COUNT I VIOLATION OF 52 U.S.C. $ 30104 (b)(2)(c) and 11 CFR 104.3 (As to Respondent Debbie Wasserman Schultz and Debbie Wasserman Schultz for Congress)

1. Under 52 U.S.C. § 30104(b)(2)(c), a principal campaign committee is required to report contributions from political party committees on FEC filings.

2. Under 52 U.S.C. § 30104(a)(1), the treasurer of each political committee is required to file reports with the FEC and to report to the FEC that the report is, "true, correct and complete." (See FEC form 3).

3. Based upon information and belief and as set forth in paragraphs 17 though 29 above, Respondent Wasserman Schultz obtained contributions from the DNC during the period of April 1, 2016 through June 30, 2016.

4. Despite the sworn FEC filings by the Debbie Wasserman Schultz campaign, FEC reports do not reflect DNC contributions.

5. On information and belief, Respondent Wasserman Schultz was personally and directly involved in this utilization of DNC resources to benefit her campaign and, accordingly, she is liable for violations outlined herein.

COUNT II VIOLATION OF 52 U.S.C. $ 30124(1) and 52 U.S.C. § 30124(2) (As to Respondent Debbie Wasserman Schultz, individually)

1. Under 52 U.S.C. § 30124: no person who is a candidate for Federal Office or an employee or agent of such candidate shall— (1) fraudulently misrepresent himself or any committee or organization under his control as speaking or writing or otherwise acting for or on behalf of any other candidate or political party or employee or agent thereof on a matter which is damaging to such other candidate or political party or employee or agent thereof; (2) willfully and knowingly participate in or conspire to participate in any plan, scheme or design to violate paragraph (1) Debbie Wasserman Schultz had control

2. of the DNC, as its chairperson and utilized staff and resources of the DNC to benefit the Debbie Wasserman Schultz campaign.

3. On information and belief, employees and agents of the DNC contacted officials in Alaska in order to undermine events that Tim Canova was participating in as a candidate for Congress, this interference was directed at the Complainant as a direct result of him being a primary opponent of the DNC chairperson.

4. Exhibits 1-4 establish that employees of the DNC and agents of the DNC conspired as a "team" in an improper effort to utilize DNC resources to assist the Wasserman Schultz campaign and by extension to undermine the Tim Canova for Congress campaign.

5. Respondent Wasserman Schultz and various DNC staffers and agents (including Ryan Banfill, Steven Paikowsky Hilary Rosen, Luis Miranda, Dave Beattie, Tracie Pough and Kate Houghton) willfully and knowingly participated in or conspired to participate this plan to undermine Tim Canova's congressional campaign.

6. Accordingly, on information and belief, Respondent Wasserman Schultz violated 52 U.S.C. § 30124, by utilizing DNC staff as an arm of the Wasserman Schultz for Congress campaign to undermine the campaign of Tim Canova for Congress.

COUNT III VIOLATION OF 52 U.S.C. $ 30104(6X1) (As to Respondent Democratic National Committee)

1. Under 52 U.S.C. § 30104(e)(1), the DNC shall report all receipts and disbursements during the reporting period.

2. The DNC contributed staff and consultants to the Debbie Wasserman Schultz for Congress campaign. In fact, Ryan Banfill was paid by both the DNC and the Wasserman Schultz campaign, in recognition of his dual responsibilities, on both the campaign and the national committee. However, various other staff and agents were employed by the DNC but performed work for the Wasserman Schultz re-election campaign (See Exhibits 1-11 and the hyperlink of emails that concern the Tim Canova campaign on DNC email servers).

3. In the case at hand, the DNC did not report contributions to the Debbie Wasserman Schultz for Congress campaign.

4. Accordingly, on information and belief, the DNC violated 52 U.S.C. § 10 30104(e)(1) by not reporting the utilization of DNC staff and resources by the Debbie Wasserman Schultz for Congress.

COUNT IV VIOLATION OF 52 U.S.C. 3 30116 (cH (As to Respondent Democratic National Committee)

1. Under 52 U.S.C. § 30116(d), national committees are permitted to contribute to contribute to the general election campaigns of candidates for federal office.

2. By extension and under the theory of Expressio unius est exclusio alterius, the principle of statutory construction which provides that "the expression of one thing implies the exclusion of another" national committees are not permitted to contribute to the primary campaigns of federal candidates.

3. In particular, in this instance, where the chairperson of a national committee is also an elected official, the chairperson may not subvert party resources to benefit their own re-election.

4. Accordingly, on information and belief, the DNC violated 52 U.S.C. § 30106 (d) by contributing staff and resources to the Debbie Wasserman Schultz for Congress primary campaign.