July 11, 2006

Michael J. Sullivan
Director
Massachusetts Office of Campaign and Political Finance
One Ashburton Place, Room 411
Boston, Massachusetts 02108

Dear Mr. Sullivan:

I am writing to request that your office open an investigation into potential campaign finance violations committed by my Democratic primary opponent, Secretary William F. Galvin.

On his campaign website, www.billgalvin.org, Secretary Galvin lists his campaign office address as “Committee to Elect Bill Galvin, 444 Washington Street, Boston, Massachusetts 02135.” However, a review of his campaign expenditures from January through June 2006 reveals that his campaign committee has only paid rent twice during this six month period, each payment in the amount of $1,100 to the Newbridge Realty Group – a company no longer in business (see www.newbridgerealty.com). The second and most recent payment made occurred on March 31, 2006.

Further, last Wednesday, July 5, 2006, I delivered by hand a letter to Secretary Galvin at the address of his campaign office calling for him to engage in a series of candidate debates on the issues in this race. When I arrived at the address, I noticed that the sign outside the building listing the various occupants did not include the Committee to Elect Bill Galvin. The three doorbells at the building’s front door had the following listings: First Floor – “Law Offices”; Second Floor – “Apartment”; Third Floor – “Apartment.” I rang the first floor doorbell and entered the law offices.

Upon entry into the law offices, I met an attorney named Anthony Donato who informed me that he accepts Secretary Galvin’s campaign mail. I repeatedly asked where I could find Secretary Galvin’s campaign office in the building, but Mr. Donato refused to answer that question. Mr. Donato accepted delivery of my letter to Secretary Galvin.

In addition, we sent via certified U.S. mail on July 5, 2006, another signed copy of this letter to that address. We received a return receipt of acceptance of that mail, signed by a “G. Sullivan” at that address.

Furthermore, since no other address is listed on Secretary Galvin’s campaign website – nor is a phone number listed – it is likely that any mailed campaign contributions are also being received at these for-profit law offices.

As you know, Massachusetts General Laws, Chapter 55, Section 8 prohibits a candidate committee from soliciting or receiving any contribution, including “any money or other valuable thing” from a corporation or business. Secretary Galvin’s statement of financial interests for calendar year 2005, filed with the Massachusetts State Ethics Commission, claims that he operates a law office at 444 Washington Street, Brighton, Massachusetts 02135. However, M.G.L. Chapter 55, Section 8 makes no exception for corporate contributions from a corporation owned by a candidate.

Secretary Galvin’s operation of his campaign from a law firm – with no apparent record of payment for the fair market value for use of that space and with no clear distinction as to where the campaign is located within that firm -- raises serious questions as to whether he is in receipt of an illegal corporate donation. A full investigation by your office is necessary to ensure that Secretary Galvin be held accountable for any such violation of state campaign finance law.

Thank you for your prompt attention to this matter.

Sincerely,
John Bonifaz

cc: Secretary William F. Galvin