NEW YORK STATE DEMOCRATIC says. sco COMMITTEE JUNE ONELL WWW.NYDEWS.ORG ccna Ostober27, 2010 Robert Behn oteccue Distr “od Valentine Co-Executive Director N.Y. State Board of Elections 440 Steuben Street, Albany, NY 12207-2108 Dear Co-Executive Directors Brehm and Valentine Pursuant to 9 NYCRR 6201.3(a)(1(), am writing yet again to notify the N.Y. State Board of Eletions of blatant violations of the Eletion Law by Donovan 2010, committee subject to provisions of Amticle 14 ofthe Election Law, forthe purpose of initiating an investigation and proceedings under Anicle 16 of the Flection Lav. Donovan 2010 seeks the election of Dan Donovan, the current Richmond County District Automey, to the office of State Attomey General, ‘On October 18, Donovan 2010 accepted $10,000 from Manhattan Luxury Automobiles, Inc., a domestic business corporation registered withthe Division of Corporations ofthe Department of State. However, under §14-116(2) ofthe state Election Law, a corporation may only contribute of a maximum of $5000 in a calendar year. Donovan 2010, therefore, has received a pe se illegal contribution of $5000, As Tam sure you recall, a similar complaint was filed against Donovan 2010 for exceeding the conteibutions limits in excess of $75,000 when the committee accepted cntibutions ever the limit from six different individuals—additional per se illegal Although ignorance is rarely a valid defense to violations of law, the leyal principle ‘gnorania juris non excusat eerainly applies toa siting district attorney, to whom ‘campaign finance violations ate refered by the Board of Elections for enforcement, and who is a candidate for State Attomey General. Ikindly suggest thatthe State Board immediately forward a copy of Article 14 ofthe State Election Law to Donovan 2010 to assure that he does no more harm to campaign finance regulations. ‘uy pan avenue SOUTH, 1TH FLOOR NEW YORK, NY 106 amnsans ‘nas an a. voeMs.one[urge you to begin an immediate investigation and a proceeding under Article 16 of the lection Law to disgorge Donovan 2010 of the per se illegal contributions before these ‘monies are spent in the general election Sincerely, BX Tay Jacobs Chairman, NYS Democratic Committee