Staff: Jenna Rinehart, Senior Commission Counsel, Paul Rasey, Special Investigator. The AIDS Healthcare Foundation (“AHF”) is represented by Bradley W. Hertz of Law Offices of Bradley W. Hertz and the Yes on 21 Committee is represented by Beverly Grossman Palmer of Strumwasser & Woocher LLP. AHF, qualified as a lobbyist employer in 2019 and as a state major donor committee in 2020. The Yes on 21 Committee is a primarily formed state ballot measure committee for Proposition 21 on the November 3, 2020 General Election ballot sponsored by AHF. Palmer serves as the Yes on 21 Committee’s treasurer. AHF, as a lobbyist employer, failed to timely disclose, on its lobbyist employer reports, other payments to influence, in violation of Government Code Sections 86116 and 86117 (2 counts). Next, AHF, as a major donor committee, failed to timely disclose, on a major donor campaign statement, non-monetary contributions made along with the payee information and source of funds used, in violation of Government Code Sections 84211 and 84222 (1 count). Additionally, AHF failed to timely disclose non-monetary contributions made and failed to timely file 24-Hour Reports, in violation of Government Code Sections 84211 and 84203 (1 count). The Yes on 21 Committee and Palmer failed to timely file 10-day reports, in violation of Government Code Section 85309 (1 count), and failed to timely file 24-Hour Reports, in violation of Government Code Sections 85309, 84203, and 84203.3 (4 counts). Total Proposed Penalty: $27,000.
