Beruflich Dokumente
Kultur Dokumente
COMPLAINT
1. The Democratic Coalition is a political action committee. Scott Dworkin is one of the
co-founders of The Democratic Coalition. Jon Cooper is a co-founder and Chairman of
The Democratic Coalition.
3. Rick Scott (“Scott”), current Governor of Florida and candidate for United States Senate,
corruptly used and attempted to use his official position and the property and resources of
the State of Florida, including but not limited to the Governor’s mansion and the
personnel, property and resources of the Florida Department of Law Enforcement, to
corruptly interfere with and influence the election being conducted to select a United
States Senator for the State of Florida, to secure a special privilege, benefit or exemption
for himself in violation of Florida Statute 112.313 (6), Florida Statute 104.31(1)(a) and
other laws of Florida and the United States.
(a) Use his or her official authority or influence for the purpose of interfering with
an election or a nomination of office or coercing or influencing another person’s
vote or affecting the result thereof.
7. On November 8, 2018 the Rick Scott For Senate campaign committee, that is under
Scott’s control, filed suit against election officials in Palm Beach and Broward Counties
in furtherance of his campaign for election to the United States Senate.
8. On November 8, 2018 Scott used the Governor’s mansion and other property of the State
of Florida to make partisan political attacks against Broward County Supervisor of
Elections Brenda Snipes and Palm Beach County Supervisor of Elections Susan Bucher
in connection with his campaign for election to the United States Senate. While standing
in the entranceway to the Governor’s Mansion, Scott stated: “I will not sit idly by while
unethical liberals try to steal this election from the great people of Florida.” Scott falsely
and corruptly implied that the County Supervisors were engaged in a “massive fraud.”
From the Governors’ mansion, Scott attacked his opponent, Senator Bill Nelson, accusing
him of hiring “Hillary Clinton’s lawyer.” Scott made false, corrupt, malicious and
defamatory statements against Senator Nelson’s lawyer, accusing him of coming to
Florida to steal the election. He announced that he was asking the Florida Department of
Law Enforcement to investigate the matter immediately. Scott stated: “No ragtag group of
liberal activists or lawyers from DC will be allowed to steal this election.” Scott made
numerous false and partisan statements. Scott used the Governor’s mansion for corrupt
and partisan purposes in service of his personal campaign for United States Senate and
not in a fair and impartial exercise of his duties as a Florida official and public servant.1
1
Damron, Aryssa, Washington Free Beacon, Rick Scott on Potential ‘Rampant Fraud’: ‘I
Will Not Sit Idly By While Unethical Liberals Try to Steal This Election,’ November 9, 2018
https://freebeacon.com/politics/rick-scott-potential-rampant-fraud-not-sit-idly-unethical-liberals-t
ry-steal-election/
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9. Scott’s use of and/or threatened use of the Florida Department of Law Enforcement
amounted to threats, intimidation or coercion against Florida election officials in Broward
and Palm Beach Counties. Scott’s words and actions were an illegal attempt to use his
office to interfere with the election for his own political gain.
10. Scott’s accusation of “rampant fraud” by election officials was without any factual
foundation, was made with knowledge of its falsity, involved a reckless disregard for the
truth and was made with malice. The false accusations were intended to unlawfully
threaten and intimidate election officials.
11. On November 8, 2018 Scott used a podium, microphone and speaker to broadcast his
statement from the Governor’s mansion. If this equipment was the property of the State
of Florida, Scott illegally and unethically used it for his political campaign. If the
equipment was the property of Scott or his campaign, his use of the property provides
further evidence that his statement was made for his own personal benefit, for the benefit
of his political campaign and not for the benefit of the people of Florida.
12. Scott’s activities provide probable cause to believe that he has engaged in illegal and
unethical activities, including but not limited to violations of Florida Statutes, Section
112.313(6) and Section 104.31.
Wherefore, the complainants demand that the Florida Commission on Ethics open an
investigation and take actions to enforce the law of Florida to the fullest extent possible.
Respectfully submitted,
J. Whitfield Larrabee, individually
and on behalf of The Democratic
Coalition, Scott Dworkin and
Jon Cooper.
_________________________
J. Whitfield Larrabee
Attorney at Law
251 Harvard Street, Suite 9
Brookline, MA 02445
jwlarrabee@gmail.com
(617) 566-3670
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