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Donald Trump Contributed More Than $40,000 of ''in-kind" Services to Florida AG Pam Bondi's Campaign, Violating State Election Laws, According to Complaint

Posted on the 16 September 2016 by Rogershuler @RogerShuler

Donald Trump Contributed More Than $40,000 ''in-kind

Donald Trump and Pam Bondi

Donald Trump violated election law by giving a campaign contribution of more than $3,000 to Florida Attorney General Pam Bondi, according to a Boston attorney's complaint.
J. Whitfield Larrabee also alleges that Bondi violated the law by failing to certify and publicly disclose Trump's illegal contribution to the Florida Division of Elections. (See full complaint at the end of this post.)
What are the possible implications for Trump, the Republican Party's 2016 presidential nominee? The answer is not immediately clear, but Larrabee already has filed complaints alleging a donation to Bondi's campaign constituted bribery and involved tax evasion and political corruption.
Is Trump withholding his income-tax information because it would reveal criminal activity related to the Bondi donation? Did Bondi withdraw from an investigation of Trump University after receiving a $25,000 campaign donation? Based on Larrabee's complaints, and reporting from a number of Florida news outlets, the answers appear to be yes. Heck, even The New York Times is starting to treat it as a real story.
Now, Larrabee is addressing possible election-law violations, and they go well beyond the $25,000 campaign contribution. Here is how Larrabee describes them in his complaint:
On March 14, 2014, Bondi held an event at the Mar-a-Lago Club in Palm Beach, Florida, in which she solicited campaign contributions in support of her campaign to be re-elected to be the Florida Attorney General.
[Fifty] or more individuals attended this event, including Trump. The minimum contribution to attend the event was $3,000 per person.
The Mar-a-Lago Club is a private club in Palm Beach located on 20 acres of gardens with ocean views. In includes an enormous mansion, beach, pool facility, spa and fine dining.
Space at the resort is expensive to rent. Trump has charged his own presidential campaign roughly $140,000 per event for use of the mansion.

The value of using the Mar-a-Lago Club for Bondi’s fundraising event was approximately $15,000 or more. The value of the use of the venue, the service of drinks and other amenities could not reasonably be less than $300.00 per person. The value of Trump’s attendance at this event was a service that further increased the value of the in-kind gift above $15,000.

In light of the $140,000 that Trump paid for use of the venue for his own events, it is highly likely that the value of the in-kind gift was far in excess of $15,000. As a professional entertainer, the value of Trump’s attendance was at least $25,000. The total value of the in-kind services provided to Bondi was over $40,000.

How do the numbers add up, and what do they mean? Larrabee sums it up:
Donald J. Trump and The Trump Organization made an in-kind contribution to Bondi by allowing her to use the club, its liquor and dining services, and its other amenities for the fundraising event. In-kind contributions are gifts of goods or services, other than monetary gifts.
The Republican Party of Florida paid only $4,855.65 for use of the Mar-a-Lago Club on March 14, 2014.
Bondi received an in-kind contribution from Donald J. Trump and The Trump Organization of approximately $35,144.35 or more. This is the difference between the $4,855.65 paid by the Republican Party for use of the facility and the $15,000 minimum actual value of the use of Mar-a-Lago resort together with the $25,000 entertainment value for Trump’s attendance.
In filings with the Florida Division of Election, Bondi failed to report the $35,144.35 in-kind contribution from Trump and The Trump Organization.

How does this edge toward unlawful activity? Larrabee explains:
In-kind contributions are subject to the same limits as are cash contributions under Florida law.
Florida Statute, 106.08, provides in relevant part:
Contributions; limitations on.—
(1)(a) Except for political parties or affiliated party committees, no person or political committee may, in any election, make contributions in excess of the following amounts: 
1. To a candidate for statewide office or for retention as a justice of the Supreme Court, $3,000.
By contributing more than $35,000 to Bondi, Donald J. Trump and The Trump Organization violated Florida Statute, 106.08(1)(a)(1) and other applicable provisions of Florida Statute 106.08.
Aside from its obvious national implications, this story has special ties to Alabama, as we noted in an earlier post:
How do Alabama and Jessica M. Garrison enter the picture? Until January of this year, the Birmingham-based Garrison was senior advisor to the Republican Attorneys General Association (RAGA) and the affiliated Rule of Law Defense Fund (RLDF). Before that, she was executive director of RAGA and President of (RLDF). Why has Garrison backed away from RAGA and its affiliated groups? That's a post for another day, but it's curious that Bondi is a major figure in RAGA -- and she has been at the heart of several controversies.
In fact, a major part of Garrison's job at RAGA apparently was to defend Bondi, who serves on the organization's executive committee as immediate past chair.
When Bondi was criticized in the Florida press for her cozy relationship with out-of-state lobbyists and corporate lawyers, Garrison came to her defense. . . .
Did Garrison break ties with RAGA earlier this year because she knew the Trump-Bondi story was a bombshell that could explode at any moment? If someone heeds calls for an investigation of the matter, perhaps we will find out.
Whitfield Larrabee, of Massachusetts, might be just the guy to do it.

Larrabee is pushing for prompt action, based on these words from his complaint:
The complainant requests the Florida Elections Commission expedite the investigation of this complaint. Said investigation is urgent because this complaint concerns the corruption of the elected and presently serving Florida Attorney General by the candidate nominated by the Republican Party to be President of the United States. Corruption of this nature interferes with the functioning of the governments of Florida and of the United States and undermines the public’s confidence in our democratic institutions.

Complaint Re Trump and Bondi With Florida Election Commission by Roger Shuler on Scribd

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