NO. SUMMONS THE STATE OF WASHINGTON SENDS GREETINGS TO: SEJU 775; AND SEIU 775 QUALITY CARE COMMITTEE,

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1 Llflvä ThurstO SEP a 4 15 :r cc"t, C STATE OFWASHINGTON, V. STATE OF WASHINGTON THURSTON COUNTY SUPERIOR COURT Plaintiff, SEIU 775; AND SEll] 775 QUALITY CARE COMMITTEE, Defendants. NO. SUMMONS THE STATE OF WASHINGTON SENDS GREETINGS TO: SEJU 775; AND SEIU 775 QUALITY CARE COMMITTEE, A lawsuit has been started against you in the Thurston County Superior Court by the plaintiff above named. Plaintiff's claim is stated in the written complaint, a copy of which is served upon you with this summons. In order to defend against this lawsuit, you must respond to the complaint by stating your defense(s) in writing, and serve a copy upon the undersigned attorney for the plaintiff within days after service of this summons, excluding the day of service, or a default judgment may be entered against you without notice. If you serve a notice SUMMONS ATTORNEY GENERAL OF WASHINGTON

2 1 of appearance on the undersigned attorney, you are entitled to notice before a default 2 judgment may be entered. 3 You may demand that the plaintiff file this lawsuit with the court. If you do so, 4 the demand must be in writing and must be served upon the plaintiff. Within 14 days 5 after you serve the demand, the plaintiff must file this lawsuit with the court, or the 6 service on you of this summons and complaint will be void. 7 If you wish to seek the advice of an attorney in this matter, you should do so 8 promptly so that your written response, if any, may be served on time. 9 This summons is issued pursuant to Rule 4 of the Superior Court Civil Rules of 10 the State of Washington. 11 DATED this th day of September, ROBERT W. FERGUSON 13 Attorney General 14 CHAD STANDIFER, WSBANo Assistant Attorney General LINDA A. DALTON, WSBA No Senior Assistant Attorney General Attorneys for Plaintiff State of Washington SUMMONS 2 ATTORNEY GENERAL OF WASHINGTON

3 L 5 Urt 1flOW Clerk STATE OF WASHINGTON THEIRSTON COUNTY SUPERIOR COURT STATE OF WASHINGTON, NO Plaintiff, COMPLAINT FOR CIVIL PENALTIES AND FOR V. INJUNCTIVE RELIEF FOR VIOLATIONS OF SEIU 775; AND SEIU 775 RCW 42./RCW 42.A QUALITY CARE COMMITTEE, Defendants I. NATURE OF ACTION The State of Washington ("State") brings this action to enforce the state's campaign finance disclosure law, RCW 42.A and its predecessor, RCW The State alleges that Defendants SEIU 775 and SEIU 775 QUALITY CARE COM1IvIITTEE (SEIU 775 PAC) violated provisions of RCW 42. and RCW 42.A by failing to properly report in-kind and/or monetary contributions from SEIU 775 to SEIU 775 PAC. The State seeks relief under RCW 42.A.750 and.765, including penalties, costs and fees, and injunctive relief. The State's campaign finance disclosure laws, formerly located at RCW 42., were recodified effective January 12 to RCW 42.A. The alleged violations span time where both statutes were in effect; for clarity purposes, Plaintiff will be referring to the current version of the statute when setting out its alleged statutory violations. COMPLAINT FOR CIVIL PENALTIES 1 ATTORNEY GENERAL OFWASHINGTON AND INJUNCTIVE RELIEF FOR VIOLATIONS OF RCW 42. /RCW 42.A

4 1 II. PARTIES Plaintiff is the State of Washington. Acting through the Washington State 3 Public Disclosure Commission, Attorney General, or local prosecuting attorney, the 4 State enforces the state campaign finance disclosure laws contained in RCW 42.A 5 I and RCW Defendant SEIU 775, formerly known during relevant time periods as 7 SERVICE EMPLOYEES INTERNATIONAL UNION HEALTHCARE 775NW, is a 8 local union affiliate of the Service Employee International Union, a nationwide union 9 which represents millions of public service workers, nurses, hospital staff, nursing 10 home care providers, building services and security guards Defendant SEIU` 775 QUALITY CARE COMMITTEE (SEIU 775 PAC) 12 : filed and registered with the Commission as a continuing political committee on August 13 14, 09. SEIU 775 PAC filed using the name "SEIU Healthcare 775NW Quality Care 14 Committee". SEIU 775 PAC subsequently amended its registration on December 3, using the name to "SEIU 775 Quality Care Committee". 16 M. JURISDICTION AND VENUE This Court has subject matter jurisdiction over Defendants, in accordance 19 with RCW 42.A. The Attorney General has authority to bring this action pursuant to RCW 42.A Defendants' actions which form the basis for the violations alleged below 22 occurred in whole or in part, in Thurston County, Washington Venue is proper in this Court pursuant to RCW COMPLAINT FOR CIVIL PENALTIES AND INJUNCTIVE RELIEF FOR VIOLATIONS OF RCW 42. /RCW 42.A 2 ATFORNEY GENERAL OF WASHINGTON

5 1 IV. FACTUAL ALLEGATIONS Pursuant to RCW 42.A.630(2), employers of lobbyists registered in 4 Washington must file a monthly political contribution report with the Public Disclosure 5 Commission ("Commission") when they make one or more contributions, including in- 6 kind and monetary contributions, during one calendar month totaling more than $110 to 7 a candidate for state or local office, an elected state or local official, an officer or 8 employee of any public agency, or a political committee. ' This report is entitled 9 "Employer of Lobbyist Monthly Political Contribution Report" and is designated by the 10 Commission as form L-3c, pursuant to WAC In lieu of this filing, a 11 lobbyist may report such contributions made by his or her employer on the lobbyist's 12 report, form L Additionally, state law requires registered political committees to report 14 contributions received and expenditures made by the committee. Included in those 15 disclosures, political committees must disclose the value of services furnished to the 16 committee for less than fair market value as an "in-kind" contribution. This is required pursuant to RCW 42.A.005(13)(a)(i) and (c) On or before August 14, 09, SEIU 775 PAC registered with the 19 Commission by filing a' Political Committee Registration (form C-lpc). SEIU 775 PAC chose the "full reporting" option for the committee. SEIU 775 PAC also declared, as its status in its registration, that it would be a continuing committee Based on SEIU 775 PAC's committee registration forms, during the 23 relevant time periods, Adam Glickman, 'David Rolf, and Sterling Harders were the campaign managers or committee officers for SEIU 775 PAC. Additionally, during the same time periods, these individuals were employed by SEIU 775 and received COMPLAINT FOR CIVIL PENALTIES AND INJUNCTIVE RELIEF FOR VIOLATIONS OF RCW 42.,RCW 42.A 3 ATTORNEY GENERAL OF WASHINGTON

6 1 compensation from SEIU 775. It is reported that in 14, SEIIJ 775 paid a salary of 2 $131,318 to Mr. Glickman, $183,237 to Mr. Rolf, and $1,404 to Mr. Harders. Upon 3 information and belief, the compensation paid these individuals by SEIU 775 included 4 for their work on behalf of SEJU 775 PAC A review of SEIU 775 PAC's expenditure reports do not identify 6 payments to any person as defined by RCW 42.A.005(35) for services to support its 7 activities. Based on SEIIJ 775 PAC's reported activities, the services provided by 8 Messrs. Glickman, Rolf, and Harders, as well as potentially other SEIU 775 staff 9 members, to support SEIU 77 5' PAC's activities exceeded $110 per month during the 100 period September 23, 10 through September 23, 15, and should have been reported 11 by SEIU 775 PAC as in-kind contributions SEIU 775 also should have disclosed on lobbying disclosure reports filed 13 by it or on its behalf, the value of services performed by SEJU 775 staff on SEIU PAC's behalf, in accordance with state disclosure requirements In addition to the SEIU 775 staff time that should have been reported by 16 I both SEIU 775 and SEIU 775 PAC, SEIU 775 PAC received and failed to report in kind contributions from SEIU 775 for its portion of the costs associated with SEIU providing SEI[LJ 775 PAC office space, postal and web services, and telephones SEIU 775 PAC reported receipt of cash contributions from SEIU 775 totaling $1,389,1.66 between September 23, 10 and September 23, 15, as follows: $5,000 (for January 1, 15 through September 23, 15); $,000 (for the PA calendar year 14), $307, (for the calendar year 13), $808,5 (for the 23 calendar year 12), $10,000 (for the calendar year 11), and $68,500 (for September 23, 10 through December 31, 10). COMPLAINT FOR CIVIL PENALTIES AND INJUNCTIVE RELIEF FOR VIOLATIONS OF RCW 42. IRCW42.A 4 ATTORNEY GENERAL OF WASHINGTON. PO Box 4OIOO

7 1 3.9 SEJU 775 failed to report in accordance with RCW 42.A.630(2) the 2 value of these cash contributions made to SEILT 775 PAC. To the extent such 3 contributions exceeded $110 in any month during the period September 23, 10 '4 through September 23, 15, SEIU 775 should have reported them as monetary 5 contributions in either its lobbyist's L-2 reports, or its own L-3 or L-3e reports, 6 depending on the timing of their contribution. 7 8 V. CLAIMS 9 Plaintiff re-alleges and incorporates by reference all the factual allegations 10 contained in the preceding paragraphs, and based Von 11 following claims:, those allegations, makes the First Claim: Plaintiff reasserts the factual allegations made above and 13 further asserts that Defendant SEIU 775, in violation of RCW 42.A.630(2), failed to 14 report its monetary and in-kind contributions, aggregating more than $110 in a calendar 15 month, to SEJU 775 PAC Second Claim: Plaintiff reasserts the factual allegations made above and further asserts that Defendant SEJU 775 PAC, in violation of RCW 42.A.235 and 18.0, failed to properly and timely file reports of in-kind contributions it received from 19 SEIU 775 through its staff members to support SERf 775 PAC activities. V1. REQUEST FOR RELIEF 22 WHEREFORE, Plaintiff requests the following relief as provided by statute: For such remedies as the court may deem appropriate under RCW 42.A.750, including but not limited to imposition of a civil penalty, all to be. determined at trial; V COMPLAINT FOR CIVIL PENALTIES 5 AUORNEY GENEPL OF WASHINGTON AND INJUNCTIVE RELIEF FOR VIOLATIONS OF RCW 42. '. /RCW 42.A,

8 1 5.2 For all costs of investigation and trial, including reasonable attorneys' 2 fees, as authorized by RCW 42.A.765(5); For temporary and permanent injunctive relief, as authorized by 4 RCW 42.A.750(l)(h); and For such other legal and equitable relief as this Court deems appropriate. 6 7 DATED this th day of September, ROBERT- W. FERGUSON Attorney General 9 10 _ 11 CHAD STANDIFER, WSBA No. 297 Assistant Attorney General 12 LINDA A. DALTON, WSBA No Senior Assistant Attorney General 13 Attorneys for Plaintiff State of Washington COMPLAINT FOR CIVIL PENALTIES 6 ATOENEY GENERAL OF WASHINGTON AND INJUNCTIVE RELIEF FOR PO Box VIOLATIONS OF RCW 42. /RCW 42.A