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    America First Legal Foundation ("AFL") brings this complaint before the Federal Election Commission ("FEC" or "Commission") seeking an immediate investigation and enforcement action against Alvin Bragg and Biden for President ("Respondents") for direct and serious violations of the Federal Election Campaign Act ("Act").

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    AFL v Bragg Biden

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    America First Legal Foundation ("AFL") brings this complaint before the Federal Election Commission ("FEC" or "Commission") seeking an immediate investigation and enforcement action against Alvin Bragg and Biden for President ("Respondents") for direct and serious violations of the Federal Election Campaign Act ("Act").

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    © All Rights Reserved
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    192 views21 pages

    AFL V Bragg Biden

    Uploaded by

    Red Voice News
    America First Legal Foundation ("AFL") brings this complaint before the Federal Election Commission ("FEC" or "Commission") seeking an immediate investigation and enforcement action against Alvin Bragg and Biden for President ("Respondents") for direct and serious violations of the Federal Election Campaign Act ("Act").

    Copyright:

    © All Rights Reserved
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    FEDERAL ELECTION COMMISSION In the matter of: Alvin Bragg MUR __ Biden for President COMPLAINT 1. America Fisst Legal Foundation (‘AFL brings this eomplaint before the Federal Blection Commission (REC or “Commission”) secking an immediate investigation and enforcement action against Alvin Bragg and Biden for President (Respondents for direst and serious violations of the Federal Election Campaign ‘et Act) 2, President Biden, the incumbent candidate for the 2024 presidential lection, looked to lawrfare to destroy his chief political opponent, former President Donald J. Trump, and made the following statement regarding Trump's electoral prospects in November 2024: “if he dees run. I'm making sure he, under legitimate efforts of our Constitution, does not become the next President again.”! 3. In coordination with Biden and his campaign, New York County Dist Attorney Alvin Bragg resurrected the “hush money” “zombie ease” a part of that lawfave strategy against Trump under a legal theory that his predecessor had previously sent “back into the grave,” out of concerns that the felony charges would not hold up in court © See Remarks by President Biden in Press Conference, Wutre House (Nor. 9, 2022), bttpsperma coZ.QP2z "See Brea Orden, How ¢ Husk Money Seandal Turned into Criminal Case, POLITICO (Apr 15, 2024), ntpe:tprma ccNOBE- KXHG (ong MARK FOMERTE, PEOPLE, ONAL THUN (202); sn STAFF OF H. Con. of THE JUDICIARY, INR REPORT: AN ANATOMY OF A POLITICAL PROSECUTION (Apr. 25, 2028), hepsi 4. By pursuing the politically motivated prosecution against Trump, Bragg mado an excessive contribution in the form of a coordinated expenditure in violation of 52 USC. § 30116(0)(1)(A) 5. Correspondingly, Biden for President knowingly accepted an excessive contribution in the form of a coordinated expenditure in violation of 52 U.S.C. § 3011660. 6. Additionally, Biden for President violated 52 U.S.C. § 30104(b) and 11 CER. § 104.3(a)-(b) by failing to provide the required disclosure information Complainant 7. Complainant AFL is a national, nonprofit organization working to promote the rule of law in the United States, prevent executive overreach, and ensure due process and equal protection for all Americans, all to promote public knowledge and understanding of the Iaw and individual rights guaranteed undor the Constitution and laws of the United States. 8. In furtherance of its mission, AFL socks to expose unethical and illegal conduct of government officials. One way that AFL does this is by gathering information related to coordinated election interference activities by government agencies and officials and making such information available to the public through its website, press releases, and social media. Publicizing campaign finance violators and filing complaints with the Commission serve AFL's mission by keeping the public informed and deterring future campaign finance law violations. Therefore, AFL is harmed when a regulated person ar entity eithor fails to disclose oF provides false information in reports requited by the Act, 52 US.C. § 30101 et sea 9. Also, AFL solios on the Commission to properly administor the Act's reporting requirements because these disclosure reports are the only source of information that AFL can use to determine if a regulated person complies with the Act. The proper administration ofthe Act includes ensuring that al iselosure reports are correctly and timely ilo with the Commission 10, Federal enforcement is necessary when federal campaign finance and support turn from independent law enforcement prosecution to election intorforonce and public corruption. McCormick v. United States, 500 U.S. 257 (1991); Evans v. United States, 504 US, 265 (1992). Therefore, AFL's programmatic activity is hindered when the Commission fails to administer the Act properly. See Campaign Legal Ctr v. FBC, 266 F. Supp. 3 141, 146 (D.D.C, 2022) (iting FEC v. Akins, 524 US.11, 14 4998). Respondents 11, Alvin L, Bragg, Jt, located at One Hogan Place, New York, NY 10013, is the Now York County District Attorney. 12, Bidon for President (FEC Idontifiention Number: 600703975), located at P.O, Box 98174, Philadelphis, Pennsylvania 19102, is Joseph R. Biden Jn’ Principal Campaign Committee for the 2024 election, Facts 13, To influence the 2024 election, Biden and his allies have pursued awfare to physically remove former President Trump from the campaign trail, drain his resources, harm his reputation, and potentially disqualify him from the ballot." Rogarding Mr. Trump's electoral prospocts in November 2024, Biden statod: “if he does run, I'm making sure he, under legitimate efforts of our Constitution, does not become the next President again.”* 14, As tho Now York County District Attorney, Alvin Bragg contributed to Biden’s lawfare strategy by resurrecting the “hush money” “zombie case” against ‘Trump under a logal theory that his predacessor had previously sent “back into the grave,” out of concerns that the felony charges would not hold up in court. The case identical tow matter that the United States concerned federal subject matt Department of Justice had previously declined to prosecute in 2018, and Bragg's prosecution relies heavily on the testimony of Michael Cohen —a felon convicted for ” See, eg, Andrew C, MeCarths, Biden's Collusion in the Anti-Trunp Laofare Gambit, NA REY (Apr. 27, 2024) hutpsiperma.colGEMD-XUQQ, Brooke Singman. Rep slordan Urges Congrese to ‘Defund Laufare Activites’ of Trump Proseuiors. FOX NewS (lune 3. 2024), bitpefperma.ceVNJ TYSZ: Josh Christenson, Republizane Tear Indo AG Merrick Garland Over Trump "Loufare’ After "Husk Money’ Conviction, NY. Post (June 4, 2024), httpsiiperma coH{3WQ-DSYE: Jordan Boyd Demoerots' Election Interference Starts With Lawfore That Keeps. Trump From Compaigning, THE Peosnatisr (Peb. 16, 2024). hrtpslipermaco/TBRS-HS4A; Elise Stefanik, Opinian, The Democrats Are Using Lawfare Against Trump Because They Can't Beot Hin Fairly, NEWSWEEK (updated Dec. 18, 2023), hutpsifperma oo 18PS-3HGF, {marty Bese Bien Confrence, We HOURS Nv. 8,202) Mtge ITED Pz *'See Erion Onden, How a Hush Monty Scandal Turned into Criminal Coes, POLITICO (Ape. 16, 202, utpaifperma.ceIMSBH-IKXHG (quoting Manx PoNbRawTz, PrDt\. DONALD TRUMP (2023). istrable animus towards Trump.* In February 2022, lying to Congress with a dem two prosecutors leading the case, Mark Pomerantz and Carey Dunne, resigned from tho District Attorney's Office because Bragg “had doubts about moving forward with the case against Trump."7 But even Pomerantz acknowledged that the charges would rely on “untested” legal theories.> 15. By virtue of holding the Office of the New Yorke County District Attorney, Bragy’s “most dangerous power [is that he will pick people that he thinks should get, rather than pick cases that need to be prosecuted [because] a prosecutor stands a fair chance of finding at least a technical violation of eome act on the part of almost anyone [, and] che greatest danger of abuse of prosecuting power lies {when} the real erime beoomes that of being unpopular with the predominant or governing group (or) being attached to the wrong political views 16, New York Rule of Professional Conduct 3. provides, inter aia, that a prosecutor “shall not institute, cause tobe instituted or maintain « criminal charge when the prosecutor or other government lawyer knows or itis obvious that the charge is not supported by probable cause.” Comment 1 to Rule 38 provides, “Ia) prosecutor has the responsibility of a minister of justice and not simply that of an advocate. This responsibility carries with it specific obligations to sce that the © Lastar from Chairman Jim Jordan, H. Comm. on the Judiciary, to the Hon. Mevsick Gatland, Att'y Gen, US. Dep'tdustice (Apr. 30,202), bespsi)perma cfTBVZ-TADY, "William K- Rashbaum et al, 2 Prosecutors Leading N.Y. Trump Inquity Revign, Clouding Case's Future, NY. ‘Ties (Peb 25, 2022), hitps:/fperma.csQUT-ASNP. Lae Cohen, Trump Hush Money Tol Sons From Zombie Gee’ Brought Bock Life, RE 9, 2024), hetps/fperma.cel64BL- WEEN. Robert H.dackson, The Federal Prosecutor, 24 J, AM, JUD, SOC 18 (1940), BL J. RDA. L 8 (1940) (address at Conference of United States Atorneys, Washington, DC. April. 1940). MIN.Y. RULFSOP PRO, CONDUCT r 58 vs (Ape defendant is accorded procedural justice and that guilt is decided upon the basis of sufficient evidence.” Comment 5 provides that, “a prosecutor's extrajudicial statement can create the additional problem of ineroasing public condomnation of the accused.” 17, Bragg’s resurrection of the “hush money” “zombie case” based on ‘untosted” logal theories against Trump violated his professional duties ax the New ‘York County District Attorney. During his campaign to become Distriet Attorney, Bragg “remind[ed] voters frequently that in his former job, he sued Mr. Trump's administration ‘more than a hundred times.” Bragg would not have prosecuted ‘Trump but for Trump's candidacy 18 Bragg's commitment to getting Trump grined him the support of senior Biden political operatives, One day after Bragg announced his primary campaign agninst his predecessor," Bragg received a contribution from Chirag Bains,!® who would later become a Deputy Assistant to the President in the Biden White House.! "NY. RULES OF PRO. CONDUCT 38cm. "NY. RULESOF PRO. Conoucrr. Bent 5. Jonah B. Bromwich et al. ? Leading Mentation D.A. Candidates Face the Trump Question, NY. ‘TIMeS (June 2, 2021, httpe/perma.coPZA-ZPOD, "See Anna Sanders, Alvin Bragg Announces Democratic Primary Compaign Against Monhatton DA (Gy Vance, N¥. Dal NBWS (June 18, 2019), htps:perma coPQGE-BV3I. © NYSBOB Public Report System: Contributions By Recipient, NY. Stat Bb. BLvctioys, hutpseiperma celVQB6-QMIB (ontch in "Candidate Name” search bar for “Alvin Bragg ~ Disteict Attorney": thon search inthe search bar fo "Bains 8 Chiraag, Bains, PAUL & DAISY SOROS FHAAONSHIMS FOR NEW AMERICANS, hitp/iprma

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