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CHICAGO BOARD OF ETHICS740 N Sedgwick AvenueFifth FloorChicago, IL 60654

OFFICE OF THE LEGISLATIVE INSPECTOR GENERAL OF THE CITY OF CHICAGO740 N Sedgwick AvenueThird FloorChicago, IL 60654

SIGNED AND SWORN COMPLAINT AGAINST ALDERMAN DEB MELL

1. This complaint is being made by Kristen Crowell, executive director of United

Working Families, who resides 1449 W. Augusta Blvd., and is being submitted to the Chicago

Board of Ethics and the Office of the Legislative Inspector General of the City of Chicago.

2. Deb Mell is considered an elected official of the City of Chicago, having been

appointed the Alderman of the 33rd Ward in 2013.

3. Section 2-156-445 (a) of the Chicago Municipal Code states, in part:

No person who has done business with the city, or with the Chicago Transit Authority,Board of Education, including the Chicago School Reform Board of Trustees, ChicagoPark District, Chicago City Colleges, or Metropolitan Pier and Exposition Authoritywithin the preceding four reporting years or is seeking to do business with the city, orwith any of the other aforementioned entities, and no lobbyist registered with the boardof ethics shall make contributions in an aggregate amount exceeding $1,500.00: (i) toany candidate for city office during a single candidacy; or (ii) to an elected official of thegovernment of the city during any reporting year of his term; or (iii) to any official oremployee of the city who is seeking election to any other office. For purposes of thissection all contributions to a candidates authorized political committees shall beconsidered contributions to the candidate. A reporting year shall be from January 1st toDecember 31st.

4. Richard Mell, former elected Alderman for the 33rdWard, owns the office space

used by his daughter, Alderman Deb. Mell, at 3655 N. Kedzie Avenue, and Citizens for Deb

Mell.

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5. According to the City of Chicago, Richard Mell has been a registered lobbyist

with the city during the entire period of his daughters tenure after having been appointed

alderman.

6. According to Board of Elections Campaign Contributions and Expenditures

reports, from Aug. 30, 2013, and June 30, 2014, Richard Mell made 11 In-Kind contributions of

$300 for rent of the Kedzie space to his daughter. What is more, this total not only exceeds the

$1,500 aforementioned yearly limit-it grossly undervalues the space when compared with the

$5,200 monthly rent that the Citizens for (Richard) Mell committee paid to Richard Mell in

2011, according to BOE records.

7. Therefore, an authorized political committee of Deb Mell, an elected official of

the City of Chicago, has received excess in-kind contributions from a lobbyist registered by the

City of Chicago, Richard Mell, in violation of Section 2-156-445 (a) of the Chicago Municipal

Code.

8. The Penalty for this violation is found in Section 2-156-465(b)(5), which states:

Improper contributions. Any person who knowingly makes, solicits or accepts a politicalcontribution in violation of section 2-156-140 or section 2-156-445 shall be subject to afine of not less than $1,000.00 and up to the higher of $5,000.00 or three times theamount of the improper contribution that was accepted for each violation of thesesections.

Under penalties as provided by law, the undersigned certifies that the statements set forth

in this complaint are true and correct to the best of the undersigneds knowledge and belief.

______________________________

Kristen Crowell

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Signed and Sworn before me on Feb. 3, 2015.

__________________________________________

Notary Public (seal)