Complaint Attachments
Complaint Attachments
Complaint Attachments
Supplement to Section 3
Attachment A
Both candidates and incumbents must file C&E reports with the Secretary of State as
required by NRS Chapter 294A. “Candidates” include anyone who files a declaration of candidacy
or otherwise receives contributions in excess of $100 dollars.
In 2020, Miller was a candidate for Clark County Commission District C, and, on
November 3, 2020 and thereafter, was Commissioner-elect. Throughout the entireties of years
2021 and 2022, Miller was the incumbent for the same position. In all three years, Miller received
contributions in excess of $100 dollars. As such, Miller filed C&E reports with the Secretary of
State.
For years 2020, 2021, and 2022, Miller is therefore covered under NRS Chapter 294A’s
reporting requirements for contributions and expenditures.
Candidates like Miller may not accept more than $10,000 in contributions per cycle from any
person.
Candidates like Miller must provide detailed descriptions of their received contributions.
Candidates like Miller must provide detailed descriptions of their campaign expenditures.
Attachment A
Violation I:
$15,000 in Contributions Received from One Person during 2020 Cycle
NRS 294A.100
During the 2020 Cycle, an organization identified as “Clark County Fire Fighters” and
alternatively as “Clark County Fire Fighter” (both are listed at the address of 6200 W. Charleston
Blvd, Las Vegas, NV 89146-1117) made an aggregate contribution of $15,000 to Miller. The
organization contributed $5,000 on June 2, 2020, $5,000 on September 22, 2020, and $5,000 on
October 2, 2020. See Attachment B. This $15,000 in contributions from one entity exceeds the
$10,000 limit. Miller therefore was required under the statute not to accept the third $5,000
contribution.
No public evidence shows that any of the three contributions were returned in order to
comply with the $10,000 limit.
Complainant therefore believes Miller violated NRS 294A.100.
Violation II:
$12,500 in Contributions Received from Unknown
NRS 294A.190
Violation III:
$20,000 in Contributions Received from One Person during 2024 Cycle
NRS 294A.100
During the 2024 Cycle, an organization identified on Miller’s 2022 yearly report as
“AllAround A Pac” and alternatively as “All Around A PAC” (both are listed at the address of
10624 S Eastern Ave, Henderson, NV 89052) made two contributions to Miller, each totaling
$10,000.00. See Attachment C. Based on this address, it is likely that this entity is the
“AllAroundA” PAC registered with the State.1 The first payment of $10,000 is reported as being
made on May 5, 2021, while the second payment of $10,000 is reported as being made on June
24, 2021.
1
See Group Details, Nevada Secretary of State,
https://www.nvsos.gov/SOSCandidateServices/AnonymousAccess/CEFDSearchUU/GroupDetails.aspx?o=mOP2uic
StO4ASQydEtz53A%253d%253d.
Attachment A
The filing that AllAroundA PAC filed with the State lists a June 28, 2021 contribution to
Miller but does not list the May 5, 2021 contribution, nor does the June date match the report from
Miller. See Attachment D. Failure to list a contribution over $1,000 is itself a violation for PACs
in Nevada.
Additionally, AllAroundA’s January 14, 2022 filing with the State lists AllAroundA’s
address as 2520 St. Rose Pkwy., Suite 112, Henderson, NV 89074. This is the same address as
Miller’s campaign committee. See, e.g., Attachments D and E. AllAroundA’s listed contact online
is James Ferrence, Miller’s campaign manager for the 2020 Clark County Commissioner’s race.
No public evidence shows that either of these two contributions were returned in order to
comply with the $10,000 limit.
Complainant therefore believes Miller violated NRS 294A.100.
Violation IV:
Failure to Itemize over $60,000 in Campaign Expenses
NRS 294A.200
Miller failed to adhere to Secretary of State guidance by not itemizing various large
expenses throughout 2022. Instead, Miller reported the name and address of the person who
received the payment as the credit card company only, leaving the public wholly unable to know
the true recipient of the funds, or the true purpose for which the funds were spent. See Attachment
D. This included “Cardmember Service” as the payee for January 4, 2022 ($4,876.23 for office,
travel, events, and miscellaneous), February 9, 2022 ($7,444.98 for office, volunteers, travel, staff,
and events), March 30, 2022 ($8,157.85 for office, volunteers, travel, staff, events, and
miscellaneous), March 16, 2022 ($5,752.99 for office, volunteers, travel, events, and
miscellaneous), August 1, 2022 ($6,057.65 for office, volunteers, travel, events, and
miscellaneous), October 28, 2022 ($6,652.57 for office, volunteers, and events); and “Bank of
America Card Services” as the payee for February 9, 2022 ($12,800.41 for office, volunteers,
travel, staff, events, and miscellaneous) and March 15, 2022 ($9,854.67 for office, volunteers,
travel, events, and miscellaneous). See Attachment D. Miller did not describe to whom these
payments ultimately were paid. Miller provided only the payments to credit card companies.
Complainant therefore believes Miller violated NRS 294A.200.
Attachment A
Attachment B
* Report #4 suffices for the 2022 Annual CE Filing only if Report #’s 1, 2, 3, are previously filed this period.
Cumulative From
Beginning of Report
CONTRIBUTIONS SUMMARY This Period Period #1 Through
End of This
Reporting Period
1. Total Monetary Contributions Received in Excess of $100 $ 204,450.00 $ 204,450.00
2. Total Monetary Contributions in the Form of Loans Guaranteed by a 3rd-Party in Excess of $100 $ 0.00 $0.00
3. Total Monetary Contributions in the Form of Loans that were Forgiven in Excess of $100 $ 0.00 $0.00
4. Total Amount of Written Commitments for Contributions in Excess of $100 $ 0.00 $0.00
5. Total Value of In Kind Contributions in Excess of $100 $ 0.00 $0.00
6. Total Value of Written Commitments for In Kind Contributions in Excess of $100 $ 0.00 $0.00
7. Total Amount of all Contributions of $100 or less $ 0.00 $0.00
8. Total Amount of All Contributions (Add Lines 1 through 7) $ 204,450.00 $204,450.00
EXPENSES SUMMARY
9. Total Monetary Expenses Paid in Excess of $100 $ 187,139.59 $187,139.59
10. Total Value In Kind Expenses in Excess of $100 $ 0.00 $0.00
11. Total Amount of all Expenses of $100 or less $ 0.00 $0.00
12. Total Amount of All Expenses (Add Lines 9 through 11) $ 187,139.59 $187,139.59
ENDING FUND BALANCE
13. Fund balance at the end of the reporting period $71428.23
AFFIRMATION
I Declare Under Penalty of Perjury That the Foregoing is True and Correct.
AND
I have agreed to the following terms and conditions:
I declare, under penalty of perjury or under an oath to God, that the information I submitted herein to the Secretary of State for the State of
Nevada is true and correct, and is not submitted for any improper purpose, and that I am authorized to submit the information, and to the
best of my knowledge complies with NRS Chapter 294A. I have reviewed the NRS 225.083 Notice. I understand it is unlawful to submit any
illegal, unauthorized, fraudulent, forged, deceptive, defamatory, illicit, or improper information, as defined by state and federal law, to the
Secretary of State, and agree to indemnify the Secretary of State, and any other parties entitled thereto, for any damages incurred for any
unlawful, unauthorized, fraudulent, forged, deceptive, defamatory, illicit, or improper information, as defined by the federal and state law,
submitted to the Secretary of State by my use of this electronic filing system. I further understand that I may be subject to criminal (NRS
239.330) and/or civil (NRS 225.084) penalties for submitting any unlawful unauthorized, fraudulent, forged, deceptive, defamatory, illicit, or
improper information, as defined by federal and state law. I understand and agree that all information submitted is the property of the
Secretary of State, and may be monitored for all lawful purposes. I further understand that during such monitoring, all information, including
personal information placed on this system, may be examined, copied, and used for any authorized purpose. By submitting this report I
intend to identify myself as the authorized person signing this document and with the present intent to authenticate my signature as such.
Attachment C
https://www.nvsos.gov/SOSCandidateServices/AnonymousAccess/ViewCCEReport.aspx?syn=AkuFvxGbSFofgd%252fw%252f%252fFd9w%253d%… 1/11
5/9/23, 10:16 AM 2021 Contributions & Expenses Annual Filing - Secretary of State of Nevada
MONETARY
Report Period # An.
CONTRIBUTIONS
* Report #4 suffices for the 2023 Annual CE Filing only if Report #’s 1, 2, 3, are previously filed this period.
Cumulative From
Beginning of Report
CONTRIBUTIONS SUMMARY This Period Period #1 Through
End of This
Reporting Period
1. Total Monetary Contributions Received in Excess of $100 $ 117,000.00 $ 117,000.00
2. Total Monetary Contributions in the Form of Loans Guaranteed by a 3rd-Party in Excess of $100 $ 0.00 $0.00
3. Total Monetary Contributions in the Form of Loans that were Forgiven in Excess of $100 $ 0.00 $0.00
4. Total Amount of Written Commitments for Contributions in Excess of $100 $ 0.00 $0.00
5. Total Value of In Kind Contributions in Excess of $100 $ 0.00 $0.00
6. Total Value of Written Commitments for In Kind Contributions in Excess of $100 $ 0.00 $0.00
7. Total Amount of all Contributions of $100 or less $ 0.00 $0.00
8. Total Amount of All Contributions (Add Lines 1 through 7) $ 117,000.00 $117,000.00
EXPENSES SUMMARY
9. Total Monetary Expenses Paid in Excess of $100 $ 130,614.63 $130,614.63
10. Total Value In Kind Expenses in Excess of $100 $ 0.00 $0.00
11. Total Amount of all Expenses of $100 or less $ 7,738.42 $7,738.42
12. Total Amount of All Expenses (Add Lines 9 through 11) $ 138,353.05 $138,353.05
ENDING FUND BALANCE
13. Fund balance at the end of the reporting period $50075.18
AFFIRMATION
I Declare Under an Oath to God that the Forgoing is True and Correct*
* A declaration under an oath to God is subject to the same penalties as declaration under penalty of perjury
AND
I have agreed to the following terms and conditions:
I declare, under penalty of perjury or under an oath to God, that the information I submitted herein to the Secretary of State for the State of
Nevada is true and correct, and is not submitted for any improper purpose, and that I am authorized to submit the information, and to the
best of my knowledge complies with NRS Chapter 294A. I have reviewed the NRS 225.083 Notice. I understand it is unlawful to submit any
illegal, unauthorized, fraudulent, forged, deceptive, defamatory, illicit, or improper information, as defined by state and federal law, to the
Secretary of State, and agree to indemnify the Secretary of State, and any other parties entitled thereto, for any damages incurred for any
unlawful, unauthorized, fraudulent, forged, deceptive, defamatory, illicit, or improper information, as defined by the federal and state law,
submitted to the Secretary of State by my use of this electronic filing system. I further understand that I may be subject to criminal (NRS
239.330) and/or civil (NRS 225.084) penalties for submitting any unlawful unauthorized, fraudulent, forged, deceptive, defamatory, illicit, or
improper information, as defined by federal and state law. I understand and agree that all information submitted is the property of the
Secretary of State, and may be monitored for all lawful purposes. I further understand that during such monitoring, all information, including
personal information placed on this system, may be examined, copied, and used for any authorized purpose. By submitting this report I
intend to identify myself as the authorized person signing this document and with the present intent to authenticate my signature as such.
Attachment D
https://www.nvsos.gov/SOSCandidateServices/AnonymousAccess/ViewCCEReport.aspx?syn=yNF2JRNO2iF18ihj3zdgNQ%253d%253d&p=t 1/10
5/9/23, 10:20 AM 2022 Contributions & Expenses Annual Filing - Secretary of State of Nevada
CATEGORIES CODE
Office expenses A
Goods and services provided in kind for which money would otherwise
J
have been paid
1 NRS 294A.362 requires “In Kind” contributions and expenses to be reported on a separate form, which is attached hereto.
Attachment D
https://www.nvsos.gov/SOSCandidateServices/AnonymousAccess/ViewCCEReport.aspx?syn=yNF2JRNO2iF18ihj3zdgNQ%253d%253d&p=t 7/10
5/9/23, 10:20 AM 2022 Contributions & Expenses Annual Filing - Secretary of State of Nevada
Cardmember Servic
P.O. Box 94014 A, C, H, O 01/04/2022 $4,876.23
Palatine, IL 60094-4014
Eight Cigar Lounge
3000 S Las Vegas Blvd H 01/07/2022 $1,127.29
Las Vegas, NV 89109
Money Baby
4455 Paradise Rd H 01/24/2022 $312.27
LAS VEGAS, NV 89169
A 01/24/2022 $287.43
A 02/23/2022 $287.43
A 03/23/2022 $287.40
ATT A 04/22/2022 $287.33
PO Box 5014
Carol Stream, IL 60188 A 04/22/2022 $287.33
A 05/23/2022 $349.40
A 06/23/2022 $299.77
A 07/25/2022 $416.33
CNC First LLC
253 NE 2nd St E 02/01/2022 $4,000.00
Miami, FL 33132
Red Rock Sta (restraunt) H 02/04/2022 $580.88
11011 W Charlston Blvd.
Las Vegas, NV 89135 H 07/28/2022 $811.24
Bank Of America Card Services A, B, C, E, H, O 02/09/2022 $12,800.41
PO Box 15731
WILMINGTON, DE 19886 A, B, C, H, O 03/15/2022 $9,854.67
Cardmember Service A, B, C, E, H 02/09/2022 $7,444.98
P. O. Box 94014
Palatine, IL 60094-4014 A, B, C, E, H, O 03/30/2022 $8,157.85
Committee to Elect Marilynn Dondero Loop
9360 W. Flamingo Road
K 02/10/2022 $1,000.00
Suite 110-264
Las Vegas, NV 89147
Consili
2520 St Rose Pkwy #112 F 02/14/2022 $25,000.00
Henderson, NV 89074
Committee to elect Lou DeSalvio
8240 Waterfall Ranch Cr. K 03/02/2022 $5,000.00
Las Vegas, NV 89131
Justin Jones for Clark County Commission
8020 South Rainbow Blvd., Ste. 100-370 K 03/02/2022 $5,000.00
Las Vegas, NV 89139
Steve Sisolak For Governor
PO Box 850 K 03/03/2022 $10,000.00
Las Vegas, NV 89125
A, B, C, H, O 03/16/2022 $5,752.99
Cardmember Service
P.O. Box 94014 A, B, C, H, O 08/01/2022 $6,057.65
Palatine, IL 60094
A, B, H 10/28/2022 $6,652.57
Conine for State Treasurer
8808 Stafford Springs Drive K 03/18/2022 $5,000.00
Las Vegas, NV 89134
Liberace Foundation
1775 E Tropicana Ave H 03/22/2022 $4,500.00
las vegas, nv 89119
Dupont Hotel
1500 New Hampshire Ave NW C, H 04/12/2022 $941.95
Washington, DC 20036
Wynn
3131 Las Vegas Boulevard South C, H 04/18/2022 $1,253.14
Las Vegas, NV 89109
Capital Grill
3200 Las Vegas Blvd S H 05/26/2022 $311.87
Las Vegas, NV 89109
LARREA
4515 Dean Martin Dr H 05/27/2022 $1,326.22
LAS VEGAS, NV 89103
Ralston Reports
2290 Corporate Circle Ste 250 A 07/15/2022 $350.00
Henderson, NV 89074
Attachment D
https://www.nvsos.gov/SOSCandidateServices/AnonymousAccess/ViewCCEReport.aspx?syn=yNF2JRNO2iF18ihj3zdgNQ%253d%253d&p=t 8/10
Attachment E
* Report #4 suffices for the 2022 Annual CE Filing only if Report #’s 1, 2, 3, are previously filed this period.
Cumulative From
Beginning of Report
CONTRIBUTIONS SUMMARY This Period Period #1 Through
End of This
Reporting Period
1. Total Monetary Contributions in Excess of $1000 $ 164,176.95 $ 164,176.95
2. Total Monetary Contributions in the Form of Loans Guaranteed by a 3rd-Party $ 0.00 $0.00
in Excess of $1000
3. Total Monetary Contributions in the Form of Loans that were Forgiven in $ 0.00 $0.00
Excess of $1000
I declare, under penalty of perjury or under an oath to God, that the information I submitted herein to the Secretary of State for the State of Nevada is true and correct,
and is not submitted for any improper purpose, and that I am authorized to submit the information, and to the best of my knowledge complies with NRS Chapter 294A.
I have reviewed the NRS 225.083 Notice. I understand it is unlawful to submit any illegal, unauthorized, fraudulent, forged, deceptive, defamatory, illicit, or improper
information, as defined by state and federal law, to the Secretary of State, and agree to indemnify the Secretary of State, and any other parties entitled thereto, for
any damages incurred for any unlawful, unauthorized, fraudulent, forged, deceptive, defamatory, illicit, or improper information, as defined by the federal and state
law, submitted to the Secretary of State by my use of this electronic filing system. I further understand that I may be subject to criminal (NRS 239.330) and/or civil
(NRS 225.084) penalties for submitting any unlawful unauthorized, fraudulent, forged, deceptive, defamatory, illicit, or improper information, as defined by federal and
state law. I understand and agree that all information submitted is the property of the Secretary of State, and may be monitored for all lawful purposes. I further
understand that during such monitoring, all information, including personal information placed on this system, may be examined, copied, and used for any authorized
purpose. By submitting this report I intend to identify myself as the authorized person signing this document and with the present intent to authenticate my signature
as such.
Attachment E
https://www.nvsos.gov/SOSCandidateServices/AnonymousAccess/ViewCCEReport.aspx?syn=sd2djtcGbYPIY51H5fPTpw%253d%253d&p=t 1/7
5/9/23, 1:18 PM 2021 Contributions & Expenses Annual Filing - Secretary of State of Nevada
MONETARY
Report Period # An.
CONTRIBUTIONS
AllAroundA PAC
Name (print) Office (if applicable) District (if applicable)
AllAroundA PAC
Name (print) Office (if applicable) District (if applicable)
NAME AND ADDRESS OF DATE OF DESCRIPTION VALUE OR COST CHECK NAME AND NAME AND
PERSON, GROUP OR IN KIND OF IN KIND OF IN KIND HERE IF ADDRESS OF 3rd ADDRESS OF
ORGANIZATION WHO MADE CONTRIBUTION CONTRIBUTION CONTRIBUTION LOAN PARTY IF LOAN PERSON, GROUP
IN KIND CONTRIBUTION GUARANTEED BY OR ORGANIZATION
3rd PARTY WHO FORGAVE THE
LOAN, IF
Attachment E
https://www.nvsos.gov/SOSCandidateServices/AnonymousAccess/ViewCCEReport.aspx?syn=sd2djtcGbYPIY51H5fPTpw%253d%253d&p=t 3/7
5/9/23, 1:18 PM 2021 Contributions & Expenses Annual Filing - Secretary of State of Nevada
DIFFERENT THAN
CONTRIBUTOR
AllAroundA PAC
Name (print) Office (if applicable) District (if applicable)
CATEGORIES CODE
Office expenses A
Attachment E
https://www.nvsos.gov/SOSCandidateServices/AnonymousAccess/ViewCCEReport.aspx?syn=sd2djtcGbYPIY51H5fPTpw%253d%253d&p=t 4/7
5/9/23, 1:18 PM 2021 Contributions & Expenses Annual Filing - Secretary of State of Nevada
Goods and services provided in kind for which money would otherwise
J
have been paid
1 NRS 294A.362 requires “In Kind” contributions and expenses to be reported on a separate form, which is attached hereto.
AllAroundA PAC
Name (print) Office (if applicable) District (if applicable)
AllAroundA PAC
Name (print) Office (if applicable) District (if applicable)
NAME AND ADDRESS OF PERSON, GROUP OR DESCRIPTION DATE OF IN KIND VALUE OR COST
ORGANIZATION WHO RECEIVED THE IN KIND OF IN KIND OF IN KIND
Attachment E
EXPENSE
https://www.nvsos.gov/SOSCandidateServices/AnonymousAccess/ViewCCEReport.aspx?syn=sd2djtcGbYPIY51H5fPTpw%253d%253d&p=t 6/7
5/9/23, 1:18 PM 2021 Contributions & Expenses Annual Filing - Secretary of State of Nevada
GOOD OR SERVICE EXPENSE EXPENSE
EL 202
Revised: 8-13-13
NRS 294A.140; 294A.150;
294A.210; 294A.220; 294A.373
Attachment E
https://www.nvsos.gov/SOSCandidateServices/AnonymousAccess/ViewCCEReport.aspx?syn=sd2djtcGbYPIY51H5fPTpw%253d%253d&p=t 7/7