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FLORIDA ELECTIONS COMMISSION REPORT OF INVESTIGATION
Case No.: FEC 15-372
Respondent: Raquel A. Regalado Counsel for Respondent: Roland Sanchez-Medina, Jr.
Complainant: Darren Centinella Counsel for Complainant: Elliot S. Berke
On June 29, 2015, the Florida Elections Commission received a sworn complaint alleging that Respondent violated Chapter 106, Florida Statutes. Commission staff investigated whether Respondent violated the following statute:
Section 106.19(1 )(a), Florida Statutes, prohibiting a person or organiZation from accepting a contribution in excess of the legal limits.
I. Preliminary Information:
1. Respondent is a 2016 candidate for the office of Mayor for Miami-Dade County. There are five other candidates in the race including incumbent candidate, Carlos Gimenez. Respondent is not a first-time candidate. In 2010, she was elected to the school board. In 2014, she was re-elected, unopposed. In 2002, Respondent was admitted to the Florida Bar.
2. On March 9, 2015, Respondent filed her Appointment of Campaign Treasurer and Designation of Campaign Depository for Candidates (DS-DE) form. Respondent named Carlos M. Trueba as her treasurer. To review the DS-DE 9 form, refer to Exhibit 1.
3. investigation. investigation.
Respondent was represented by Roland Sanchez-Medina, Jr. during this Michael Montiel, another attorney with the firm, also assisted during the
4. Serving Miamians is an active electioneering communication organization (ECO) registered with the Division of Elections. Roland Sanchez-Medina. Jr. is listed as its chairman and Carlos M. Trueba (Respondent's treasurer) is listed as its treasurer. To review the printout from the Division of Elections website, refer to Exhibit 2.
5. Complainant is the digital communications manager for American Commitment based in Washington, D.C. He has been involved with a number of election campaigns including the 2012 Romney for President Campaign.
II. Alleged Violation of Section 106.19(l)(a), Florida Statutes:
6,, I investigated whether Respondent violated this section of the election laws by accepting an excessive in-kind contribution from Serving Miamians.
7. According to Complainant, Respondent accepted an excessive in-kind contribution from Serving Miamians in the form of her campaign website and a campaign video, which contained express advocacy that supported her campaign. To review the printout of the website, refer to Exhibit 3.
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8. Complainant provided a printed copy of Respondent's webpage. It appears to contain a button from a video; however, Complainant did not include a copy of the video. The webpage states, "Raquel Regalado for Miami-Dade County Mayor." The disclaimer reads, "Paid and approved by Serving Miamians."
9. According to the Division of Elections website, Serving Miamians disclosed two expenditures on its 2015 M3 Report to "Ennovva, Inc." The information on the 2015 M3 Report revealed that the two expenditures occurred on March 10, 2015; one for $1500 for "Web Design" and one for $3580 for "Advertising Production." To review the printout of the expenditures from the 2015 M3 Report from the Division of Elections website, refer to Exhibit 4.
10. Respondent's attorney, Mr. Sanchez-Medina, filed a response on behalf of Respondent. He stated that Serving Miamians, ECO,
Mistakenly engaged Ennovva, Inc. (the Vendor) to design the website for www.raquelregalado .. com.... The Vendor has since returned the funds to Serving Miamians ... Ms. Regalado's [Respondent] campaign account has since paid the Vendor for the work performed, as well as an extra fee for changing the disclaimers on the video found on the Website, and removing all references to Serving Miamians, both on the Website and in the video.
Currently, the Website is offline and any visitors will find a message with states that the Website is under construction.
To review the written statement, refer to Exhibit 5 .. To review the refund check, refer to Exhibit 6 ..
11. The table below is a time line of events regarding the publication of Respondent's website.
03/09/15 Website, ~~_ww.raquelregalado.ccom, went live 3
03/09/15 Respondent filed her DS-DE 9
03110/15 Serving Miamians pays vendor 7
03/12/15 CTR shows Respondent's first contribution for $250 8
04/02/15 Complainant printed copy of website 3
06/25/16 Complainant swore to the complaint
06/29/15 FEC received complaint
09/04/15 Copy of website provided by R's attorney 5, page 3
09/25/15 · CTR shows Respondent pays vendor 9
01/21/16 I printed Respondent's website 10
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12. According to Respondent, she did not become aware of the website until she received the letter from the Florida Elections Commission regarding the complaint. When asked if she reviewed the video before it was posted on the website, Respondent replied, "though I appear in the video, I had not reviewed the final product." Respondent also stated that she did not discuss the website with any of the officers or members of Serving Miamians. To review Respondent's affidavit, refer to Exhibit 11.
13. When asked what actions were taken to prevent visitors from accessing the website, Respondent replied, "The Website was not intended to be viewed by any visitors during the time the video was posted. Upon receipt of the letter from the Florida Elections Commission dated June 30, 2015, I contacted Ennova (sic), Inc. and demanded that the video and the website be taken offline immediately." To review Respondent's affidavit, refer to Exhibit 11.
14. According to Mr. Roland Sanchez-Medina, the ECO's chairman, the ECO did not pay for advertising. ML Sanchez-Medina stated that the ECO paid for the web design and the creation of one video.. He stated that the officers and members of the ECO did not discuss the website with Respondent. To review Mr. Sanchez-Medina's affidavit, refer to Exhibit 12.
15. When questioned about who reviewed and approved the website, Mr. Sanchez-Medina stated,
The Website had not been approved or reviewed. As referenced in the letter above, the website was in a period of initial construction and was not intended to go "live" at the time of posting of the video. The Website was not completed and no content was available on Website. To my knowledge, Ennovva, Inc. was in the process of testing the design and connectivity of the website at the time the video was erroneously uploaded.
To review Mr. Sanchez-Medina's affidavit, refer to Exhibit 12. To review the website, refer to Exhibit 3 ..
16. When asked why the ECO published the website, Mr. Sanchez-Medina stated,
Servicing Miamians was in the process of publishing a new website about Raquel Regalado in conformity with IRS rules and regulations.. Serving Miamians has been informing Miami-Dade County residents regarding Raquel Regalado and Tomas Regalado for five (5) years. The language included in the video requesting support for Ms. Regalado was simply a mistake, as the intent of the video was to educate Miami-Dade County regarding various issues. The video was immediately removed from the Website.
To review Mr .. Sanchez-Medina's affidavit, refer to Exhibit 12 .. To review the website, refer to Exhibit 3.
17. Invoices provided by Mr. Sanchez-Medina show that the video was filmed and edited on February 26, 2015, March 5, 2015 and March 6, 2015. The cost for the video was $3,580 .. 00 .. The invoice for the web design shows a cost of $3000; half due up front and half due at the completion of the website. To review the invoices, refer to Exhibit 13.
18.. Serving Miamians issued two checks on March 10, 2015; one for $3580 and one for $1500. On September 25, 2015, Ennovva, Inc .. issued a check to Serving Miamians for $5080.. (The Commission received the complaint on June 29, 2015.) To review copies of the
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checks, refer to Exhibit 7.
19. Mr. Sanchez-Medina also stated on his affidavit that Ms. Amelie Ferro was responsible for the verbiage on the website. I called Ms. Ferro to query about whether Respondent assisted with the development of the website. During a telephone interview, she stated that she preferred for me to send her my questions in writing via email. I emailed the questions to Ms. Ferro: however, she did not respond. To review my email to Ms. Ferro, refer to Exhibit 14.
20. I requested that Respondent's attorney provide copies of the checks issued from Respondent's campaign to Ennovva, Inc. (the vendor); however, the checks were never provided. I subpoenaed bank records from the bank listed on Respondent's DS-DE 9, City National Bank; however, the bank stated that they could not find an account in Respondent's name.
21. I subpoenaed the ECO's bank records. The bank records confirmed that the ECO issued the checks to Ennovva, Inc. on March 10, 2015. Ennovva, Inc. issued a refund check to the ECO on September 25, 2015. To review the bank records, refer to Exhibit 15.
22.. No record of Respondent having previously violated this section of the election laws was found.
III. FEC History:
23.. Respondent was named in FEC 12-041 that alleged a violation of Section 106.07(5), Florida Statutes. Respondent entered a pre-probable cause consent order and paid a $2,000 fine on March 9, 2012. Respondent was also named in FEC 12-087; however, it was deemed legally insufficient
Conclusion:
24. On June 16, 2016, I interviewed Mr. Montiel, Respondent's attorney, by telephone. He stated that the entire thing was a "mix-up" because the vendor really didn't understand the election process. He stated that Ennovva (vendor) didn't realize that the ECO and the candidate had different rules and restrictions. He added that Ennovva told them that they were using the website as a test site. He stated that they (the ECO) were not aware of the test site. He added that they were not aware that the website was "live" until they received the notification from the Florida Election Commission. He stated that the invoice shows that half of the cost is required up front and the remaining balance is due upon completion; the ECO never paid the remaining balance because it was their understanding that the website was incomplete.
25. Respondent's filing officer is the Miami-Dade Supervisor of Elections. According to the Affidavit of Filing Officer, Respondent was not a first-time candidate. According to the affidavit, Respondent was initially elected to the County School Board, District 6, in 2010. In 2014, she was unopposed. The filing officer stated that Respondent received copies of Chapters 104 and 106, Florida Statutes, and the 2016 Candidate and Campaign Treasurer Handbook. To review the Affidavit of Filing Officer, refer to Exhibit 16.
26. Respondent acknowledged receiving copies of Chapter 106, Florida Statutes and the Candidate and Campaign Treasurer Handbook. She stated that she served as treasurer for Tomas Regalado's mayoral campaign in 2008.. When asked what actions she had taken to determine her responsibilities under Florida's election law, Respondent stated, "I am a constitutionally elected official." To review Respondent's affidavit, refer to Exhibit 11.
27. On March 9, 2015, Respondent filed the Statement Candidate form certifying that
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she had been provided access to read and understand the requirements of Chapter 106, Florida Statutes. To review the statement of candidate, refer to Exhibit 17.
The Honorable Raquel Regalado 1985 NW 88th Court, Suite 101 Doral, Florida 33172
Roland Sanchez-Medina, Jr. SM & GQ Attorneys at Law 201 Alhambra Circle, Suite 1205 Coral Gables, Florida 33134-5107
Ms. Christina White Miami-Dade Supervisor of Elections Post Office Box 521550 Miami, Florida 33152-1550
Copy furnished to:
Mr. David Flagg, Investigator Manager
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Respectfully submitted on June 17, 2016.
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Mr. Darren Centinello c/o Berke Farah LLP 1200 New Hampshire Ave. NW, Suite 800 Washington, DC 20036
Elliot S. Berke, Esquire, Managing Partner Berke Farah, LLP 1200 New Hampshire, NW, Suite 800 Washington, DC 20036
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Exhibit 1
Exhibit 2
Exhibit 3
Exhibit 4
Exhibit 5
Exhibit 6
Exhibit 7
Exhibit 8
Exhibit 9
Exhibit 10
Exhibit 11
Exhibit 12
Exhibit 13
Exhibit 14
Exhibit 15
Exhibit 16
Exhibit 17
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FLORIDA ELECTIONS COMMISSION REPORT OF INVESTIGATION
Raquel Regalado -- FEC 15-372
DS-DE 9 Form
Printout from the Division of Elections Website
Printout of Website
Written Statement from the Attorney
ECO's 2015 M3 Report Expenditures
Refund Check
ECO's Checks to Vendor
2015 M3 Report
2015 M9 Report
Website Printout
Respondent's Affidavit
Mr. Sanchez-Medina Affidavit
Invoices
Email to Ms. Ferro
Bank Records
Affidavit of Filing Officers
Statement of Candidate
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APPOINTMENT OF CAMPAIGN TREASURER AND DESIGNATION OF CAMPAIGN DEPOSITORY FOR CANDIDATES
(Section 106 .. 021(1), F S)
(PLEASE PRINT OR TYPE)
NOTE: This form must be on file with the qualifying officer before opening the campaign account.
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2015 MAR ~9 AM IQ: t 8
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•. ~yHECK APPROPRIATE BOX(ES):
. U-'·--l.r@al Filing of Form Re-filing to Change: D Treasurer/Deputy D Depository 0
OFFICE USE ONLY
Office D Party
2 Name of Candidate (in this order: First, Middle, Last) 3. Address (include post office box or street, city, state, zip
Raquel A Regalado code) --·-·--···--··---~-----·-------! 1850 SW 36th Avenue 4. Telephone 5. E-mail address Miami, FL 33145 ( 305 ) 593·-2644 [email protected]~ ·----·-------~·-----·--------·---'--~c··--·-·------·····-··-·-·---------·---6. Office sought (include district, circuit, group number)
Miami··Dade County Mayor
7. If a candidate for a nonpartisan office, check if applicable:
D My intent is to run as a Write-In candidate. -·--------------·------·---------------~·------·----·-----------·------------
8. If a candidate for a partisan office, check block and fill in name of party as applicable: My intent is to run as a
0 Write .. ln [] No Party Affiliation 0 -----.. ------··--·-------·-·-·Party candidate
9. I have appointed the following person to act as my lZJ Campaign Treasurer 0 Deputy Treasurer ---··-- ·---------... ···--·-----------·
10. Name of Treasurer or Deputy Treasurer
Carlos M. Trueba
11;8~~: ;~~~~~ - ~ ··-=_J2~~::~h;;_::---·-· 13 .. City 14 .. County 15 .. State 16 Zip Code 17 E-mail address
Doral Miami-Dade FL 33172 [email protected]
UNDER PEt,.Jf.~ Tl.~S Of PERJURY, I .DESf;;~~:~:A'T I HAVE READ THE FOREGOING FORM FOR APPOINTMENT OF CAMPAIGN TREASURER AND '~· '°"' '" . ' bESIGNA'libN~f!?(:i)'.'~pAJGN DEPOSITORY AND THAT THE FACTS STATED IN IT ARE TRUE.
11-2-5--D-at-e----·~·· 11 • 1
., • ,;z:·.···..:+..4-·~' ~·· ----·-----,-2-6-.. -§9Jirui·~~~··~· ;_(i-~~~~-§.:.--~;;;;;;;;;;;;;;:---------·-0 \ '· . - .. - ,: ' .· . ,, , ..... - i.i .. -;;;-· / -~l:.·~-;;r---·-
21
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~ ~ "71'"') I\---~ ... ...... d.. A ,--'J " -- ] :.~O ~;oei'Jt1ts~E#11.S A.6'~tiniee of Appointment (fill in th; blanks a'nd check the appropriate block)
~!@3M. Trueba ·-----.. ----------· , do hereby accept the appointment
Alli~ '' l 1 'IN..:, '"' (fii@cki~W¥rht-or Type Name)
designated-above a-:;·,, .. v;·,;,.,.;,@' · --eampaign Treasurer O (:'C:_.-_~::: ....... -~--1f-:7'~~: .~" ,-,,xw<! _X ___ S_i_g_r-)a-tu-re-of_C_a_m_p_a-ig-~-·-,__. re_a_s-ur-·e-r-or--D-e_p_u-ty-T-re_a_s-ur_e_r -·--
OS-DE 9 (Rev. 10/10) Rule 1$-2.0001, F.A.C.
EXHIBIT_-""'---
Committee Tracking systen;i - Florida Division of Elections - Departµ:ient of State / ( .
Committee Tracking System·
Serving Miamians
Type: Electioneering Communications Organization
Status:Active
Address:1985 Northwest 88th Court
Suite 101
Doral, FL 33172
Phone: (305 )593-2644
Chairperson:Roland Sanchez-Medina
Treasurer:Carlos Trueba
1985 Northwest 88th Court
Suite 101
Doral, FL 33172
Registered Agent:Parker D Thomson
Purpose:
Affiliates:
200 South Biscayne Boulevard
Suite 400
Miami, FL 331310000
Finance Activity
EXHIBIT _ __.8'.___ __
http://dos.elections.myflorida.com/committees/ComDetail.asp?account=60265
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6/16/2016
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-··-------·· .. ·--·--·--r'<'--"-»>--............. ~ ..... , ........ --·---~.:-----··"··-·-~ . ... ~"""'---~--- .. ···~--~-·.-·-·-···-·-----
out I:laqu.~J aegalad.o Raquel Reg~lado l$ a lifelong r~slq~nt of the Miami-Dade County School Board
Distrt.ct a, whith encompasses tne areas tifKey Blscayne, the Roads, East uttre Hava.na, $hemmcioah, Sllw~r Bluff; Cqconut Grove. Coral Gable.~, south Miami and
Wast~hester. Ort the Board, Ms. Regala.dp ppatrs the Facilities and Consttuctic:m
Reform Committee; and serves as a member of the Instructional Excellence. & • . .- .. , ' ' . ., : ., . .,<. ' . ~ ·, ' • , . . ' ' ·.. ' .' . . . •
Gf.imrriunity Eng~gemeht Schoo1 $1.lppott & Acc~l!ntttoillty. and 1nnov~tio11,
EXHIBIT
R;ll;Qti~ R!!CJAlADG I fl>i: Mia~l Dad,tl Ci>~ntvMavy.r I
p~~!l€If~ ~~ 't@~Ph t,fl~ b~C$ of compµter pro~remlng. also 1<119w11 as Code. to all
MP~P$,sttl4f~ntsAA$. ~egaI$¢h;? nti$ ~l~m tirgariized several !aw daY$ throughout
th~ ~tmt~ f<>r ~~1derits ~nd p~retlt$ to me~t wtth pro bano attorney$ ~ru:l ... ··. :.·.·· ..• . •' . ' . ,. .•. ' .'<". . .
~~rr1m,ent~~~rt¢1es Where p$'tttctp~fu$ r~af\la atiVice regarding issues ranging
frpm :fqr~plq~µre ~ng i~ndl'ord t~nanttl~ht$t(J ~isaf;lility benefits.
ff.,~ ~ Scff!l91 '~P~t~ Mem~et ~h~ h~$ ~\lB,4 'mt:l W$Y fer Hti provements ln tiisttict wide traris~e~tton and brougl'lho ttie board a ffveyear pfain which r~ultl?d In
~me ~pf~tzemeflt C>f ol~ ~ml inefficient ~cliqa! bµses with energy efficient bt!Set:i
ttiat ax~ed the Sli~te's safety l"e:qufreme:nts; As a mern ber of th~ sot;rtl:teast
Ft~tilii8 Reginfiial Partn~rshtp Exe'c(!tive committee~ $he Fief ped de\fise the
severiso plan to secure the economic future and improving the quality orlfre tn tn~ s$~t1;..~tJ.unty tt\gfqn ¢~rf1prJslng M9rttoe. Miamt~oaae, Brow~rd, Palm i3e~chi
Marifn, st. Lucie arid Illdlan River cotil1t1es dwring the next ~O yea~ and beyond~
Afth~ n~tlqn~l lavel. Ms. Re~f;llado ~as partJcip~t~(:l rn pr0:grams rega-rt!lng
comp,reheos!ve 'fmmlgratibfl i~fotm a;htf the scihbdl districts role in asslmll~tron
a.n,g Engllsh l@mfag, As a board memb~r Of the National ASsoc.fation of Latino
Elect~d and Appointed officials CNAJ.EO) Ms. Re~alado has spoken natiottalty on
the need for immigration reform and on jt:Jvenne justice and the ben~fits of
Florrda1s cMf ¢itatioh ~.ltemative. As a Hlspanlc English learner. Ms. Regalado has
also been an aqvoc~te for bflingual et,iupatJon, a frequent speaker at conferences to $¢ll~1n pt.i~U~ edubatioh tr~tn an EngUsh learner$' perspective, debunk the
myth that tl1f$liSh i~am~rs are not t1cadernic ~chfevers; and champion~d the
important rote that bilingual equcatlon wm have In l=!orlda's new economy.
A graduate af Coral Gables High, Ms. Regalado attended Miami-Dade Community
Collegi;i a.nd then Florid~ lnternatlon~I University •. earning a degree ln Liberal
Studies With hor1ors, earning a Juris Doctorate degree from St Thomas University
~pheol of Law, At St. Thom~sj she WP1s the recipient of the Florida Bar's Young
Lawyers Division Scholarah!p and wtnner oftheSt ihomas University Schoof of
L~w c. Clyde Atkins Memorial Mo.at court Competition and Amerlcan Trial
Lawyers Associatrbn Open/Cfos.e competitlon. Ms. Rega la.do was a memb13r of the
St. Thema$ U!IW Revi~w and the Moot Court T~am.
Ms. Regalado is admitted to practice law in Florida state courts and in the United
EXHIBIT
G:a@jn~JJ~l~~~~~~O.to~:. :;:::;::.~:;;!\!~*".'.. • Q;1t1U. ~IQ':liH1l l'*!m P.<:ilr.k tA<lnm. St. t11t::1{· 1H1rl lflcttartRWet COI!lltit::. tlunng lhe t!Oh! SO yeais ,1rr(l tle'\'l'lfltl.
A; tho n.1tio;•at tcvr:t Ms. Rcgai;nlo has µu11n:1pamd m pr<?£1;lfl)? t~arclmg comprt>Mns1ve ;;nrn1{tr.auoa !'(>!mm M1tl i!Y.: scl10:ll
drswcts n:dC m 11ss1m!l~tion <.•nrl Engl1sn 1e:m0mg M a bcmnl mcmiiu1 ni 11¥.i t<L1;mn;il f!.r.sn::rnllnf• o! l;it1no Bocwd ;uul Ao1w:w111:ti
Olfitiafs f1*Alf:Ol Mi;. He~'\lnoo ti,-n; 'Sf;!pk<m.!~llt!\)M!l'{'01'l the nea<l lot 1mni<gaitmn rntnnn mod <ITT Jll\ltltll!e JUSIH:u ;ind !h~ ueooltl> of
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i:;1mu~ "' :t(!{lrne m uber.;I swaic~ wall l'li>imrs. Mmmg a Jurts frru:h11;11l: o~reo uom SI. 'fn{lm,"ls Ul\:11c1sw; StMOI ct 1.t1.-r. A; Sl.
\'\;~Hnr.s. £t.r: \'111$ tne l&lf!l<'!lt nt it'.$ fh"Jr!da ufl(S"fl:l1tllU,LWJV1\IS Dl!(J&rl:l Str.r>l;w,;.ltjfl aml \'.'lmlf:f 01 tnc SL Tt10ntl1: ll!lWi'.!!Slty SCIW!Ol
or lilW C. r.tl'(le Atkins Memon;;! Moor f.'Q<.H1 C<impoillm~ ond N;wac;in fn.:tt wwyers Assot•<inoo Qpan;t1osa Compe11Hcn. Ms.
~i:<ga!Mlo was i'\ 1¥100\!mttil lht'. ::.1. 11w1ih•~ L:!w :Revww <'l'ltl !ht Moot <:0011 ·nwm
:.ts. <?i::g111;1do is aomntm'l m prnct1en tiw1111 flo11d<1 s1t1ti'.:' courts .«no tn me: 1.1111100 suncs Oh>tt!Ct Cou1t f-Ot 1f1c ':><:Mhi:ttn !J1s1nct 01
?l-Orrd'1. l;J$, Rcg{'tt:aoo 1:> 110 t.clivc f!tl?moc·r ()< sever<i! tmr nssccmtrons. mt;tvdmg the Amencnn ~()1 As:scc1ti1mrt Cul'.liln Am.cni::oo &ti
A:>soo~1101't.. am:hs ~ti& nl\imb!:r OI tr«! 1111~K<tuill ?toperty l;iw Msoc1i/lt1on {It noncll:i. SIW: WM! an AtlJlllliCl f'r<Jte:isru •.14 £.(!Sl.OO>ss taw ,1t Mrnnu D;m~ toH<::gc-. Vl<l!!sm1 tatrtpvs. Ms. Rogaitltlo was li'lltled a P.mng s;;:u m 1mcucr:iu;it Proof.'rtY ~1t1gvtron b';' nem:ia Trnncl
mllsil:N1t" it!'\~ n.nrmuf tllllOJlg the !Op .HJ llllcmcys 111 Mm1m·l!!1dC COW~l\' vndci 1\0 years Q1(1 by Jlte C't'S!tc fl!lrnS!S fOO!tllr>!!O•t.
su~cc 2009. Ms. flt.«g~{lu hns comJucioo" tli!ilY Sl);}n1:m 1angm1g0 w<l10 pmgram on lil P(l(loiosil. ~!O AM. dectic<11er1to1flio1rn1ng
'.iS!CfiCI!. i!llt.lll! hn:nl OO!tt1ts.10tluc;r11-0n i\ntl socml iiCflllO:S. /\nmhN IJl ill!! j)ll\JC<l!l IS ESJ,'I ScmH!WtCOO Ra{Juc;, a ~·ro<:!d\i le!C">'!S!(t:I
si1oww11h jID\lt1c1ii unti nc-i.'Js Jit1i1!ys15, ;u1mr; on ieif:mmrrn 1nw11g!1out Hie s;ste 01 f!nm1n. lalmvtow lto:n i:£!il scmimn t-On 1t:i<1ttc!
t:llil ne S{:N'< nn htti:rJlwi'fl,Y.yootub~.com/m-Or1Raquef1u1!l()gatc3dO/vldoos. Ms. ncgnlndo also ~mtes !or £1 hlut"llU He1;1!el ilntl llm
!!t:llin~um r>:is1 ;mt! llM cc11:nllu1~1 Ju !Jl(? Mwrm l!erntr.. El Omn(J m: !;1s. Arncni:a:. tlf)(C. L!b~micf ;inti curnrrmntly ?apet:. tti•wns
w11ttor1 ti(YJ.N\~ 01 ;iH1clcs. !?tr 1;iw::.r 91;c\, i:1111 l.ll:? ioul'ld on llnp:!/mque!tegarndoopinims.blogspol.etim/ flm111y. Ms. Rc;;.alnoo t<; r,
mal\l i.x:t o! m~ Com01uru1y i.iWl!;('l;y ~1r<101 WL~. Chnnruil 11. m !.'.:arm. f'kmmt.
Ms. ?.CI!illl1dt:HS the prntitl mo!hm N twfr c:tu<omn ;imJ the tlatigllwr o! Tomas ll.eg;il?:•o. Inc M;1yo1 o! me C11y of M1t1m1.
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I-= 00 -~
Campaign Expenditures - Division of Elections - Florida Department of State
Campaign Expenditures Serving Miamians
Florida Department of State Division of Elections
Page 1of1
This information 1s being provided as a convenience to the p_ublic, has been processed by the Div1s1on of Elections ana should be cross referenced with the onginal report on flle with the Div1s1on of Elections in case of questions. About the Campaign Finance Data Base
Rpt Yr Rpt Type Date
2015 M3 2015 M3 2015 M3 2015 M3 2015 M3
03/10/2015 03/10/2015 03/10/2015 03/17/2015 03/23/2015
5 Expenditure(sJ Selected
Amount Expense Paid To
1,500.00 ENNOVVA INC. 3,580.00 ENNOVVA INC.
350.00 RODRIGUEZ, TRUEBA ~ CO., CPA 10,000.00 BRifu~ ANDREWS USA, LLC
5, 000. 00 REGALADO JOSE L
20,430.00
Address
100 N BISCAYNE BLVD, SUITE 2906 100 N BISCAYNE BLVD, SUITE 2906 1985 NW 88TH COURT, SUITE #101 255 MOCKINGBIRD TRAIL 2424 SW 20TH STREET
Query the Campaign Finance Data Base
City State Zip
MIAMI I, FL 33132 MIAMI!, FL 33132 DORAL, FL 33172 PALM BEACH, FL 33480 MIAMI, FL 33i45
[Department of State! [Div1s1on of Elections! [Candidates and Races] !Campaign Finance lnformat1on1
http://dos.elections.myflorida.com/cgi-bin/TreFin.exe
Purpose
WEB DESIGN ADVERTISING PRODUCTION ACCOUNTING o REPORTING SERVICES MARKETING CONSULTING SOCIAL MEDIA
1/21/2016
~
..... as s: x w
ATTORNEYS AT LAW
September 4, 2015
Via Certified Mail Return Receipt Requested
Erin R.iley Deputy Agency Clerk Florida Elections Commission 107 W. Gaines Street Suite 224 Tallahassee, FL 32399
Re: Case No.: FEC-15-372; Respondent: Raquel Regalado
Ms. Riley:
This correspondence is in response to the letter from the Flodda Elections Commission ("FEC") dated June 30, 2015 (the "FEC Letter"). Ms. Regalado has addressed all of the issued and concerns found in the FEC Letter .. Please see Ms. Regalado's response to the FEC Letter, attached hereto. If you have any questions, please contact me directly at 305.377.1000.
el:RSM
Copy to: Raquel Regalado (Via E-mail) Michael Montiel
Sincerely,
Roland Sanchez-Medina, Jr
EXHIBIT ;) ~0e I ~ _; SANCHEZ MEDINA. GONZALEZ, QUESADA, LAGE, CRESPO, GOMEZ, MACHADO£~~ PREIRA LLP i SMGO.LA'N COM
201 ALHAMBRA CIRCLE SUITE 1205 CORAL GABLES FL33134-5107 I TEL: 305 .. 377 1000 I FAX: 305.424.0237 I TOLL FREE: 855 213 4806
(
RAQUEL REGALADO'S RESPONSE TO THE FEC LETTER
Serving Miamians, an Electioneering Communications Organization ("ECO") mistakenly engaged Ennovva, Inc (the "Vendor") to design the website for :xvww"rfill.uelregalado"!,:_Qm (the "Website"). Serving Miamians contacted the Vendor regarding this error in order to take steps to correct the error. The Vendor has since returned the funds to Serving Miarnians. The refund will be reflected in the September ECO report and will be provided to the FEC Furthermore, Ms. Regalado' s campaign account has since paid the Vendor for the work performed, as well as an extra fee for changing the disclaimers on the video found on the Website, and removing all references to Serving Miamians, both on the Website and in the video. 11lis will also be reflected in Ms. Regalado' s September campaign report which will be provided to the FEC when it is due on October 10, 2015. Some of the confusion in connection with the error was likely caused by the fact that Serving Miamians intended to engage the Vendor to create videos which are in furtherance of its purpose as an ECO.
The Website, although "live" on March 9, 2015, was never fully completed by the Vendor. In fact, the Vendor's bill for the creation of the Website indicates that the Website was still currently under construction at the time it went "live". As such, it was never the intention of Serving Miamians, nor Ms. Regalado, for the Website to be accessed by visitors, nor to serve as a campaign advertisement for Ms. Regalado's campaign.. The Website was simply a "landing page" as opposed to an advertised or marketed website.
Currently, the Website is offline and any visitors will find a message which states that the Website is under construction. The video which was previously featured on the Website is no longer accessible. Please see the screenshot of the Website attached hereto ..
As referenced above, Serving Miamians intends to continue to engage the Vendor for the creation of additional videos which fully comply with Florida law Despite Serving Miamians' unintentional mistake described above, moving forward Serving Miamians will continue to exist as an ECO. As the mistake has been corrected, Serving Miamians does not need to, and will not, register as a Political Committee. All acts undertaken by Serving Miamians in the future will be fully in accordance with its purpose as an ECO, in accordance with Florida law.
F: \General Clients \Raquel Regalado \RegaladoResponse ToFECdocx
EXHIBIT 5
www .. raquelregalado.com
< <
<J () []
( 1 \
I \I \ ( ( \ )·
i 11
fEXHIBIT _,_Wl/p:;,.__ __ _ ....,....,, _______ ··--·-·-- ..
-w====---~~~~~--~~~~~~~~~-~~~~~~~~~~~~--~ 0 SERVING MIAMIANS ECO"
1985 NW sen; CT #101 MIAMJ, FL 33172 .. 2648
PAY TO THE Ennovva Inc. OADEROF---·,--------------------
1146
3/1012015
l i
$ ~3.5a0.00 j Three Thousand Five Hundred Eighty and 001100•••••••00••"1 '" .. ""'"'"" .... • .......................... , .. d .... .
-------~- . --- 001.t..ARS ~
MEMO
1146
-r:.-..
Ennovva Inc. 100 N Biscayne Blvd,. Suile2906 Miami, FL33132
Invoice 00438
$3,SSO .. OO 3/13/2015
--------. -.:::J
EXHIBIT -_ .. 1 fk''" l ~ 1
(
P"'V1'0THE OROEA or
"SERVING MIAMIANS ECO" 1985 NW 8STH CT 1'1' 101 MIAM1. P .. 33172 ·2548
Ennovva Inc
/
(
=~ ..... ::;;·--··---~-;~-;, -·~- '-''ll.'\Q
31101::015
a s
J _ __::ne ~ousand_Flve HJndred and co11co ---------------------===---- OOUAAS ©
MEMO
1145
Ennowalnc 100 N Biscayne Blvd Suite2906 Miami, FL 33132
Invoice #0437
$1,500.00
I -~·_ .... ___ j
3/13/2015
(
CAMPAIGN TREASURER'S REPORT SUMMARY
(1) Raquel A.-~:-~!.~.~-<: ................... - ... - .......... ______ _ OFFICE USE ONLY ONL~INE SUBMISSIOI\T
[1086828) Name
(2) 1850 SW 36th Av_e_n_1:1.::. ....... --............ ---···-·----Submitted on:
Address·(number and street) 4/8/2015 11:34:17 (eastern)
Miami, FL 33145 ··----···--·-----· .. ·---··-------
City, Staie, Zip Code
0 Check here if address has changed
(4) Check appropriate box( es):
(3) JD Number: ________ 1 __ 4 __ 2_1 _____ J
I!! Candidate Office Sought: _ May~r-------------------------------0 Political Committee (PC) D Electioneering Communications Org .. (-ECO) D Party Executive Committee-(P'fY")
D Independent Expenditure (IE} (also covers an individual making electioneering communica.:ti.ons)
D Check here if PC or ECO has disbanded 0 Check here if PTY has disbanded 0 Check here if no other IE or EC reports will be filed
(5) Report. Identifiers
Cover Period: From 3 I 1 /_2015 To 3 I 31 12015 Reporttype: 15M03
~Original [] Amendment 0:...Special Election Report
(6) Contributions This Report
Cash & Checks $ 48' 310 00
Loans $ ' ' 0 00 ··~~--- ~----- --
Total Monetary $ 48' 310 00
ln··Kind r :. ,J ... '; .i ~ ... ... ' ,, . . ... . 0 00 ~ :, • .,J.t'~'"tld.•"\1!.·I' .~.!.~ ' ._............... ·-·-·--
· ·· ·~·~:1 ~Y:~·tr."~::l/or :~<~ ~:.r~1
~:-~- 1
, I ,> :::t:::.~fr'.-' :2 ·i•: "'.~ 1 ; ' ;>. ' • , , .... ~ .... ... :-1; . . _.~; ,.'i:··~ ... ~ .... ,.
(9) To::tru.: Nra~~t~iY c~HMoiitions'To Date ' .. ·, : ..
$ .. :..:.:~.1t:..... 1 . LA.§. , -~ 3 lo . o o ~~.,; ~ ''. . "" .... ,; . ..
(7) Expend~tures This Report
Monetary Expenditur-es $ '
0 -- ----
00
Transfers to Office Account $ 0 00
Total Monetary $ '
0 00 ................... -·---·
(8}- Other Distributions
$ _ .... --·-···" ' ........................... ' ....................... Q 00
(10) TOTAL Monetary Expenditures To Date
$ -·- '-···--' 0 00
.. : i'\ . •.• ... . (11) Certification It is a first degree misdemeanor for any person to falsify a public record (ss. 839.1"3, F .S.)
I certizy;J~ITT'.! tl9Y!1' exam;ii[ied 'this report and it is true, correct, and complete:
(Type name) .. --··--';:"'"1:'""':'"''"""''':"'1"'----:~------~-~--.---·-
0 lndividu<'ll ictniy for IE ~O "Treasurer .· · D Deputy Treasurer or electioneering comm )
x ------------·--------------Signature
DS-DE 12 {Rev .. 11/13)
EXHIBIT
(Type name)
0Candidate
x Signature
0 Chairperson (only for PC and PTY)
SEE REVERSE FOR INSTRUCTIONS
(
CAMPAIGN TREASURER'S REPORT - ITEMIZED C:ONTRlBUTiONS
(1) Name Raquel A Rega J ado {2) LD. Number 1421
3/1/2015 3/31/2015
(3) Cover Period t I through I I {4) Page 1 of 16
(SJ 0 (~) (B) . .(1(}) :(11)
D$te Full Name (6) (Last, SUffix, First; Middle',)
$eq.uence Str~.E:\t AdtJ.fE:\ss & Cdhtributor GoritribUtibn Jn.kffid +----~N_u.~m'-b~e_r ---+--·~C_ify~,_s_ta~t'-e_,_,._Z__,_iP_C~~o_,_d~e---+_T__,v+P·.'-,e"-+-~o~·c;~c~.U'~P.a~ti~·o_n-+ __ T~v-P ~e-· --+-D_e~15~c;_ri~p1t_io~n_. --;-A_m_e_n_dm_•e_r._t--r-- Amount
Regalado, Tomas P :t [city of CH $250. oc 3/12/2015 2424 sw 20th street ttiiami
, ___ / __ ~{ __ --<Miami, F.C 33145 mayor
1
Fourth Amended & 3/20/2015 Restated , ___ !~--~'----Declaration
2060 Biscayne Blvd
2
3/20/2015
2nd Floor Miami, FL 33137
Braman, Norman 2060 Biscayne Blvd
,__ _______ _.Miami, FL 33137
3
I
B ireal ~state
I f'.3.Uto peal er
CH
CH
3/20/2015 Braman, Irma
2.0.60 Biscayne Blvd Miami, FL 33137
I ~omemaker CH
f J t---------1
4
CH 13 f'.3.UtO
~ealer 312012015 ,. Braman\ C~dillac
~ 1nc., •. ,. / n ~ ''.''.:. ,;<9,@",~ispMM 8.lv.d
.• Miami, FL 33137
~ ' . .i. .... ,
l ' '
$1, ODO DC
$1, ODO OC
$1, 000 DI
$1,DDO .. DI
,__--'.--· -·-r.:;T'-1-'t. B"t;~ri'~:.~· ... -.:~~ -I----+--B-+--,,-_u_t_o----+-C-H------r--------+---·---+---$-1-, D-D-Ooc 312. 0;2·0,1·"'"'", .... ._ ... J;'f!W~f\., .. u,t;()., • nc .. ~
.J.,;;J ... , ' ' ;2·060 Brscayne' Bl'(ftt' dealer f 7 Miami, FI:;· 331.3 7 ! !
.~~ i~
6
J,,'\ ~- ........ ,. ···-····"· ... ··~··· Braman Hyundai,
3/20/2015 2060 Biscayne Blva'
____:!.:.:_: ..... ~._1._;_,_______ Ml ams. , ···FL 3.313 1
7
312012015 Braman .Mot.ors, 2060 )3isc.o.yne Blvd
I I Miami; ·FL 3313 7 r-~------~
8
B auto dealer
B auto dealer
CH
CH
bS-DE 13 (Rev .. 11113 ) SEE REVERSE FCiR INSTRUCTIONS AND CODE VALUES
EXHIBIT
$1, DOO DC
$1, DOO DI
CAMPAIGN TREASURER'S REPORT SUMMARY
(1) Raquel A .. Regalado
Name (2) 18 5 0 SW 3 6th Avenue
·-----Address (number and street) Miami, FL 33145
OFFICE USE ONLY IN.E SUBMI SS
[1092635]
Submitted on:
10/13/2015 09:49:21 (eastern) ________ ,, __ , _____ .... _ .. __________ _ City, State, Zip Code
0 Check here if address has changed (3) ID Number: --------· 1421 __
(4) Check appropriate box( es):
~ Candidate Office Sought: . May::_:_ ______ ·----·------··---·--·---·-·----···--------D Political Committee (PC) 0 Electioneering Communications Org .. (ECO) 0 Party Executive Committee (PTY) 0 Independent Expenditure (IE) (also covers an individual making electioneering communications)
0 Check here if PC or ECO has disbanded 0 Check her.e if PTY has disbanded 0 Check here if no other IE or EC reports will be filed
(5) Report Identifiers
Cover Period: From 9 I 1 I 2015 To 9 1 30 12015 Report Type: 15M09
89 Original 0Amendment [] Special Election Report
(6) Contributions This Report
Cash & Checks $ I 4 I 455 00 -·----·-·· ·--.. ·--·· --··--· ·-··-·-··
Loans $ I I 0 00 ... - ............. --.. ·--·· --· ---
Total Monetary $ I 4 , 455 00 ··-·"•"•···
__ .. ____ . ....... -.... -... ···-·--·
In-Kind $ ' ' 0 00
--- ----·- --.. -· -··-·-
(9) TOTAL Monetary Contributions To Date
$ -------· I -·~_Q_§... I - 5 6 ~ 0 0
(7) Expenditures This Report
Monetary Expenditures $ 15,402 .70
--···--- ... -·--··"-" ·---·--·-· ····--·-···-··
Transfers to Office Account $ ' ' 0 00
--·····- ·---- -- --
Total Monetary $ ' 15 ' 402 70
·---····- -·-- --- -·--
(8) Other Distributions $
·-·-....... -... I -----·- I _, ...... - .... .Q 00
(10) TOTAL Monetary Expenditures To Date
$ ---.. --- I 23 I 704 16
( 11) Certification It is a first degree misdemeanor for any person to falsify a public record (ss. 839.13, F.S.)
I certify that I have examined this report and it is true, correct, and complete:
(Type name) ---·-------------··---·--------0 Individual (only for IE D Treasurer 0 Deputy Treasurer or electioneering comm )
x Signature
OS-DE 12 (Rev .. 11/13)
EXHIBIT
(Type name)
0 Candidate D Chairperson (only for PC and PTY)
x ---····-·-------------·---·-Signature
SEE REVERSE FOR INSTRUCTIONS
(
CAMPAIGN TREASURER'S REPORT - ITEMIZED CONTRIBUTIC'iNS
{1) Name Raqnel A Regalado (2) 1.0. Number J42]
(3) Cover Peri.od 9/1/2015
J j
9/30/2015 thr.ough I I (4) Page 1 of 2
.{5) fl) (8) (9) (10) (11) (12)
Date Full Name (t)) (Last, Suffix, First, Middle)
Sequence Streiet Address & Contributor Contribution In-kind
.. ___ f\!_ll_J'!lbeL _______ -·-· _ _fJ!}'., __ §_t<¥_~_:?i_e__fod~----Wol f son, Ellen D
J:Y.P.~--·- OC£~~_()_!1 ________ T_ye_~--- _ _ ___ Q~~c:rlr_
CAMPAIGN TREASURER:;S REPORT- ITEMIZED ·CONTRIBUTIONS
11) Name __ RaqJJel A Regal ado
9/1/2015
(3) .Cd~er Period 1 I
.(~) (7)
D;ate Full Name (6) (last, Suffix, First, Mk.Idle)
Sequence Street Addres~~
-------~"'!_u_!!1_be~--------- ---~L~1§t~te, ~-~O~E;l __ Kaloti Metals &
9/30/2015 Logistics, t---····-····-·-··· '··--·········--··--·-·--'···-·····-···-····----···-! 5 5 NE 1 st St Y. e.E: t
Unit 34
9 Miami, FI. 33132
•(2) l.D. Number ___ --1.4_2.J__ __ _
9/30/2015 I I (4) Page 2 Of 2
(&) (9) (10) (12J
Contributor Contributibn In-kind Tv>Ye OccJ:P;ation ______ .IY::e~----- ___ Q~~Q~j_e!is>E__ Ame~~ent _ Amj_)tJrlt __
B logistics CH $750 oc
!------- --+----~-------·--·-----------~--··----+--------
I
_____ /_ ____ _!_ __ _
_ ! ___ I ___ _I
DS-DE 13 (Rev .. 11/13 ) SEE REVERSE .FOR INSTRUCTIONS AND CODE VALUES
EXHIBIT
(
CAMP'AIGN TREASURER'S REPORT - JTEM.IZE.D EXPENDITURE$ (1)Name_ Raquel A .. Regalado {2) l.D. Number 1421
9/1/2015 9/30/2015 (3)"Cover P·eriod __ 1_· __ 1_· __ through __ l __ /__ (4) P(Jge __ l ____ o"f ___ 2 ___ ,
(5) o.ate
(6.) Sequence Number
9/4[2015 LJ_L_
1
(7)
FUJI.Name (Last, Suffi')\, .First, Middle) · Street Ad~ress &
City, state, Zip Co.de
Mario's Kids Photo Studio, J 601 Le Jeune Rd Coral Gables, FL 33134
(~)
PJ,Jrpose (add Offfoe sought if
contribution to a candidate)
photography
(9} (1Q) {11}
Expenditure ryp:e Amendmi,rtt
MO $1, 388 7'
1---------+-------·------·-------·-1---------------------+-------1-------9/11/2015
2
9/12/2015
,___/_/ __ 3
Rodriguez Trueba & Co. CPA, 1985 NW 88th Court Suite 101 Doral, Fl 33172
Newwegg BusJ.ness, 17560 Rowland Street City of Industry, CA 91748
accounting & reporting services
check voided
MO $1, 275 oc
MO $-1, 566 ,, o:
1--=9....,.,,./1~5~/~2~0~1~5=-+-=B-o_r_c_e_g_u_e-.,-J~u-a_r_1--------+-c-a_m_p--a-i~g-n_w_o_r~k---1--~M~O=----'f--------11--·~~$-s-o-o-o~<
5 41 ~>W 4. 2nd Avenue.
I I Apt 126 f---"'----#.------1 Miami, Fl 3 3134
4
1--------+-------·----------t---------~1-------+-----1--------9/24/20l5 Outfront Media, outdoor MO $7,500.oc
8530 NW 23rd Street advertising
LL Dora.l, FL 33122
-- - --5
·---·--·------- ---------------·---··--·-----·w- 1----------w--i---·----·---t---••-•- ----w•-w·---•••-
9/24/2015
I I 6
Outfront Media, 8530 NW 23rd Street Doral, FL 33122
advertising production
MO $ 52 5 oc
~·--· -- ·-·---------------·-----·--- ----·-·-----·--·-------·-t------ -------9/25/2015 Ennovva, Inc., web design MO $1, soo .. o<
100 N Biscayne Blvd
/ _f_ S~ite 2906 ~---4"-· ·- Mianu, FL "3.1132
7
9/25/2015 Ennovva, Inc .. ,
I I 100 N Biscayne Blvd Suite 2906
1--------1 Miami, FL 3'132
8
advertising production
MO
DS-DE 14{Rev .. 11/13 ) SEE REVERSE FOR INSTRUCTIONS AND COD.E VALUES
EXHIBIT
$3,780.0(
CAMPAISN TREA.$URER~$ ~EP:QRT- ITEMIZED EXPENPJTU~ES f1) Name. Raquel A, Regalado (2) 1.0. Number 1421
9/1/2015 9/30/2015 {3)"Cover Period __ / __ 1_· __ through __ ;/_ __ }__ (4) ~<il9~ 2 of __ 2 __
9
.(5) Date
(6:) Sequence Number
(7)
FulfName (Last; Suffix, First, Middle} · Street Address &
City, State, Zif) Co.de
Borcegue, Juan 541 SW 42nd Avenue
Apt 126 Miami, FL 3 3134
(8)
Purpose (add office sought if · contribution to. a
candldate}
campaign work
f9) f10J
Expenditure Typ:e Afl!emim~rit
MO
(11)
Amount
$500 0(
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--------- ·---·--·-----··-···------·- ·----------·----- -·-----------!-·------
__ __j___L_
t----£-1__.I.__. __
OS-DE 14 (Rev..11113 ) SEE REVERSE FOR INSTRUCTIONS AND CODEVALUES
EXHIBIT
"'"<. ._,,~ ..... ,.,..._, """"'· ........................ I " ._ ......... ,. .... """'"" ........... ._..,.__, ·- .............. • •• .............. ·• ......... .
) . .. '"""<. . .._...._,, .... , , .............. ,. ,,...._ .. ,....., ....... I·• -···· ·•""'"'·· .... ·•••• .................... , ._......,. ._.. .. ·• •• ....... "·• ......... .
Via E-Mail
Margie B. Wade Investigation Specialist II Florida Elections Commission 107 West Gaines Street, Suite 224 Tallahassee, FL 32399
Re: FEC 15-372
Dear Ms. Wade:
(
May 31, 2016
This office represents Ms. Raquel Regalado .. Please find attached the affidavits requested in connection with the above-referenced matter.
In addition to the attached affidavits, it is important to clarify a number of items. The website described in the affidavits, www.raquelregalado.com (the "Website"), was simply a "landing" website. In other words, there was no content available to be viewed on this website. During the time that the video referenced in the affidavits was erroneously uploaded to the Website, the Website was currently under construction and not a finished product.
The contract between Serving Miamians and Ennova, Inc., attached hereto, references payment in the amount of 50% of the invoice upon execution of the contract, and 50% payment upon completion of the Website. At the time the video was posted, the final 50% had not been paid, as work on the Website was still ongoing. Neither Ms. Regalado nor Serving Miamians had been advertising the Website .. In fact, it was not intended that the Website be viewed by any visitors at the time the video was posted.
If you have any questions or require additional information, please do not hesitate to contact me directly at 305..377.1000. Thank you for your time and attention ..
MM;ka Ends. Copy to: Raquel Regalado, Esq.
Roland Sanchez-Medina Jr., Esq.
Sincerely,
F'\38210001\R"i>O"""'""'- FEC15-372do~ EXHIBIT // /l"6' Ii ;'i SANCHEZ-MEDINA, GONZALEZ, QUESADA, LAGE, CRESPO, GOMEZ, MACHA: 0 .f§t PRE.IRA LLP I SMGQLAW COM ------·-----·---
?()1 Al 1-lAMRRA l:IR!:I f:' !=;I ll'TI=' 1 ?()<=; rnRAI <::ARI f:'C: l='I "l':\ 1':\L[,,<=;1 ()'7 I 'T'l='I '':\()<=; ':\77 1()()() I l='A)( R<=;<=; ':\?7 ()':\Q1
AFFIDAVIT OF BACKGROUND INFORMATION Case Number: FEC 15-372
STATE OF FLORIDA County of Miami-Dade
Raquel Regalado, being duly sworn, says:
1. This affidavit is made upon my personal knowledge.
2. I am of legal age and competent to testify to the matters stated herein. I am currently
employed by Miami-Dade County Public Schools as School Board Member.
3. Have you ever run for public office? If so, please name the office(s) you ran for and the date(s) of the election(s) you ran in.
Yes, I ran for School Board Member in 2010. I was elected for a four (4) year term, and I ran again for re-election in 2014. I was re-elected to a second fom (4) year term.
4. Have you ever been appointed to act as a campaign treasurer for a candidate? If so, please name the candidate(s) you served as treasurer, the office(s) the candidate ran for, and the dates of the election(s).
Yes, I was campaign treasurer for Tomas Regalado's mayoral campaign in 2008.
5. Have you ever held the office of chairperson, treasurer, board member, or other similar position for a political committee? If so, please list the names and addresses of the committees and dates when you held the position.
No.
6. Have you ever prepared or signed a campaign treasurer's report? If so, please list the name of the candidate or committee whose report you prepared or signed.
Yes, as campaign treasurer for Tomas Regalado's mayoral campaign in 2008.
7. What action have you taken to determine your responsibilities under Florida's election laws?
I am a constitutionally elected official.
8. Do you possess a copy of Chapter 106, Florida Statutes?
9. If so, when did you first obtain it? 2010, 2014, and 2015.
10.
11.
Have you read Chapter 106, Florida Statutes?
Do you possess a copy of Chapter 104, Florida Statutes?
12. If so, when did you first obtain it? 2010.
13.
14.
Have you read Chapter 104, Florida Statutes?
Do you possess a copy of the Handbookfor Candidates?
EXHIBIT Inv040 ( 6/08)
~Yes D No
~Yes
~Yes
D No
D No
~Yes D No
~Yes D No
(
15. If so, when did you first obtain it? 2010.
16. Have you read the Handbook for Candidates? rgj Yes D No
17. List any additional materials you received from the Supervisor of Elections.
None at this time.
18. Please describe your communication with the officers and members of Serving Miamian regarding the creation and "launching" of the website and video. Please include the time and place the communications occurred. If there were any written communications, please provide copies.
None.
These questions below pertain to the campaign website.
19. Did you review the website before it became "live"?
No, I did not review the website before it became "live".
20. Did you approve the website before it became "live"?
No, I did not approve the website before it became "live".
21. When did you become aware of the website?
I became aware of the website upon receipt of the letter from the Florida Elections Commission dated June 30, 2015 ..
22. How did you become aware of the website?
I became aware of the website upon receipt of the letter from the Florida Elections Commission dated June 30, 2015.
23. According to the written response submitted by your attorney, it was not intended for the website to be accessed by visitors. What did you and/or your campaign do to prevent visitors from accessing the website?
The Website had not been approved or reviewed at the time it went "live". Neither I nor my campaign had been advertising the Website. The Website was not intended to be viewed by any visitors during the time the video was posted. Upon receipt of the letter from the Florida Elections Commission dated June 30, 2015, I contacted Ennova, Inc. and demanded that the video and the website be taken offline immediately.
The questions below pertain to the video.
24. Did you review the video before it was posted on the website?
No, though I appear in the video, I had not reviewed the final product.
25. Did you approve the video before it was posted on the website?
No, I had not reviewed the final product. Furthermore, it was not my position to approve the posting of the video.
26. When did you become aware of the video?
EXHIBIT Inv040 (6/08)
.I became aware of the video, with respect to its posting on the website, upon receipt of the letter from the Florida Elections Commission dated June 30, 2015.
27. How did you become aware of the video?
I became aware of the video, with respect to its posting on the website, upon receipt of the letter from the Florida Elections Commission dated June 30, 2015.
EXHIBIT Inv040 ( 6/08)
(
I HEREBY SWEAR OR AFFIRM THAT THE FOREGOING INFORMATION IS TRUE AND CORRECT TO nm BEST OF MY KNOWLEDGE.
Case Investigator: MBW
Inv040 (6/08)
------~&A~.._'tQHPl/'-----·--' 2016 I
Signature
Print, Type, or tamp Commissioned Name of'Nota1y Public
Personally Known ____ 01 Produced Identification /
Type of Identification Produced: !Fi..-,-.,a.t.;JA i")R.XVc;@(\
-------~------>=k=.zi=J_,,..-Y:au::~.~<-·~~--~-
~-;:--;:;;~,;~., -~--··-·---i~0~ Af<.(;\ J~M Fl !HENIE : ~-. i*) MY COMMISSION #FF151526 -:,·.-1-~;.:Q~::
{~0(;;;.f' EXPiRES August 14, 2018 407) ·39;;· 0153 FloridaNotaryService.com ---
EXHIBIT ____.it..t..1_,.f?i"51:l~....,e.. _E"-l!f-f-~ .... 4
/
1. ( t_
AFFIDAVIT OF ADDITIONAL INFORMATION Case Number: FEC 15-372
STATE OF FLORIDA COUNTY OF MIAMI-DADE
ROLAND SANCHEZ-MEDINA JR., being duly sworn, says:
1. This affidavit is made upon my personal knowledge.
2. I am of legal age, sui juris and competent to testify to the matters stated herein. I am currently employed by Sanchez-Medina, Gonzalez, Quesada, Lage, Gomez & Machado, LLP as an attorney.
3. My telephone number is 305-377-1000, Ext.108.
4. According to the information disclosed on your 2015 M3 Report, you made an expenditure to Ennova, Inc. for "Web design." Please provide copies of the artwork and invoice for the web design.
Copies of the artwork and invoice for the web design are attached.
5. According to the information disclosed on your 2015 M3 Report, you made an expenditure to Ennova, Inc. for "advertising." Please provide copies of the adverting and the invoices.
No expenditure was made to Ennova, Inc. for advertising. The attached invoice was limited to web design and the creation of one video.
The following questions pertain to Attachment A.
6. The disclaimer on the web site states, "Paid and approved by Serving Miamians." Please provide the name and contact information for the person responsible the verbiage in the disclaimer.
No disclaimer was provided to Ennova, Inc. The disclaimer language was created by Ennova, Inc. as a result of the execution of the contract between Serving Miamians and Ennova, Inc.
7. Please provide the name and contact information for the person responsible for verbiage on the web site.
Amelie Ferro. She may be contacted at 305-938-0728.
8. Please provide the name and contact information for the person that reviewed and approved the web site and the person that reviewed and approved the video.
The Website had not been approved or reviewed. As referenced in the letter above, the website was in a period of initial construction and was not intended to go "live" at the time of the posting of the video. The Website was not completed and no content was available on the
EXHIBIT
lnv041 ( 6/08) 1
/
i
Website. To my knowledge, Ennova, Inc. was in the process of testing the design and connectivity of the website at the time the video was erroneously uplOaded.
9. Please provide the invoices for the web site and video that appears on the web site.
The invoices are attached hereto.
10. Please provide a copy of the payment instruments for the web site and the video.
The payment instruments are attached.
11. Please provide a copy of the video.
I am not in possession of the video, though I am attempting to obtain a copy from Ennova, Inc.
12. Was Ms. Regalado aware that your published the web site? ( ) Yes ( X) No
To the best of my knowledge, Ms. Regalado was unaware that the Website was "live" and published
13. Did any officer or member of Serving Miamians discuss the web site with Ms. Regalado? No.
If so, please provide the name(s) and contact information for each person that communicated with Ms. Regalado. Not applicable.
14. Did Ms. Regalado provide the information for the web site? ( ) Yes ( X) No
There was no information on the Website.
15. Did Ms. Regalado review the web site? ( ) Yes ( X) No
16. Did Ms. Regalado review the video? ( ) Yes ( X) No
17. Did Ms. Regalado approve the web site? ( ) Yes ( X) No
18. Please explain why Serving Miamians published the website?
Serving Miamians was in the process of publishing a new website about Raquel Regalado in conformity with IRS rules and regulations. Serving Miamians has been informing Miami-Dade County residents regarding Raquel Regalado and Tomas Regalado for five (5) years. The language included in the video requesting support for Ms. Regalado was simply a mistake, as the intent of the video was to educate Miami-Dade County regarding various issues. The video was immediately removed from the Website.
lnv041 ( 6/08) 2
/
( (
I HEREBY SWEAR OR AFFIRM THAT THE FORGOING INFORMATION IS TRUE AND CORRECT TO THE
BEST OF MY KNOWLEDGE.
+() .... ~:,v.~'::'t- MICHAEL A. MONTIEL * * MY COMMISSION #FF 923292
EXPIRES: October 1, 2019 Bonded Thru Budget Notary Services
Case Investigator: MBW
Inv04 l ( 6/08)
EXHIBIT
Signature of Affiant
Sworn to (or affirmed) and subscribed before me this S 1 ,,-r day of May, 2016
Signature '\f Nitary Public - State of Florida
Print, Type\ir Stamp Commissioned Name of Notary Public
I ;1.. 12'f!r ,Jj 3
3
----------·--·--. (
February 25, 2015
we are thrilled to assist with your production needs.. Below please find two options. Both include the
different needs we discussed. In the first option I have also included as a value added the use of our studio for your campaign commercials as well as the ability to perform live streaming with interaction from third parties .. This may be very interesting for any kind of survey and to increase engagement with
your constituents
Option .1: All Inclusive
~·-------·--··-----·--·----- ---------- - -·--·-·····---
Service Unlimited Monthly Access to Studio Facility and Production Team Unlimited Access for:
Short format segments with director and editors that provide all post-production work .. ··--Digital Platform Live Streaming with interaction of unlimited concurrent users ..
Production of Campaign Commercials. (Studio Use)
Design of Website
Hosting of Website and a secured FTP server Video Platform Sites: Development ofYouTube branded channel with campaign website color and image theme and the publishing all productions on platform ..
-- Monthly Fee: $10,000 ''··
Option 2: Per Usage ____ , ___________ ...,.._ ____________ ..., _____ ... --Service FuHDay Half Day
Studio, camera lighting and audio equipment, camera operator, fiber line $1,40( $1,080
Editing, Grafic Package and Post Production $600 $500
Publish productio.ns on company website, secure FTP, social media & video platforms $20 per production
Design of Website $3,000
Hosting of Website and a secured FTP server $40a month
Access to Live Streaming with Interaction of Unlimited and Concurrent Users TBD Access to Studio Facility for Campaign Commerical Production TBD
I look forward to seeing you tomorrow and continuing to explore opportunities to work together!
Best,
www.CIMACAST.com 100 N Biscayne Boulevard Suite 2906 Miami Florida 33132 ..
-· -----·------·-· ··-·-··· ----·---
INVOICE
ENNOWAINC. 100 N Biscayne Blvd, Suite 2906 Miami, FL 33132 Phone: (855) 366 6882 EIN 45-3765499
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invoice N(). -···--'-- Date 0438 3 6 2015
Bill To· i------··..__;.;_-· -··-~---~· --- Shi To ----··-·· .. ·--'-·------Setvings Miamians
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Ou:antiru · bescription ·.
-··--···--·-..:. ... _,. . ...;, __ . Anfount ... ·Tetanus~
1 Full day February 26, .2015 and March 5, 2015 Studio, camera lighting and audio equipment, camera operator, fiber line $ 1,400.00 $ 1,400.00 Editing, graphic package and postproduction $ 600.00 $ 600.00
1/2 Day ·March 6, 2015 Studio, camera lighting and audio equipment, camera operator, fiber line $ l,080.00 $ 1,080.00 Editing, graphic package and postproduction $ 500.00 $ 500.00
Please make payments to: ENNOWAINC.
100 N. Biscayne Blvd. Suite 2906 Miami, FL 33132
,..,_:'.: . . ..
L ..
TOTALUSD $ 3,580.00
EXHIBIT ll
INVOICE
ENNOWAINC. 100 N Biscayne Blvd, Suite 2906 Miami, FL 33132 Phone: (855) 366 6882 EIN 45-3765499
,.,..B_ill_~_o..,... ---·---;·--·---.. ·------·--.. -------------------
Servings Miamians
I OuaintitY · -Qescdption - . .. Web Design
50% due upon receipt of invoice
50% Due at completion of website
'
Please make payments to: ENNOWAINC.
100 N. Biscayne Blvd. Suite 2906·
Miami, FL 33132
--~-----. ' ---·i invoice No. · · Date · 0437 - 3/6/2015
.--. ----------. ·-------. Shi. To
--·-----------'
--· ---:-.. Amount. -·· .TotaHJSD.
$ 3,000.00 $ 3,000;00
--DUENOW $1,500.00 BALANCE $, i,soo~oo
. .,,
EXHIBIT J S . fk'f;< $ g :s z
- Regalado website Margie Wade to aferro
Dear Ms .. Ferro,
/ (
06/01/2016 04:25 PM
As we discussed in our earlier telephone conversation, when I reviewed the initial website, www .. raquelregalado .. com, the site appears to be a website for Ms .. Regalado's mayoral campaign but the disclaimer reads, "Paid and approved by Serving Miamians .. " I need to know the following
1.. Who contacted your company to produce the website? 2.. Who contacted your company to produce the video on the website? 3.. Was the website Ms .. Regalado's website or Serving Miamians' website? 4.. Who decided what content the website would contain? 5.. Who decided on the verbiage used in the disclaimer? 6.. What instructions, if any, were you given regarding the content of the website? 7.. When was the website scheduled to be accessible to the public? 8.. How was Ms .. Regalado involved in the design/production of the website? 9.. Did Ms .. Regalado review the website? If so, how do you know that she reviewed the website?
10.. Did Ms .. Regalado review the video? If so, how do you know that she reviewed the video? 11.. When (on what date) was the website completed and ready for public viewing?
~g', 'Wade Investigation Specialist II Florida Elections Commission 107 West Gaines Street, Suite 224 Tallahassee, FL 32399 850-922-4539 (phone) 850-921-0783 (fax)
EXHIBIT _...._1__..L/_. __
,, .. (
"S~~\l'IN«:i\ WilfAMDbl.~$ IEC©" 1985 NW 88TH CT #10~ MIAMI, FL. 33172·2648
PAY TO THE Ennowa Inc ORDER OF---------·-·------------ ----·----·--·------
·--------·------------·-- ·---
MEMO
Ennowalnc WO N Biscayne Blvd .. Sulte2908 Miami, Fl 33132
Invoice #0437 J
Check#: 1145 for $1,500.00 Posted: 3/13/2015
i145
3110/2015
$ "'°'i,500.00
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- -----·-···-----·-· -- ---·-··-·----------· - - ----·-·----- -- --- --------- .. ------·-------
Check#: 1145 for $1,500.00 Posted: 3/13/2015
EXHIBIT
CltY C!At!CC\IAL !!lAl41( 1146 """"·~"""'
0 SEJPJV!til;!JG lillli6il.l\ll1ANS EC@• 1134311/iCO
1985 NW 88TH CT #101 MIAlllll, FL 33172-2648
3/1012015 - i
8 PAY TO THE Ennowalnc. J $ ""3,580.00 j ORDER OF -·
Thr~ Thousand five Hundred EigMy and 001100•••••••••••••000-••••••-•••
00••••••""•"••••••••••••••·- !'.El
-- .. .____:DOUARS
Ennowa Inc. ~ 100 N Biscayne Blvd 1 Suite2906
~ j Miami, FL 33132
MEMO J Invoice lil0438 --··--··------2e
t AlJTl10AILED SIGNATURE
-·
Check #: 1146 for $3,580.00 Posted: 3/13/2015
6/9/2016 Page 2
===================================~~-================~1r-~~·~
Check#: 1146 for $3,580.00 Posted: 3/13/2015
EXHIBIT
... - -- -.••-. _,.. -- .. ·- :....:.:- -··-
Ennowa,lnc 100 Biscayne, Blvd Suite 2906 Miami, Fl.33132
Transit - 10/1/2015
--- 1 ·--- --·---
CNB Doral 2015-10-01
6; .;;, _016 Page 1
..... ·-1
Tr~ansl t - fo7T726f.5 ---.. ---- ............ _________ _.._ _______ ____,
'SEllVINO MIAMIAHS ECO' 1985NWesTH CT #101 MIAMI, Fl 3J172·2&qB $
DEPOSIT TICKET
TOTAL ITEMS rn OEP0Sf1S AMY 1'0T BE AVAii.ABLE FOTI
IMMEOIATEWITH011AWAI...
6l-ll6JS6Q
RE .. EMTER CRAflD TOTAL IN SCREENED BOXES
'--------------- ---------------- ------------.-------- ---------.. ------------------------"-------__, DDA Credi ts - 10/l/2~xl5_1B'T ~
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AFFIDAVIT OF FILING OFFICER Case Number: FEC 15-372
1. Please provide certified copies of the listed items from the following can~~~~tf~ bai:pr.aigt!;fil~; t n Raquel Regalado. -- - · ' :,(. · '- v
f"l .·
' Check ITEM
./ The Statement of Candidate form for 2016. (Statement of Candidate provided was signed on 03109115)
Appointment of Treasurers and Designation of Campaign Depository form for 2016 .. (Appointment of Campaign
./ Treasurer and Designation of Campaign Depository provided was signed on 03109115)
./ 2015 M3, M4, and M5 Reports (attached)
Un-redacted copies of any checks issued to your office. (NIA - Payment to the Elections Department is due at the ./ time of qualifying in June 2016)
--./ Statements of financial interest (Form 1 and Form 6) for 2016 .. (NI A - The required Statement of Financial
Interest is due at the time of qualifying in June 2016) -
2.. Please check each item provided to the candidate or his or her staff, and list the date that the item was provided. (If the item is published by the Division of Elections, it is unnecessary to provide a copy of the item. If your office published the item, please send a copy of the item with this affidavit.)
Check ITEM
Chapter 106, Florida Statutes (Provided to the candidate as part of A Comnilation of ./ .The Election Laws of the State of Florida. (Link to this page is found in the Elections
Department website in Candidate Qualifyjng Handbook) -
Chapter 104, Florida Statutes (Provided to the candidate as part ofA Comnilation of ./ The Election Laws of the State of Florida Link to this page is found in the Elections
Department website in Candidate Qualifj;ing Handbook)
Candidate Handbook Please indicate Year -(2016 Candidate Qualifying ./ Handbook.)
Political ad and disclaimer supplement (Provided as part of the 2016 Candidate and ./ Campaign Treasurer Handbook. Link to this page isfound in the Elections
Department website in Candidate Qualifj;ing Handbook)
DATE
03/09/15
03/09115
03/09/15
03/09/15
·-
·-
./ Calendar of Election dates (Calendar of Election Dates is available on the Elections 03/09/15; 03/16/15; and
Department website. Calendar of Reporting Dates was provided to the candidate as 12/28/15
an attachment to the Acknowledgement Letter dated 03116115, and as part of thee-mail to candidates dated 12128115). In addition, the Calendar of Reporting Dates can befound in the Election Department's website in Candidate Qualifj;ing Handbook)
Any other election related document, Please indicate the title of the related 03/16/15 ./ document (Guidelines to a Success[_ul Cameaign Reeort was provided to the
candidate along with the Acknowledgement Letter)
( '
3 Please list all other written materials provided to the candidate or his or her staff, the date ofreceipt, and a brief description of the written materials. Did you notify the candidate that the campaign handbook was available on the Division of Elections website?
The following written materials were provided: Acknowledgement Letter dated 03116115, Incomplete Report letter for l 5-M03 dated 04108115 and delivered 04113115; E-mail regarding campaign reporting dates sent on 12128115. The candidate was notified that the campaign handbook was available on the Division of Elections website through submittal o[the MD-ED 2 "Access to Handbook and the Election Laws of the State of Florida" (attached). This iriformation is also provided to the candidate via the Candidate QualifVing Handbook and the Oualifving Information Handbook package for Mayoral Candidates 20 I 6)
4. Please list all training seminars that were attended by the candidate, along with the date of attendance .. If a staff member attended for the candidate, list his name and position.. If available, please attach a copy of any attendance sheets from the seminar(s)..
NIA. Please refer this question to the Miami··Dade County Commission on Ethics and Public Trust as they coordinate candidate trainings.
5.. Please list the su~jects covered during these seminars .. If available, please provide a copy of the syllabus and outline for the seminar.
NIA. Please refer this question to the Miami-Dade County Commission on Ethics and Public Trust as they coordinate candidate trainings. The Elections Department covers a portion of the training relating to becoming a candidate; .campaign financing; legislative changes, and other information.
6.. Please list any other contacts with this candidate by you or your staff concerning a provision of Chapter 104, Section 105 .. 071, or Chapter 106, Florida Statutes.. Indicate whether the contact was in person, in writing, or by telephone and the subject matter of the contact. Also,provide copies of any documentation of the contact Please provide a separate affidavit from anymember of your staff who was in contact with this candidate or his or her staff, detailing thesubject matter of the contact Candidate and Treasurer received routine e-mail notifications regarding upcoming deadlines for the filing of campaign reports (see attached).
7. Please list each year the candidate ran for office, the office the candidate ran for, the dates of the elections, and the results of the elections ..
08124110 School Board, District 6 Elected (http;/ lresults. enr. clarityelections. comlF LIDadel203471325 781enlsummary.htmlJ
08126114 School Board, District 6 Elected Unopposed (htto./lwww. voterfocus. comlwslmdccand/candidate pr.php? c=miamidade&el= I 7)
08130116 Mayor, Miami-Dade County Announced Candidate (http./lwww. voterfocus. comlwslmdccand/ candidate pr. php? c=miamidade&el= 20)
EXHIBIT
(,-- (.'
I SWEAR OR AFFIRM THAi ~ .AE INFORMATION CONTAINED rt, L~iS DOCUMENT IS COMPLETE
AND ACCURATE TO THE BEST OF MY KNOWLEDGE.
EXHIBIT
Sworn to (or affirmed) and subscribed before me this-~: ;,_;; ___ day of -- . /"Z ;~; 1.AAA.> ··1 r.,;:i
d ------~ 2016
·1 I 1'
•'":i/vvv! { > ~~i',L:'.S: .. i.;_. /)[,hr_;: tt. vt
Signature of · otary PubJfc .. State of Florida
Pr~--11111111ilftlllllltll1mimoofil11iflfiMmffit1t~fNotary Public = ' . -= ~ = § ~<;~ ANNE VANESSA INNOCENT i § ":·, ~ Notary Public. State of Florida ~. Si ' • ,o.~- My Comm Expires Jun 2 2018 § - f?.".... ~ -§ 1,19:,:,;'2-.•" Commission # FF 116919 § !ID111111111111!•i!!l!lilllllflli!llllllllllllllJ.llllillllllllllllllllllllllllllllllllllll~. • •
Personally Known~or Produced Ident1ficat10n _____ _
Type of Identification Produced: -------------
---·---·--------
STATEMENT OF CANDIDATE
(Section 106.023, F.S.)
(Please print or type)
I, _ Raquel A. Regalado
{ '
H~tJ~W.SE8'!LY
2015 HAR .. 9 AM m: ~ 6
MlA.Ml-DA~E eLEtT\ONS
candidate for the office of Miami-Dade County Mayor
have been provided access to read and understand the requirements of
Chapter 106, Florida Statutes.
'tJ:"t~r, ;~~ffi ' ' ~l :~~ ::;;(1 ('./\!
,• ~·~ll~ " .. ~~~ t;
Each canditlate ... mu$t fi!e ... ~;,.statem~nt with the qualifying officer within 10 days after the Appointment of Campaign Treasu.rer ~nd Designation of Campaign Depository is filed. Willful fa,ilure .to f:tl§»~:Yfyf~mJi§d} .{lr,:s.bp.~S,ree misdemeanor and a civil violation of the Campa!gn Financing Act which may resuft tna fine of up to $1,000, (ss. 106 .. 19(1)(c), 106..265(1), Florida Statutes).. i3ViOll~):LJ
Al!fHr· [ ~ t'(i~Uf;,;) ~(~'~.u ~ j:-,lf.(1
DS-DE 84 (05/11)
EXHIBIT t 17
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