Mr. Anthony has demonstrated a total disregard for key provisions of Nevada’s long held campaign finance laws. He plays fast and loose with his campaign money, shielding key information about special interest donors, shifting money between mysterious bank accounts and openly violating maximum contribution limits which are punishable as a criminal felony.

1. Mr. Anthony Committed Multiple Violations of Nevada’s Campaign Finance Limits Which Are Punishable as Felony Offenses.

Mr. Anthony committed multiple violations of Nevada’s campaign finance limits. Article 2 Sec. 10 (2) of our Nevada constitution provides, “the Legislature shall provide by law for the limitation of the total contribution by any natural or artificial person to the campaign of any person for election to any office, except a federal office, to $5,000 for the primary and $5,000 for the general election, and to the approval or rejection of any question by the registered voters to $5,000, whether the office sought or the question submitted is local or for the State as a whole. The Legislature shall further provide for the punishment of the contributor, the candidate, and any other knowing party to a violation of the limit, as a felony.” Additionally, NRS 294A.100 provides in relevant part:

      1.  A person shall not make or commit to make a contribution or contributions to a candidate for any office, except a federal office, in an amount which exceeds $5,000 for the primary election, regardless of the number of candidates for the office, and $5,000 for the general election, regardless of the number of candidates for the office, during the period:

(a) Beginning January 1 of the year immediately following the last general election for the office and ending December 31 immediately following the next general election for the office, if that office is a state, district, county or township office; or

      (b) Beginning from 30 days after the last election for the office and ending 30 days after the next general city election for the office, if that office is a city office.

      2.  A candidate shall not accept a contribution or commitment to make a contribution made in violation of subsection 1

  4.  A person who willfully violates any provision of this section is guilty of a category E felony and shall be punished as provided in NRS 193.130.

1. Mr. Anthony Accepted Contributions from Single Contributors, Exceeding Nevada’s Maximum Limits

On at least two occasions, Mr. Anthony’s own reports filed under penalty of perjury clearly and inarguably demonstrate that he violated the maximum limits. To wit, Mr. Anthony reported that he accepted $20,000 from California Hope Trust and $15,000 from Ed Bozarth Nevada #1 Chevrolet. These contributions clearly exceed the aggregate $10,000 maximum limitation that is established by our Nevada Constitution, where it mandates that the seriousness of this offense be punished as a criminal felony. These offenses should be aggressively enforced especially since the damage to public interest in Mr. Anthony accepting in excess of the Constitutional limits from a single contributor is done. These funds were likely already utilized by his current campaign and Mr. Anthony and these contributors have already reaped the benefits of excess funds to illegally persuade voters. These offenses cannot therefore be simply corrected by simply requiring Mr. Anthony to return excess funds.

The contributions are identified in Mr. Anthony’s publicly filed reports as follows:

CALIFORNIA HOPE TRUST 6401 Centennial Center Blvd Las Vegas, NV 89149	04/04/2019	$5,000
CALIFORNIA HOPE TRUST 34212 Pacific Coast Highway Dana Point, CA 92629	07/22/2019	$5,000
CALIFORNIA HOPE TRUST 34212 Pacific Coast Highway Dana Point, CA 92629	08/17/2020	$10,000

Ed Bozarth Nevada #1 Chevrolet 5501 Drexel Road LAS VEGAS, NV 89130	03/25/2019	$10,000
Ed Bozarth Nevada #1 Chevrolet 5501 Drexel Road LAS VEGAS, NV 89130	09/24/2020	$5,000.00

1. Mr. Anthony Illegally Accepted Over $100,000 From a Federal PAC, exceeding Nevada’s Maximum Limits

Mr. Anthony also violated campaign contribution limits by accepting over $100,000 from the Battle Born Liberty Political Action Committee. In reports filed with your office, Mr. Anthony misleadingly and fraudulently identified the contributor as “Stavros Anthony for Congress c/o Battle Born Liberty PAC”  In fact, the federal PAC maintained no affiliation with Mr. Anthony. Per its own Statement of Organization filed on 2/08/18, the PAC was designated as a “committee that supports or opposes more than one Federal candidate.” Importantly, the Battle Born Liberty PAC was not Mr. Anthony’s principal campaign committee or an authorized committee, nor is the PAC registered with the Nevada Secretary of State (See attached Statement of Organization).  The designation as “Stavros Anthony for Congress” affiliation is a fiction to give the misleading impression that the transfer of funds was from his official congressional candidate account. In fact, no such congressional candidate account ever existed, and Stavros received $0 in contributions as a federal candidate (detailed below). Instead, the PAC is designated as a multicandidate PAC even though it does not appear to meet the criteria for that type of PAC nor adhere to federal campaign finance limits (a separate complaint is pending before the FEC for federal law violations by the PAC). The PAC was terminated after funneling over $100k to Mr. Anthony’s Commission campaign.

The contributions to Mr. Stavros’ County Commission campaign from the Federal Battle Born Liberty PAC are as follows:

Battle Born Liberty PAC                    01/23/2019                              $10,000.00

PO Box 750201
Las Vegas, NV 89136

Stavros Anthony for Congress c/o Battle Born Liberty PAC PO Box 751271 Las Vegas, NV 89136

05/13/2019

$90,888.00

 

Mr. Anthony’s Federal Campaign Committee Candidate Summary:

Candidate information

Candidate ID	H8NV04026
Election years	2018
Office sought	House
Political party	REPUBLICAN PARTY
State	Nevada
District	04
First statement of candidacy	Statement of candidacy 2017 Filed: July 10, 2017
Most recent statement of candidacy	Statement of candidacy 2017 Filed: July 10, 2017

Financial totals for 2017–2018

Receipts	$0.00
Disbursements	$0.00
Ending cash on hand	$0.00
Debts owed by committee	$0.00

 

Apart from the fact the Battle Born Liberty PAC was not Mr. Anthony’s campaign committee and subject to Nevada’s $10,000 maximum cap, the transfers even when traced to individual contributors include felony violations because the Battle Born Liberty PAC accepted contributions from individuals who also contributed to Mr. Anthony’s campaign in limits that exceed the $10,000 contribution limitation.

Aggregate contributions to Battle Born Liberty PAC and Mr. Anthony’s County Commission campaign which exceed $10k limit:

BINION, JACK
07/19/2017 $5,400.00  (PAC)
4/18/19 $10k (Commission)

Jim Hammer
9/22/17 $1k (PAC)
7/8/19 $10K (Commission)

JAMES, MARK
8/4/2017 $5,4000 (PAC)
1/22/20 $10,000 (Commission)

STEVENS, DEREK
10/20/2017 $5,400.00 (PAC)
10/08/2019 $5,000.00 (Commission – ID’d as “Derek Stevens Trust)

1. Mr. Anthony commingles accounts through multiple accounts violating various provisions of Nevada’s campaign finance restrictions

Importantly, Mr. Anthony received considerable donations into different accounts apparently associated with various campaigns for other offices and then funneled huge sums of money back into his current campaign. Through that conduct, it appears that Mr. Anthony openly and wantonly violates these same campaign finance limits. Additionally, Mr. Anthony likely violated multiple provisions of Nevada and Federal campaign finance laws by commingling funds from various accounts he apparently maintains and then transferring those funds into his current campaign. Mr. Anthony has an unusually high number of accounts in which he has raised money for office.  To wit, there are 1) the Stavros S. Anthony for City Council account, which Mr. Anthony used from 2012 to 2017; 2) the Stavros Anthony for City Council, which has been active from 2016 until present day; 3) the Stavros Anthony for Congress, which was active in 2018 and 2019 and appears to be currently active as well; 4) Battle Born Liberty PAC, which is not affiliated with Mr. Anthony’s candidate committee and also not registered with the Secretary of State’s Office, 5) the Committee to Elect Stavros Antony, which appears to have made two contributions in 2015 to the same entity and is likely the result of misreporting by that recipient, and 6) the Stavros Anthony Campaign, which is also currently active and has been so for the last three years.  As you are aware, Nevada law places the onus of candidate reporting on the candidate, and we do not require nor allow a candidate to register a campaign committee with the Secretary of State’s Office.  Thus, no matter how may fictional names or accounts are created, the obligations and limitations relating to campaign finance in Nevada are placed on the candidate, not some fictional committee the candidate creates.

Mr. Anthony reported the following transfer of commingled funds to his Commission campaign:

Stavros Anthony for City Council 3275 S Jones Blvd. Las Vegas, NV 89146

09/29/2020$100,000.00

It is abundantly clear that the law applies to the candidate for public office, namely Mr. Anthony, and not any fictional campaign committees that Mr. Anthony has apparently established in order to openly violate the law.  Mr. Anthony cannot skirt the provisions of the law by establishing separate accounts and then commingling these funds into his current campaign. To allow otherwise would be a mockery of the provisions of the Constitution because a candidate could easily circumvent the law by simply opening multiple accounts with different campaign committees, accepting multiple $10,000 contributions from a single contributor and then transferring the money into a single account. That practice has long been held illegal in Nevada and has been enforced and prosecuted as such.

Mr. Anthony’s conduct violates important public interest considerations associated with basic campaign finance transparency and limitations on campaign contributions. Those limitations are intended to guard against public corruption and provide information on individuals who may be attempting to influence our elected officials. For those reasons, these are very serious violations and they should be investigated and prosecuted as such.

1. Mr. Anthony Committed Twenty-Two Separate Disclosure Violations of NRS 294A.210

Mr. Anthony also repeatedly and openly violated key transparency provisions of campaign finance laws, evidencing a complete disregard for the provision requiring that contributors be identified with an address. NRS 294A.120 (10) requires, “The name and address of the contributor and the date on which the contribution was received must be included on the report for each contribution in excess of $100 and contributions which a contributor has made cumulatively in excess of that amount since the beginning of the current reporting period.” Despite this clear requirement and the fact that the Secretary of State’s online filing system requires an address as a required field, twenty-two contributions on his reports associated with his campaign for County Commission fail to identify an address and instead simply indicate “Requested”.

With respect to these violations, I acknowledge that the Secretary of State may in some instances waive enforcement where good cause is shown after full consideration of, among other factors, the seriousness of the offense and whether the offense was inadvertent. Clearly, these offenses are well outside of any instance where good cause can be found. Mr. Anthony’s conduct in this campaign is a serious offense and is clearly not inadvertent or excusable given: 1.  The violations are numerous 2. Mr. Anthony has had ample time to correct any failure to provide legal disclosure and apparently simply refuses to do so and 3. the repeated violations are so pervasive that significant percentages of overall contributions fail to provide key transparency. Put simply, the number of violations over such a sustained period of time clearly evidences Mr. Anthony’s willful disregard for the law.

While it may be understandable or excusable for a candidate to not timely identify an address where a contributor failed to provide one, Mr. Anthony’s report fails to provide required disclosures for nearly TWENTY percent (20%) of the total contributions he received in Report #3.  Notably, despite the fact he received contributions with an unidentified address as far back as 481 days ago, Mr. Anthony has still not amended his reports. This conduct shows a complete disregard for the transparency required by law, especially considering the fact the election ends in only 7 days away with considerable numbers of voters having already cast their ballots who were not provided with information legally required as to who is financing Mr. Anthony’s campaign. The twenty-two violations were disclosed as follows:

Vegasnomics Requested Las Vegas, NV 89139	07/01/2019	$500.00
Gilbert & Associates Requested Las Vegas, NV 89139	12/01/2019	$250.00
JOHN ALLEN REQUESTED Las Vegas, NV 89104	01/10/2020 01/10/2020	$500.00 $500.00
Las Vegas Paving Corp Requested Las Vegas, NV 89104	08/28/2020	$5,000.00
Evaluation Services, LLC Requested Las Vegas, NV 89104	09/04/2020	$500.00
Lees Discount Liquor Requested Las Vegas, NV 89104	09/04/2020	$2,000.00
Jodi Farano Requested Las Vegas, NV 89104	09/08/2020	$100.00
M Con, Inc Requested Las Vegas, NV 89104	09/08/2020	$1,000.00
Russell Dorn Requested Las Vegas, NV 89104	09/08/2020	$500.00
Sonny Neighbors Requested Las Vegas, NV 89104	09/09/2020	$25.00
American Nevada Holdings Requested Las Vegas, NV 89104	09/09/2020	$1,000.00
Chris Powell Requested Las Vegas, NV 89104	09/09/2020	$250.00
Las Vegas Loyalty PAC Requested Las Vegas, NV 89104	09/09/2020	$100.00
Associated General Contractors Build PAC Requested Las Vegas, NV 89104	09/10/2020	$7,500.00
Thomas HAWKINS Requested Las Vegas, NV 89104	09/11/2020	$200.00
Strategic Medical Management Requested Las Vegas, NV 89104	09/12/2020	$1,000.00
Nevada Heart & Vascular, LLP Requested Las Vegas, NV 89104	09/15/2020	$10,000.00
Martin Lee Edelman Requested Las Vegas, NV 89104	09/16/2020	$2,500.00
Randall Randall Jones Requested Las Vegas, NV 89104	09/17/2020	$5,000.00
Marstone Capital, LLC Requested Las Vegas, NV 89104	09/17/2020	$1,000.00
Will Kemp Requested Las Vegas, NV 89104	09/17/2020	$5,000.00
Mike Turner Requested Las Vegas, NV 89104	09/18/2020	$700.00