IN THE OHIO ELECTIONS COMMISSION

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1 IN THE OHIO ELECTIONS COMMISSION N. ZACHARY WEST 340 East Fulton Street Columbus, OH Complainant, vs. Case No. BAISE QUALITY PRINTING AND GRAPHICS 694 Koebel Avenue Columbus, OH and, TROY BAISE 694 Koebel Avenue Columbus, OH and, PIERCE COMMUNICATIONS, INC. 208 East State Street Columbus, OH and, JOHN DOES 1-10 Respondents. State of Ohio County of Franklin SS. COMPLAINT N. Zachary West, being first duly sworn, deposes and says as follows 1. I am the Ohio Democratic Party s General Counsel and make this complaint based upon personal knowledge.

2 2. Respondent, Baise Quality Printing & Graphics ( Baise Printing ), is an Ohio company located at 694 Koebel Avenue, Columbus, OH Respondent, Troy Baise, is the sole proprietor of Baise Printing. 4. Respondents John Doe 1-10 are unknown individuals or entities who will be identified through the discovery process. 5. Respondent, Pierce Communications, Inc. is an Ohio corporation located at 208 East State Street, Columbus, OH On information and belief, Respondents John Does 1-10 hired Pierce Communications to design and produce political publications opposing Cincinnati Mayor Cranley s reelection. 7. Respondent Pierce Communications is an experienced political communications firm that knew, or should have known, Ohio s disclaimer requirements for political publications. 8. Respondent Pierce Communications hired Baise Printing to print and distribute political publications opposing Cincinnati Mayor John Cranley s re-election. 9. Respondents published and distributed by direct mail several political publications opposing John Cranley s re-election. The mailing was sent to Cincinnati voters. 10. Exhibit A is a true and accurate representation of a direct mail piece that has been distributed to Cincinnati voters. This mail piece includes claims that Mayor Cranley is weak on crime, that he Gave [an] award to [a] cop killer, and that he tried to create an $87 million Slush fund. 11. Exhibit A is a political publication aimed at defeating Mayor Cranley s re-election. This mailer was sent less than a week before a contested general election during which John

3 Cranley, is seeking re-election. The political publication is intended to persuade voters to vote for Mayor Cranley s opponent. 12. Exhibit A does not identify the entity or individual responsible for the political publication in a clear and conspicuous place. 13. Exhibit A does not identify the entity or individual responsible for the political 14. Exhibit A s only identifying feature was the direct mail permit, Columbus Permit No. 15. Exhibit B is a true and accurate representation of a direct mail piece that has been distributed to Cincinnati voters. This mail piece exhorts recipients to Fight racist policies at City Hall and says that Cincinnatians are praying for God to change and bless our city. 16. Exhibit B is a political publication aimed at defeating Mayor Cranley s re-election. This mailer was sent less than a week before a contested general election during which Mayor John Cranley is seeking re-election. The political publication is intended to persuade voters to vote for Mayor Cranley s opponent. 17. Exhibit B does not contain a disclaimer or identify who paid for the political publication in a clear and conspicuous place. 18. Exhibit B does not identify the entity or individual responsible for the political 19. Exhibit B s only identifying feature was the direct mail permit, Columbus Permit No.

4 20. Exhibit C is a true and accurate representation of a direct mail piece that has been distributed to Cincinnati voters. This mail piece falsely claims that Mayor Cranley acted aggressively against Black leaders and includes photos of prominent Cincinnati African- Americans. 21. Exhibit C is a political publication aimed at defeating Mayor Cranley s re-election. This mailer was sent less than a week before a contested general election during which Mayor John Cranley is seeking re-election. The political publication is intended to persuade voters to vote for Mayor Cranley s opponent. 22. Exhibit C does not contain a disclaimer or identify who paid for the political publication in a clear and conspicuous place. 23. Exhibit C does not identify the entity or individual responsible for the political 24. Exhibit C s only identifying feature was the direct mail permit, Columbus Permit No. 25. Baise Printing maintains Columbus Permit No and uses this permit to send direct mailings on behalf of its clients. 26. Respondent Baise Printing admits to printing and mailing Exhibits A-C, and Respondent Troy Baise has admitted that Respondent Pierce Communications, Inc. hired Baise Printing to do so. Exhibit D. 27. Ohio Revised Code Section (B)(1) states in pertinent part that [N]o entity shall unless the name of the entity appears in a conspicuous place on or is contained or included within the publication [i]ssue a form of political publication in support of or opposition to a candidate

5 28. R.C (G)(1) states in pertinent part that No person operating an organ of printed media shall print a paid political communication that does not contain the identification required by this section. 29. Respondents violated Ohio law by failing to include a clear and conspicuous disclaimer or identification of the individual or entity responsible for the political publication, as expressly required by R.C (B)(1). 30. Respondents violated Ohio law by producing and distributing a paid political communication through an organ of the printed media that does not include a disclaimer or identification in violation of R.C (G)(1). WHEREFORE, Complainant requests that this matter be fully investigated, that all Respondents be found in violation of R.C (B)(1) and that Respondents Baise Printing and Troy Baise additionally be found in violation of R.C (G)(1), and that Respondents be referred for prosecution, or in the alternative, that the Commission impose a fine in an amount sufficient to deter similar misconduct in future election cycles. Further Affiant sayeth naught. N. Zachary West. Sworn to before me and subscribed in my presence, this day of November Notary Public

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