Complaint Filed with District Attorney General Charme Allen on three campaign financial disclosures of Trustee Candidate Jacobs

I am in receipt of a Summary of a Complaint that I have been told has been delivered to the Office of District Attorney Charme Allen for a complaint on the three campaign financial disclosures 1/31/2022, 3/21/2022 and 4/26/2022 of Richard Jacobs, candidate for Knox County Trustee. The Jacobs campaign Treasurer is believed to be Knoxville Attorney David Headrick, based on the Appointment of Treasurer form on file with the Knox County Election Commission, here.

The TN Registry of Election Finance takes these serious. Former County Commissioner Amy Broyles was called to Nashville twice (that I am aware of) Former State Rep. Jeremy Durham, State Rep. Glen Casada the two most notable.

Below is the verbiage, I was provided of the Summary of the complaint to be delivered on Monday May 2, 2022 to DA Allen’s office (images of the summary is provided below as well)

Summary of Complaint Richard Jacobs, candidate for Knox County Trustee, has failed to make Best Efforts to obtain required information from donors, including last names, addresses, occupations, employers and dates of donations. Candidate may have accepted contributions from ineligible foreign individuals and/or non-existent entities. Reporting was, in some cases, incomplete or illegible. Fundraising expenses were treated inconsistently from one report to the next. Candidate did not disclose loan as a receipt as required by Tennessee law. Total contributions were understated on one report. Please see the following in support of these complaints.

Report Date: 1/31/2022

Issue 1: Line 3 (Election Date) is recorded simply as “May.”

Issue 2: Reporting Period Beginning and Ending Dates are not recorded on lines 8a and 8b.

Issue 3: Line 2 (Report Covering the Period) is different on each page of the Itemized Statements of Contributions. Page 1 lists “Sept to Nov” and page 2 lists “Nov to Jan 22.”

Issue 4: For contributor listed as Avi (no last name) and/or Kopita LLC, was the contribution from an individual or business?

Issue 5: If above contribution is from the individual, why is no last name, occupation or employer recorded?

Issue 6: If above contribution is from the individual, an internet search reveals an individual named Avi Zenatti is the chef for KoPita Authentic Mediterranean restaurant. The restaurant website states, “Avi is a Moroccan/Israeli.” Does Mr. Zenatti have lawful Permanent Residence status? Is he legally allowed to contribute to a US election campaign?

Issue 7: If above contribution is from the named business, is the business considered a corporation under campaign finance law? If so, has business registered and filed campaign financial disclosure reports as a PAC, as required under Tennessee law for corporations contributing amounts greater than $1,000?

Issue 8: For contributor listed as Rick (no last name) and/or Paradigm Healthcare Group, was the contribution from an individual or business?

Issue 9: If above contribution is from the individual, why is no last name, occupation or employer recorded?

Issue 10: If above contribution is from the named business, a search of Tennessee Secretary of State records does not reveal any currently active entity by this name or any similar derivate of it. Is the business a legally existing entity? If so, in what state? Is the business considered a corporation under campaign finance law? If so, has the business registered and filed campaign financial disclosure reports as a PAC, as required under Tennessee law for corporations contributing amounts greater than $1,000?

Issue 11: For contributor Tommy Jones of Pikeville, KY, no occupation or employer is recorded.

Issue 12: For contributor Tammy Jones of Pikeville, KY, no occupation or employer is recorded.

Issue 13: For contributor Steve Fultz of Lewisville, TN, no occupation or employer is recorded.

Issue 14: For contributor Mellisa Fultz of Lewisville, TN, no occupation or employer is recorded.

Report Date: 3/21/2022

Issue 15: Line 12c is illegible.

Issue 16: Lines 19b, 19c, 20 and 21 were not completed.

Issue 17: For contributor Neil Waxman of Cleveland, OH, employer and date of contribution are missing. Aggregate amount is illegible.

Issue 18: For contributor Mike Rossberg of Knoxville, TN, address, employer and date of contribution are missing. Amount of contribution is illegible.

Issue 19: For contributor Doug Harris of Knoxville, TN, employer is missing.

Issue 20: Line 5 on first page of Itemized Statement of Contributions is illegible.

Issue 21: For contributor Bruce Williams of Knoxville, TN, employer is missing.

Issue 22: For contributor Foster Arnett or Knoxville, TN, occupation and employer are missing.

Issue 23: Line 5 on second page of Itemized Statement of Contributions is illegible.

Issue 24: Amount of expenditure to Anedot on page two of the Itemized Statement of Expenditures is illegible.

Report Date: 4/26/2022

Issue 25: Lines 15, 17, 19, 20 and 21 are blank.

Issue 26: Failed to record loan as a receipt on line 16 and 12b, as required by TCA 2-10-102(4), and as an outstanding obligation on line 12f. Itemized Statement of Loans, sections 3 and 4 are blank.

Issue 27: Line 5 on Itemized Statement of Contributions indicates contributions of $1,821.20. The actual amount of contributions listed on the candidates supplemental report is $2,100. Candidate appears to have deducted fundraising expenses and refunds from contributions rather than reflecting them on the Statement of Expenditures. This is inconsistent with candidate’s treatment of these expenses on the 3/21/2022 report.

Issue 28: For contributor Zach Abrams of Cleveland, OH, no occupation or employer is recorded.

Issue 29: For contributor Paula Porten of Pelham, NH, no occupation or employer is recorded.

Issue 30: For contributor Ben Rosenberg of Mantoloking, NJ, no occupation or employer is recorded.

Candidate Campaign Finance Disclosure Booklet is here

Tennessee Code is here


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