Mike Coffman's complaint to the Federal Election Commission

COMPLAINT TO FEDERAL ELECTION COMMISSION

Identification of Respondents:

Protect Colorado Jobs, Inc.

1799 Pennsylvania Street

Suite 270

Denver, CO 80203

John Berry, Esq.

1799 Pennsylvania Ave.

Suite 270

Denver, CO 80203

Curt Cerveny

1410 Grant Street

D-315

Denver, CO 80203

Protect Colorado Jobs, Inc. ("PCJ") is a non-profit Colorado corporation organized under Section 501(c) (4) of the Internal Revenue Code.

John Berry is Secretary and present Treasurer of PCJ.

Curt Cerveny ("Cerveny") is the former Treasurer of Protect Colorado Jobs, Inc. and during the time relevant to this complaint was a signatory on Protect Colorado's Jobs' checking account.

Identification of Non-Respondent Parties:

Mike Coffman

9249 South Broadway

#200-501

Highlands Ranch, CO 80129-5690

Andrew Zuppa

8501 Grant Street

Denver, CO 80229

Mike Coffman ("Coffman") is a candidate for the 6th Congressional District of Colorado.

Andrew Zuppa is associated with PCJ.

Recital of Facts:

During the last week of July, 2008, approximately three weeks before the Republican primary for the 6th Congressional District, PCJ used corporate funds1 to pay for an attack mailing against Coffman.2  The attack piece was mailed to every Republican voter who requested a primary absentee ballot.3  Cerveny signed PCJ's corporate check to pay for the mailing.4

____________________________

Mike Coffman, Complainant

9249 South Broadway

#200-501

Highlands Ranch, CO 80129-5690

303-791-6453

Under penalty of perjury, the foregoing complaint was signed and sworn to before me

this ___ day of August, 2008, by Mike Coffman, Complainant.

My commission expires:  _________________

____________________________

Notary Public

1 Information and belief based on statements from John Berry and Andrew Zuppa

2 Copy of mailing is attached as "Exhibit A"

3 Information and belief based on a sampling of Coffman supporters who received the mailing

4 Information and belief based on statements from John Berry and Andrew Zuppa