NEW JERSEY ELECTION LAW ENFORCEMENT COMMISSION

P.O. Box 185

Trenton, New Jersey 08625-0185

NEW JERSEY ELECTION LAW COMPLAINT AND NOTICE OF

ENFORCEMENT COMMISSION,
OPPORTUNITY FOR A HEARING
Complainant,

v.

RAMON M. HACHE
C-9 0251 03 04-M2016
Candidate for Municipal Office,
Ridgewood Village,
Bergen County,

and

TINA YORK
Treasurer,

Respondents.

PLEASE TAKE NOTICE that the New Jersey Election Law Enforcement
Commission (Commission) hereby files a Complaint against Ramon M. Hache
(Respondent Hache) and Tina York (Respondent York) (collectively, Respondents) and
offers Respondents an opportunity for a hearing pursuant to the Administrative Procedure
Act, N.J.S.A. 52:14B-1 et seq., to determine whether Respondents failed to comply with the
New Jersey Campaign Contributions and Expenditures Reporting Act, N.J.S.A. 19:44A-1
et seq. (Campaign Act) and N.J.A.C. 19:25-1 et seq., (Commission Regulations), and
whether penalties provided by the Campaign Act should be imposed.
The Commission by way of Complaint alleges:

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 COUNT ONE
PROPOSED FINDINGS OF FACT:
1. Respondent Hache sought election to Municipal Office in Ridgewood Village, Bergen County,
in the 2016 municipal election held on May 10, 2016 (election).
2. On March 7, 2016, Respondent Hache filed a Single Candidate Committee – Certificate of
Organization and Designation of Campaign Treasurer and Depository (Form D-1), reporting
the establishment of a single candidate committee, “Ramon Hache for Village Council,” for
the election. The Form D-1 named Respondent York as the campaign treasurer. Both
Respondents certified the Form D-1.
3. On July 14, 2016, Respondents filed a certified Report of Contributions and Expenditures
(Form R-1) as a 29-day preelection report (29-day report), reporting contributions received
and expenditures made from the inception of the campaign through April 8, 2016 (29-day
reporting period).
4. On the 29-day report, Respondents reported six contributions received from Ramon M. Hache,
totaling $4,400.00, but did not report occupation and employer information for these
contributions.
5. Upon information and belief, two of the six contributions reported from Ramon M. Hache,
totaling $900.00, were not contributions made by him.
6. Respondents deposited $720.00 in currency into the campaign account on or about April 6,
2016. As of the date of this Complaint, Respondents have not reported contribution
information related to the $720.00 in currency deposits.
7. On the 29-day report, Respondents reported $4,475.00 as the sum of contributions of $300.00
or less.
8. On the 29-day report, Respondents reported five expenditures, totaling $5,336.87.
Respondents did not report payee addresses for three of the five expenditures, totaling
$1,007.58.
9. On August 25, 2016, Respondents filed a certified Form R-1 as an amended 29-day report
(amended 29-day report), reporting occupation and employer information for the six
contributions described in paragraph four, and reporting payee addresses for the three
expenditures described in paragraph eight.

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PROPOSED CONCLUSIONS OF LAW:
10. Respondent Hache was at all times relevant to this Complaint a candidate for Municipal Office
as defined by N.J.S.A. 19:44A-3c, and was therefore subject to the requirements of the
Campaign Act and Commission Regulations.
11. Respondent York was at all times relevant to this Complaint, the campaign treasurer for
Respondent Hache’s single candidate committee and was therefore subject to the requirements
of the Campaign Act and Commission Regulations.
12. Respondents were required by N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.2 to file a certified
Form R-1 as a 29-day report on April 11, 2016, reporting all contributions received and
expenditures made during the 29-day reporting period.
13. For each contribution exceeding $300.00 in the aggregate and for all currency contributions,
Respondents were required, pursuant to N.J.S.A. 19:44A-16, 19:44A-11.8 and N.J.A.C. 19:25-
10.2, to report the (1) date of receipt; (2) contribution amount; (3) contributor’s name; and (4)
contributor’s address. Where the contributor was an individual, N.J.A.C. 19:25-10.2A
required Respondents to report (5) his or her occupation and (6) the name and address of his
or her employer.
14. Pursuant to N.J.S.A. 19:44A-11 and N.J.A.C. 19:25-10.6, Respondents were prohibited from
receiving any currency contribution in excess of $200.00 from a single contributor for the
election.
15. Respondents violated N.J.S.A. 19:44A-16, N.J.A.C. 19:25-8.2, 19:25-10.2 and 19:25-10.2A
by reporting four contributions, totaling $3,500.00, on July 14, 2016 (94 days late) and by
reporting occupation and employer information for the four contributions on August 25, 2016
(136 days late).
16. Respondents continue to violate N.J.S.A. 19:44A-16, N.J.A.C. 19:25-8.2, 19:25-10.2, 19:25-
10.2A and 19:25-10.3 by failing to correctly report $900.00 in contributions, described in
paragraph 5.
17. Respondents violated, and continue to violate, N.J.S.A. 19:44A-16, 19:44A-11.8, N.J.A.C.
19:25-8.2, 19:25-10.2 and 19:25-10.2A by failing to report contribution information relating
to $720.00 in currency deposited into the campaign account. If any of these currency
contributions are in excess of $200.00 then Respondents violated N.J.S.A. 19:44A-11 and
N.J.A.C. 19:25-10.6 by receiving a currency contribution(s) in excess of the $200.00 limit.

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18. Pursuant to N.J.A.C. 19:25-10.3, Respondents were required to report the sum of contributions
of $300.00 or less on the 29-day report.
19. Respondents violated N.J.S.A. 19:44A-16, N.J.A.C. 19:25-8.2 and 19:25-10.3 by reporting
contributions of $300.00 or less, totaling $4,475.00, on July 14, 2016 (94 days late).
20. Pursuant to N.J.A.C. 19:25-12.2, for each expenditure made, Respondents were required to
report the (1) date expenditure was made; (2) full name and address of payee; (3) purpose; (4)
amount; and (5) check number.
21. Respondents violated N.J.S.A. 19:44A-16, N.J.A.C. 19:25-8.2 and 19:25-12.2 by reporting
five expenditures, totaling $5,336.87, on July 14, 2016 (94 days late) and by reporting payee
addresses for three of the five expenditures, totaling $1,007.58, on August 25, 2016 (136 days
late).
22. Respondents are each subject to imposition of the penalties prescribed by N.J.S.A. 19:44A-22
and N.J.A.C. 19:25-17.1 et seq., which may not be more than $7,600.00 for each transaction
which has not been reported in the manner or in the time prescribed by the Campaign Act or
Commission Regulations.

COUNT TWO
PROPOSED FINDINGS OF FACT:
23. The Proposed Findings of Fact contained in Counts One are repeated and incorporated herein.
24. On July 14, 2016, Respondents filed a certified Form R-1 as an 11-day preelection report (11-
day report), reporting contributions received and expenditures made from April 9, 2016 to
April 26, 2016 (11-day reporting period).
25. On the 11-day report, Respondents reported a $1,000.00 contribution received on April 7,
2016. (April 7, 2016 is during the 29-day reporting period).
26. On the 11-day report, Respondents reported two $500.00 contributions, totaling $1,000.00.
One of the contributions received on April 17, 2016 was from an LLC.
27. On August 25, 2016, Respondents filed a certified Form R-1 as an amended 11-day report
(amended 11-day report).
28. On the amended 11-day report, Respondents reported the individual contributor for the
$500.00 LLC contribution described in paragraph 26.

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29. On the 11-day report, Respondents reported $1,479.82 as the sum of contributions of $300.00
or less.
30. On the 11-day report, Respondents reported an expenditure of $1,590.00 made on April 11,
2016.
PROPOSED CONCLUSIONS OF LAW:
31. The Proposed Conclusions of Law contained in Count One are repeated and incorporated
herein.
32. Respondents were required by N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.2 to file a certified
Form R-1 as an 11-day report on April 29, 2016, reporting all contributions received and
expenditures made during the 11-day reporting period.
33. For each contribution exceeding $300.00, Respondents were required, pursuant to N.J.S.A.
19:44A-16 and N.J.A.C. 19:25-10.2, to report the (1) date of receipt; (2) contribution amount;
(3) contributor’s name; and (4) contributor’s address. Where the contributor was an individual,
N.J.A.C. 19:25-10.2A required Respondents to report (5) his or her occupation and (6) the
name and address of his or her employer.
34. Respondents violated N.J.S.A. 19:44A-16, N.J.A.C. 19:25-8.2, 19:25-10.2 and 19:25-10.2A
by reporting the $1,000.00 contribution referenced in paragraph 25 (94 days late) and a $500.00
contribution (76 days late) on July 14, 2016.
35. Pursuant to N.J.A.C. 19:25-11.10(c), LLCs are not permitted to make contributions as entities.
For each contribution drawn on the account of an LLC, Respondents were required, pursuant
to N.J.A.C. 19:25-11.10(c), to determine the individual contributing member or members, and
maintain a record of contribution information.
36. For each contribution received in excess of $300.00 from a contributing member of an LLC,
Respondents were required, pursuant to N.J.S.A. 19:44A-16, N.J.A.C. 19:25-10.2, 19:25-
10.2A and 19:25-11.10(c), to report the (1) name and address of the individual contributor; (2)
contribution amount (3) date of receipt; (4) contributor’s occupation; and (5) name and address
of the individual contributor’s employer.
37. Respondents violated N.J.S.A. 19:44A-16, N.J.A.C. 19:25-10.2, 19:25-10.2A and 19:25-
11.10(c) by reporting the LLC member as the contributor for the $500.00 contribution
described in paragraph 26 on August 25, 2016 (118 days late).

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38. Pursuant to N.J.A.C. 19:25-10.3, Respondents were required to report the sum of contributions
of $300.00 or less on the 11-day report.
39. Respondents violated N.J.S.A. 19:44A-16, N.J.A.C. 19:25-8.2 and 19:25-10.3 by reporting
contributions of $300.00 or less, totaling $1,479.82, on July 14, 2016 (76 days late).
40. Pursuant to N.J.A.C. 19:25-12.2, for each expenditure made, Respondents were required to
report the (1) date expenditure was made; (2) full name and address of payee; (3) purpose; (4)
amount; and (5) check number.
41. Respondents violated N.J.S.A. 19:44A-16, N.J.A.C. 19:25-8.2 and 19:25-12.2 by reporting an
expenditure of $1,590.00 on July 14, 2016 (76 days late).
42. Respondents are each subject to imposition of the penalties prescribed by N.J.S.A. 19:44A-22
and N.J.A.C. 19:25-17.1 et seq., which may not be more than $7,600.00 for each transaction
which has not been reported in the manner or in the time prescribed by the Campaign Act or
Commission Regulations.

COUNT THREE
PROPOSED FINDINGS OF FACT:
43. The Proposed Findings of Fact contained in Counts One and Two are repeated and
incorporated herein.
44. On July 14, 2016, Respondents filed a certified Form R-1 as a 20-day postelection report (20-
day report), reporting contributions received and expenditures made from April 27, 2016 to
May 27, 2016 (20-day reporting period).
45. On the 20-day report, Respondents reported a $300.00 contribution (an aggregate of $600.00)
and a $1,000.00 currency contribution, but did not report occupation and employer information
for the currency contribution.
46. On August 25, 2016, Respondents filed a certified Form R-1 as an amended 20-day report
(amended 20-day report).
47. On the amended 20-day report, Respondents reported occupation and employer information
for the currency contribution described in paragraph 45.
48. Respondents deposited into the campaign account an additional $100.00 in currency during the
20-day reporting period. As of the date of this Complaint, Respondents have not reported
contribution information related to this $100.00 currency deposit.

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49. On the 20-day report, Respondents reported $3,485.00 as the sum of contributions of $300.00
or less.
50. On the 20-day report, Respondents reported nine expenditures, totaling $10,614.10.
PROPOSED CONCLUSIONS OF LAW:
51. The Proposed Conclusions of Law contained in Counts One and Two are repeated and
incorporated herein.
52. Respondents were required by N.J.S.A. 19:44A-16 and N.J.A.C. 19:25-8.2 to file a certified
Form R-1 as a 20-day report on May 31, 2016, reporting all contributions received and
expenditures made during the 20-day reporting period.
53. For each contribution exceeding $300.00 in the aggregate and for all currency contributions,
Respondents were required, pursuant to N.J.S.A. 19:44A-16, 19:44A-11.8 and N.J.A.C. 19:25-
10.2, to report the (1) date of receipt; (2) contribution amount; (3) contributor’s name; and (4)
contributor’s address. Where the contributor was an individual, N.J.A.C. 19:25-10.2A
required Respondents to report (5) his or her occupation and (6) the name and address of his
or her employer.
54. Respondents violated N.J.S.A. 19:44A-16, 19:44A-11.8, N.J.A.C. 19:25-8.2, 19:25-10.2 and
19:25-10.2A by reporting the two contributions referenced in paragraph 45, totaling $1,300.00,
on July 14, 2016 (44 days late) and by reporting occupation and employer information for the
currency contribution on August 25, 2016 (86 days late).
55. Respondents violated, and continue to violate, N.J.S.A. 19:44A-16, 19:44A-11.8, N.J.A.C.
19:25-8.2, 19:25-10.2 and 19:25-10.2A by failing to report contribution information related to
the additional $100.00 currency deposit.
56. Respondents were prohibited by N.J.S.A. 19:44A-11 and N.J.A.C. 19:25-10.6 from receiving
any currency contribution in excess of $200.00.
57. Respondents violated N.J.S.A. 19:44A-11 and N.J.A.C. 19:25-10.6 by receiving a $1,000.00
currency contribution, which exceeded the $200.00 limit for currency contributions.
58. Pursuant to N.J.A.C. 19:25-10.3, Respondents were required to report the sum of contributions
of $300.00 or less on the 20-day report.
59. Respondents violated N.J.S.A. 19:44A-16, N.J.A.C. 19:25-8.2 and 19:25-10.3 by reporting
contributions of $300.00 or less, totaling $3,485.00, on July 14, 2016 (44 days late).

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60. Pursuant to N.J.A.C. 19:25-12.2, for each expenditure made, Respondents were required to
report the (1) date expenditure was made; (2) full name and address of payee; (3) purpose; (4)
amount; and (5) check number.
61. Respondents violated N.J.S.A. 19:44A-16, N.J.A.C. 19:25-8.2 and 19:25-12.2 by reporting
nine expenditures, totaling $10,614.10, on July 14, 2016 (44 days late).
62. Respondents are each subject to imposition of the penalties prescribed by N.J.S.A. 19:44A-22
and N.J.A.C. 19:25-17.1 et seq., which may not be more than $7,600.00 for each transaction
which has not been reported in the manner or in the time prescribed by the Campaign Act or
Commission Regulations.

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OPPORTUNITY FOR HEARING:
Pursuant to N.J.A.C. 19:25-17.1, Respondents shall have the opportunity for a hearing
pursuant to the Administrative Procedure Act, N.J.S.A. 52:14B-1 et seq., and 52:14F-1 et seq., and
N.J.A.C. 1:1. Respondents may appear personally or by attorney. However, if Respondents fail to
file a written answer with the Commission within 20 days after service of the Complaint, the
Commission may enter a Final Decision including imposition of a monetary penalty, pursuant to
N.J.A.C. 19:25-17.1A.

NEW JERSEY ELECTION LAW

ENFORCEMENT COMMISSION

BY: ________________________
Benjamin Kachuriner, Esq.
Assistant Legal Counsel
DATE: July 31, 2019

Ramon M. Hache, Candidate

CERTIFIED MAIL NO.: 7009 3410 0001 8440 9914
RETURN RECEIPT REQUESTED

Tina York, Treasurer

CERTIFIED MAIL NO.: 7009 3410 0001 8440 9921
RETURN RECEIPT REQUESTED