigan United for Liberty, and deleted posts on others for
violating the company’s policy against inciting violence. Facebook announced
last month that it will remove groups and events that encourage people to defy
social-distancing measures. Facebook also is investigating the other groups.
“We removed one group for violating our policies and will remove any other
violations as we continue our review,“ a Facebook spokesperson tells Metro
Times.
Assassinating Whitmer is a common theme among members of the groups.

Dozens of people have called for her to be hanged.
“We need a good old fashioned lynch mob to storm the Capitol, drag her
tyrannical ass out onto the street and string her up as our forefathers would
have,” John Campbell Sr. wrote in a group called “People of Michigan vs.
Gov. Gretchen Whitmer,” which had nearly 9,000 members as of Monday
morning.
Steve Doxsie had the same idea: “Drag that tyrant governor out to the front
lawn. Fit her for a noose.”
“Either President Trump sends in the troops or there is going to be a midnight

lynching in Lansing soon,” Michael Smith chimed in.
Others suggested she be shot, beaten, or beheaded.
“Plain and simple she needs to eat lead and send a statement to the rest of the
democrats that they are next,” James Greena, of Fennville, wrote.
Russel Christopher Rozman said, “She needs her ass beat. Most of these
politicians need a good ass whooping. Just. Punch there lights out.”
When someone suggested the guillotine, Thomas Michael Lamphere responded,

“Good ol’ fashioned bullets work better, but I like the enthusiasm.”
“Wonder how long till she’s hit with a shotgun blast,” Chris Parrish wrote.
Matthew Woodruff had another idea: “Can we please just take up a collection
for an assassin to put that woman from Michigan down,” he asked.
The comments are especially disturbing because some of those calling for
violence are planning to attend an armed rally at the Capitol building in
Lansing on Thursday. On April 30, hundreds of protesters, some of them
heavily armed, descended on the state Capitol during the “American
Patriot Rally,” and there were armed protesters as part of “Operation Lansing”
on April 15. A two-day rally is also planned for the weekend.
“We could’ve taken over the capital last time if we wanted,” Chris Coffey said.
“This was just a display. Next time won’t be!”
“If she thinks the last protest was bad she hasn't seen anything yet,”
DonnaCookie Grady warned.
“We haven’t had any bloodshed yet, but the populous is counting to three, and
the other day was two,” Dave Meisenheimer wrote in Michiganders Against
Excessive Quarantine, which has more than 385,000 members. “Next comes
watering the tree of liberty with the blood of tyrants.”
Gordon Chapman says he’s going to the Thursday rally and hopes
demonstrators are “armed to the teeth.”
“Voting is too late we need to act now,” Chapman said.
The potential for violence prompted some public officials, including Whitmer
and Attorney General Dana Nessel, to promote banning firearms from the
Capitol building.
“There are legislators who are wearing bulletproof vests to go to work,”

Whitmer told ABC News last week. "No one should be intimidated by someone
who's bringing in an assault rifle into their workplace.”
At 11 a.m. Monday, the bipartisan Michigan State Capitol Commission

plans to discuss a firearms ban. In a letter to the six-member commission,
Nessel told the panel that it has the legal authority to ban guns from the
Capitol.
Nessel’s support of the ban drew anger on another private Facebook page,
Whitmer Recall Movement, which has more than 3,500 members.
“We are sharpening a stick for you Dana,” Pete Scudamore wrote.
“DO you want me to bring the rope, shouldn’t be too hard to find a good tree,”
Russell Kynn asked.
Nessel’s spokeswoman Kelly Rossman-McKinney says the attorney general’s
office will not tolerate threats.
“We take every threat seriously — and, of course, we are doing everything we
can to minimize threats,” Rossman-McKinney tells Metro Times.
In January, Metro Times chronicled another Facebook page that was rife
with sexism, Islamophobia, and threats against Whitmer and other politicians.
Whitmer responded with a letter to Facebook.
"As a lawyer who respects the First Amendment right to freedom of speech and
expression, I realize there is only so much purview media platforms have for
the content posted by their users," Whitmer wrote. "However, better
enforcement of Facebook's own community standards — where 'attacks' are
defined as, 'violent or dehumanizing speech, statements of inferiority, or calls
for exclusion or segregation' — this election cycle is needed now more than
ever. Mine is not a singular ask."
The private Facebook groups are a hub for far-fetched conspiracy theories and
disinformation, reinforcing people’s fears and anger. For some, the state’s stay-
at-home order is an unconstitutional plot by liberals to strip residents of their
freedoms and steal the election from President Trump. Some insist the
coronavirus is a hoax, and others believe it’s a manmade disease designed to
enrich billionaires and force vaccines on the masses.
One of the most popular and influential conspiracies is featured in

“Plandemic,” a 26-minute documentary-style video with ominous music that
racked up millions of views in the past week. The video features a widely
refuted researcher named Judy Mikovits, who spins a baseless tale about
wealthy people intentionally spreading the coronavirus to boost vaccination
rates. She also warns against wearing masks, saying they can exacerbate viral
symptoms. Facebook, YouTube, and Instagram have been removing the video,
saying the false claims pose a threat to public health.
Not surprisingly, many members of the groups say they will never wear a mask
because they believe they are unsafe or represent tyranny.
Birbot Arvo suggested he would resort to violence if police approached him

about wearing a mask.
“Cop or not. You come at me strong about a mask and I will break your face,”
Arvo said.
Nathan Silver declared he “will not submit to their cultural Marxism.”
“I refuse to wear one,” wrote Rich T. Tyra II. “They cause more problems than
they prevent and its a sign of being silenced and submission and its training
for the forced vaccinations.”
To Melody DeCaire, wearing a mask is useless because the coronavirus isn’t

real.
“theres no such thing as Covid,” she insisted. “Its radation [sic] poisoning
coming from the 5g,” referring to the conspiracy theory that 5G towers
cause the illness.
As it struggles to stem the spread of disinformation, Facebook has become the

go-to platform for anti-government talking points.
In an April 20 interview with ABC News’ Good Morning

America, Facebook CEO Mark Zuckerberg said that the “stuff that people are
saying that is false around a health emergency like this can be classified as
harmful misinformation that has a risk of leading to imminent danger, and
we’ll take that content down.”
When reached for comment, Facebook users who posted comments about
violence said they were merely exercising their right to free speech.
Thomas Allan Morse, who wrote, “Army 11 bravo vet here ready to rumble. Two
to the chest one to the head,” responded that he “earned” the right to exercise
free speech because he served in the military.
“Did you serve this country in the armed forces? Let alone ground combat?”
Morse asked Metro Times via Facebook Messenger. “I earned my 1st
ammendment (sic).” ‘
He declined to say whether he planned to attend Thursday’s rally.
Sexism also is rampant among members of the private groups.
“I'm dying here a woman talking strategy is like a man explaining what its like
to go through menopause. PLEASE,” Eric John Mayer said.
James Davis added, “Men advanced civilization from the days of banging two
rocks together. I don’t doubt there are smart women out there. However, the
smart women are busy doing things like having families, not corrupting
themselves with power and ruining people’s lives.”
Facebook users called Whitmer a “Nazi,” “spawn of the devil,” “wicked witch,”
“arrogant facist [sic] pig,” “Gestapo Gretchen,” “tyrant,” “Soros puppet,” and
“baby killer tyrant.”
For Patricia Folk, threats are the logical next step to regaining her freedoms.
“I honestly believe that the only way that Congress and the Senate are going to
start listening to ‘We the People’ are threats,” Folk wrote on one of the private
pages. “They no longer respect the voter, or the people they represent. Maybe a
tarred and feathered election official, may wake them up.”
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EXHIBIT 5
8/19/2021 ‘Tyrants Get The Rope’: Small anti-Whitmer protest rocks Capitol, reporter hit by gun ⋆ Michigan Advance
CIVIL RIGHTS COVID-19 HEALTH CARE HEALTH POLICY RACE EQUITY

STATE GOVERNMENT WOMEN'S RIGHTS
‘Tyrants Get The Rope’: Small anti-

Whitmer protest rocks Capitol, reporter
hit by gun
BY: ANNA LIZ NICHOLS - APRIL 30, 2020 4:26 PM
     

https://michiganadvance.com/2020/04/30/tyrants-get-the-rope-small-anti-whitmer-protest-rocks-capitol-reporter-hit-by-gun/ 1/13
 Conservative protest at the Capitol against Gov. Gretchen Whitmer, April 30, 2020 | Anna Liz
Nichols
Updated, 6:38 p.m. with comments from Chat eld’s spokesman
fi
A couple hundred right-wing protestors chanting “Lock her up” and
“Heil Whitmer” spilled into the Michigan state Capitol Thursday
after holding a rally on the Capitol steps, even though the building
is currently closed for tours and events to stop the spread of
COVID-19.
While jammed outside the House chamber, one protestor carrying a

long gun turned and hit this reporter in the head with a ri e. The
fl
incident did not appear intentional, but was reported to the
Michigan State Police (MSP). Lt. Brian Oleksyk said MSP arrested
one protestor for assaulting another protestor at the rally.
Anna Liz Nichols

@annaliznichols
Just got slammed in the head by a protestor’s rifle.
There is no care for safety or social distancing in the

crowd
12:43 PM · Apr 30, 2020 from Lansing, MI
18.2K See the latest COVID-19 information on Twitter
Tweet your reply
Gideon D’Assandro, spokesman for House Speaker Lee Chat eld

fi
(R-Levering), noted the Capitol “is currently closed to functions,
including group events, meetings and tours, etc. But the public is
still allowed to view meetings of the Legislature, so they are allowed
in when the House or Senate is in session.” He declined to comment
on the incident with the reporter until the speaker talks with
personnel onsite. A spokesperson for Senate Majority Leader Mike
Shirkey (R-Clarklake) did not return a request for comment from
the Advance.*
Many of the shouts from speakers and protestors were directed at

Democratic Gov. Gretchen Whitmer to end what they said was
“tyrannical rule” and stop the stay-home order during the pandemic
that’s sickened more than 40,000 and killed more than 3,700 in
Michigan. The order is in effect through May 15.
Signs ranging from profane and misogynistic (“Tyranny Bitch”) to

violent (“Tyrants Get The Rope”) were raised at the event. A
speaker at the protest acknowledged the more than a dozen militia
members at the Capitol, saying that they were there for security to
protect protestors. Several speakers discussed conspiracy theories
about the disease.
Conservative protest Conservative protest Conservative protest

at the Capitol against at the Capitol against at the Capitol against
Gov. Gretchen Gov. Gretchen Gov. Gretchen
Whitmer, April 30, Whitmer, April 30, Whitmer, April 30,
2020 | Anna Liz 2020 | Anna Liz 2020 | Anna Liz
Nichols Nichols Nichols

Conservative protest Conservative protest Many anti-lockdown

at the Capitol against in the Capitol against and pro-Trump rallies
Gov. Gretchen Gov. Gretchen featured QAnon signs
Whitmer, April 30, Whitmer, April 30, and slogans like this
2020 | Anna Liz 2020 | Anna Liz popular one about
Nichols Nichols accused child
trafficker Jeffrey
Epstein, pictured next
to gallows, at a
conservative protest
at the Capitol against
Gov. Gretchen
Whitmer, April 30,
2020 | Anna Liz
Nichols

Conservative protest Conservative protest Police and sergeants-

at the Capitol against at the Capitol against at-arms try to keep
Gov. Gretchen Gov. Gretchen order at the
Whitmer, April 30, Whitmer, April 30, conservative protest
2020 | Anna Liz 2020 | Anna Liz at the Capitol against
Nichols Nichols Gov. Gretchen
Whitmer, April 30,
2020 | Anna Liz
Nichols
Conservative protest Conservative protest

at the Capitol against at the Capitol against
Gov. Gretchen Gov. Gretchen
Whitmer, April 30, Whitmer, April 30,
2020 | Anna Liz 2020 | Anna Liz
Nichols Nichols
Speakers called out the Legislature for letting Whitmer’s stay-home

order stand, even though many legal experts don’t believe
lawmakers have the authority to do overturn it.
The protest took place as the GOP-led Legislature prepared to go

forward with legal action against Whitmer and appease
conservative protestors and interest groups by trying to limit her
orders.
Gov. Gretchen Whitmer’s approval rating for handling COVID-19

has remained high throughout the crisis, with most recent
Navigator polling taken April 22 through Tuesday showing her at
65% approval. President Donald Trump is at 43% approval in
Michigan for his COVID-19 response.
As for measures to stop COVID-19, polls have consistently found

support across party lines. A Politico/Morning Consult poll found
81% of voters believe we “should continue to social distance for as
long as is needed to curb the spread of coronavirus, even if it means
continued damage to the economy.” A super-majority of both
parties agreed, with 89% of Democrats and 72% of Republicans on
board.
COVID-19 cases surpass 20K, Detroit sees

slowdown in cases
The state is reporting that the number of COVID-19 cases has reached
20,346, an increase of 1,376 since Tuesday. A statewide coronavirus hotline
is open 7 days a week from 8 a.m. to 5 p.m. at 1-888-535-6136.
Information can be found on the DHHS website or the U.S. Centers for
Disease Control (CDC) and Prevention … Continue reading
Michigan Advance
More than 40 states adopted stay-home orders to combat COVID-

19, which has spread to more than 1 million people nationwide and
killed almost 62,000.
Similar small protests have taken place in other states, many of

which were organized by well-connected conservative groups like
Freedom Works, which also funded tea party events against former
President Obama.
Freedom was a major theme as protestors staged a smaller version

of Operation Gridlock, an event from earlier this month where
more than 3,000 people gathered to protest the stay-home order,
but greatly resembled a Trump rally.
Both rallies featured Confederate flags and swastikas, with

protestors chanting “Heil Whitmer” and calling her executive
orders a violation of their civil liberties.
Like in Operation Gridlock, social distancing and mask usage was

minimal. This time, most protestors did not stay in their cars.
Oleksyk said 600 to 800 people gathered outside for the rally and
police let 275 individuals into the Capitol. Short of the one arrest,
Oleksyk said the event was a peaceful protest.
Michigan reaches more than 41K COVID-19

cases, 3,700 deaths
There are now 41,379 positive cases of COVID-19 in Michigan as of 3 p.m.
Thursday, although state officials believe the actual number of cases is
much higher. This is an additional 980 cases since Wednesday. A statewide
coronavirus hotline is open 7 days a week from 8 a.m. to 5 p.m. at 1-888-
535-6136. Information can … Continue reading
Michigan Advance
“Everything else has been peaceful. People are behaving and we’re
creating a safe environment for them to practice their freedom of
speech. Other than that one arrest so far everything’s been good,”
Oleksyk said.
Outside the doors of the House, the majority of protestors that

entered the Capitol gathered seeking entry to the session. The
crowd hurled insults at Capitol o cials and police calling them
ffi
“bastards” and “cowards.”
Republicans state House candidate Michelle Gregoire, who is

running against state Rep. Jim Haadsma (D-Battle Creek), returned
to the Capitol after a confrontation with House Chief Sergeant
David Dickson on Wednesday. Reporter Ali Kasben from Gongwer
noted Gregoire’s videos Thursday.
Ali Kasben
@kasbenal
Even though the protester who was thrown out of the

House gallery yesterday asked for Chief Sergeant David
Dickson's name so she could press charges, she keeps
calling him "the black guy" in her videos from today an
yesterday.
12:50 PM · Apr 30, 2020
29 5 Share this Tweet
Tweet your reply
A group focused on the sergeants, who wear red blazers, called them
“red coats” and declared America has fought red coats before.
Dozens of armed individuals stood in front of the House doors

yelling, “Let us in” even though the public is not allowed on the
oor. Over in the Senate, 22 people were allowed in the gallery.
fl
This included a few people with large guns.
Advance Editor Susan J. Demas contributed to this story.
REPUBLISH
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site. Please see our republishing guidelines for use of photos and graphics.
ANNA LIZ NICHOLS 

Anna Liz Nichols is a former Michigan Advance intern. She is a Michigan
State University graduate who has reported for several publications,
including MLive and Michigan State University’s award-winning student
paper, the State News, where she covered the many tendrils of the Larry
Nassar sexual abuse scandal.
MORE FROM AUTHOR
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and white… just 2 other…
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EXHIBIT 6
8/19/2021 In Michigan, a Dress Rehearsal for the Chaos at the Capitol on Wednesday - The New York Times
https://www.nytimes.com/2021/01/09/us/politics/michigan-state-capitol.html
In Michigan, a Dress Rehearsal for the Chaos at the Capitol on Wednesday

In April, armed protesters crowded into the State Capitol in Michigan. Frightened lawmakers saw echoes of that day in
Wednesday s deadly riot at the Capitol in Washington.
’
By Kathleen Gray
Jan. 9, 2021
LANSING, Mich. — First came the “Unlock Michigan” protest. More than 1,000 cars, many draped with flags supporting
President Trump, drove around the Michigan State Capitol, blaring their horns and decrying Gov. Gretchen Whitmer’s
coronavirus lockdown orders. Hundreds of others, many armed with military-style weapons, milled about on the lawn.
Two weeks later, on April 30, the dissent escalated. Gun-toting protesters rushed the State Capitol, not long after Mr.
Trump tweeted “Liberate Michigan.” They demanded entry into the House of Representatives’ chamber, chanting “Let Us
In.”
Subscribe to The Times to read as many articles as you like.

nytimes.com/subscription
https://www.nytimes.com/2021/01/09/us/politics/michigan-state-capitol.html 1/2
8/19/2021 In Michigan, a Dress Rehearsal for the Chaos at the Capitol on Wednesday - The New York Times
https://www.nytimes.com/2021/01/09/us/politics/michigan-state-capitol.html
In Michigan, a Dress Rehearsal for the Chaos at the Capitol on Wednesday

In April, armed protesters crowded into the State Capitol in Michigan. Frightened lawmakers saw echoes of that day in
Wednesday s deadly riot at the Capitol in Washington.
’
By Kathleen Gray
Jan. 9, 2021
LANSING, Mich. — First came the “Unlock Michigan” protest. More than 1,000 cars, many draped with flags supporting
President Trump, drove around the Michigan State Capitol, blaring their horns and decrying Gov. Gretchen Whitmer’s
coronavirus lockdown orders. Hundreds of others, many armed with military-style weapons, milled about on the lawn.
Two weeks later, on April 30, the dissent escalated. Gun-toting protesters rushed the State Capitol, not long after Mr.
Trump tweeted “Liberate Michigan.” They demanded entry into the House of Representatives’ chamber, chanting “Let Us
In.”
Subscribe to The Times to read as many articles as you like.

nytimes.com/subscription
https://www.nytimes.com/2021/01/09/us/politics/michigan-state-capitol.html 2/2
EXHIBIT 7
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Protester explains doll, noose demonstration at Capitol,

wants to gift props to Trump
Updated: May. 18, 2020, 8:17 p.m. | Published: May. 18, 2020, 5:48 p.m.
28
Skirmish at Michigan Capitol over doll with a noose around neck
T 2,834
shares
By Samuel Dodge | [email protected]
The controversial protester who brought a symbolic doll with a noose wrapped around its neck to a
demonstration at the state Capitol last week isn’t necessarily a coronavirus denier, he said.
James Chapman said Monday that his real beef at Thursday’s protest in Lansing was two-fold: restrictions on
public gatherings - which he argues violate the First Amendment, and Gov. Gretchen Whitmer’s unilateral
assertion of emergency powers.
Advertisement
The Van Buren Township native sought to make his point by hanging a brunette doll from a noose at the end of
his 13-star Betsy Ross flag and a fishing rod.
He has a criminal history and wants to be a Michigan lawmaker. Thursday, he carried a doll in a noose to
the state Capitol.
The noose is “one size fits all” for anyone not standing up to Whitmer and her “tyranny,” the Republican
candidate for the 21st state House district seat said Monday. That includes RINOs, or Republicans in Name Only,
he said.
News you need. Stories you care about.

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“The Republicans need to be cleaned out,” Chapman said. “I would like to give some political symbolism here.
That noose is one size fits all, and we will kick your RINO butt out of there... This is the reason Gretchen Whitmer
has not been called out on the carpet (the Capitol floor) by the legislature.”
Advertisement
Chapman feels a deep connection to the Revolutionary War that’s inspired him to research the history of a
millstone on the Huron River that may have stood on the Delaware River near Valley Forge back in the 1700s. It’s
also led him led him to take on an aggressive style of protest that includes depicting violence against political
leaders.
“The First Amendment protected (these) forms of protest. It’s something the original patriots did,” he said. “They
not only hung them in effigy, but they burned them in effigy.”
He accused Whitmer of violating First Amendment protections of public and religious assembly. She banned
public meetings between anyone not in the same household in Executive Order 2020-42. Places of worship are
public meetings between anyone not in the same household in Executive Order 2020 42. Places of worship are
exempt from punishment under Executive Order 2020-11.
Churches sue Whitmer, claim coronavirus orders hinder religious gatherings despite exceptions
Advertisement
On May 14, Chapman attended a protest organized by the group Michigan United for Liberty against the state’s
stay-home order, carrying the doll by a noose just as he did at an April 15 rally. He told MLive on Monday that the
doll was meant to represent Whitmer.
A brief fight broke out when a female protester attempted to take the doll. Lt. Brian Oleksyk public information
officer for the Michigan State Police said troopers spoke the man after the incident and that no one involved was
injured or arrested.
Erica Pettinaro, a co-founder of Michigan United for Liberty, denounced Chapman’s demonstration, as did
Michigan Republican Party Chair Laura Cox.
“Our organization does not agree with or encourage violent threats or actions of any kind,” Pettinaro said, adding
that the organization is non-partisan. “We have made several statements in regards to keeping our events
peaceful.”
peaceful.
The scuffle with the female protester led to three violations of his personal rights, Chapman said.
“She tried to violently destroy my First Amendment prop,” he said. “Number one, (That’s) a violation of my First
Amendment rights. Number two, malicious destruction of property. Number three was larceny from a person,
because they stole my axe.”
The axe, which he named Paul Bunyan, is a tool of his tree-cutting service in the Belleville area, he said.
Chapman has had several run-ins with the criminal justice system over the last few decades, according to law
enforcement records and local news reports reviewed by MLive.
In 1990, Chapman was found guilty of assault with intent to do great bodily harm less than murder and a firearms
charge and was sentenced to three to 10 years in prison, according to Michigan Department of Corrections
records. He was also put on probation for a stalking charge in 2015.
Chapman was sentenced to six months in jail in 2018 after being found guilty of resisting a police officer,
according to The Belleville-Area Independent. A Michigan Court of Appeals opinion summarized the incident,
noting Chapman argued with and attempted to stab an acquaintance at a house in Van Buren Township, and
eventually dove into Belleville Lake in an attempt to evade police.
The criminal record, Chapman said, makes him the most-qualified candidate for the state House Judiciary
Committee, should he win the 21st district.
He has a plan to wipe that record clean, however. He intends to visit President Donald Trump during his
scheduled visit to the Ford Rawsonville manufacturing plant in Ypsilanti Township on Thursday.
Trump planning Thursday tour of Michigan Ford plant where ventilators, PPE are made
In exchange for a clean record, he plans to give Trump the fishing rod and noose as a gift.
Advertisement
READ MORE
Complete coverage at mlive.com/coronavirus
Monday, May 18: Latest developments on coronavirus in Michigan
PREVENTION TIPS
In addition to washing hands regularly and not touching your face, officials recommend practicing social
distancing, assuming anyone may be carrying the virus.
Health officials say you should be staying at least 6 feet away from others and working from home, if possible.
Use disinfecting wipes or disinfecting spray cleaners on frequently-touched surfaces in your home (door handles,
faucets, countertops) and carry hand sanitizer with you when you go into places like stores.
Michigan Gov. Gretchen Whitmer has also issued an executive order requiring people to wear face coverings over
their mouth and nose while inside enclosed, public spaces.
Read all of MLive’s coverage on the coronavirus at mlive.com/coronavirus.
Additional information is available at Michigan.gov/Coronavirus and CDC.gov/Coronavirus.
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EXHIBIT 8
'Credible Threats' to Kill Gov. Gretchen Whitmer Lead to Charges, Police Say - The New... Page 1 of 2
https://www.nytimes.com/2020/05/15/us/virus-michigan-whitmer-threats.html
Man Faces Terrorism Charge After

Threatening to Kill Michiganʼs Governor,
Officials Say
Robert S. Tesh made “credible threats” via social media messages to kill Gov. Gretchen Whitmer
and Michiganʼs attorney general, Dana Nessel, the authorities said.
By Christopher Mele
Published May 15, 2020 Updated Oct. 9, 2020
A Detroit man has been charged with threatening to kill Gov. Gretchen Whitmer of Michigan and
the state attorney general, Dana Nessel, prosecutors said on Friday.
The man, Robert S. Tesh, 32, was charged with false report of threat of terrorism, a felony. Mr. Tesh
relayed what prosecutors called “credible threats” to an acquaintance, using more than one social
media messenger on April 14, First Lt. Mike Shaw, a spokesman for the Michigan State Police, said
on Friday.
He said that the authorities had received a tip about the messages and that Mr. Tesh was arrested
later that day at his home. Lieutenant Shaw declined to say which social media platforms were used.
If convicted, Mr. Tesh could face up to 20 years in prison.
The threats were not specifically related to the governor’s stay-at-home orders issued in March to
stem the spread of the coronavirus, Maria Miller, a spokeswoman for the Wayne County
Prosecutor’s Office, said on Friday. She declined to provide more details, saying they would be
revealed in court.
The governor has been the target of demonstrators, some of them armed, who have crowded the
State Capitol in Lansing to oppose the restrictions. Ms. Whitmer, a first-term governor, has been
called out by President Trump as one of the governors standing in the way of reopening the country
and slowing a return to economic activity in the face of the pandemic.
Robert S. Tesh
Detroit Police Public Safety Office, via
Associated Press
https://www.nytimes.com/2020/05/15/us/virus-michigan-whitmer-threats.html 8/20/2021
'Credible Threats' to Kill Gov. Gretchen Whitmer Lead to Charges, Police Say - The New... Page 2 of 2
“The alleged facts in this case lay out a very disturbing scenario,” Kym L. Worthy, the prosecutor
for Wayne County, which includes Detroit, said in a statement. “We understand that these times can
be stressful and upsetting for many people.”
She said the authorities “will not and cannot tolerate threats like these” against public officials who
are carrying out their duties “as efficiently as they can.”
As for what made the threats “credible,” Lieutenant Shaw said, “You can’t make threats against
anybody — members of the public, a member of a school board or about shooting up a Walmart or
one of our elected officials.”
Mr. Tesh was arraigned on April 22, posted $50,000 bond and remains on a “GPS tether,” officials
said.
“It is never acceptable to make threats of violence to anyone, but our officeholders as well,” the
governor said on Friday, adding that officials take threats “very seriously,” The Associated Press
reported.
A representative for the attorney general could not be immediately reached on Friday. Neither Mr.
Tesh nor his lawyer, Jonathan Simon, could be reached.
Susan Beachy contributed research.
https://www.nytimes.com/2020/05/15/us/virus-michigan-whitmer-threats.html 8/20/2021
EXHIBIT 9
8/20/2021 Michigan man charged with threatening to kill Biden, Pelosi and Whitmer | Reuters
Discover Thomson Reuters Directory of sites Login Contact Support
World Business Markets Breakingviews Video More
U.S. LEGAL NEWS MARCH 16, 2021 / 6:10 PM / UPDATED 5 MONTHS AGO
Michigan man charged with threatening to kill Biden, Pelosi

and Whitmer
By Reuters Sta 3 MIN READ
ff
(Reuters) - Michigan state prosecutors have charged a 21-year-old man with threatening to kill
President Joe Biden, House Speaker Nancy Pelosi and Michigan Governor Gretchen Whitmer, all
Democrats, saying he claimed to “be the catalyst” for an American revolution, o cials said on Tuesday.
ffi
https://www.reuters.com/article/us-michigan-whitmer/michigan-man-charged-with-threatening-to-kill-biden-pelosi-and-whitmer-idUSKBN2B831H 1/4
Slideshow ( 3 images )
Whitmer previously had been the target of right-wing militia extremists who plotted to kidnap her ahead
of last November’s election, according to U.S. prosecutors.
The new and separate charges come as U.S. law enforcement officials including FBI Director Christopher
Wray have warned of the growing threat of homegrown violent extremism in the United States.
The office of Michigan Attorney General Dana Nessel on Monday charged Joshua Docter, 21, of Holland,
Michigan, with threatening terrorism and using a computer to commit a crime. Each count carries a
sentence of up to 20 years in prison.
The suspect turned himself in on Monday and faced a judge on Tuesday, Nessel’s office said in a
statement.
A lawyer for Docter could not immediately be identified.
The FBI, which initiated the investigation, received a tip that Docter posted threats on the social media
site iFunny, and the case was later taken over by Michigan State Police, the statement said.
“Michigan Attorney General Dana Nessel has charged a Holland man with crimes for making death
threats against President Joe Biden, U.S. Speaker of the House Nancy Pelosi and Michigan Gov.
Gretchen Whitmer,” the statement said.
“In those posts, Docter stated he would use a gun to shoot and kill the elected officials and would ‘be the
catalyst’ for a new American revolution. Docter also had information on how to make a bomb and where
to find the necessary materials on his smart phone,” it said.
In the previous plot against Whitmer, federal o cials arrested and charged six men here with conspiring
ffi
to abduct her from her vacation home last summer. One of them has pleaded guilty.
Eight other men accused of taking part in the plot have been charged in Michigan state court with
domestic terrorism.
Investigators linked the suspects to an anti-government militia group based in Michigan called the
Wolverine Watchmen.
Reporting by Daniel Trotta; editing by Grant McCool
Our Standards: The Thomson Reuters Trust Principles.
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All quotes delayed a minimum of 15 minutes. See here for a complete list of exchanges and delays.
© 2021 Reuters. All Rights Reserved.
EXHIBIT 10
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EXHIBIT 11
8/20/2021 Michigan GOP chair calls top Democratic women 'witches' and quips about assassination of Republican congressmen - CNNPolitics
LIVE TV
HAPPENING NOW
The Defense Department holds a brie ng on the situation in Afghanistan
fi
Michigan GOP chair calls top Democratic women 'witches' and quips about
assassination of Republican congressmen
By Veronica Stracqualursi, CNN
Updated 11:55 PM ET, Mon March 29, 2021
https://www.cnn.com/2021/03/27/politics/michigan-republican-party-ron-weiser-witches-assassination/index.html 1/5
Source: CNN
Michigan AG responds to state GOP chair's 'witches' comment 03:00
(CNN) — The chairman of the Michigan Republican Party faced swift backlash Friday for comments in which he called the three top Democratic women in
the state "witches" and quipped about "assassination" as a way to rid the state of two Republican congressman who voted to impeach former President
Donald Trump.
Ron Weiser said in a tweet later Friday that he "should have chosen my words more carefully," but the state party chairman stopped short of apologizing
for what he called "off-the-cuff comments" after video obtained and first reported by The Detroit News showed him making the comments at a local
Republican club meeting Thursday night.
Video obtained by the newspaper shows Weiser fielding questions from the crowd about how to get Republican Reps. Fred Upton and Peter Meijer out of
office and cut off party donations to the two US congressmen, who voted in February to charge Trump with incitement of insurrection. In the video,
Weiser says that the only way to change leadership is to "get out and vote."
He also tells an audience member that the GOP is focused on winning 2022 races and "focused on the three witches" in an apparent reference to
Michigan Gov. Gretchen Whitmer, Attorney General Dana Nessel and Secretary of State Jocelyn Benson -- all three Democratic women up for reelection
next year.
At another point during the event, Weiser says the GOP's "job now is to soften up those three witches and make sure that when we have good
candidates to run against them, that they are ready for the burning at the stake."
In the video, a woman in the crowd argues that Republicans can't win "when we don't have our own leadership that has our back."
"Ma'am, other than assassination, I have no other way other than voting out," Weiser replies, prompting some laughter from the crowd. "You people have
to go out there and support their opponents. You have to do what you need to get out the vote in those areas. That's how you beat people."
Weiser in his Friday tweet said that his remarks were being taken out of context. "While I should have chosen my words more carefully, anyone who
knows me understands I would never advocate for violence," he said, adding that he's spoken with Upton and Meijer.
Meijer's office on Monday declined to comment. CNN has reached out to Upton as well as to Weiser for additional comment.
Ted Goodman, a spokesman for the Michigan Republican Party, told CNN in a statement that Weiser was being "very clear that it is up to the voters to
determine the nominees of the Republican Party, and to suggest anything else is dishonest and irresponsible." Goodman also pointed out that Weiser
had personally donated to all Republican congressmen in Michigan.
But Michigan Democratic Party Chair Lavora Barnes called Weiser's comments "not only sexist, but markedly dangerous," and Whitmer press secretary
Bobby Leddy condemned them, saying that "given the dramatic increase in death threats against Michigan elected o cials during the Trump
ffi
Administration, this type of rhetoric is destructive and downright dangerous."
"We saw this rsthand when Republican legislators met with the very militias that tried to kidnap and kill the governor, and when Republican party
fi
leaders helped organize the January 6th protest at the U.S. Capitol building," Leddy said in a statement to CNN.
Leddy added, "As the governor has said repeatedly, it's time for people of good will on both sides of the aisle to bring down the heat and reject this kind
of divisive rhetoric."
Whitmer on Twitter Friday also posted a photo of her with the book "The Witches Are Coming," with the quote from author Lindy West: "For a long time, a
certain set of men have called women like me 'witches' to silence and discredit us."
Nessel responded with a tweet that included an edited photo of herself, Benson and Whitmer with witch hats, saying, "Witches who magically decrease
Covid spread, increase voter turnout and hold sexual predators accountable without any help from the legislature? Sign me up for that coven. Do better,
Michigan GOP."
She later added that as "a gay, Jewish woman, I have long since learned to respond to hateful rhetoric with humor. But as a prosecutor, I know these
remarks are certain to inspire further death threats which will eventually be acted upon."
And Benson wrote on Twitter, "Thinking of all the young women leaders out there who aspire to serve and hold public o ce, hearing this hateful rhetoric
ffi
in the headlines (and) feeling discouraged, deterred, or dismissed."
"My message: Keep leading. The world needs your voice, your service, (and) your courage," she added.
Weiser's comments also prompted calls for his resignation from the University of Michigan's board of regents.
Jordan Acker, a Democrat who serves with Weiser on the board, said that he should resign and that his "reckless and dangerous language does not
re ect the values of our Board and our Institution."
fl
"Comments about removal by 'assassination' are a literal attack on our Democracy, and are incredibly dangerous in light of the January 6th insurrection
at the Capitol. And the FBI-thwarted attacks on our Governor," Acker wrote on Twitter Friday. Whitmer was the target of a kidnapping plot last year.
Weiser has said he does not intend to resign from the board of regents.
This story has been updated with additional information.
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EXHIBIT 12
EXHIBIT 13
FEDERAL ELECTION COMMISSION
Washington, DC 20463
March 25, 2021
ADVISORY OPINION 2021-03
Jessica Furst Johnson, Esq.

Chris Winkelman, Esq.
Holtzman Vogel Josefiak Torchinsky PLLC
2300 N Street, Northwest, Suite 643A
Dear Ms. Johnson and Mr. Winkelman:
We are responding to your advisory opinion request on behalf of the National Republican
Senatorial Committee (the “NRSC”) and the National Republican Congressional Committee (the
“NRCC”) regarding the application of the Federal Election Campaign Act, 52 U.S.C. §§ 30101-
45 (the “Act”), and Commission regulations to the proposed use of the campaign funds of the
members of Congress who comprise the NRSC and NRCC to pay for personal security to protect
themselves and their families. The Commission concludes that the proposed use of campaign
funds for bona fide, legitimate, professional personal security personnel against threats arising
from the members’ status as officeholders is a permissible use of campaign funds under the Act
and Commission regulations.
Background
The facts presented in this advisory opinion are based on your letter received on January
27, 2021, on public disclosure reports filed with the Commission, and on statements made by
you and/or your client at the Commission’s March 25, 2021 public meeting.
The NRSC and NRCC are national party committees. Advisory Opinion Request at
AOR002. 1 The NRSC is comprised of all sitting Republican members of the United States
Senate, and the NRCC is comprised of all sitting Republican members of the United States
House of Representatives. Id. The NRSC’s and NRCC’s primary functions are to aid in the
election of Republican candidates for office, and in that role the NRSC and NRCC provide
1
See also NRSC, FEC Form 1 (Statement of Organization) (filed Oct. 3, 2020),
https://docquery.fec.gov/pdf/753/202010039285004753/202010039285004753.pdf; NRCC, FEC Form 1 (Statement
of Organization) (filed Feb. 5, 2021),
https://docquery.fec.gov/pdf/441/202102059427031441/202102059427031441.pdf.
AO 2021-03
Page 2
guidance to Republican candidates for federal office and officeholders. Id. The NRSC and
NRCC seek this advisory opinion “on behalf of their Members currently serving in federal
office.”
The request lists numerous instances of “concrete threats of physical violence against
Members and their families” and responses by law enforcement agencies, going back several
years and continuing to the present, and the “worsened” threat environment as assessed by the
Capitol Police. Id. AOR003-007. In response to the recent and ongoing threats of physical
violence against senators and representatives and their families due to their status as
officeholders, some officeholders have considered increasing security measures, including hiring
personal security personnel. AOR002. Senators’ and representatives’ “vulnerability to potential
threats is significantly heightened when they are away from home,” while the responsibilities of
their offices require them and their families to appear frequently in public settings. AOR005.
Thus “the most practical and effective solution for protecting the safety of Members and their
families is the employment of personal security personnel.” Id. “The request would only apply
in those instances where federal agents are not protecting the Member or Member’s family, and
in no way would any private personnel retained pursuant to this request interfere with the
operations of federal law enforcement agencies.” AOR002.
Question Presented
May the Members of the United States Senate and United States House of
Representatives that comprise the NRSC and NRCC permissibly use campaign funds to pay for
bona fide, legitimate, professional personal security personnel to protect both the Member and
the Member’s immediate family due to threats arising from his or her officeholder status?
Legal Analysis and Conclusion
Yes, Members of the United State Senate and United States House of Representatives
that comprise the NRSC and the NRCC may use campaign funds to pay for bona fide, legitimate,
professional personal security personnel to protect themselves and their immediate families due
to threats arising from their status as officeholders when they are not otherwise being protected
by federal law enforcement agents or the United States Capitol Police. 2
The Act identifies six categories of permissible uses of contributions accepted by a

federal candidate, two of which are “ordinary and necessary expenses incurred in connection
with the duties of the individual as a holder of Federal office,” and “any other lawful purpose”
not prohibited by 52 U.S.C. § 30114(b). 52 U.S.C. § 30114(a); see also 11 C.F.R. § 113.2(a)-(e).
The Commission has issued a number of advisory opinions authorizing the use of
campaign funds to protect against threats to officeholders’ physical safety, on the grounds that
the need for such security expenses would not exist if not for the officeholders’ activities or
2
As indicated in the request, “immediate family” means members of the officeholder’s household, including
a spouse, minor children, or other relatives who normally reside with the officeholder. AOR001 n.3.
AO 2021-03
Page 3
duties. In Advisory Opinion 2020-06 (Escobar), Advisory Opinion 2011-17 (Giffords),

Advisory Opinion 2011-05 (Terry), and Advisory Opinion 2009-08 (Gallegly), members of
Congress faced specific and ongoing threats to the safety of themselves and their families. The
facts presented in those advisory opinions suggested that the threats were motivated by the
requestors’ public roles as federal officeholders, candidates, or both.
The Commission concluded in each instance that the expenses for the proposed security
upgrades would not have existed irrespective of the requestors’ duties as federal officeholders or
candidates. Therefore, the Commission concluded that the use of campaign funds to pay for the
security upgrades was permissible under the Act or Commission regulations. See Advisory
Opinion 2020-06 (Escobar) at 3; Advisory Opinion 2011-17 (Giffords) at 3; Advisory Opinion
2011-05 (Terry) at 4; Advisory Opinion 2009-08 (Gallegly) at 4.
The Commission has also previously considered the implications of the heightened threat
environment faced by Members of Congress collectively, necessitating increased residential
security measures even if an individual Member has not received direct threats. In Advisory
Opinion 2017-07 (Sergeant at Arms), the Commission considered information from the House
Sergeant at Arms about the threats faced by Members of Congress due to their status as federal
officeholders, and the recommendation of the Capitol Police that Members of Congress install or
upgrade residential security systems to protect themselves and their families. In light of that
information, the Commission concluded that certain costs of installing or upgrading home
security systems would constitute ordinary and necessary expenses incurred in connection with
Members’ duties as federal officeholders, and that therefore Members of Congress may use
campaign funds to pay for reasonable costs associated with home security systems.
See Advisory Opinion 2017-07 (Sergeant at Arms) at 3.
Here, the Commission considers the need for officeholders to take proactive measures to
protect themselves and their immediate families due to threats arising from their status as
officeholders. Similar to the need for increased residential security, the need for personal
security for officeholders and their immediate family members in the context requested arises
due to officeholders’ roles as elected officials. Under these circumstances, the reasonable costs
of bona fide, legitimate, professional personal security personnel for officeholders and their
immediate family members constitute ordinary and necessary expenses incurred in connection
with officeholders’ duties and are a permissible use of campaign funds under the Act and
Commission regulations.
Accordingly, the Members that comprise the NRSC and NRCC may use campaign funds
to pay for bona fide, legitimate, professional personal security personnel to protect themselves
and their immediate families due to threats arising from their status as officeholders, when
federal agents are not protecting the Members or the Members’ families. The Commission
emphasizes this conclusion is based on the information provided about security threats that exist
due to the Members’ duties as federal officeholders. See Advisory Opinion 2017-07 (Sergeant at
Arms); Advisory Opinion 2011-17 (Giffords) at 3.
This response constitutes an advisory opinion concerning the application of the Act and
AO 2021-03
Page 4
Commission regulations to the specific transaction or activity set forth in your request. See 52
U.S.C. § 30108. The Commission emphasizes that, if there is a change in any of the facts or
assumptions presented, and such facts or assumptions are material to a conclusion presented in
this advisory opinion, then the requestor may not rely on that conclusion as support for its
proposed activity. Any person involved in any specific transaction or activity which is
indistinguishable in all its material aspects from the transaction or activity with respect to which
this advisory opinion is rendered may rely on this advisory opinion. See id. § 30108(c)(1)(B).
Please note that the analysis or conclusions in this advisory opinion may be affected by
subsequent developments in the law including, but not limited to, statutes, regulations, advisory
opinions, and case law. Any advisory opinions cited herein are available on the Commission’s
website.
On behalf of the Commission,
Shana M. Broussard
Chair
September 1, 2011
CERTIFIED MAIL RETURN

RECEIPT REQUESTED
Michael McNulty
Chairman
Giffords for Congress
P.O. Box 12886
Tucson, AZ 85732-2886
Dear Mr. McNulty:
We are responding to your advisory opinion request on behalf of Giffords for

Congress (the “Committee”) concerning the application of the Federal Election
Campaign Act of 1971, as amended (the “Act”), and Commission regulations to the use
of campaign funds to pay for enhanced security at Representative Gabrielle Giffords’s
home.
The Commission concludes that because the need for enhanced security at
Representative Giffords’s home is due to violence and security threats stemming from her
activities as a Member of Congress, the use of campaign funds to pay for such security
measures does not constitute personal use of campaign funds, and is permissible under
the Act and Commission regulations.
Background
The facts presented in this advisory opinion are based on your letter received on
August 17, 2011, and public disclosure reports filed by the Committee with the
Commission.
Representative Gabrielle Giffords is a Member of the U.S. House of

Representatives from Arizona’s 8th Congressional District. The Committee is her
principal campaign committee. Representative Giffords was both a Federal officeholder
and a candidate for re-election to the House of Representatives when the events giving
rise to this request occurred.
AO 2011-17
Page 2
On January 8, 2011, Representative Giffords was shot and severely wounded at an

event sponsored by her congressional office. Since that time, Representative Giffords has
been undergoing treatment at TIRR Memorial Hermann Hospital in Houston, Texas. She
was recently transferred to outpatient rehabilitation, allowing her to reside in the family
home in the Houston area when she is not receiving treatment.
After Representative Giffords was shot, at the request of the U.S. House of
Representatives Sergeant at Arms, the U.S. Capitol Police conducted a security
assessment of the Houston area family home and the general threat to Representative
Giffords. The U.S. Capitol Police, following its standards and best industry practices,
made several recommendations to increase the home’s security that are specific to the
identified security needs of Representative Giffords. The recommendations include
installing improved exterior lighting, improved locks, and a duress alarm button. The
estimated cost of the improvements is $2,200. The Committee states that these security
improvements are not intended to increase the value of the property.
Question Presented
May the Committee use campaign funds to pay the costs of installing the
recommended additional security measures to Representative Giffords’s home?
Legal Analysis and Conclusions
Yes, the Committee may use campaign funds to pay the costs of installing the
recommended additional security measures to Representative Giffords’s home because
these costs would not constitute personal use of campaign funds under 2 U.S.C. 439a(b).
The Act identifies six categories of permissible uses of contributions accepted by

a Federal candidate. They are: (1) otherwise authorized expenditures in connection with
the candidate’s campaign for Federal office; (2) ordinary and necessary expenses
incurred in connection with the duties of the individual as a holder of Federal office;
(3) contributions to organizations described in 26 U.S.C. 170(c); (4) transfers, without
limitation, to national, State, or local political party committees; (5) donations to State
and local candidates subject to the provisions of State law; and (6) any other lawful
purpose not prohibited by 2 U.S.C. 439a(b). 2 U.S.C. 439a(a); see also 11 CFR
113.2(a)-(e).
Under the Act and Commission regulations, contributions accepted by a candidate

may not be converted to “personal use” by any person. 2 U.S.C. 439a(b)(1); 11 CFR
113.2(e). Conversion to personal use occurs when a contribution or amount is used “to
fulfill any commitment, obligation, or expense of a person that would exist irrespective of
the candidate’s election campaign or individual’s duties as a holder of Federal office.”
2 U.S.C. 439a(b)(2); see also 11 CFR 113.1(g).
The Act and Commission regulations provide a non-exhaustive list of items that
would constitute personal use, none of which applies here. See 2 U.S.C. 439a(b)(2)(A)-
AO 2011-17
Page 3
(I); 11 CFR 113.1(g)(1)(i)(A)-(J). For items not on this list, such as payments for home
security systems, the Commission determines on a case-by-case basis whether an expense
would fall within the definition of “personal use.” 11 CFR 113.1(g)(1)(ii). The
Commission has long recognized that if a candidate “can reasonably show that the
expenses at issue resulted from campaign or officeholder activities, the Commission will
not consider the use to be personal use.” Explanation and Justification for Final Rules on
Personal Use of Campaign Funds, 60 FR 7862, 7867 (Feb. 9, 1995).
The Commission has previously concluded that payments for, or improvements

to, a home security system, under circumstances very similar to those presented here, do
not constitute personal use under the Act and Commission regulations. In Advisory
Opinions 2011-05 (Terry) and 2009-08 (Gallegly), Members of Congress who were also
candidates for re-election faced specific ongoing threats to the safety of themselves and
members of their families. The facts suggested that the individuals threatening both
Representatives Gallegly and Terry were motivated by the Representatives’ public roles
as candidates and activities as Members of Congress. In both of those advisory opinions,
the proposed security upgrades to the Representatives’ homes were recommended by the
U.S. Capitol Police specifically because of the continuing threats. The Commission
concluded in both advisory opinions that the threats would not have occurred had the
Representatives not been Members of Congress or candidates for re-election, and that the
expenses for the proposed upgrades to the Representatives’ security systems would not
exist irrespective of the Representatives’ campaigns or duties as Federal officeholders.
Similarly, here, the Commission concludes that the ongoing security needs of
Representative Giffords identified by the U.S. Capitol Police would not exist were
Representative Giffords not a Federal officeholder or a candidate for re-election.
Representative Giffords was shot and severely wounded while engaged in her duties as a
Federal officeholder, and the expenses for the proposed upgrades to the security system at
Representative Giffords’s family home would not exist irrespective of her duties as a
Federal officeholder or as a candidate for re-election. Therefore, the use of campaign
funds to pay for these security system upgrades would not constitute personal use of
campaign contributions, and would not be prohibited by the Act or Commission
regulations. 2 U.S.C. 439a(b).
This response constitutes an advisory opinion concerning the application of the

Act and Commission regulations to the specific transaction or activity set forth in your
request. See 2 U.S.C. 437f. The Commission emphasizes that, if there is a change in any
of the facts or assumptions presented, and such facts or assumptions are material to a
conclusion presented in this advisory opinion, then the requestor may not rely on that
conclusion as support for its proposed activity. Any person involved in any specific
transaction or activity which is indistinguishable in all its material aspects from the
transaction or activity with respect to which this advisory opinion is rendered may rely on
this advisory opinion. See 2 U.S.C. 437f(c)(1)(B). Please note that the analysis or
conclusions in this advisory opinion may be affected by subsequent developments in the
law, including, but not limited to, statutes, regulations, advisory opinions, and case law.
AO 2011-17
Page 4
The cited advisory opinions are available on the Commission’s website, www.fec.gov, or
directly from the Commission’s Advisory Opinion searchable database at
http://saos.nictusa.com/saos/searchao.
(signed)
Cynthia L. Bauerly
Chair
January 22, 2021
Honorable Veronica Escobar

Member of Congress
Veronica Escobar for Congress
P.O. Box 3961
El Paso, TX 79923
Dear Representative Escobar:
We are responding to the advisory opinion request you submitted on behalf of yourself
and Veronica Escobar for Congress, your principal campaign committee, regarding the
application of the Federal Election Campaign Act, 52 U.S.C. § 30101-45 (the “Act”), and
Commission regulations to the proposed use of your committee’s campaign funds for expenses
related to installing a residential security system at your home. The Commission concludes that
the proposed use of campaign funds for wiring and lighting costs that are necessary for the operation
of the residential security system as recommended by the House Sergeant of Arms is permissible
under the Act and Commission regulations and would not constitute a prohibited conversion of
campaign funds to personal use.
Background
The facts presented in this advisory opinion are based on your letter received on
December 22, 2020.
You are a member of the U.S. House of Representatives from Texas’s 16th
Congressional District. Since taking office, you have received numerous direct threats to your
safety, which the Capitol Police have investigated. Advisory Opinion Request at AOR001. You
have consulted with the Office of the House Sergeant at Arms about these threats, and they have
recommended installation of a home security system, including cameras for a detached garage
and surrounding your home. Id. The additional wiring and lighting would provide electricity to
the cameras and enough light for them to pick up images, and therefore would be necessary for
these recommended security measures to function properly. Id. You state that the additional
AO 2020-06
Page 2
wiring and lighting are intended solely to support the effectiveness of the security system, and
are not intended for the purpose of improving your home. Id
Question Presented
May Veronica Escobar for Congress use excess campaign funds to pay the costs of
lighting and wiring required as part of a residential security system at your home? 1
Legal Analysis and Conclusion
Yes, Veronica Escobar for Congress may use campaign funds to pay for costs of wiring
and lighting that are necessary for the operation of a residential security system at your home as
recommended by the House Sergeant at Arms, without such payments constituting prohibited
conversion to personal use of campaign funds.
The Act identifies six categories of permissible uses of contributions accepted by a

federal candidate, two of which are “ordinary and necessary expenses incurred in connection
with the duties of the individual as a holder of Federal office,” and “any other lawful purpose not
prohibited by 52 U.S.C. § 30114(b).” 52 U.S.C. § 30114(a); see also 11 C.F.R. § 113.2(a)-(e).
Under the Act and Commission regulations, contributions accepted by a candidate may
not be converted to “personal use” by any person. 52 U.S.C. § 30114(b)(1); 11 C.F.R.
§ 113.2(e). Conversion to personal use occurs when a contribution is used “to fulfill any
commitment, obligation, or expense” of a federal officeholder “that would exist irrespective” of
the officeholder’s duties. 52 U.S.C. § 30114(b)(2); 11 C.F.R. § 113.1(g).
The Act and Commission regulations provide a non-exhaustive list of items that would
constitute conversion to personal use per se, none of which applies here. See 52 U.S.C.
§ 30114(b)(2)(A)-(I); 11 C.F.R. § 113.1(g)(1)(i)(A)-(J). For items not on this list, such as
payments for residential security systems, the Commission determines on a case-by-case basis
whether such expenses would fall within the definition of “personal use.” 11 C.F.R.
§ 113.1(g)(1)(ii). The Commission has long recognized that if a candidate “can reasonably show
that the expenses at issue resulted from campaign or officeholder activities, the Commission will
not consider the use to be personal use.” Personal Use of Campaign Funds, 60 Fed. Reg. 7862,
7867 (Feb. 9, 1995).
The Commission has previously concluded that payments for, or improvements to, a
residential security system, under certain circumstances, do not constitute personal use under the
Act and Commission regulations. In Advisory Opinion 2011-17 (Giffords), Advisory Opinion
1
The advisory opinion request asks whether members of Congress may use campaign funds for the proposed
residential security costs. Commission regulations provide that requests regarding the activities of third parties
do not qualify as advisory opinion requests. 11 C.F.R. § 112.1(b). As such, the Commission is responding to
Representative Escobar’s request only as it applies to her. Other federal officeholders may rely on it to the
extent their factual circumstances are materially indistinguishable from those described here. See 11 C.F.R.
§ 112.5(a)(2).
AO 2020-06
Page 3
2011-05 (Terry), and Advisory Opinion 2009-08 (Gallegly), members of Congress faced specific
and ongoing threats to the safety of themselves and their families. The facts presented in those
advisory opinions suggested that the threats were motivated by the requestors’ public roles as
federal officeholders, candidates, or both. In all three instances, the Capitol Police recommended
specific security upgrades to the members’ homes due to the continuing threats.
The Commission concluded in each instance that the threats would not have occurred had
the members not been federal officeholders or candidates, and that the expenses for the proposed
security upgrades would not have existed irrespective of their duties as federal officeholders or
candidates. Therefore, the Commission concluded that the use of campaign funds to pay for the
security upgrades recommended by the Capitol Police would not constitute a prohibited personal
use of campaign contributions under the Act or Commission regulations. See Advisory Opinion
2011-17 (Giffords) at 3; Advisory Opinion 2011-05 (Terry) at 4; Advisory Opinion 2009-08
(Gallegly) at 4.
The Commission has also previously considered the implications of the heightened threat
environment faced by members of Congress collectively, necessitating increased residential
security measures even if an individual member has not received direct threats. In Advisory
Opinion 2017-07 (Sergeant at Arms), the Commission considered information from the House
Sergeant at Arms about the threats faced by members of Congress due to their status as federal
officeholders, and the recommendation of the Capitol Police that members of Congress install or
upgrade residential security systems to protect themselves and their families. In light of that
information, the Commission concluded that certain costs of installing or upgrading home
security systems would constitute ordinary and necessary expenses incurred in connection with
members’ duties as federal officeholders, and that therefore members of Congress may use
campaign funds to pay for reasonable costs associated with home security systems. See
Advisory Opinion 2017-07 (Sergeant at Arms) at 3. The Commission’s conclusion in that
advisory opinion was limited to the use of campaign funds for “non-structural security devices”
and the Commission specifically authorized the use of campaign funds for the installation or
upgrade of “cameras, sensors, distress devices, and similar non-structural security devices, as
well as locks, in and around a Member’s residence.” Id.
As in the previous advisory opinions concerning federal officeholders who faced direct
threats, you have also received direct threats since taking office as a Member of Congress, and
the House Sergeant at Arms has recommended that you install specific security measures at your
home in response. AOR001. Similar to the circumstances of the previous advisory opinions,
your need for a residential security system arose due to your role as a federal officeholder, and
the proposed wiring and lighting are “meant solely for supporting the effectiveness of the
security system and not as an ‘improvement’” to your home. Id.; see Advisory Opinion 2011-17
(Giffords) at 2; Advisory Opinion 2011-05 (Terry) at 2; Advisory Opinion 2009-08 (Gallegly) at
2. Therefore, the costs of installing the recommended security measures will not constitute a
prohibited personal use of campaign funds.
Moreover, even in the absence of specific threats directed at you, you are currently
subject to the heightened threat environment faced by members of Congress that was considered
AO 2020-06
Page 4
by the Commission in Advisory Opinion 2017-07 (Sergeant at Arms). As such, the costs of
installing a residential security system as recommended by the House Sergeant at Arms
constitute ordinary and necessary expenses incurred in connection with your duties as a federal
officeholder, and are a permissible use of campaign funds.
The specific recommendations of the Sergeant at Arms in your case require installing
additional wiring and lighting around your home and detached garage. AOR001. While these
particular costs may not, on their face, fall within the category of “non-structural security
devices” authorized in Advisory Opinion 2017-07 (Sergeant at Arms), the recommended security
cameras would not function properly without the additional wiring and lighting. As such, these
costs constitute an integral part of an ordinary and necessary expense that may be paid with
campaign funds under the Act. Id. Accordingly, Veronica Escobar for Congress may use
campaign funds to pay those costs without such payment resulting in a prohibited conversion of
campaign funds to personal use.
This response constitutes an advisory opinion concerning the application of the Act and
Commission regulations to the specific transaction or activity set forth in your request. See 52
U.S.C. § 30108. The Commission emphasizes that, if there is a change in any of the facts or
assumptions presented, and such facts or assumptions are material to a conclusion presented in
this advisory opinion, then the requestor may not rely on that conclusion as support for its
proposed activity. Any person involved in any specific transaction or activity which is
indistinguishable in all its material aspects from the transaction or activity with respect to which
this advisory opinion is rendered may rely on this advisory opinion. See 52 U.S.C.
§ 30108(c)(1)(B). Please note that the analysis or conclusions in this advisory opinion may be
affected by subsequent developments in the law including, but not limited to, statutes,
regulations, advisory opinions, and case law. Any advisory opinions cited herein are available
on the Commission’s website.
Shana M. Broussard
Chair
F (313) 309-6910 Detroit, MI 48226
F (313) 965-8252
August 23, 2021
Via Email, only

Adam Fracassi
Bureau of Elections
430 W. Allegan St.
Lansing, MI 48918
Re: Supplemental Exhibit to Response to Complaint in Ventimiglia v Whitmer

No. 2021-07-17-21
Dear Mr. Fracassi:
Please accept this letter and its attachment as a supplement to the response my office
submitted on August 20, 2021 on behalf of Governor Gretchen Whitmer, the Gretchen Whitmer
for Governor candidate committee, and Michigan Transition 2019 in the above-referenced
complaint.
This letter’s attachment – which we have designated as Exhibit 14 – is an article from

today, August 23, 2021, and is relevant to – and supplements –pages three through seven of our
response, which detailed numerous threats against Governor Whitmer’s safety and life in the last
18 months. The article reveals that on August 23, 2021, Attorney General Dana Nessel charged a
man from Clarkston, Michigan with making malicious threats to Governor Whitmer through a web
submission portal in January and March 2021. Id. Attorney General Nessel’s office released one
of the messages sent to Governor Whitmer by the man, which stated as follows: “Take care . . .
and maybe shelter. We have been watching and know your every step. You f--- with everyday
hard-working Americans, we F--- WITH YOU.”
Sincerely,
CLARK HILL PLC
CMT:vcs
clarkhill.com
263855345
EXHIBIT 14
8/23/2021 Clarkston man charged after leaving 'malicious' messages for Gov. Whitmer
MICHIGAN
Clarkston man charged after leaving 'malicious'

messages for governor
Beth LeBlanc The Detroit News
Published 1:03 p.m. ET Aug. 23, 2021
A 31-year-old Clarkston man has been charged with sending 'malicious' messages to Gov. Gretchen Whitmer, according to a
statement from Attorney General Dana Nessel's office.
Kevin Dawe turned himself in to Michigan State Police on Aug. 19 and posted a $500 bond after he was charged with
sending messages to Whitmer through a web submission portal in January and in March, Nessel's statement said.
He was charged with two counts of malicious use of telecommunications services. Both counts are misdemeanors
punishable by up to six months in jail or a $1,000 fine.
An example of one of the messages, provided by Nessel's office, said: “Take care . . . and maybe shelter. We have been
watching and know your every step. You f--- with everyday hard-working Americans, we F--- WITH YOU.”
"There is a fine line between airing grievances with an elected official and threatening their life or their loved ones,” Nessel
said in a statement. “My office stands ready to pursue criminal charges against anyone who crosses that line.”
The charges come more than 10 months after 14 people were charged in connection with an alleged plot to kidnap Whitmer
over pandemic restrictions. One of the individuals has pleaded guilty. Several others await trial.
[email protected]
https://www.detroitnews.com/story/news/local/michigan/2021/08/23/clarkston-michigan-man-charged-malicious-messages-gov-gretchen-whitmer/8244419002/ 1/1
F (313) 309-6910 Detroit, MI 48226
F (313) 965-8252
August 23, 2021
Via Email, only

Adam Fracassi
Bureau of Elections
430 W. Allegan St.
Lansing, MI 48918
Re: Supplemental Exhibit to Response to Complaint in Ventimiglia v Whitmer

No. 2021-07-17-21
Dear Mr. Fracassi:
Please accept this letter and its attachment as a supplement to the response my office
submitted on August 20, 2021 on behalf of Governor Gretchen Whitmer, the Gretchen Whitmer
for Governor candidate committee, and Michigan Transition 2019 in the above-referenced
complaint.
This letter’s attachment – which we have designated as Exhibit 14 – is an article from

today, August 23, 2021, and is relevant to – and supplements –pages three through seven of our
response, which detailed numerous threats against Governor Whitmer’s safety and life in the last
18 months. The article reveals that on August 23, 2021, Attorney General Dana Nessel charged a
man from Clarkston, Michigan with making malicious threats to Governor Whitmer through a web
submission portal in January and March 2021. Id. Attorney General Nessel’s office released one
of the messages sent to Governor Whitmer by the man, which stated as follows: “Take care . . .
and maybe shelter. We have been watching and know your every step. You f--- with everyday
hard-working Americans, we F--- WITH YOU.”
Sincerely,
CLARK HILL PLC
CMT:vcs
clarkhill.com
263855345
EXHIBIT 14
8/23/2021 Clarkston man charged after leaving 'malicious' messages for Gov. Whitmer
MICHIGAN
Clarkston man charged after leaving 'malicious'

messages for governor
Beth LeBlanc The Detroit News
Published 1:03 p.m. ET Aug. 23, 2021
A 31-year-old Clarkston man has been charged with sending 'malicious' messages to Gov. Gretchen Whitmer, according to a
statement from Attorney General Dana Nessel's office.
Kevin Dawe turned himself in to Michigan State Police on Aug. 19 and posted a $500 bond after he was charged with
sending messages to Whitmer through a web submission portal in January and in March, Nessel's statement said.
He was charged with two counts of malicious use of telecommunications services. Both counts are misdemeanors
punishable by up to six months in jail or a $1,000 fine.
An example of one of the messages, provided by Nessel's office, said: “Take care . . . and maybe shelter. We have been
watching and know your every step. You f--- with everyday hard-working Americans, we F--- WITH YOU.”
"There is a fine line between airing grievances with an elected official and threatening their life or their loved ones,” Nessel
said in a statement. “My office stands ready to pursue criminal charges against anyone who crosses that line.”
The charges come more than 10 months after 14 people were charged in connection with an alleged plot to kidnap Whitmer
over pandemic restrictions. One of the individuals has pleaded guilty. Several others await trial.
[email protected]
https://www.detroitnews.com/story/news/local/michigan/2021/08/23/clarkston-michigan-man-charged-malicious-messages-gov-gretchen-whitmer/8244419002/ 1/1
September 16, 2021
Adam Fracassi By email transmission

Bureau of Elections [email protected]
Richard H. Austin Building, 1st Floor
430 W. Allegan
Lansing, MI 48918
Re: Ventimiglia v. Gretchen Whitmer and Gretchen Whitmer for Governor

Campaign Finance Complaint
No. 2021-07-17-21
Rebuttal Statement
Dear Mr. Fracassi:
INTRODUCTION
Thank you for your letter dated September 3, 2021 which contained the response (the “Response”)
submitted by the Respondents in the above-referenced matter. Please consider this letter to be the
Rebuttal Statement submitted on behalf of the Complainant.1 The Response’s “smoke and
mirrors” approach never answers why Governor Whitmer’s personal trip to West Palm Beach,
Florida (the “Florida Excursion”) has any relationship whatsoever to ”carrying out the business of
an elective office” to allow a candidate committee to finance these expenses as an incidental
expense pursuant to MCL 169.221a and MCL 169.209(1). With all due apologies to the late poet
James Riley,2 if an expense looks like a personal expense, swims like a personal expense, and
quacks like a personal expense, then we call that a personal expense.
THERE IS ONLY ONE FACT THAT MATTERS: THE PURPOSE OF THE FLORIDA
EXCURSION WAS EXCLUSIVELY PERSONAL
The Response confirms the dispositive fact (the “Dispositive Fact”) alleged in the Complaint:
“As stated by the Governor’s office, this was a two-day weekend trip to visit her
ailing father, with a travel day on each side of the visit.” Response, page 2.
1
All capitalized terms not otherwise defined herein shall have those meanings as set forth in the
Complaint filed in the above-referenced matter. The Complaint is hereby incorporated herein by
reference, including, but not limited to, the sections entitled “Conclusion” and “Request for
Action by the Secretary of State”.
2
Duck test - Wikipedia
Once the Dispositive Fact was admitted by the Respondents, nothing else matters. MCL 169.221a
allows Respondent Gretchen Whitmer for Governor to make an expenditure for an “incidental
expense” which means an “expenditure that is an ordinary and necessary expense, paid or incurred
in carrying out the business of an elective office.” MCL 169.209(1). Although the Response can
waste pages referring to Michigan Transition 2019 (which is not a Respondent here) or the threats
made to Respondent Whitmer, there is one inescapable fact that the Respondents cannot explain
away:
Respondent Whitmer’s personal trip to visit her father in Florida was wholly unrelated to
“carrying out the business of an elective office.”
ANY ASSERTION THAT A PERSONAL WEEKEND VACATION IS JUSTIFIED BY

SECURITY CONCERNS IGNORES THAT THIS EXPENDITURE WOULD HAVE
OCCURRED IRRESPECTIVE OF RESPONDENT WHITMER’S STATUS AS
GOVERNOR
The Response cites both an Interpretative Statement issued to Kevin Hertel dated April 15, 2021
and Federal law to justify the expenditure of candidate committee funds for personal use. See
Response, pages 8-10. However, the Florida Excursion is a personal weekend vacation, not a
home security system.
According to the Michigan Department of State:

“To determine whether a disbursement is a personal expense, the Department applies
a “but-for” test in order to determine whether the expenditure may be personal in
nature: If the disbursement would have occurred irrespective of the individual’s status
as a candidate or an office holder, the expenditure is a prohibited personal expense.”
“The burden is on the committee at the time of filing a campaign statement to
demonstrate that the disbursement would not have been made but for the candidate’s
status as an officeholder.”
Interpretative Statement issued to Kevin Hertel dated April 15, 2021.
Certainly, the Respondents are not seriously arguing that visiting a family member on a weekend
vacation would not have occurred “but for” Respondent Whitmer’s status as Governor. Therefore,
based on the Hertel ruling, the expenditure for the Florida Excursion cannot be an incidental
expense.
Moreover, even a cursory review of Federal law illustrates that the expenditure for the Florida
Excursion cannot be an incidental expense. Significantly, the Federal law “personal use”
regulations expressly recognize that a “vacation” is “personal use” which cannot be financed from
a candidate committee account. 11 CFR 113.1(g)(1)(i)(J). Similar to the Hertel ruling, the Federal
authorities employ a “but for” analysis:
Page 2 of 4
“…the use of campaign funds to take the candidate’s family out to dinner in a
restaurant would be personal use, because the family’s meal expenses would exist even
if no member of the family were a candidate or an officeholder.”
Personal Use of Campaign Funds, 60 Fed. Reg. 7862, 7868 (Feb. 9, 1995).
Whether the expense is family dinner or a personal trip to West Palm Beach, Florida, this trip “to
visit her ailing father” would have been made whether or not Respondent Whitmer was Governor.
Unless the Bureau of Elections continues to adhere to the Hertel “but for” analysis, then the
personal use prohibition becomes meaningless.
Accordingly, the Respondents’ security “justification” to finance the Florida Excursion ignores
that the Florida Excursion is a personal expense. If the Respondents want to utilize candidate
committee funds to purchase a home security system or to finance security expenses with respect
to a trip which relates to “carrying out the business of an elective office”, then so be it. However,
such is not the case here with respect to the Florida Excursion.
OTHER ADMISSIONS IN THE RESPONSE WILL ASSIST THE BUREAU OF

ELECTIONS TO ESTABLISH THE APPROPRIATE PENALTIES UNDER THE
MICHIGAN CAMPAIGN FINANCE ACT
Other important facts, alleged in the Complaint and now conceded by the Respondents, include:
1. “The value of the flight was $27,521.” Response, page 3. Compare Complaint, paragraph 10.
2. “…the cost of the flight was then paid from the Gretchen Whitmer for Governor campaign
fund….” Response, page 3. Compare Complaint, paragraph 14.
3. “…Governor Whitmer voluntarily reimbursed the Gretchen Whitmer for Governor candidate
committee for an amount equivalent to the cost of a first-class commercial airline ticket for herself
and her daughters. Response, page 3. Compare Complaint, paragraph 14.
As set forth in the Complaint, the foregoing facts establish: (1) the amount of the violation, (2) that
Respondent Gretchen Whitmer for Governor is attempting to pay a personal expense of
Respondent Whitmer, and (3) that Respondent Whitmer’s reimbursement of a portion of the
expenses of the Florida Excursion serves as an admission that these expenditures are not incidental
expenses.
* * *
Accordingly, the Complaint sets forth the serious nature of the Michigan Campaign Finance Act
violations at stake here. The Response’s factual concessions only serve to bolster the Complaint.
Unless the Bureau of Elections and Secretary of State protect the prohibition against personal use
Page 3 of 4
December 21, 2021
Eric Ventimiglia
123 W. Allegan, Suite 770
Lansing, MI 48933
Re: Ventimiglia v. Whitmer

Campaign Finance Complaint
No. 2021-07-17-21
Dear Mr. Ventimiglia:
The Department of State (Department) has finished investigating the campaign finance
complaint filed against Governor Gretchen Whitmer by you alleging violations of the Michigan
Campaign Finance Act (MCFA). This letter concerns the disposition of that complaint.
The complaint alleges that Governor Whitmer improperly used campaign funds from the
Gretchen Whitmer for Governor Campaign Committee (Committee) to pay for a chartered flight
as part of a personal trip to and from Florida. The complaint alleges that, because the trip to
Florida was made entirely for personal reasons, all expenses incurred as a result of that trip must
be personal expenses that cannot be reimbursed from Committee funds.
In response to the complaint, Governor Whitmer confirmed that the Committee’s funds were
used to pay for a chartered flight to and from Florida and confirmed that the Florida trip was not
taken for any official reason. 1 Governor Whitmer stated that the chartered flight was necessary to
ensure her personal security and provided multiple news articles and social media
communications documenting the threats against her. Further, Governor Whitmer reimbursed the
Committee on May 27, 2021 for the cost of four first-class one-way tickets between Lansing and
Florida – one for Governor Whitmer’s flight to Florida, one for Governor Whitmer’s return flight
1
While Governor Whitmer’s response states that the Governor continued to take meetings and carry out her official
duties during her time in Florida, nothing in the response suggests that any official business required Governor
Whitmer to be present in Florida; the only apparent reason that Governor Whitmer traveled to Florida was to visit
her father. If no official reasons justify the trip to Florida, the trip cannot be categorized as an official trip.
BUREAU OF ELECTIONS
RICHARD H. AUSTIN BUILDING  1ST FLOOR  430 W. ALLEGAN  LANSING, MICHIGAN 48918
www.Michigan.gov/Elections  (517) 335-3234
Eric Ventimiglia
December 21, 2021
Page 2
to Lansing, and two for each of the Governor’s daughters who were also on the return flight to
Lansing. 2
You submitted a rebuttal statement, which reiterated that the personal nature of Governor
Whitmer’s trip to Florida necessarily meant that all expenses associated with the trip are non-
reimbursable personal expenditures.
In Michigan, candidate committees may make an expenditure only “to further the nomination or
election of the candidate for which [the committee] is formed.” MCL 169.244(2). Office holders
may also make expenditures for incidental office expenses – expenses that are “ordinary and
necessary, paid or incurred in carrying out the business of an elective office.” MCL 169.209(1).
However, candidates may not use committee funds for the personal benefit of an individual.
Interpretive Statement to Christopher LaRose, Issued November 2, 1978.
To determine whether an expense incurred by a candidate committee is an impermissible

personal expenditure, the Department applies a “but-for” test: “[i]f the disbursement would have
occurred irrespective of the individual’s status as a candidate or an office holder, the expenditure
is a prohibited personal expense.” Interpretive Statement to Kevin Hertel, issued April 15, 2021.
Conversely, disbursements that are entirely attributable to an individual’s status as a candidate or
an office holder are incidental expenses that may be paid by a committee regulated by the
MCFA. The committee bears the burden of showing that the disbursement would not have been
made but for the individual’s status as a candidate or officeholder. Id.
The Department has reviewed the evidence submitted in this matter and concludes that
insufficient evidence has been submitted to support a finding that a potential violation of the
MCFA has occurred. While Governor Whitmer’s trip to Florida was taken solely for personal
reasons, the fact that a specific expense was incurred as part of a broader set of activities with a
purely personal purpose is not dispositive as to whether that specific expense is a personal
expenditure or an incidental expenditure. Instead, the but-for test must be applied to the
individual expense – each expense incurred by the individual in question must be examined to
determine if, but for the individual’s status as an elected official, that expense would not have
been incurred.
Here, the but-for test categorizes some expenses associated with the Florida trip as personal and
others as official. Governor Whitmer concedes that her trip to Florida was a personal trip
2
Governor Whitmer’s two daughters only traveled on the return charter flight from Florida to Michigan; they did
not travel on the initial charter flight from Michigan to Florida. Governor Whitmer’s response to this complaint
states that the Governor reimbursed the Committee “for an amount equivalent to the cost of a first-class ticket for
herself and her daughters.” The Department interprets this to mean that Governor Whitmer reimbursed the
Committee for four tickets, as explained above. The Department also does not examine whether the reimbursement
was indeed equivalent to the cost of four first class tickets, as the issue was not raised by the complainant in either
the original complaint or in his reply.
Eric Ventimiglia
December 21, 2021
Page 3
unrelated to her official duties. If Governor Whitmer was not an elected official, she still would
have traveled to Florida – but presumably not on a chartered flight. Because Governor Whitmer
would have incurred the cost of domestic airline ticket even if she did not hold office, the cost of
that ticket must be paid by Governor Whitmer personally – and Governor Whitmer bore that
cost. Importantly, Governor Whitmer reimbursed the Committee for the fair market value of
first-class prior tickets within 10 days of the Committee making the expenditure – the Committee
learned of the expense on May 17, 2021, and Governor Whitmer reimbursed the Committee on
May 27, 2021. 3
Had Governor Whitmer not reimbursed the Committee for the fair market value of commercial
plane tickets, or had done so in response to news coverage or a complaint, there may have been
reason to believe that a potential violation of the MCFA had occurred. Further, had Governor
Whitmer not promptly reimbursed the Committee for the cost of the tickets upon learning of the
expenditure, there may have been reason to believe that a potential violation of the MCFA had
occurred.
The next question is whether the additional costs – those attributable to using a chartered flight
rather a commercial airline – would not have been incurred but for the Governor’s status as an
elected official. To be justifiable, the expense must be rationally related to a condition created by
an individual’s status as a candidate or officeholder, and the candidate committee bears the
burden of proof. Hertel, supra.
Here, Governor Whitmer asserts that travel via chartered flight was necessary because numerous
and documented threats against her life made travel on a commercial airline unsafe. Further,
Governor Whitmer claims that these threats stem from her status as Governor, and but for that
status, she would not be the recipient of death threats, her safety would not be in question, and
she would be able to take commercial flights rather than being required to travel on private,
charted flights.
In this case, the Department finds that Governor Whitmer’s stated concern for her safety and
security is a direct result of her status as Governor, and that, particularly given the tenor and
intensity of the threats included with Governor Whitmer’s response statement, travel via private
chartered flight rather than by commercial airline is a response rationally related to those security
concerns. 4
3
While the charter flight was taken in March, Governor Whitmer claims that a good-faith error regarding which
entity would pay for the flight prevented the Committee from becoming aware of its obligation to pay the expense
until May 17, 2021. Because the nature of the error is not contested by the complainant, the circumstances
surrounding the error are irrelevant to this determination.
4
The Department is not in a position, nor will it attempt, to evaluate whether these specific measures taken to
protect the safety of a public official, relative to some other hypothetical action that might have been taken, are the
only or most optimal method of protecting safety. However, an official or candidate claiming an otherwise personal
expense is necessary because of a safety concern must demonstrate that the expenditure would not have been
Eric Ventimiglia
December 21, 2021
Page 4
The complaint errs in asserting that the personal nature of the Florida trip means that no
individual cost associated with the trip could be an incidental expense payable by a committee
under the MCFA. As explained above, expenses may be incidental expenditures payable by a
committee if the expense is attributable to an individual’s status as a candidate or an elected
official.
Because the violation of the MCFA alleged in the complaint has not been substantiated by
sufficient evidence, the Department dismisses the complaint and will take no further enforcement
action.
Sincerely,
Adam Fracassi
Bureau of Elections
c: Chris Trebilcock, Attorney for Gretchen Whitmer for Governor
necessary but for the official or candidate’s status, and the expenditure is a response rationally related to that
concern.

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Complaint Against:

Gretchen Whitmer for Governor

Dated: July 26, 2021

Filed Pursuant to MCL 169.215

August 20, 2021

Via Email, only

Re: Response to Complaint in Ventimiglia v Whitmer

Dear Mr. Fracassi:

A. Michigan Transition 2019

Michigan Transition 2019 is organized as a Michigan nonprofit corporation. Exhibit 1,

Article II of the Articles of Incorporation of Michigan Transition 2019 describes the

 To operate for the promotion of civic action and social welfare by

 To advocate citizen participation and obtain support for public policies in

B. The March 2021 Florida Trip

C. The Significant and Continuing Threats to Governor Whitmer’s Life

[Twitter, @CraigDMauger, 4/30/20]

Numerous individuals also sent threatening messages directly to Governor Whitmer’s

Recently, in response to a request by Representative Kevin Hertel, the Bureau of Elections

In unequivocal language, the Bureau of Elections determined that a candidate committee

The Department agrees with these conclusions and determines that

However, the disbursement must be done as a result of their

CLARK HILL PLC

LARA Home Contact LARA Online Services News MI.gov

ID Number: 802253099 Request certificate Return to Results New search

Identification Number: 802253099

City: EAST LANSING State: MI Zip Code: 48823

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Copyright 2021 State of Michigan

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