appendix to appellate brief of plaintiff-respondent state of wisconsin - state of wisconsin v. kelly...

STATE OF WISCONSIN

C O U R T O F A P P E A L S

DISTRICT I __________

Appeal No. 2013AP362-CR (Milwaukee County Cir. Ct. Case No. 2012CF438)

STATE OF WISCONSIN,

Plaintiff-Respondent,

v. KELLY M. RINDFLEISCH,

Defendant-Appellant.

ON APPEAL FROM AN ORDER DENYING SUPPRES-SION AND FROM A JUDGMENT OF CONVICTION

ENTERED IN MILWAUKEE COUNTY CIRCUIT COURT, THE HONORABLE DAVID A. HANSHER PRESIDING

SUPPLEMENTAL APPENDIX TO BRIEF OF

PLAINTIFF-RESPONDENT STATE OF WISCONSIN

J.B. VAN HOLLEN Attorney General

CHRISTOPHER G. WREN Assistant Attorney General State Bar No. 1013313

Attorneys For Plaintiff- Respondent State of Wisconsin

Wisconsin Department of Justice Post Office Box 7857 Madison, Wisconsin 53707-7857 (608) 266-7081 [email protected]

RECEIVED04-11-2014CLERK OF COURT OF APPEALSOF WISCONSIN

TABLE OF CONTENTS FOR SUPPLEMENTAL APPENDIX TO BRIEF OF PLAINTIFF-RESPONDENT STATE OF WISCONSIN

(State of Wisconsin v. Kelly M. Rindfleisch, Appeal No. 2013AP362-CR) (Milwaukee County Circuit Court Case No. 2012CF438)

DESCRIPTION OF DOCUMENT PAGE(S)

Page 1 of 4

Milwaukee County Circuit Court order denying defendants motion to suppress evidence obtained via search warrants

(Document No. 51) ........................................................................... 101 Judgment of conviction (Document No. 78) * ................................................................... 102-103 Criminal complaint (Document No. 3)* ..................................................................... 104-160 Information (Document No. 11)* .......................................................................... 161 Preliminary hearing questionnaire and waiver (Document No. 12) ........................................................................... 162 Milwaukee County Circuit Court protective order (Document No. 15) .................................................................... 163-164 Rindfleischs motion to suppress evidence obtained via

search warrants (Document No. 23) .......................................................................... 165 Rindfleischs memorandum supporting motion to

suppress evidence obtained via search warrants (Document No. 24) ................................................................... 166-176 Affidavit of Rindfleischs counsel supporting motion to

suppress evidence obtained via search warrants (Document No. 25) ................................................................... 177-178

* Contains redactions intended to obscure birthdates or parts of birthdates.




Page 2 of 4

Exhibits to Rindfleischs motion to suppress evidence obtained via search warrants

(Document No. 26) ................................................................... 179-205 Tab 1 Yahoo! search warrant .................... 179-182 Tab 2 Gmail search warrant ...................... 183-186 Tab 3 court decisions (first pages

only; other pages omitted) ............... 187-205

States response to motion to suppress (Document No. 36) ................................................................... 206-215 Prosecutors affidavit in support of States response to

motion to suppress (Document No. 37) ................................................................... 216-225 Rindfleischs reply memorandum supporting motion to

suppress evidence obtained via search warrants (Document No. 40) ................................................................... 226-237 States rejoinder to Rindfleischs reply memorandum (Document No. 41) ................................................................... 238-239 States response not objecting to proposed order denying

suppression (Document No. 47) .......................................................................... 240 Wisconsin Court of Appeals opinion and order denying

Rindfleischs petition for leave to appeal a nonfinal order

(Document No. 66) .......................................................................... 241 States revised offer of settlement (Document No. 72) ................................................................... 242-244 Plea questionnaire and waiver of rights (Document No. 73) .................................................................... 245-254




Page 3 of 4

Order closing John Doe Proceeding (Document No. 90) ........................................................................... 255 Wisconsin Court of Appeals order to supplement

appellate record with John Doe documents (Document No. 86) ................................................................... 256-257 Affidavit in support of enlarging John Doe proceeding

and application for John Doe subpoenas (Document No. 87:Exhibit 3) ................................................... 258-275 Affidavit in support of search warrants (Document No. 87:Exhibit 6) ................................................... 276-308 Search warrant for Milwaukee County Executive's office

(color-photo exhibits omitted) (Document No. 87:Exhibit 7) ................................................... 309-311 Return of Google search warrant (without accompanying

e-mail records totaling 16,168 pages) (Document No. 87:Exhibit 11) ................................................. 312-313 Order permitting use and dissemination of John Doe

information and materials (Kelly Rindfleisch) (Document No. 87:Exhibit 10) ........................................................ 314 Transcript John Doe search warrant application (Document No. 87:Exhibit 9 (unnumbered

document))................................................................................. 315-441 Transcript oral decision denying Rindfleischs motion

to suppress evidence obtained via search warrants (Document No. 83) .................................................................... 442-452 Transcript change of plea (Document No. 84) .................................................................... 453-475




Page 4 of 4

States memorandum responding to Rindfleisch's motion to seal the supplemental appellate record (excerpt) ............... 476-489

Wisconsin Court of Appeals order denying motion to

continue supplemental appellate record under seal ............... 490-492 Rindfleisch counsels letter objecting to court order to

unseal supplemental appellate record ..................................... 493-494 Wisconsin Court of Appeals order unsealing

supplemental appellate record ................................................. 495-500 Wire and Electronic Communications Interception and

Interception of Oral Communications (a.k.a. Electronic Communications Privacy Act) - 18 U.S.C. 2510 through 2522 ............................................................... 501-523

Stored Wire and Electronic Communications and

Transactional Records Access (a.k.a. Stored Communications Act) - 18 U.S.C. 2701 through 2712 ........................................................................................... 524-535

Rule 41, Federal Rules of Criminal Procedure ............................ 536-542 Certificate of compliance with Wis. Stat. (Rule)

809.19(13)(f) .................................................................................. 543

STATE OF WISCONSIN CIRCUIT COURT MILWAUKEE COUNTY

STATE OF WISCONSIN,

Plaintiff,

vs. Case No. 12-CF-000438

KELLY M. RINDFLEISCH,

Defendant.

ORDER DENYING DEFENDANT'S MOTION TO SUPPRESS

EVIDENCE OBTAINED VIA SEARCH WARRANTS

The Court having considered defendant Kelly M. Rindfleisch' s motion for an

order suppressing evidence obtained by the state via search warrants issued on

October 20, 2010, including all pleadings and papers of record and the arguments of

counsel, for the reasons set forth from the Bench on August 21, 2012, the motion is

hereby DENIED. r-

Dated this -+1 day of September, 2012.

Drafted by: Kathryn A. Keppel Gimbel, Reilly, Guerin & Brown LLP 330 East Kilbourn Avenue l\1ilw-aukee,VVisconsin53202 Telephone: 414/271-1440 crim/rindfleisch/p/dimisssuppressorder2012-09-06

BY

State v. Kelly M. Rindfleisch, Appeal No. 2013AP362-CR

R-Ap. 101

_ST..;..;Ac..;.T;;..;.E;;_O.:;_F;...._;;.:W;..;;_IS"-'C"-'O:;.;;N.;;..;;S=IN;.;;.._ _ ___;;C;...;;.IR;...;;.C.:;_U=>IT COURT BRANCH 42 MILWAUKEE COUNTY Far Official Use Only

State of Wisconsin vs. Kelly M. Rindfleisch

Date of Birth: '.. .--. ?":;; .f"'">- -~1 . ;"""

~. ~~.-~-!ii'.. . ..,,.. .. f;J .....

The defendant was found guilty of the following crime(s):

Ct. Description Violation

1 Misconduct/Office 946.12(3)

Judgment of Conviction Sentence Withheld, Probation Ordered

FILED 11-27-2012

John Barrett

Case No. 2012CF000438 Clerk of Circuit Court

Plea Severity

Guilty Felony I

Date(s) Committed

04-14-2010

Trial To

Date(s) Convicted

10-11-2012

IT IS ADJUDGED that the defendant is guilty as convicted and sentenced as follows:

Ct. Sent. Date Sentence Length Agency Comments 11-19-2012 Probation, sent withheld 3YR Department of Court will allow probation and condition time to be

Corrections transferred to Columbia County.

Conditions of Sentence or Probation Obligations: (Total amounts only)

Fine Court Costs

20.00

Attorney Fees

D Joint and Several Restitution Other

13.00

Mandatory Victim/Wit. Surcharge

92.00

5% Rest. Surcharge

DNA Anal. Surcharge

250,00

Conditions Ct. Condition Length Agency/Program Begin Date Begin Time Comments

Ct.

House of Correction

Condition

Costs

Other

6MO

Firearms/Weapons Restriction

Agency/Program Comments

Release for work and family healthcare. ST A YED pending appeal.

Provide DNA sample if one has not previously been provided, pay surcharge. Pay all court costs, fees and surcharges. Failure to pay shall result in entry of a civil judgment. Standard rules of probation. Defendant advised as a convicted felon she may never possess a firearm or body armor; her voting privileges are suspended and she may not vote in any election until her civil rights are restored.

Pursuant to 973.01(3g) and (3m) Wisconsin Statutes, the court determines the following:

The Defendant is 0 is not 0 eligible for the Challenge Incarceration Program. The Defendant is 0 is not 0 eligible for the Substance Abuse Program. The following charges were Dismissed but Read In

Ct.

2 3 4

Description Violation Plea Severity

Misconduct/Office 946.12(3) Felony I Misconduct/Office 946.12(3) Felony I

Misconduct/Office 946.12(3) Felony I

IT IS ADJUDGED that O days sentence credit are due pursuant to 973.155, Wisconsin Statutes

IT IS ORDERED that the Sheriff shall deliver the defendant into the custody of the Department.

Date(s) Date(s) Committed Read In

04-16-2010 10-11-2012 05-03-2010 10-11-2012 05-04-2010 10-11-2012

CR212(CCAP), 08/2011 Judgment of Conviction, DOC 20, (08/2007) 939.50, 939.51, 972.13, Chapter 973, Wisconsin Statutes This form shall not be modified. It may d with additional material. Page 1 of 2

R-Ap. 102


_ST_A_T_E_O_F___..W_IS_C_O_N_S_IN ___ C_IR_C_U_IT COURT BRANCH 42

State of Wisconsin vs. Kelly M. Rindfleisch

Date of Birth:

Distribution:

David A. Hansher-42, Judge Bruce J Land11raf, District Attorney Franklyn M Gimbel, Defense Attorney

MILWAUKEE COUNTY

Judgment of Conviction Sentence Withheld, Probation Ordered

Case No. 2012CF000438

BY THE COURT:

For Official Use Only

FILED

11-27-2012

John Barrett Clerk of Circuit Court

Electronically signed by John Barrett Circuit Court Judge/Clerk/Deputy Clerk

November 27, 2012 Date

CR212(CCAP), 08/2011 Judgment of Conviction, DOC 20, (08/2007) 939.50, 939.51, 972.13, Chapter 973, Wisconsin Statutes This form shall not be modified. It may be supplemented with additional material. Page 2 of 2


R-Ap. 103

ll..'

STATE OF WISCONSIN

STATE OF WISCONSIN

vs.

CIRCUIT COURT CRIMINAL DIVISION

Plaintiff,

DO NOT HEMOVE MILWAUKEE COUNTY

CRIMINAL COMPLAINT

DA Case No.: 2012ML001714

Rindfleisch, Kelly M. Complaining Witness: 331 West Harrison Street Columbus, WI 53925 DOB:

Defendant,

Investigator Robert Stelter

Court Case No.: t 8'e_ ~ {J)()Lj ~~

THE ABOVE NAMED COMPLAINING WITNESS BEING DULY SWORN, ON INFORMATION AND BELIEF STATES THAT:

COUNT 01: MISCONDUCT IN PUBLIC OFFICE The above-named defendant, on April 14, 2010, at 901 North 9th Street, Milwaukee, Wisconsin, while acting in the capacity of a public employee did exercise a discretionary power in a manner inconsistent with the duties of the defendant's public employment and with the intent to obtain a dishonest advantage for herself, all contrary to Sections 946.12(3) of the Wisconsin Statutes.

COUNT 02: MISCONDUCT IN PUBLIC OFFICE The above-named defendant, on April 16, 2010, at 901 North 9th Street, Milwaukee, Wisconsin, while acting in the capacity of a public employee did exercise a discretionary power in a manner inconsistent with the duties of the defendant's public employment and with the intent to obtain a dishonest advantage for herself, all contrary to Sections 946.12(3) of the Wisconsin Statutes.

COUNT 03: MISCONDUCT IN PUBLIC OFFICE The above-named defendant, on May 3, 2010, at 901 North 9th Street, Milwaukee, Wisconsin, while acting in the capacity of a public employee did exercise a discretionary power in a manner inconsistent with the duties of the defendant's public employment and with the intent to obtain a dishonest advantage for herself, all contrary to Sections 946.12(3) of the Wisconsin Statutes.

COUNT 04: MISCONDUCT IN PUBLIC OFFICE The above-named defendant, on May 4, 2010, at 901 North 9th Street, Milwaukee, Wisconsin, while acting in the capacity of a public employee did exercise a discretionary power in a manner inconsistent with the duties of the defendant's public employment and with the intent to obtain a dishonest advantage for herself, all contrary to Sections 946.12(3) of the Wisconsin Statutes.

AS TO COUNTS 01 TO 04: . Upon conviction of these offenses, each being a Class I felony, the defendant may be fined not more than $10,000, or imprisoned not more than 3.5 years or both, as to each Count.

Complainant states that he is a Milwaukee County District Attorney Investigator and bases his complaint upon the sources of information identified in the paragraphs below.

R-Ap. 104


Kelly M. Rindfleisch, DOB: Page2

A. AUTHORIZATION OF DOE JUDGE

This investigation was conducted under the auspices of an ongoing Milwaukee County John Doe investigation, Milwaukee County Case No. 1 OJDOOOOO?. The Honorable Neal Nettesheim presides over this John Doe proceeding. The John Doe is subject to a Secrecy Order. To the extent thatthe John Doe investigation relates to Kelly Rindfleisch, Brett Davis, Brett Davis for Lt. Governor, a campaign committee, the Friends of Scott Walker, a campaign committee, and such other individuals as are named in this complaint, Judge Nettesheim has authorized the release of information necessary for the prosecution of this criminal matter.

B. IDENTIFICATION OF RELEVANT PARTIES

For purposes of this complaint, the following persons are identified in alphabetical order and described by role as it relates to this criminal complaint.

Bader, Jill. Ms. Bader was the Communications Director for the Friends of Scott Walker at times relevant to this complaint.

Davis, Brett H. In 2010, Mr. Davis was an Assemblyman and a candidate for the Office of Lieutenant Governor. Mr. Davis hired Ms. Rindfleisch to serve as his campaign fundraiser in early 2010.

Ermert, George. Mr. Ermert was a friend of Kelly Rindfleisch. He is employed as a consultant with Martin Schreiber & Associates, Inc. in Madison, Wisconsin.

Gilkes, Keith. Mr. Gilkes was the Campaign Manager for the Friends of Scott Walker at times -relevant to this complaint.

Graul, Mark. Mr. Graul was an unpaid consultant to the "Brett Davis for Lt. Governor'' campaign committee.

Loe, Emily G. Ms. Loe served as the first campaign manager for the Brett Davis campaign committee, "Brett Davis for Lt. Governor." She left this position in about late March 2010.

Nardelli, Thomas. Mr. Nardelli was the Chief of Staff serving in the County Executive's Office at all times relevant to this complaint.

Rindfleisch, Kelly M. Ms. Rindfleisch was hired by Deputy Chief of Staff Tim Russell as a County Executive employee. She began work in January 2010 as a Policy Analyst and was promoted to Deputy Chief of Staff in March 2010 when Tim Russell took the position of Housing Director for the Department of Health and Human Services.

Russell, Timothy D. As noted above, Mr. Russell was the Deputy Chief of Staff in the Office of the County Executive at times relevant to this complaint prior to March 2010. In March 2010, he was given the position of Housing Director for the Department of Health and Human Services.

Thompson, Stephan. Mr. Thompson was the Deputy Campaign Manager for the Friends of Scott Walker at times relevant to this complaint.

Villa, James. Mr. Villa was a former Chief of Staff to then County Executive Scott Walker. Mr. Villa served as an informal advisor to the Friends of Scott Walker. He is


R-Ap. 105


and was a personal friend to Governor Scott Walker. Villa also rented a room to Kelly Rindfleisch in West Allis, Wisconsin between March 2010 and the election in November 2010. .

Walker, Scott K. Mr. Walker, the current Governor of the State of Wisconsin, was at all times relevant to this criminal complaint the County Executive of Milwaukee County. Mr. Walker was also a candidate for Governor, and he was the candidate supported by the campaign committee known as the Friends of Scott Walker.

Werwie, Cullen. Mr. Werwie served as the second campaign manager for the Brett Davis campaign committee, "Brett Davis for Lt. Governor." He replaced Emily Loe in that position following Emily Loe's March 2010 departure from the Davis campaign.

Wink, Darlene. Ms; Wink was an employee responsible for Constituent Services in the Office of the Milwaukee County Executive. In May 2010, Ms. Wink resigned her position after it was revealed that she was posting comments of a political nature on the Milwaukee Journal Sentinel web site.

C. INTRODUCTiON & SUMMARY OF OFFENSES

Kelly Rindfleisch was hired by Deputy Chief of Staff Tim Russell in early 2010 to fill a position as Policy Advisor within the Offices of the County Executive. When she arrived for her first day of work, Chief of Staff Tom Nardelli was unaware she had been hired. Rindfleisch, however, was a former legislative aide who had worked in Madison. There she had met the then County Executive's friend and advisor, Jim Villa. She also knew Keith Gilkes from her work in Madison.

Using a non-County issued, personal laptop computer and a non-County, private wireless Internet connection supplied by Tim Russell, Ms. Rindfleisch worked on projects assigned to her by Russell (at least according to her own description shortly after starting in the County Executive's Office as a policy advisor). In an Internet chat on January 25, 2010 with a friend, George Ermert, after Ermert learned of the private wireless network in the County Executive's Office, Ermert asked Rindfleisch if she "was going to be helping out the campaign too." Rindfleisch replied to Ermert that:

"half of what I'm doing is policy for the campaign."

Rindfleisch stated that she worked on Operation Freedom as well. See Figure 1 below.

ermegj: who do you work with? ermegj: what are your policy areas? rellyk: tim russell rellyk: fran rellyk: I don't have specific policy are.as rellyk: I do projects tiin gives me ermegj: what's your title? reflyk: pollcy advisor ermegj: that's fancy rellyk: not really rellyk: but I don't need fancy - ~

]

R-Ap. 106



ennegj: i wish you didn't work for government... now i can't .talk to you about campaign stuff online rellyk: I'm on my laptop rellyk; separate !System ermegj: oh .. not shit ermegj; so It's cool? rellyk: yah ermegj: are you goiign to be helping the campaign out too? rellyk: really, half of what l'm doing is policy for tlie campaign rellyk: its policy stuff but its for use over there rellyk: I'm also doing operation freedom

Figure 1

Rindfleisch was promoted to Deputy Chief of Staff in March 2010. Her office was located less than twenty-five feet from the office of then County Executive Scott Walker. See Appendix A

From February until July 2010, Rindfleisch worked as a fundraiserforthe campaign committee "Brett Davis for Lt. Governor." Detailed below, substantial fundraising work was done for Brett Davis during business hours while Rindfleisch was paid to do work on behalf of Milwaukee County.

Persons associated with the Friends of Scott Walker campaign committee generally favored Brett Davis over other candidates for the office of Lieutenant Governor.

Darlene Wink resigned her position in the County Executive's Office on about May 14, 2010 because of her apparent political work during the business day. In the weeks thereafter, Ms. Rindfleisch thereafter decreased the amount of fund raising work she did from the County Executive's Office.

Dan Morse, a fund raiser for the Friends of Scott Walker, was brought on to help with Davis' fund raising activities in June 2010 .. Rindfleisch did not work well together with Morse and she resigned her position with the Davis campaign in July 2010. Morse continued his role as a Davis and a Walker fund raiser through the end of each of these campaigns.

After leaving county goverr)ment in November 2010, Ms. Rindfleisch worked on the Governor Walker Inauguration. Thereafter, although her salary is listed as an "In Kind" contribution from the Republican Party of Wisconsin to the Friends of Scott Walker, Ms. Rindfleisch worked as a fundraiserforthe Friends of Scott Walker. To my knowledge, Ms. Rindfleisch left this position in the second week in January 2012.

D. VENUE AND JURISDICTION

Based upon a review of Rindfleisch's personnel file produced by Candace Richards of the Department of Human Resources of Milwaukee County in response to a John Doe subpoena, I know that Ms. Rindfleisch was employed as an "Administrative Secretary, Policy Advisor'' in the Office of the County Executive for the period of January 13, 2010 to March 14, 2010.

Further, based upon a review of Rindfleisch's personnel file, on March 15, 2010, Ms. Rindfleisch was promoted to the position of Deputy Chief of Staff in the Milwaukee County Executive's Office. Ms. Rindfleisch held this position through November 2010.

f


R-Ap. 107

Kelly M. Rindfleisch, DOB: Pages

The Office of the County Executive is located in the Milwaukee County Courthouse, located at 901 North gth Street, City of Milwaukee, State of Wisconsin.

Milwaukee County is a political subdivision of the State of Wisconsin.

Ms. Rindfleisch established a residence in Milwaukee County in March 2010. Based upon a review of personnel records produced by Candace Richards, Department of Human Resources of Milwaukee County, I know that as of June 2, 2010 Ms. Rindfleisch claimed her residence as 1331 South 93rd Street, West Allis, Wisconsin.

James Villa was the former Chief of Staff for the Milwaukee County Executive's Office. He is a long-time personal friend of Scott Walker. He served as an informal advisor to the Friends of Scott Walker in 2010. In his testimony before the John Doe Judge, James Villa stated that he resides at 1331 South 93rd Street, West Allis and that in March 2010, Ms. Rindfleisch began living at his home several days a week. This is the same address that Ms. Rindfleisch claimed as her Milwaukee County residence to fulfill her residency ,requirement as a Milwaukee County employee.

Andrea Boom is a woman who worked with Kelly Rindfleisch prior to Rindfleisch's employment in Milwaukee County. In 2011, Ms. Boom worked together with Ms. Rindfleisch at the offices of the Friends of Scott Walker. In her testimony before the John Doe Judge, Andrea Boom stated that she engaged in "chat sessions" with Ms. Rindfleisch using the chat account of [email protected]. Boom identified the moniker of "rellyk" as belonging to Kelly Rindfleisch. Figure 2 is a copy of part of a "chat session" recovered from Kelly Rindfleisch's laptop computer.1 According to the information obtained from the Rindfleisch laptop and as confirmed by the John Doe testimony of Andrea Boom, Ms. Rindfleisch engaged in a "chat session" with Andrea Boom, which chat session bears a date of Wednesday April 28, 2010 beginning at 8:20 a.m. As set forth in Figure 2, Rindfleisch "chatted" that she does have a residence requirement as an employee for Milwaukee County and that she lives on "93rd and Greenfield" at the home of her friend, Jim Villa.

1 The Rindfleisch laptop was recovered on November 1, 2010 when Investigators for the Milwaukee County District Attorney's executed a search warrant in the Milwaukee County Executive's Office seeking evidence of Misconduct in Public Office and Political Solicitation Involving Public Officials and Employees. Rindfleish's laptop was imaged and examined by Milwaukee County District Attorney Office Information Technology Manager and certified Encase forensic computer examiner James Krueger.

R-Ap. 108


Kelly M. Rindfleisch, DOB:

Figure 2

rellyk: I was thinking you not trevor Andrea: well, yeah Andrea: but neither one of us lives there rellyk: nope Andrea; do you have a residency requirement? rellyk: yep rellyk: I live on the corner of 93rd and Greenfield rellyk: you .actually get six months to move Andrea: dude Andrea: did you sell your house? rellylc which in this case, if he wins, it wouldn't matter rellyk: no rellyk: it's my friend villa's housee Andrea: nice

, rellyk: I stay 2 nights a week rellyk: hence having michaela take care of the beasts Andrea: so when he wins, you can just live in Columbus rellvk: vep

Page 6

Further, on November 1, 2010, I executed a Search Warrant at Rindfleisch's residence at 1331 South 93rd Street, West Allis. At that time, Rindfleisch accompanied me. She let investigators into the house with her key, and Ms. Rindfleisch showed me the bedroom where she stayed.

E. STATUTES AND RULES APPLICABLE TO MILWAUKEE COUNTY EMPLOYEE CONDUCT

Ms. Rindfleisch, at all relevant times, was.a public employee within the meaning of Wisconsin Statutes 946.12.

Wisconsin Statutes 946.12(2) prohibits a public employee from acting, in the employee's capacity as an employee, in a manner which the employee knows is forbidden by law to be done in the employee's official capacity.

Wisconsin Statutes 946.12(3) prohibits, whether by act of commission or omission, a public employee from exercising a discretionary power in his or her capacity as a public employee with the intent to obtain a dishonest advantage for another.

Wisconsin Statutes Section 11.36( 4) provides:

No person may enter or remain in any building, office or room occupied for any purpose by ... any political subdivision [of the State] ... or send or direct a letter or other notice thereto for the purpose of requesting or collecting a contribution.

Wisconsin Statutes Section 11.36(2) provides:

No person may solicit or receive from any officer or employee of a political subdivision of this state any contribution or service for any political purpose during established hours of employment or while the officer or employee is engaged in his or her official duties.


R-Ap. 109


Milwaukee County Ordinances further provides at 9.05(2) that:

No county public official or employee shall use his/her public position or office to obtain financial gain or anything of substantial value for the private benefit of himself/herself or his/her immediate family, or for an organization with which he/she is associated.

Milwaukee County Ordinances further provides af 9.06 provides that:

No county public official or employee at his or her place of employment while engaged in his or her official duties shall, for the apparent purpose of seeking to elect or defeat a person seeking elective office:

(a) Wear or display any campaign material.

(b) Distribute any campaign literature.

(c) Solicit contributions for any candidate.

(d) Engage in political campaign activities for any candidate.

The conduct of public employees is further guided by the judicial decision emanating from the Caucus Scandal. See State v. Chvala, 2004 WI App 53, 271 Wis.2d 115, 678 N.W.2d 880. .

F. ACKNOWLEDGEMENT OF RULES FOR MILWAUKEE COUNTY EMPLOYEE CONDUCT

Laurie Panella is the Acting Director of the Milwaukee County Information Management Systems Division {"IMSD") of the Department of Administrative Services.

Pursuant to John Doe Subpoena, Ms. Panella produced IMSD documents and records relevant to the John Doe investigation. In this regard, I have reviewed a document entitled "USE OF TECHNOLOGIES POLICY" signed "Kelly Rindfleisch" and dated January 13, 2010. The Rindfleisch signature appears immediately below the following text:

I acknowledge that I am in receipt of Milwaukee County's Use of Technologies Policy and that violations of my obligation to adhere to this policy may result in progressive steps of discipline, which may include my discharge from Milwaukee County service. I also understand that violations of the policy on my part may result in Milwaukee County taking action that will deny me access or rights to any of Milwaukee County's technology resources.

My signature on this Policy does not imply agreement with the policy, but rather shows that I have read and received a copy of this policy from the management of my workplace.

1

R-Ap. 110


Kelly M. Rindfleisch, DOB: Pages

The. Milwaukee County Technology Policy prohibits the use of county equipment2 for fund raising, political campaign activities, or public relations activities not specifically related to County government activities.

G. THE RECORDS OF THE CERIDIAN TIMEKEEPING SYSTEM FOR MILWAUKEE COUNTY DOCUMENT WHEN KELLY RINDFLEISCH WAS WORKING AS AN EMPLOYEE AND WHEN SHE CLAIMED OFF-TIME

I am familiar with a Milwaukee County timekeeping system known as the "Ceridian" system. In the course of this John Doe investigation, subpoenas were served upon Milwaukee County for records relating to the time reporting of Kelly Rindfleisch. These records reflect Rindfleisch's off-time due to vacation, personal holidays, sick time and other forms of sanctioned employee leave. Except as otherwise noted in the paragraphs below, when I refer to an action taken by Kelly Rindfleisch between the hours of 8:00 a.m. and 5:00 p.m. Monday through Friday, I have checked the Ceridian records and confirmed that Kelly Rindfleisch reported no employee off-time on that day:

H. THE JOHN DOE INVESTIGATION HAS GATHERED RECORDS TENDING TO ESTABLISH THE DATES AND TIMES THAT KELLY RINDFLEISCH WAS AT HER DESK IN THE COUNTY EXECUTIVE'S OFFICE

I know that Milwaukee County Courthouse Complex employees are routinely issued electronic "Key Cards" that allow access to otherwise secure areas of county buildings. These areas include the exterior entrances to the Courthouse and the offices of the County Executive. The "Key Card" system maintains a digital record of each time a specific card is swiped by the cardholder, including the location accessed by the cardholder. As part of the John Doe investigation, these Key Card accessrecords for the Key Card assigned to Kelly Rindfleisch were subpoenaed and examined.

Like county "Key Card" records, CPS Parking also maintains records for those persons who park in MacArthur Square parking lot on a monthly basis. The John Doe Judge issued a subpoena for these records, which I have also reviewed as they relate to Kelly Rindfleisch. The MacArthur Square parking lot is immediately adjacent to the Milwaukee County Courthouse, and many persons who work in the Courthouse Complex rent space for parking there. CPS Parking issues access cards to its monthly parking customers. These access cards are scanned at the time of entry into and exit from the MacArthur Square parking lot. A record. is created at the time of entry and exit recording the date, time and the card used for entry or exit. Obtained by John Doe subpoena, I have examined these CPS Parking records for Kelly Rindfleish.

Based upon my review of parking records during the time that Ms. Rindfleisch parked

2 The policy states:

For the purpose of this policy, technologies in the work environment shall refer to a wide array of equipment and/or software, including, but not limited to: analog and digital telephone services (voice mail, message broadcasting, message/call forwarding), facsimile (fax) machines and servers, image scanning and copying equipment, shared and stand-alone computers (both fixed and portable) and their peripherals, pagers (text and voice), cellular phones, data networks, dial-up network facilities, global positioning systems (GPS), radios (VHF, UHF, 800 MHz, 800 MHz trunked, fixed and portable units), and wireless services.


R-Ap. 111


her car in the MacArthur Square parking lot (April 1, 201 Oto November 2, 201 O) and based upon my review of county "Key Card" records (April 1, 201 O to November 2, 2010), I can state as a general matter that Ms. Rindfleisch arrived at the Courthouse Complex at about 7:00 a.m. and left from the MacArthur Square parking lot between 4:30 and 5:30 p.m.

I. INVOLVEMENT WITH CAUCUS SCANDAL

The information in this section of the complaint is based upon my review of the reports written by Department of Justice Division of Criminal Investigation Special Agent Dorinda M. Freymiller.

Because it bears upon Ms. Rindfleisch's knowledge of the proper limits placed upon the conduct of public employees under the laws of the State of Wisconsin, I note that, on December 16, 2002, Ms. Rindfleisch was interviewed by State Department of Justice Agents investigating the Caucus Scandal.

As part of the interview, Rindfleisch was shown an Immunity letter from then Dane County District Attorney, Brian Blanchard, according to the reports of the Special Agents conducting the interview.

Rindfleisch was employed as a staffer for Representative Scott Gunderson from January 1995 - May 1999. She worked at the Assembly Republican Caucus (ARC) in legislative services and media from May 1999 - March 2000. Rindfleisch worked at the Senate Republican Caucus (SRC) from March 2000 - December 2001 as a policy analyst, and was - at the time of the interview - employed as a staffer for State Senator Mary Panzer.

Rindfleisch stated that, when she began working at the ARC, Sherry Schultz helped Rindfleisch with planning and organizing fundraisers for Assembly Republican Members.

Rindfleisch stated that ARC staffers were assigned to work with specific new members of the Assembly. ARC staffers were expected to help the new member with setting up their office structure, policy issues and fundraising. Rindfleisch stated she left the ARC before the 2000 campaign cycle began, so her involvement with fund raising was mostly related to compiling lists of potential people to invite.

Rindfleisch stated that she was approached by a Brian Fraley who asked her to work at the SRC. Rindfleisch gave statements regarding her work on political campaigns as directed by Brian Fraley. She stated that her pay as a state employee would be reduced by 80% to 100% during these times. Rindfleisch also spoke about campaign materials removed from the SRC and placed in storage at the direction of Brian Fraley, after the 2000 campaign season and before January 1, 2001.

9

R-Ap. 112


Kelly M. Rindfleisch, DOB: Page 10

J. FROM THE DEPUTY CHIEF OF STAFF'S OFFICE IN THE COURTHOUSE, RINDFLEISCH CONDUCTED FUNDRAISING FOR LT. GOVERNOR CANDIDATE BRETT DAVIS, THE "BEST CANDIDATE" FOR THE FRIENDS OF SCOTT WALKER, ALL WHILE BEING PAID BY BOTH THE TAXPAYERS OF MILWAUKEE COUNTY AND THE DAVIS CAMPAIGN COMMITTEE

1. Brett Davis was the favored Lieutenant Governor candidate of the Friends of Scott Walker.

a. Keith Gilkes, Campaign Manager of the Friends of Scott Walker, considered Davis as "the" candidate for Lieutenant Governor.

Keith Gilkes served as the manager for the campaign committee, the Friends of Scott Walker.

TOl

!i!~bJileb Date;

Kelty A1ndnMh

RE: fJ!day, May rr7, 2010 10:49tl9 AM

lWill do that as qulcillY as I can.

I talked to Keith. He got your e-mail about Ed Mooney. He thought you wanted hrm to ask- him to write a i:heck. I tlarlfled that we wanted him to tell him that you are the best match to help' Scott get the Gtivemo~s office. Essentially, he'.11 be doing a block: Qn Collins. He happily agreed to do that. He Jus!: didn't want to ask hlin to write a check. l told hlin that Ed Is ready to write the check, we just need someone to reinforce you are th.e guy.

--Original Message--- From: [email protected] [ma!JtoBrett.Da\/js@c!Jarter net] Sent: Friday, May 07, 2010 5:23 AM To: Kelly Rindfleisch Cc: Cullen Werwle Subject:

Kelly,

Let me.know when you can talk today about the La CroliSeevent.

Also, could you pull together a Racine call list and e'mali It to Robin Vos at robh c6m.

Thanks,

Brett Sent via BlackBerry by AT&T

Figure 3

As set forth in Figure 3 at top of thread,3 on the morning of May 7, 2010, a furlough day for Rindfleisch, at about 10:50 a.m., Kelly Rindfleisch wrote to then Assemblyman and Lieutenant Governor Candidate Brett Davis. She advised Davis that she had been speaking with Keith Gilkes (the Friends of Scott Walker [FOSW] campaign manager) and that Gilkes said that he (Gilkes) had gotten Davis' e-mail about Ed Mooney. See Figure 3. Rindfleisch explained to Brett Davis that Gilkes thought that he (Gilkes) was supposed to ask

Mooney for a contribution. That was not correct, Rindfleisch said, and she clarified for Gilkes as follows, "I clarified that we wanted him (Gilkes) to tell him (Mooney) that you are the best match to help Scott get the Governor's office." Rindfleisch goes on to explain to Davis, "I told him (Gilkes) that Ed is ready to write the check, we just need someone to reinforce you are the guy." See Figure 3.

3 This e-mail was obtained from Google Gmail, provided in response to a Search Warrant authorized by the John Doe Judge for the account of [email protected]. This e-mail account has consistently been identified in John Doe testimony as belonging to Kelly Rindfleisch.

10


R-Ap. 113


With an e-mail to Gilkes on May 19, 2010 at about 12:50 p.m., Rindfleisch followed up on her earlier e-mail asking Gilkes if he had an opportunity to speak with Mooney. See Figure 4 at bottom of thread. On May 19, 2010 at 1 :23 p.m., Gilkes responded to Rindfleisch, "I talked with him personally Friday. I think he agreed with why I thought Brett is the candidate." See Figure 4 at top of thread.4

Fram: Kelth Gll!ses - friends of swtt Walker To: kmrlmffle!sch@gmall mm Subject: RE: Davis D;ite: Wednesday, May 19, 2010 1:2z::n PM

I talked with him personally Friday. I think he agreed with why I thought Brett is the candidate.

Keith Gilkes Friends of Scott Walker Office: (414) 453-2010

-----Orlglnal Message----From: [email protected] [mailto:kmrlndflejsch@gmailcom) Sent: Wednesday, May 19, 2.010 12:49 PM To: Keith Subject: Davis

Additionally, Gilkes assisted Rindfleisch in her fundraising efforts for Brett Davis. On June 18, 2010 at 9:50 a.m., a workday, Kelly Rindfleisch wrote to Brett Davis during her . workday. See Figure 5. Based upon her e-mail to Brett Davis and to Davis' campaign manager, Cullen Werwie, Gilkes was to provide to Kelly Rindfleisch the names of two people who did

successful events for ---------------------- Scott Walker in the

Figure 4 Racine area.

Were you able to talk to Ed Mooney? He Is writing a check to Brett. Sent from my U.S. Cellular BlackBerryR smartphone

From: To: subject: Date:

kmcindflejscb@amai! rnm

Brett davjs; Cullen Wetwie

Racine Friday, June 18, 2010 9;49:55 AM

I talked keith this morning about the trouble with racine. He is going to send me the names of the two people who did successful events for scott down there. Sent from my U.S. Cellular BlackBerry smartphone

Figure 5

b. Stephan Thompson. Deputy Campaign Manager for the Friends of Scott Walker. supported Brett Davis as the Lieutenant Governor candidate.

Stephan Thompson served as the Deputy Campaign Manager for the Friends of Scott Walker during 2010.

Mr. Thompson confirmed in his John Doe testimony on October 18, 2011 that he favored Brett Davis as the candidate for Lieutenant Governor, and he further confirmed

4 See footnote 3 for source information.

11

R-Ap. 114



that "generally speaking the campaign favored Davis as the Lieutenant Governor candidate."

c. Jim Villa. chair of the Walker Inaugural Committee and a close personal advisor to the Friends of Scott Walker. supported Brett Davis for Lieutenant Governor.

Noted above, James Villa was, prior to Tom Nardelli, the Chief of Staff for County Executive Scott Walker. In 2010 he served as an informal personal advisor to Scott Walker and his campaign. He has known Scott Walker since college.

Villa supported Brett Davis as a candidate for Lieutenant Governor in a number of ways. First, he helped raise funds. On April 14, 2010 at 7:15 a.m. on that date, Rindfleisch wrote to Brett Davis as shown in Figure 6.5

On June 10, 2010, as

From: To: subject: Date:

Ktllx Rjndflel


d. John Hiller. Treasurer of the Friends of Scott Walker. supported Brett Davis for Lieutenant Governor.

I have reviewed the Wisconsin Government Accountability Board Campaign Finance Information System records for the contribution activity of John Hiller, the Treasurer for the campaign committee Friends of Scott Walker. GAB records show that Hiller contributed to one Lieutenant Governor candidate only, that being Brett Davis, giving $200 on June 6, 2010.

2. Rindfleisch worked to raise funds for Brett Davis from her office in the County Executive Office Suite in the Courthouse.

Kelly Rindfleisch served as the fund raiser for Brett Davis for the time period of about January 31, 201 O until she resigned that position in July 201 O. Kelly Rindfleisch was replaced by Dan Morse, a person who also worked as a fundraiser for the Friends of Scott Walker.6

From my knowledge of the race for Lieutenant Governor and from my review of GAB filings, I know that Brett Davis was a candidate for the Office of Lieutenant Governor. He was the candidate identified in campaign registration papers filed for the committee identified as "Brett Davis for Lt. Governor" with the GAB. I also know that a Primary Election was held in the race for the Republican candidate for Lieutenant Governor. That primary was held on September 14, 2010. Mr. Davis did not successfully emerge from the primary and was defeated by Rebecca Kleefisch.

a. Rindfleisch's fundraising work during the course of her official duties was not isolated during the time period of Februarv 2010 to Julv 2010.

Based upon my review of e-mails obtained by Search Warrant from the Google Gmail account of Kelly Rindfleisch, [email protected], I know that Rindfleisch exchanged e-mails with [email protected], an account maintained by Brett Davis, a minimum of approximately 300 times between the hours of 8:00 a.m. and 5:00 p.m., Monday through Friday between February 3, 2010 and July 9, 2010.7 These e-mail contacts were almost always, if not exclusively, related to fundraising efforts.

Overall, from February 3, 2010 to July 9, 2010, between the hours of 8:00 and 5:00 p.m. other than the days on which she was out of the office for holidays or personal off-time, the investigation has identified about 1,380 e-mails sent or received by Kelly Rindfleisch related to fundraising activities.

6 See footnote 3. 7 This calculation excludes days on which Ms. Rindfleisch claimed off-time from work.

13

R-Ap. 116



b. Rindfleisch's fundraising work was accomplished using a secret e-mail svstem available to and used by select ''insider" staffers for both official and unofficial business.

I know8 that Rindfleish's e-mail communication was accomplished using an unofficial, personal laptop computer and networking equipment.

The unofficial networking system Rindfleisch used9 was established by Tim Russell. In the course of the execution of a Search Warrant in the Office of the County Executive on November 1, 2010, Milwaukee County District Attorney investigators searched the office of the Deputy Chief of Staff, formerly occupied by Tim Russell and occupied by Rindfleisch on the day of the search. In an armoire in that office, I am advised by investigators that they found packaging for two network devices. First, they found a box for an AT&T "USBConnect" "LaptopConnect" device. This is pictured on packaging as a USB device designed to be plugged into equipment for purposes of making a 3G broadband Internet connection. Second, investigators found a box for a wireless Netgear .3G Mobile broadband Wireless Router. Instruction sheets accompanying this Netgear device illustrate that it was designed to be connected to a "3G USB Modem," among other types of connections. Packaging labels found with these boxes bore the name of ''Timothy Russell" and were addressed to 901 North 9th Street, Ste 306, Milwaukee, WI 53233-1425." The John Doe Judge issued a subpoena for the AT&T records of Timothy Russell and I have examined the records that AT&T produced. These records show that Russell was paying for a device with wireless numbers matching the AT&T "USBConnect" "LaptopConnect" device described immediately above and the records show a "Service Start Date" of October 16, 2009.10

The unofficial e-mail system was routinely used by selected insiders within the Walker administration. The existence of this e-mail system, which was based on personal Internet e-mail accounts and was used both for official and unofficial purposes, was never disclosed to county employees outside a closely held group within the Walker administration.

In fact, even though the secret e-mail system was used for business purposes which could have and which did include communications within the scope of Open Records requests, the existence of the system was never disclosed to Laurie Panella, the Acting Director of the Information Management Services Division. Panella was responsible for gathering all relevant e-mails in response to Open Records requests and she was part of an Open Records Committee that

8 This statement is based upon the information developed in the course of the execution of a Search Warrant by Milwaukee County DA investigators including the seizure of Rindfleish's laptop computer, an examination of that laptop computer, and statements of other County Executive office employees. 9 In his testimony before the John Doe Judge, former county employee Jon Myhre, a Policy Analyst for the County Executive in March and April of 2010, testified that Rindfleisch used a router device that allowed for a connection between a laptop and the Internet. He stated that he had assisted Kelly on at least one occasion with a router malfunction. 10 The equipment itself was not found. At the time the search warrant was executed, Ms. Rindfleisch's laptop was found "tethered" to her cell phone.


R-Ap. 117


had been formed to respond to Open Record requests submitted to the Walker administration in May 2010. Panella testified that although it would have been important for her to know about such a private e-mail system, it was never disclosed to her. See Appendix B.

c. Between February and Julv 2010, besides fundraising for Brett Davis. Rindfleisch otherwise spent significant .periods of county time on communications with the Friends of Scott Walker campaign committee.

Besides raising funds for Brett Davis, Kelly Rindfleisch maintained regular contact with the Friends of Scott Walker campaign committee. Identified within the [email protected] e-mail account seized by virtue of a John Doe search warrant, for the time period of February 3, 2010 to July 9, 2010 (excluding weekends, holidays and off-time) during standard business hours (8:00 a.m. and 5:00 p.m.), the John Doe investigation has identified in excess of 1,000 e-mails on which either campaign manager Keith Gilkes, deputy campaign manager Stephan Thompson or campaign communications director Jill Bader was a sender or recipient. In other words, on more than 1,000 occasions between February and July 2010, Rindfleisch either sent e-mails to Gilkes, Bader or Thompson or she received an e-mail which was also received by either Gilkes, Bader or Thompson. This averages to about 10.8 such e-

" mails per day, with a maximum number of 7 4 such e-mails on April 29, 2010. Because Ms. Rindfleisch communicated with other campaign representatives (but on a less frequent basis), these numbers are illustrative and do not conclusively summarize e-mails on which Ms. Rindfleisch was either the sender or a recipient.

d. The Contract to Raise Funds for Brett Davis and Conference Calls with the Davis Campaign Committee.

The contract between Rindfleisch and Brett Davis for fund raising services itself was exchanged via e-mail on Thursday February 4, 2010 at 3:40 p.m., with Rindfleisch sending the contract to Davis using her kmrindfleisch @gmail.com account. According to the terms of that contract, Rindfleisch was to be paid $1,000 per month. A review of Ms. Rindfleisch's bank records, obtained by virtue of a subpoena issued by the John Doe Judge indicate that a sum total of

From: To: Subject: Date:

ernjly@mtehrettdayjs com4. rel'vk u5@vabnp mm~ "Brett Dayjf' RE: Funds call Wednesday, February 03, 2010 3:'!0:30 PM

Call In Number: (218) 862-1300 code:156235

From: [email protected] [mallto:[email protected]] Sent: Wednesday, February 03, 2010 3:30 PM To: relly"[email protected]; Mark Graul; Brett Davis Subject: Funds call

Gall is set for 2:00, this Friday afternoon.

Mark, could you please provide us with a call-in number?

thanks .all! $5,000 was deposited .._ ___________________ ..

into Rindfleisch's Figure 7

R-Ap. 118



account paid to her by the Brett Davis campaign committee.

While many of the communications concerning fund raising were accomplished by Ms. Rindfleisch using e-mail, she also particiBated in conference calls with other members of the campaign. See Figure 7. 1

e. To Raise Funds for Brett Davis. Rindfleisch dealt with multiple different fundraiser hosts while she was in the County Executive's Office.

As part of the John Doe investigation, a number of fund raiser hosts and fundraiser facilitators who dealt with Kelly Rindfleisch gave statements before the John Doe Judge. Fromi Kelly iado.om These persons !:~tt o.is Evnt included Ms. Candee o ... , Fridy, Mardi 19, 2010 Ml:os AM Arndt, Ms. Crystal Berg, Ms. Patty DeGraff, Ms. Bronwyn Glojek, Mr. Michael Huebsch, Ms. Kathy Kiernan, Mr. Tim Lightner, Mr. Steve Peotter and Dr. Barrett Straub. Mr. Jason Thompson, the Treasurer for the campaign committee Brett Davis for Lt. Governor and a fundraiser host, also gave a statement to investigators. These individuals have confirmed their dealings with Ms. Rindfleisch during regular business hours, although they generally stated they were unaware that she worked in the Office of the Milwaukee County Executive.

Attachments: Washincib::>n,xls

Hi Chrystal - I have attached a potential host list. If you could take a look at it and add people that are missing, that would be great

Figure 9

From: 'r .. Sqbje,ct: i>m.: At.tachrqents:

KeUy Bjnd!lei5di

RE;E~t

Tuesday:, April 061 l010 10:06i'48 AM f)reqon.xls

Hi Steve- I have attached a list of donors in Oregon. It's ab1>ut 100 people,

Let me know if you have any questions.

From: Brett Davis [mailto:[email protected]] Sent: Tuesday, April 06, 2010 8:53 AM To: 'Kelly Rindfleisch' Cc: 'Steve Peotter' Subject: RE: Event

Kelly,

My friend Steve Peotter is going to host a fund raiser in Oregon for me with the goal of raising $3,000. Right now we're thinking Monday, May24,butthat date is not officially set yet can you

put together a list of Oregon donors that Steve can work off of? You can e-mail hint directly at the address I cc'd in this e-mail.

Thanks!

Brett

Figure 8

11 Figure 7 was obtained by virtue of a John Doe Search Warrant served on the Yahoo account of rellyk [email protected]. Doe witness James Villa identifies this moniker "rellyk_us" as belonging to Kelly Rindfleisch.

i{o


R-Ap. 119


With all of these individuals, as a general practice, Ms. Rindfleisch followed the same pattern of interaction. Initial contact usually took the form of sharing a list of potential donors. See Figure 9,12 Figure 8,13 and Figure 10.14

fl'om: To; Subje


J:mm1 T C


From: ro: Subject: Date: Attachmenbl:

Kelly Qjndflejg;b 11 Rmnwyn GJgiek11

RE: Fundraiser Tuesday, April 201 2010 8:01:04 AM Waukesha Invite.cdf

Page 19

Bronwyn -here is the invite with the changes you requested. Let me know what you think.

Thanks, Kelly

Figure 13

I The Glojeks & Cohosts Invite you to a11. Hors d'oeuv:res Reception in support of

Figure 14

Brett Davis C8.ndi4ft,fe for Lieterumt Governor

Monday, May 17 5:30pm ,. 7 :30 pm

Piano Blu 179 West Wisconsin Avenue

Pewaukee, Wisconsin

All contributions gratefully accepted Suggested Donation: $50

The Tables set forth below are a compilation of Kelly Rindfleisch's fundraising activities for chosen dates.17 The "Date" column records the date of the activity .. The "Time" column records the time of the activity. The "Activity'' column describes the nature of the activity. Specifically, the terrn "Parking" means the entry into or exit from the MacArthur Square Parking lot. "Key Card" indicates a swipe of a key carder reader, indicating access to a part of the Courthouse Complex. "E-Mail" refers to an e-mail sent or received by Ms. Rindfleisch on her

17 The e-mails in the Tables below are taken from the Gmail account of Kelly Rindfleisch, [email protected], as obtained by a Search Warrant issued by the John Doe Judge. The text of the e-mails in the tables is copied in a form substantially identical to the text of the original e-mail. Personal identifying information such as addresses, phone numbers and e-mail addresses for persons peripherally involved in this investigation have been redacted.

R-Ap. 122



private account, [email protected]. "LN" refers to a Lotus Notes e-mail sent by Kelly Rindfleisch using the official Milwaukee County Lotus Notes system. "Chat" refers to Chat Text identified on the Rindfleisch laptop that was seized at her office on November 1. 2010. "Phone" refers to a phone call.

------~-- --~ ~-~~~ -~- - - -- ~~-- ~ fi!l9&Wlii!iliit iiiikifi ~ -~-:J ____ _j~~!'_~ll1L _____ l_IN P~_r:~ir:i~L----------------------------------------------------------1

---~-~~~---~~~~~~--~---~

I 4/12/2010 6:57 ! Key Card I Access to County Executive Offices I I 4/12/2010 10:20 : E-Mail I KR to Jennifer Holzmann, Werwie: Hi Jennie - I wanted to thank I I I I you again for all your help with the fundraiser. I heard it was a I

i I wonderful event and was well attended. I I - i I' I Any expenses you incurred for the event need to be reported as II I I an in-kind contribution on Brett's report. I know there was a trade- i i I out for the food and beverages (which would be reported), but I ! i I wasn't sure if you had any other expenses.

:I! i If you could shoot me, or Cullen, an e-mail with the expenses so 1 they can be reported, that would be wonderful. I want to make

I I sure we don't miss anything. ! I I I Thanks again, I

---------L---------------~ K~y_--------------------------------------------------------------------------------------------1 10:35 I E-Mail I Jennifer Holzmann to KR: Thanks for your assistance Kelly as I

I 1 well! i 1 I I

I I

I

l __ I 411212010 I

I I will see if the caterer charges exceed the credit we had with ! j them. I

I Do you have any idea how successful the event was? I , I

I , ! l 0 I Jenn - I !----------------- ----------.. ---T----------;--------------r--:-_;----------;----------------.. ----;-----------------------------;------~ i 4/12/2010 10:38 ! E-Mail i KR to Jennifer Holzmann: I think the total was close to $4,000 1f I

l--411"272010-~-1-1:39----[-E=Maif- -----l--S~~~-~~~uTz~fo!~R~}~\t:~~11~{~;;~~~~~~~f 1


! 4/12/2010 13:58 i E-Mail i Davis to KR: About 12 people total. Good grass roots folks. i j--------------- ---------------------------t--------------------------------------------------------------------------- I 4/12/2010 14:01 i E-Mail i KR to Davis: Lunch events are really hard. Not many people i l---------------- __________ J ____________________ l_~~ll:!.U_y_~tend,_ ______________ _:_ _________________________________ ~ i 4/12/2010 . 14:06 ! E-Mail ; Davis to KR: Still have to check the PO Box but we've raised i I I i I $2,080 for the green bay event so far. Collecting for hosts needed j l I too. I 4/12/2010 14:13 l E-Mail ! KR to Davis: Were you able to make any calls for the La Crosse i f-4H21201-1f 14::n----h~=fiA-an-------------J-5~r~~~Rif9~g-~:~~-~a~~--~~~~1~;a~~fg~:~~o~=~Ey~f ~;e~~--i f-471212iffif- --:f4:2o-----~E:--=--rV1aii------------1 ~~1~1~a-~i~ti do-n'Hfi"iii_ists:a-?i>-etfzers ____ -1 I I ! I are served and the event is ~ree. O~ the day of the big tea party [

bm~1~crn~:~IJ~4:~!~~~-~faE~~Ic~=~-~===tK~y~:8~i;~~~~~~~[~~~(~l~~~l~t~~~u~~~IT~A~1~~jfi~L=j

~I

R-Ap. 124



l--4ff212010+14:so---+E=-Mail-------I ~~t~~:~1~-~~~r~~~1~a1t~~~~~~s~!-%-~~~t~~\!ij~filvitesto_r_~ I J I them. Could you do that? I I I I I ' I i Crystal Berg \

I ' I xxxxxxxxxxx '

Ii

i II.I I Hartford, WI 53027 I [ Kathy Kiernan

I. I I I xxxxxxxxxxx I i i Richfield, WI 53076 i

L I :I~ I II ---------+----+------ I Sorry about that. .. 1

4/12/2010 14:54 ! E-Mail_ I Davis to KR re having Werwie find a date that works: Thanks I 4/12/2010 14:57 I E-Mail I Kathleen Kiernan to KR re updates to RSVP list for 04/19 Davis I

L _ i i fundraiser: Thank you Kelly - Kathy 1[

I 4/12/2010 15:12 i LN ! Lotus Notes sent I 4/12/2010 15:16 I E-Mail j Werwie to KR re 30 invites for 04/19 Davis fundraiser: No worries- i I l i I'll send them out right away. - i i 4/12/2010 15:17 I E-Mail I KR to Werwie re sending 30 invites for 04/19 Davis fund raiser: :_i I 1 i Thanks! 1 !---------------- -----------------------------------,------------------------------------------------------------------------------ 1 4/12/2010 15:29 I E-Mail i Bronwyn Glojek to KR re mock up invite for 05/17 Davis !

l-4ff212010-f--fs:3a-+"E~M'aTI----------\--~17


-- -I 411412010 '7:28 I E-Mail

!

KR to Davis: He gave me six names and asked if you'd talked to I them. 4 of the 6 were on your big donor call list.

1

1 I !

I

i

Jon Litscher Fred Luber (on list) Bill McCoshen Jack McKeithan (on list) Tim Michels (on list) Ed Mooney (on list)

' Hopefully, he will make the calls to those that were on the list and I 1 at least get them to take your call. J 4/14/2010 i 7:37 E-Mail KR to Werwie: Hi Cullen - do you know if Brett ever met with Mary

k.1~~.,--~~!i;;;;.%:;;:;;:~~~;;;_~ l------------------ _ _j__ ____ ~ ______________ Jb_~_l!19!_f!il.:19: _________________ ------------------------------------------------------------! 4/14/2010 i 7:55 Chat veha06: I talked to Brett I 4/14/201 O ! 8:42 --E-Mail Werwie to KR: He hasn't, do you have contact for her? If you give ! I it to me I can set it uo. l 4/14/2010 8:45 I E-Mail Werwie to KR: Brett forwarded this to us just to provide us with an 1 update on his end on the events he has had and his goals for I future events.

I I I 8:5o

I

i 4/14/2010

I

E-Mail

I'm going to be working to setup dates for the potential fundraisers ASAP. I'll keep you in the loop. Kathleen Kiernan to KR Werwie cc Crystal Berg: Kelly & Cullen

Crystal & I are wondering if it's possible for us to have the list of who you sent invitations to for our fundraiser on April 19. We are both giving the extras to potential supporters, but we found a few people said they already got them.

Thanks,

I I

I

I,

Kathy & Crystal I / ps ... Cullen ... will you be attending? --J I 9:55 E-Mail Werwie to KR: Kelly- r-h nf I I I've sat down over the last few days and ran through a bunch of 1 l!

I fund raising stuff with Brett. Do you have a half hour this afternoon ' I to touch base over the phone to run through a few things? If so I !, I

1

just let shoot me an email and let me know what time works for ) you. My cell# is 414-XXX-XXXX. Thanks-

L_ __________________ j _____ ---~------- ________ _Gullt:i_~-- ___________________________________________ -------------------------------------! 4/14/2010 ! 10:00 I E-Mail Davis to KR: Barrett Straub wants to talk with you about the I I j ! ozaukee event may 13. He's going to be at the airport tomorrow. J i I I Not sure what time but his # is 414- XXX-XXXX if it shows up on J I i ,_ caller I'd. _J

1:::-+:+;;;.-~~~ii~;;,:~:~~~~~'1:'_~ [_ _________________ , ________ _J__________________ --- --- --- -- -- -------- ----- --- - --- -------------------------------------------------------------'

14/14/2010 !

R-Ap. 126



~,~2010 [112ofrn~- 1 P.~~~!i~~E,~~~:h~~~!~~)~~!,~~:=~~~ . I the crossover.

1 1 I

I : j But I'm glad to hear people :r:_~:~t'.:~-~~~~es instead of not J

; : 1 _______ QiQ_y_Q~get a chance to ask him about the contract. __J [ 4/14/2010 ifi:56 J E-Mail KR to Davis: Tomorrow is clear for me, so I'll make sure I have my I

l I phone with me the whole time. i ! [ I-Jus_qo c!a_r~y. h_e'll_call_ m_ei w,hen be's cit!he_airpg_rt, rigllt~ _ __ __ J

4/14/2010 T11:56 E-Mail Werwie to KR: 2:00 works for me. I did talk to him. He wants to I i renew, but he forgot it at his house. He promised that he'd fill it I

i 411412010 h1057 TMall ~~~~ii:1}~~:r~;;:o~~::~;;:;~;;;;;":::~=n=:~ j : i just wanted to make sure he hadn't changed his mind. I

i I I Thanks!! I - ----- ---- - -- ----- -- -,------ --- ---- - ---------- -- ------- -- -- ----------- ------ ------ -- ---------- --- --- ------------------------------- ------- ------ ------------- ----- --- -1

l~;;,:~~ t: :.::+:;::;~H ~ii~[ ~~~;,.;,;~ii~J~~~w~;;~;;;~:~d-~ 1 ! 4/14/2010 i 11 :59 1 E-Mail KR to Davis re Barrett Straub contact: Ok. I [ __ -~7Hl?,c)j(j-_J:I?:~T]Iff=:-=-- __ hO!ljs__f\JQ!eis_ s_~nc_-_:::::::--- - ___ ---- :_-_________ ------. :_:-:::_:- J I 4/14/2010 I 12:36 i E-Mail KR to Werwie: Cullen - we could do the phone call now if you \ 1 I i wanted. I t 4/14/2010 [ 12:381 E-Mail __ Y'!E'l~iE'lt


I

following: 1. Host calls 2. Host cutoff and 3. Invite out, so for each event we would simply fill in the date that it needs to be done by.

I think that makes the most sense. Let me know what you think. , I

! i Thanks for your help with this-1-------------------f------------ -------------------- ~-~-------------------------------.----- ----------------------------------! 4/14/2010 1 14:39 I E-Mail KR to Werwie with Attached "FR schedule.xlsx" (9KB): Maybe I [_ 471472515---+1~F44--f--E--~faii _____ ---- ---~~~f~t~~~~~J~~~~~-*~~~f~1~~ci~~i~~~-~1~t'fuhr~~~~Jj%~~~~-----

8pm. She is going to put the invite together, put together the invite list, and get all of the hosts. She said the only thing we will need to do is mail out the invites. She said she doesn't want Brett to "invite" too many of his friends, because she doesn't want this to be a "big" event. With that said I told her you'd be contacting her (email: [email protected], cell: 262-XXX-XXXX) just to see if there is anything we can provide assistance with. Brett seems confident that Candee will be able to put this whole event together by herself. So we won't need Brett to make host calls for this event and Candee is adamant that she wants to design the invite. I'm going to keep in touch with Candee just to make sure this event moves forward as planned. With that said, if you could put together the list of people you think we should invite to this event, I'd like to have further conversations with her to see if she'll let us invite people through our standard list building/mailing process. While it is her house and she totally has a right not to want boatloads of people there, in my eyes, there is no such thing as a bad "big" event. So once I have my hands on that list I may either try to convince her it'll be a good thing to invite all of these people, or have Brett make the sale.

I hope that makes sense-'II

1 .. 1--4ii'4i201 o- ;li_i ,. -~ f ~:~!~l~Ef;=:~=r=-~;-1~~~~~~~~:~-----answering machine and no one picked up.

! I Thanks-! i Cullen !--------------------------~------------- ------------------ -------------------------------------------------------------------- ------------------------------------------------------- ---- ------------! 4/14/2010 f 15:06 E-Mail Werwie to KR: This is perfect. Thanks. I can send you a reminder i but if you could email me an .updated ! spreadsheet every Friday, so that I know I have an updated one

1 ! I for every Sunday meeting I have

[-4H412010---hs:33- E~Mail ------- -~!:l~i-~!~~~~~~~~~~~c!~~~!~~~~i;~~;~1~~~~~~!he-------1 j i returns so you can clean up your lists or should we just toss them I

\__________ _ _______ j__________ ------------ -~~.~ea~~:~:~~~--------------------------------------------------------------j It 4/14/2010 i 16:09 E-Mail Werwie to KR Sorry for the rash of emails this afternoon, I want to

make sure I have stuff correct on the calendar. Just two quick I questions-L _____ _j_ ------------

R-Ap. 128



I'

-Am I correct in saying that the Waukesha/Glojek event has been set in stone, and the fundraising process has begun? It is marked on Brett's calendar as tentative, and I want to make sure I don't

\ drop the ball on confirming a date.

! -The Ozaukee event on May 13th is also marked on Brett's I calendar as "Need Details from Barrett." Has this date been i finalized? Do I need to confirm anything or follow-up with Barrett?

'''I

I Once we get to the point where I'll be scheduling all of these and getting you dates it'll be easier for me to keep track of where we

I are at with all of these. Thanks-l__ ! --+l_C~u~ll~e~n---~--~---~-------~---,--1 i 4/14/201 O i 16:36 E-Mail KR to Werwie: You have to be careful with Candee. She does a lot ' I of events and is very politically involved. I will contact her and feel i ! her out on it. I'm inclined to just let her do it her way. She LOVES I!

!.'

111

1 Brett and will be extremely helpful with any events we do in Waukesha. We just need to find someone there willing to do a big event.

i 4/14/2010 ! 16:37 E-Mail KR to Werwie re phone number for Casi Murphy: Cullen- I don't ! ! have it. I can do some searching through lists I have to see if I can I _____ - -- ----- -t------ - - --- ____ .. _,, ___ .. .f.!!!c:l_.i!~---------------------------------.. --------.. ------.. ------... ! 4/14/2010 I 16:38 E-Mail KR to Werwie re weekly spreadsheet updates: Not a problem. You [_ __ ------ _ J_ _______________ !!l~Y._h~ve ~.!~111.!.r:ic:l_i:!!E!!_ l!_aj I wil~,9~ !J!YJ>.~~L _____________ _ I 4114/2010 116:41 E-Mail KR to Werwie re bad address returns: Yah, if you could get them

L47141201cl'-.. J-.. 15:44-- --E=Mafi .. ______ ~:!~;!!~I!:~~~~~~~i:n~ds~tr1~~;-r~~~~r~:~~


' I need to do anything to help move this event along let me know, otherwise let's make sure we set some target dates set like we J discussed this morning, if possible by Sunday so I can show Brett

i l ----------- ~~-'.~~_!!!~~!!9J_QrwarQ .. ~th ~he~~~ent~ _ _I~!:,l_k_~-------.. ------.. l-471.47201o--nT33 E-Mail KR to Werwie re "Oregon/Steve Peotter event" on 05/24: I'll get in I J touch with him ASAP. That one is already on the schedule for due GtT472010--111:42- -Parkin ____ --~d~~P8-r1

Kelly M. Rindfleisch, DOB: . Page 28

4/16/2010 E-Mail

So, unless you feel differently (as I said, I hemmed and hawed), Brett doesn't need to make calls for the hosts. Mark Graul to Werwie KR re Werwie's request for Dick

1-------1---,--1------+--L_ei_n_enkugel's contact info: 1-800-JIM-DOYLE, _________ ...; 4/16/2010

4/16/2010

4/16/2010 4/16/2010 4/16/2010 4/16/2010

4/16/2010

4/16/2010

4/16/2010

4/16/2010

4/16/2010

4/16/2010

4/16/2010 I 4/16/2010

E-Mail

E-Mail

14:27 LN 14:59 LN 15:17 LN

i 15:251 E-Mail

I I

15:28 E-Mail

15:47 I E-Mail

16:02 E-Mail

116:20 I E-Mail 16:29 E-Mail

, 16:29 E-Mail

16:34 LN

16:431 E-Mall-

KR to Mark Graul Werwie re Werwie's request for Dick Leinenku el's contact info: Ok, that made me laugh. KR to Mark Graul Werwie re Werwie's request for Dick Leinenkugel's contact info: You could try Jason Thompson, if you can get ahold of him.

[email protected] Lotus Notes Sent Lotus Notes Sent Lotus Notes Sent Kathleen Kiernan to KR Crystal Berg: I know that the following people are coming ... will bring checks with them: Betty Kalaher, Paul & Joanelle Klumb .... I know Harders are coming ... I forgot what she told me about their check. Carolyn & Tony Turner are coming. Did you do a spreadsheet for returned rsvp's? Kath KR to Kathleen Kiernan Crystal Berg re RSVP spreadsheet for 04/19 Davis fundraiser: I haven't. The responses go to Cullen. I can ask him if he can put one together. KR to Werwie with Attached 'Washington.xlsx" (45KB): Attached is the invite list for the Berg/Kiernan event. Kathy asked if I would keep a spreadsheet of responses. So, can you mark what you have and send it back? I'm sorry to do that to you. OR, you can send me a list. Whichever is less painful. Werwie to KR re RSVP spreadsheet for 04/19 Davis fundraiser: Sure, I can update it. I'm going to be out of town all weekend with Brett traveling the north part of the state. So the only update I can give Kathy will be on Monday. Kathleen Kiernan to KR and Crystal Berg: Sorry to be pesty, but

I I'm just used to keeping track of our events in our county. Besides, I'll erha s do a few follow-u calls. KR to Werwie re Werwie updating 04/19 fundraiser RSVP spreadsheet: That will work. KR to Kathleen Kiernan Crystal Berg re 04/19 fundraiser RSVP spreadsheet I'll have Cullen get you something. Lotus Notes sent Crystal Berg to Kathleen Kiernan KR: I got $100 from Marie Schmidt today in the mail.

This is oin to be fun. 4/16/201 O 17:05 Parking OUT Parking Table~2o--'----'-----=---'----~'--------------------~

20 Table 3 reflects only fundraising-related e-mails. In addition to these e-mails, Ms. Rindfleisch also sent or received six e-mails from County Executive staff members. Additionally, her account included two e-mails which she either sent to, received from or was a recipient with persons associated with the campaign committee, Friends of Scott Walker.


R-Ap. 131


[3~~~~~~--r---~~~+-k-~~~&~rd--+~c!e~~T!-ta-u-n1Y-Executrve-001ce-5--------------------. ----------1 I 4/20/2010 I 7:05 i E-Mail '\, KR to Fundraiser Host Barrett Straub: Hi Barrett- I am hoping to 1' j i get the invites out for the event on Monday, April 26. I was hoping . i I ! : you could get the list of hosts to me by that Sunday night (April 25) !

I I I and I can put together the invite for you to approve. I I I I I I 1-4120120-:nr - ----7:14+-~~ra:n __ c ______ +R~ffi~f:~~%i~~~-H~~p-~~~~~~fii~-~~J~'%nwyn-~-rwa5-9oin9---J 1 I I over the timeline for the event. Is it possible for you to get me the I ! ! 1 h~st list by Frid~y? It is g~ing to take ? few days to get the invite , I I I printed and I'd like to get 1t out by April 28 and I want to get your I

.'I

I approval for it. I Also, is there a specific printer you want to use? Let me know your I

-+-------+------ I tho!:l_ghts. -----------,..-,..------------; !4720/2010 7:15 i E-Mail I KR to Fundraiser Host Steve Peotter: Hi Steve - I'm going over

i I the timeline on events. Is it possible for you to get me the host list i ! by April 30? Then I can refine the invite and get it to you for

' approval and send any invites out that need to go by mail by May 3.

L I Let me know your thoug~h_ts_------------------< 11

4/20/2010 7:32 i E-Mail ! KR to Fundraiser Hosts Crystal Berg and Kathy Kiernan: Kathy & I, II Crystal - I am so sorry about the missing people. I figured out i .I what happened. I did add the extra list that Kathy sent to my I master list. What I didn't do was mark them so they would come

I I up on my list for Washington County. It was totally my fault and I

'Ill.I

! I feel terrible. I should have sent you the list to look through before I I sent out the invites. I apologize. I knew I had added the list, but couldn't figure out why they wouldn't have gotten invites.

L ! I 1 hope the event went well even with my mistake. 1

I :a:;:f- _;;;,+::-H-~~~~-~;;~~;"'.:"~~ l 4/20/2010 7:34 I E-Mail ! KR to Kathleen Kiernan, Crystal Berg cc Werwie: Kathy & Crystal i I i I - I am so sorry about the missing people. I figured out what ! I I I happened. I did add the extra list that Kathy sent to my master list. I I I What I didn't do was mark them so they would come up on my list

I for Washington County. It was totally my fault and I feel terrible. I I should have sent you the list to look through before I sent out the

invites. I apologize. I knew I had added the list, but couldn't figure out why they wouldn't have gotten invites.

I hope the event went well even with my mistake.

Thanks for all of your help,

R-Ap. 132



I 4/20/2010 I !

8:17 \ E-Mail i KR to Brett Davis and Werwie with Attached "April Invoice.dot" ! (40KB): Forwarding her invoice for fundraising servic.e_s_. ____ --1

14/20/2010 9:09 ! E-Mail

I t------------------------L---- --------------1----------------- .. -1412012010 I 9:14 l E-Mail

) Bronwyn Glojek to KR: This looks great! I know we are kind of in a ! i crunch, but we told our cohosts to get back to us no later than ' I April 25 so I think we have to wait until Monday after the mail. I Sorry about that. I do know we need to get the invitations out l quickly. I will email you the names on Monday. We have no ideas I about printers so if you have one in mind that would be good. Let j us know the cost. Another question: can we print return i envelopes addressed to Brett Davis for Lieutenant Governor c/o i Bronwyn Glojek, XXXXXXXXXX, Pewaukee, WI 53072 so I can I keep track of approximate numbers or is that not done? Do you ! have a list of people you think should be invited - we would be j happy to add them to our list.

I 1 know this is a tight timeline, but our times in May were limited i because of the state convention and then we have a grand baby I due in Montana the end of the May. Candee's fundraiser is in ! June so we are scrambling! . . .. .. .. . .... T RFfto-8ron\VYn.8iC>}er


i Would you be willing to do another phone call at some point next i week so we can discuss Mark's ideas? Let me know what works

i I best for you. Thanks i 4/20/2010 10:51 ! E-Mail I Bronwyn Glojek to KR re sending fundraiser invites: Could you II ! i send us the entire list and maybe we could pare it down by i ! location and people we know. What is the typical response rate k- . ' for this kind of event? Do ou have an avera e numbers? 1 ! 4/20/2010 10:53 i E-Mail l Werwie to KR re backlog of checks. We have a huge backlog of 1

1 l 1 I I checks that need to be electronically entered and tracked. I'll give 1 -----.. ----1------j_ ___________ J_~~lc~ ~IL~~-~~el~~;~-~~f~~:.. ~~;~~~~~-~-:~~-:~:~r~~:~~- _J

I 4/20/2010 10:56 i E-Mail I KR to Werwie re phone call: Tuesdays are always betterfor me, I I I 1 but next week, Thursday would work also. I also am on furlough 1 I ! on Friday, so I could do it any time that day. Let me know what I f-412w2ofo-j--1a:s--r:+-E::Mair---f -R~~~~!~-~~~ ~~rc~~~N~Ggp~~~~~~ !~fai~ understari_r:1_3\

R-Ap. 134



11 a tough host team but we ask no more from those we work with

than we give ourselves. The event is more than just gathering 1 people ... it is putting ourselves & our reputation on the line for a j candidate that we believe in. We have to get it right because as

1 'I community leaders, we will need to tap into those people again I , and so far, they have trusted us enough to give serious

1,1:

1 I consideration to what we say. ! Brett Davis is a great candidate but, as you know, his field is I crowded with other candidates who are 'marketing' themselves so

each time you reach out on his behalf it must begin with a product I that oozes pride for Brett, his values and his ability to step into

whatever role Scott Walker will want the Lt. Gov to play. Begin 1 with an invitation that boldly informs the invitee of a 'EVENT

i 1 INVITE' on the envelope and a message that causes people to

l.'i

l I take notice, be curious and anticipate attending ... this sets the bar , for expectations and in many cases is the first contact Brett will ! have with people. Make it a great impression. The mailing list

I I also tells people a story about the candidate ... if a household gets l I multiple invites, the addressee is deceased, name misspelled, I ! needless to say, it reflects badly on Brett. People don't take time

lli

l I I to realize it is 'staff or volunteers making these decisions. ! I We would be happy to discuss some host 'tips' to make the I i I process of introducing Brett through events clearer, stronger and !

! 4hol2-o1o ---T1-:34-j-"E.:Maii- -- --t1

- ~~~w~~~~recrystai-Ber9-e-=-mail: o'k~rm going-to takea ____ --1 i i breath and then decide if it's prudent to respond to Crystal. I love i

)-472oi2a1a ------r1:39--f-E:Maii--------1-~~~~~~P~J~idi~~~~~~f~P~~~~tes--ro--ore9an------j i t ! ' ber amont event": FYI I 8[?::q7_~_Q!Q. ______ tl~i~JE.~.M~!.________ We_l!':'J_~~_ISB..!:._~_g~-!~J __ ~~r~~-maJ!: I to~!IY u_r:i_cl_ers!~.1.:. __ --=:=) i 4/20/2010 11 :49 i E-fvlail , Bronwyn Glojek to KR: Do you have a list of people who have I I I I signed up to specifically support Brett (not necessarily in ! ! I / Pewaukee - it could be all of the western suburbs)? Would it be I

l 1 a ro riate for us to use that list instead? 4/20/201 O 12:13 i E-Mail 1 KR to Bronwyn Glojek re list for Davis support in western suburbs: i

I l I Absolutely. Let me see what I have. : ........ ________ ,,, .. ,_, ______ ,, _______ ,,,, _____________ ,,! _______ .. ________________________________________ ,, _____________ .. _______ ,,, ________ _ Ii 4/20/201 O 13:31 J E-Mail 1 KR to Bronwyn Glojek re list for Davis support in western suburbs: J , l I I looked through Brett's list and because he's never had an event I l I i i in Waukesha, there wasn't anyone that has given him money. I I ! 1 I I know Cullen is behind in entering checks, but I don't think there'd i : I I be much in what he hasn't entered. Let me think about where else I i-4}2012610 --13;33 h~-:Mar--- --ti ~1:~o't>~~taf Berg re-BrettDavis events: Any'hosr"tips"you can-- -I j I 1 ' : _ -------------- ________ --1----- --- ------~P!-9~~~ WO_l!~-~~-gr~~t, _______________________________________________ J I 4/20/2010 13:34 , E-Mail

1

. Werwie to KR re Huebsch event: FYI-We're looking at having the I ! ! Rep. Huebsch event on June 7th. I'm confirming the location, i i 1 which should be done in the next day or two. I'll let you know what I '-------------------- __ , _________________ L __________ -----j-_Jb~J~_Q_C?D~---~-~~-~e ~-~!!__l!!~~-fC?.~rQ_!~-~~~Y~L(~g_~J_~J~.--------~ l 4/20/201 O 13:36 i E-Mail 1 KR to Werwie re Huebsch event: Wonderful. I know all the Lt. Gov. I / I stuff is being done in complete campaigns. Do you have Brett's L . ; I donor list for the Assembly? , / ._'Y~.9~9-~_Q._L_.!_~~~gJ ~=-~~.!!_ ______ J~!_c_>_~~.!!-~_igi_~~l~-~~-!:.~_!i~~!.


i Even the people who sign up at the events - I think to be on a 1 i mailing list???? _ ! 4/20/2010 13:42 i E-Mail I Werwie to KR re Davis donor list: Yes, it is -in_c_o_m_p_l-et_e_c_a_m_p_a_i_g-ns __ __,i f 4F2012010 -14:21-1-E=rvfott - rwerwie-101


1-- ____________________ --------------~ .. ----------~.'Y~_l!!l-~~_r:~!!_~_ I JU~t_~~11_!_wa_11t t~p~~-~b_er of_f_:_ ___________ J I 4/20/201 O 14:55 I E-Mail I Werwie to KR re Arndt: I'm totally fine with that, whatever you work !

C~g~~'}a---~:J_Irt:Kel_g_a~c[~J ~~~~~~e~e~~~~~[~I_P,_dmi~!~t.rati~~-ery-i~~~~~~=:=~-~~~=:~~__j i 4/20/2010 15:15 j E-Mail I Access to County Executive Offices j

4/20/201 O 15:52 I E-Mail !I Steve Peotter to KR: We are moving along nicely with getting 1 1 1 hosts for the event signed up at the $250 support level. Do I need

I l 4/20/201 o I I

I / to be thinking about any kind of reporting requirements for donors ! 'i' or any political fund raisers issues? I have not done this before so

I don't want to do anything incorrectly without knowing it.

, Also, where and to whom should hosts be writing their checks? 15:58 I E-Mail ! KR to Steve Peotter re reporting requirements: The only

i I requirement is the contribution limit. That's $10,000 for the Lt. I I Gov. So, I don't think we need to worry about that.

'1'1,.11

1 j With the $250 donation, we will need occupation, employer and 1

employer address for the report.

I They should write the check to: Brett Davis for Lieutenant , i Governor

I J I They can send it to:

l ____ 1 ..... -L .. _ J:::;::0h~------~j [_ 1~Q~ QJ ____ _1_?:2. -'-~~~Ln~L_ ___ L QI:'_! f~~Ln~L_ ~- ______ _ __ _ __________________________________________ __! Table4

~-1/~2.~?_QJ.9~---~~~2 ____ J_f~i:_~_njl ______ L!~J:~_r:_~11_g _________________ -----------------------------------------.! ~-i'_~2./_~Q_1_Q__ 6:~-~-----J _ _15~_y-~~_!:.~----~-~-C'.~~~~~-Q~_un_~-~~1:!~!Y~ Off~~~-------------------------j 1 4/22/201 O 8:02 ! E-Mail ! KR to Werw1e re new contacts: Cullen - I'll add these to both the I 1-------------- ___________ J _____________ [_b_ig __ Q_Q_nor list -~nd_E_~l!lJ>letf:)_Call}~jg_l}~,__ _______________________________ J r-%~~~~ ~--,-~~1~-- ---1~=~~~------+~~~l~ ~~~~-~=-~~~--~~~~~~-1-~~~~~~~~:d saYiustacicrt11e--------I [_. -------------t- -------------------------------J_.Q_lles.Jri . .!.ti~- e'!l_~l_!_()_Qi~_ ~~J_I list_~_~..Q!!!P.!f:l!~~~-!!!P~Jg_r_i~,------------~ 'I 4/22/2010 8:45 I E-Mail I Bronwyn Glojek to KR, Candee Arndt: Kelly, 1 ' i 11 ha~e a question regardin_g our location for the fundraiser. Piano I 11

; , Blu 1s where we are planning to hold the event and they have put I 1 ! us in the upstairs room which is VERY nice and perfect for a I I smaller group. The problem is that it is called the "Rhino Room" I _ and even has a Rhino head on the wall above the fireplace. I had l I a concern about that and

appendix to appellate brief of plaintiff-respondent state of wisconsin - state of wisconsin v. kelly...

Documents

search warrants document

2012cf438 state of wisconsin

waiver document

information document

rindfleischs motion

criminal complaint document

clerk of court

court decisions