Robert Guzzardi, Esquire 119 East Montgomery Ave., Unit #3 Ardmore, PA 19003-2523 215.873.1317 bobguzzardi@bobguzzardi.

com March 12, 2014 Honorable Kathleen Kane Pennsylvania Office of Attorney General 16th Floor, Strawberry Square Harrisburg, PA 17120 There appears to be probable cause based on the public time line that there was unlawful coordinated activity involving the upcoming special and primary elections in State Senate District 28 York County. My request is that you investigate to determine if a crime has, in fact and in law, been committed. Using government/taxpayer money for a private, partisan political campaign was the basis of the Democrat Bonusgate and Republican Computergate convictions. It appears that government/ taxpayer resources were used for a quid pro quo in the special and the primary elections in State Senate District 28. Former Senator Waugh initially stated he would be serving his full-term which ends December 2014, he agreed to quit mid January after being offered the job as Farm Show executive director at $104,000 plus benefits despite the fact that there was, and is, an executive director in place who is remaining on the job with a different title, special adviser to Farm Show Complex Executive Director Mike Waugh. It appears that former State Senator Waugh was given the job, paid for with government money, as an incentive to resign his seat by Republican Party leaders in order that they could manipulate the outcome of Primary election for Senate District 28. Respectfully submitted Robert Guzzardi

The Timeline Evidences Probable Cause To Investigate The Timeline evidences probable cause to investigate whether Commonwealth/Taxpayer resources were illegally used to manipulate and illegally influence the election process and whether there was an illegal quid pro quo given to former state Senator Mike Waugh for his unplanned early resignation as State Senator. The coordination and collaboration in plain sight for those who want to see what can be seen Is probable cause for to investigate an apparent illegal quid pro quo to manipulate the outcome the Republican primary election in York Senate District 28. The faces of the Quid Pro Quo This course of events did not happen to happen; these people made them happen.

The Collaborators: Republican Senate Majority Leader Dominic Pileggi, former Republican Senator Mike Waugh of York County Senate district 28, Republican Representative Ron Miller of York House District 93, Republican Governor Tom Corbett and Republican Lt. Governor Jim Cawley and York County Republican Committee Chair Rob Wilson and York County Republican Committee, a private political organization. The timeline from August 2013 to mid Jan 2014 is evidence of probable cause that there was a carefully coordinated and concerted course of action by Republicans in leadership positions to collaborate unlawfully to manipulate the outcome of a special election the outcome of a

Republican primary in the State Senate district 28. Senate district 28 has an overwhelming number of voters who vote Republican so that the winner of the Republican primary of May 20 will very, very likely win the general election in November 2014. August 2014, Mike Waugh announces he will retire at end of his term December 2014. Read more PoliticsPa 9 August 2014 Nick Field and Jan Murphy Patriot-News 13 August 2014. No mention is made of any interest in becoming Farm Show Complex Executive Director. Silence until 2 January 2014, on that Scott Wager reports he has raised $267,000 from contributors other than himself. It is expected Scott Wagner will contribute substantial money to his own campaign. Read more PoliticsPa Nick Field 2 January 2014. On 9 January, it is reported that Senator Mike Waugh will announce his resignation as Senator to take job as Farm Show Complex executive director even though there was, and is, already a highly competent executive director, Patrick Kerwin, who is still on the job at $95,000 plus pension and health care benefits. . Read More York Daily Record 9 January 2014 Senator Waugh and Senator Pileggi meet with Governor Corbett for a private meeting in Harrisburg on January 7th 2014. On 13 January 2014 Senator Waughs sudden resignation is officially announced by the Senate, effective 12 January triggering a special election. On the same day, 13 January 2014, Mike Waugh is appointed by Governor Corbett to his new job at more money and the same platinum pension benefits which he voted for with Act 26 of 2001. No reason was given for urgency in appointing a new Farm Show Complex Executive Director. Mike Waughs surprise and sudden resignation triggered the need for a special election. On the same day, 13 January 2014, Lt. Governor Cawley announces special election on 18 March 2014. The special election for 18 March costs Pennsylvanias taxpayers $200,000 or more which would not have been incurred if the special election had been scheduled for the primary. Within 24 hours, on January 14th, incumbent Ron Miller announces he is a candidate for Senate 28. Then on 23 January 2014, as expected, the favored Ron Miller is chosen nominee by York County Republican chair and committee. The Republican Committee of York County picks the candidate without input from Republican voters. In this Republican district, the special election Republican candidate, Ron Miller, is all

but guaranteed a win in the special election. Ron Miller will then run in the primary of 20 May as the endorsed incumbent against the independent Republican Scott Wagner.

Sources: Read more PoliticsPa Nick Field 2 January 2014. [Scott] Wagner raises $267,000 in state senate race http://www.politicspa.com/wagner-raises-267k-in-state-senate-race/53941 Read more Sources Waugh to Resign; Special Election 8 January 2014 http://www.politicspa.com/sources-waugh-to-resign-triggeri PoliticsPa 8 January 2014 and PR Newswire 13 January 2014 http://www.prnewswire.com/news-releases/governor-corbett-n Read More York Daily Record 9 January 2014 Mike Waugh Resignation Triggers Special Election http://www.yorkblog.com/ydrpolitics/2014/01/09/politicspa-says-sen-mike-waughplanning-to-resign-soon-will-trigger-a-special-election / Read more PoliticsPa 9 August 2014 Nick Field http://www.politicspa.com/state-sen-waugh-toretire/49964 / and Jan Murphy Patriot-News 13 August 2014 http://www.pennlive.com/midstate/index.ssf/2013/08/sen_mik Read more Senator Waugh Announces Resignation from Senate Official statement 13 January 2014. http://pasenategop.com/news/2014/0114/waugh-011314.htm Read more Office of Lt. Governor 13 January 2014 Lt. Gov announces special election for 18 March 2014 http://www.pa.gov/Pages/NewsDetails.aspx?agency=PAGovNews&item=15176#.UwNO3PldW AR Read more: State Rep. Ron Miller wants the Republican nomination to replace Mike Waugh in Pa. Senate http://www.ydr.com/local/ci_24909074/state-rep-ron-miller-wants-republican-nomina Read more: Rep. Ron Miller wins GOP nod in contest for state Senate seat from York County PennLive 23 January 2014 Jan Murphy http://www.pennlive.com/midstate/index.ssf/2014/01/rep_ron_miller_wins_gop_nod_in.html #incart_river_default Read more Dennis Owens and abc27 on 11Februay 2014. 2 Farm Show heads + 1special election = political intrigue.

Read More Our take: Sen. Waugh's resignation could have waited a bit York Daily Record editorial 02/18/2014 http://www.ydr.com/opinion/ci_25168826/our-take-sen-waughsresignation-could-have-waited

Former Farm Show Complex executive director Pat Kerwin is now serving as a "special adviser" to his successor Mike Waugh for the same salary he earned in his old job. PennLive Jan Murphy On February 12th Dennis Owens on ABC 27 Two Farm Show Heads 1 Special Election = Political Intrigue http://www.abc27.com/story/24697263/2-farm-show-heads-1-specialelection-political-intri and the Patriot News Jan Murphy Farm Show Complex pays two people to oversee facility during yearlong transition: necessary or wasteful? 12 February 2014 http://www.pennlive.com/midstate/index.ssf/2014/02/farm_show_gets_two_heads_for_t.h tml report that Patrick Kerwin, the person Senator Waugh so abruptly resigned to replace, is still working at the Farm Show Complex being paid $95,000 a year plus pension and health care benefits while former Senator Waugh is being paid in over $104,000 a year plus pension and health care benefits. So you have 2 people doing the same job. This is the first time in history of the Farm Show that the past executive director of the farm show stayed on after they were replaced. And Patrick Kerwin is staying on for 11 months according to Jan Murphy at the Patriot News. What duties and functions are Patrick Kerwin performing that Mike Waugh is not? What duties and functions is Mike Waugh performing that Patrick Kerwin is not?