Judicial Commission of Wisconsin 110 E Main St, Unit 700 Madison, WI 53703
March 13, 2025
I, Julie Saunders-Seegers, allege for this Judicial Commission complaint the following: The Susan Crawford of Wisconsin (“SCW”) registered campaign committee is using fictitious names to fund its campaign. In this fraudulent scheme, 1,397 real citizens' names are being used without their knowledge or permission. The total amount is $63,903.63 and is comprised of over 2,179 transactions. This allegation is conservative and not exhaustive. The Code violations are listed at the end of this complaint. I request a full investigation be conducted on SCW. Several Wisconsin campaign finance statutes have been violated including, but not limited to: 1) 11.1303(1) No disbursement may be made anonymously and no contribution or disbursement may be made in a fictitious name or by one person or organization in the name of another. 2) 11.1204 Unlawful political contributions. (1) Subject to sub. (2), no person may, directly or indirectly, make any contribution other than from funds or property belonging to the person. No person may, directly or indirectly, give funds or property to another person for the purpose of making a contribution in other than the first person's name. (3) No person may intentionally receive or accept any contribution made in violation of this chapter. 3) 11.1201 False reports and statements. No person may prepare or submit a false report or statement to a filing officer under this chapter. There is more than enough reasonable suspicion that justifies opening a full investigation into SCW. Evidence in this complaint strongly shows that the recorded donors may not be the actual sources of these funds. These people are known as Smurfs, and the scheme is known as Smurfing. See https://www.investopedia.com/terms/s/s/smurf.asp for a concise explanation. The SCW campaign must ensure that every suspicious donation listed is legitimate and originates from the stated donor. Per Chapter 11 ignorance cannot be a defense for accepting illegal donations. § 11.1400(7),(8). Smurfs are a) over the age of 65, b) largely have occupations recorded as: unemployed, not employed, retired, unknown, or none, c) have extraordinarily high number of contributions. These transactions are being electronically executed using computer bots. Bots are a kind of computer algorithm. See “Exhibit A, Crawford Potential Smurf Sample” a sampling of SCW identified Smurfs (using real people’s names and addresses without their knowledge). Part of their scheme is to mix legitimate contributions with fictitious ones. David J Mahoney, the SCW treasurer listed on the CF-1 form and Park Bank, 33 E Main St., Madison, WI is the financial institution listed under “depository information”. The financial platforms used to deposit funds into the SCW campaign are in question. SCW uses ActBlue Express as a contribution processor, see https://www.crawfordforwi.com/ . Another platform SCW is using is also ActBlue but on a different platform:
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