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SB Attorneys at Law
LLP
LITIGATION GROUP FERNANDO SANTIAGO
SB
PARTNER
Email: Fernando@litgrp.com
Our office represents Marjorie Byrnes, who is a candidate for the 133rd Assembly
District. This letter constitutes a formal complaint against the Assemblyman Joe Errigo
and/or the “Friends of Joe Errigo” for a violation of the Fair Campaign Code (Part 6201 of
the Rules and Regulations of the New York State Board of Elections) based on a misleading
and inaccurate flyer circulated by his campaign.
| 1250 Pittsford Victor Road | Building 100 | Suite 190 | Pittsford, New York 14534 | Phone: (585) 563-2400 |
| Fax: (585) 563-7526 (Fax and email Not for Service) | www.Litigation-Group.com |
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improperly and incorrectly refers to a lawful payment as a “Bribe” and falsely states that the
referenced payment was not disclosed despite the fact that payments were in fact disclosed
in required filings. The flyer further falsely references a non-existent “admission of guilt.”
Moreover, the flyer inaccurately and falsely suggests that this was reported in the news and
further falsely depicts a photo-shopped gathering of Marjorie Byrnes, Andrew Cuomo, and
Jason McGuire appearing to laugh about the alleged bribe, which constitutes a falsely
identified writing. Additionally, the content of the flyer has also been posted as a video on
social media at https://www.facebook.com/friendsofjoeerrigo/videos/254113505239591/,
under the following post: “HAVE YOU HEARD THE NEWS??? Marjorie Byrnes is under
investigation for BRIBERY!”.
All future communications regarding this complaint and investigation should be made
to the following counsel: Michael A. Burger, Esq. and Fernando Santiago, Esq. The email
addresses to be used for further communications are: mike@litgrp.com and
fernando@litgrp.com. We can be further contacted at Santiago Burger LLP, 1250 Pittsford-
Victor Rd., Bldg. 100, Suite 190, Pittsford NY 14534.
Fernando Santiago
FS/
Enclosure (Proof of service)
Cc: Joseph A. Errigo (via certified mail & first class mail)
30 Office Park Way
Pittsford, NY 14534
Friends of Joe Errigo (via certified mail & first class mail)
17 Pine Cone Drive
Pittsford, NY 14534
| 1250 Pittsford Victor Road | Building 100 | Suite 190 | Pittsford, New York 14534 | Phone: (585) 563-2400 |
| Fax: (585) 563-7526 (Fax and email Not for Service) | www.Litigation-Group.com |