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Driscoll Complaint Mailed to District Attorney Allen


I am in receipt of a summary of a complaint I am told was mailed to District Attorney Charme Allen on Tuesday April 26, 2022 concerning at Large Commission seat 11 candidate Devin Driscoll‘s previous three campaign financial disclosures, 7/9/2021, 1/24/2022 and 4/11/2022. I have reached out to confirm that the complainant filed this complaint and she told me, “I filed this because everyone should be held to the same standards and it’s concerning the lack of oversight of financials”.

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 a Summary of the complaint (images of the summary is provided below as well)


Candidate Driscoll appears to have violated several campaign financial disclosure rules, including failing to adhere to “Best Efforts” to obtain the occupation, employer and complete address for contributions; collecting contributions over the allowable limit of $1,600; failing to report aggregate contributions; failing to accurately report total contributions collected; failing to report balance on hand properly; failing to fully disclose his in-kind contributions; and possibly spending campaign funds that are not reported properly or are not qualified expenses. Additionally, many of the entries are illegible.


Specifically, looking through all three of the disclosures as submitted, there are several errors and omissions. One report is missing a page; the addresses of contributors are not disclosed; very few have full employer information; all three reports show that his contributions were taken in on very few days of the reporting period; and all of the contributions are not recorded in
chronological order. Mr. Driscoll has collected seven single donations over the $1,600 limit, totaling $18,844.31. He has also failed to report aggregate information on all his reports. There are a total of six donors who donated over the $1,600 aggregate limit over the course of the reporting period, totaling $11,900. The total sum Mr. Driscoll collected in the scenarios above is $30,744.31.


This does not conform with the statutory regulations regarding campaign finance reporting requirements as outlined by Knox County and the State of Tennessee.


Included with this complaint is a copy of the campaign finance reports he submitted over all three reporting periods.


Below is a list of details that support the statements made above. Some of these are minor, but others are more significant violations.

  1. Many of the entries on the report dated 4.8.2022 are illegible.
  2. On the 4.8.2022 report, the “Balance on Hand” Section (12.f) does not balance.
    $92,767.46+$45,330.00=$138,097.46 $138,097.46-$23,548.01=$114,549.45 Amount reported is $114,598.45.
  3. Report dated 1.15.2022-expediture for “Marcus Hill” in the amount of $2,844 is listed as Internship—this would not be an allowable expense as written.
  4. Report dated 1.15.2022—in-kind for “Jordan Mollenhour” in the amount of $255.69 is listed as event expenses—what event, what expenses?
  5. Report dated 6.30.2021 references $1,036.88 as in-kind over $100 to be itemized; however, the itemization is not reported.
  6. Report dated 6.30.2021 is missing page 3 of 31.
  7. There are no aggregate totals for individual contributions or in-kind reported.
    a. In the 6.30.2021 report, there are two that should have aggregate totals reported. (Denise Davis & Ryan Hickey) b. In the 1.15.2022 report there are 7 donors who should have a reported aggregate and 3 of them are over the campaign limit of $1,600.
    i. Aggregate only: Lou Browning, Ryan Burrell, Scott Davis and Ryan Hickey ii. Aggregate and over the limit: Mark Padgett, Wes Stowers, & Kyle Ward

c. In the 1.15.2022 report there is a Bob Petrone and a Robert Petrone—are these the same person? If so, the contributions are over the limit.
d. On 4.8.2022 report there are 9 contributors that should have been reported as aggregated and 2 of them are over the limit. i. Aggregate only: Kelly Headen, Gordon Heins, Ray Hill, Ryan Mefford, J. Vandersteen, Russ Watkins, & J Roddy ii. Aggregate and over the limit: Darby Campbell, Chris Ooten

  1. On the 6.30.2021 report, Driscoll reports collecting $51,485; however, it adds up to $51,585.
  2. On the 1.15.2022 report, Driscoll reports collecting $58,019.31; however, it adds up to $58,969.31.
  3. On the 4.8.2022 report, Driscoll reports collecting $45,330; however, it adds up to $45,280.
  4. Specifically on the 6.30.2021 report (but also on the other two) Driscoll reports his contributions on only a few days of the period. The only expenditure on this report was credit card fees; therefore, one would expect that Mr. Driscoll has donations that go in more frequently than just a few days of the period and should be able to report those details as such. The $645.33 in fees represents 1.12%, while typical credit card fees are about 3%. Accordingly, approximately $18,000 of his donations could have come in via credit card and one would expect to see details supporting that via multiple contribution dates.

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