8/13/2019 9-12-12 MEC Ethics Violation Complaint
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Parties:
Jefferson County Republican Central Committee (JCRCC) MEC
ID:C000983Voters for Good Government (VGG) MEC ID:C021020Janet
Engelbach 3489 LINHORST RD HILLSBORO MO 63050 (636) 475-6328George
Engelbach 3489 LINHORST RD HILLSBORO MO 63050 (636) 475-6328Leslie
HansonTreasurer of JCRCC PO BOX 284 HIGH RIDGE MO 63049 Hm (636)
376-3378 Wk
(314) 605-9894William Hardin IV -- Treasurer of VGG 3396
Cottonwood Dr St Charles Mo 63301 (636) 578-3496
Facts:1. George and Janet Engelbach were both candidates on the
2012 Republican Primary Ballot.
Janet as candidate in August 7thprimary for committeewoman.
George as candidate on August 7thprimary for committeeman and for
county council.
2. In the days leading up to this election, Voters for Good
Government paid for a mailing thatsupported George, Janet and other
candidates for the 2012 Republican Primary.
(A scanned copy of the mailing is provided)
3. George and Janet Engelbach are both members of the JCRCC.4.
Janet Engelbach is, and was, the Chairman of the JCRCC at the time
of the financial
transactions which are the subject of this complaint.
Timeline of known facts:
1. July 10, 2012- Jefferson County Republican Central Committee
authorizes the transfer of$5,000 to a newly created PAC which they
also control called Jefferson County Organization to
Reinforce Citizen Awareness (JCORCA) PAC MEC ID:C121401
2. July 26, 2012George Engelbach makes a reported contribution
to Voters for GoodGovernment (VGG) in the amount of $3,400
3. July 28, 2012VGG makes two reported expenditures ($2,594.75
for design and printing and$756.50 for postage) totaling
$3,351.25
4. August 16, 2012The Jefferson County Republican Central
Committee (JCRCC) makes areported expenditure to Janet Engelbach
for an election mailing in the amount of $3,400
Allegations:
George and Janet Engelbach colluded to receive and make
contributions in a manner as to conceal theidentity of the actual
source of the contribution in violation of Section 130.031, and
attempted andactually did control and direct two continuing
committees to the benefit of their own campaigns as isdescribed and
prohibited in MEC Opinion No. 2003.07.104.
If the JCRCC intended to pay for political mailings for
candidates, then the JCRCC should have doneso directly rather than
try to juggle funds between accounts and individuals calling them
contributions,
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8/13/2019 9-12-12 MEC Ethics Violation Complaint
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$5,000 to the approved Committee, Chairwoman Janet Engelbach and
member and husband GeorgeEngelbach then colluded to "disburse and
launder the funds without the consent of the full body, toVGG, by
issuance of a check drafted from the JCRCC Account payable to Janet
Engelbach, who thenliquidated those funds, transferred them to
George, who then contributed them to Voters for GoodGovernment in
his own name, with the intent of concealing their origin. These
funds were thenexpended, as seen on the 24 hour expenditure report
on 7/29, by the VGG in support of the candidaciesof George
Engelbach, Janet Engelbach, John Gebel, Dwight Vermette, Diane Bast
Berberich, KenHollenberg, Linda VanDeRiet, David Courtway, Teresa
Kreitler, Gerald Bollinger, Janet Bollinger, andAngela Alter-Wren
who are all voting members of the JCRCC. As such, the use of the
funds for suchan expenditure by the JCRCC would be a gross blatant
violation of Missouri Ethics Law per MECOpinion No. 2003.07.104, so
instead, they chose to intentionally conceal the origin of the
funds, inviolation of RSMO Section 130.031, in order to attempt to
circumvent the letter and spirit of the law.
Due to there being no record of the body of the JCRCC approving
the expense or disbursement of acheck directly to Janet Engelbach
for the purpose of reimbursing George Engelbach for the funds
heprovided to Voters for Good Government PAC , this would seem to
constitute theft from the JCRCC.And as such, combined with the fact
that the funds misappropriated were in the amount of $3400 andthe
check was cashed and then the cash was transferred to George
Engelbach to shield and conceal theorigin of the funds, this would
seem to meet the statutory requirement for "criminal activity", and
assuch violates RSMO 574.105.2(2), as the proceeds from a criminal
act were then laundered with theintent to conceal their
origin,ultimately in an attempt to make an expenditure which would
otherwisehave been illegal had the actual source of the funds been
known.
ConclusionGeorge and Janet Engelbach coerced, controlled and
directed the VGG and JCRCCPolitical Action Committees for the
benefit of their own personal campaigns and colluded toreceive and
make contributions in such a manner as to launder the money and
conceal the identityof the actual source of the contribution to
allow for a use of the funds (support of select JCRCCcandidates)
which would have otherwise been prohibited by law per MEC Opinion
No.2003.07.104. had the funds been expended by JCRCC PAC. These
actions are clearly inviolation of Section 130.0313 RSMO, Section
574.105.2(2) RSMO and MEC Opinion No.2003.07.104.
