IN THE OHIO ELECTIONS COMMISSION

MARKW.STAHL21421 W. ToledoWilliston, Ohio 43468Phone: (419)836-5038

Complainant,

vs.

OHIO DEMOCRATIC PARTYCHRIS REDFERN, CHAIRMAN340 East Fulton StreetColumbus, Ohio 43215Phone: (614) 221-6563

Respondents.

COMPLAINT

State of Ohio :County of Franklin : SS.

Mark W. Stahl, being first duly sworn, deposes and says as follows:

1. I am a registered Ohio voter and make this Complaint based upon my personal

knowledge.

2. I am a candidate for re-election as Ottawa County Commissioner in the election to

be decided on November 6, 2012. I have served as Ottawa County Commissioner since January,

2009.

3. In an attempt to influence the results of my election campaign, Respondents the

Ohio Democratic Party and Chris Redfern have recently mailed throughout Ottawa County the

campaign flier attached hereto as Exhibit A.

4. Respondents' campaign flier falsely quotes the News Herald as follows:

News Herald"Stahl has been

working on personalbusiness from his

county office"

5. The campaign flier also states "Stahl's using County resources to increase

profits for his personal insurance business", and footnotes as authority for this statement,

"Port Clinton News Herald 9/28/12".

6. In fact, the Port Clinton News Herald never stated that Stahl has been working on

personal business form his county office. Rather the September 28, 2012 Port Clinton news

article only stated that "a lawsuit by an Elmore insurance company . . . claims Stahl has been

working on personal business from his county office".

7. A true copy of the September 28, 2012, Port Clinton News Herald article is

attached hereto as Exhibit B.

8. Moreover, unlike Respondents' flier, the Port Clinton News Herald also reported

that "Stahl denied using the county office for personal business". Indeed, the only time I have

even used the fax machine for a matter unrelated to county commissioner matters was a single

occasion in 2010, when I faxed a short four page document to my lawyer or accountant.

9. I do not operate an insurance business or any other business from my county

office. Respondents' statement that the News Herald reported that I did is a false statement.

10. A true copy of the September 25, 2012, Complaint which was the subject of the

news article is attached hereto as Exhibit C.

11. As the Port Clinton News Herald article indicates, the insurance company's

complaint was in response to a lawsuit that my wife filed in March 2012. The underlying dispute

relates to a dispute between my wife (who is a minority owner of Diversified Insurance Service,

LLC) and the controlling shareholders. In a fairly transparent attempt to punish my wife for

suing them for their misconduct, Diversified waited six months and then filed a Complaint

(Exhibit C) against me shortly before the election.

12. Diversified's Complaint does not even claim to have any knowledge that I

conduct a personal business at the Board of Commissioners office. Rather, paragraph 4, of the

Complaint attached hereto as Exhibit C merely claim that "Mark W. Stahl . . . is believed to

maintain offices through which he conducts his personal business, both at 21321 W. Toledo,

Williston, Ottawa County, Ohio, 43468, and at Board of Ottawa County Commissioners

office...."

13. Furthermore, neither Diversified's Complaint, nor the News Herald article ever

say that I have a "personal insurance business" or have used County resources on my "personal

insurance business" or otherwise,

14. I do not have a "personal insurance business". I do not own an insurance

business, nor am I a licensed insurance agent.

15. Respondents" statement that "Stahl's using County resources to increase profits

for his personal insurance business", and their citation as authority for this statement, the "Port

Clinton News Herald 9/28/12" are both false statements.

16. Respondents also falsely state that "Mark Stahl's using taxpayer money for his

own personal gain," and that "Mark Stahl. . . profited on your dime." I have not done so,

and nothing in the News Herald article cited by Respondents states that I have.

17. R.C. 3517.21(B)(8) makes it unlawful to "[fjalsely identify the source of a

statement."

18. Respondents have violated R.C. 3517.21(B)(8) by falsely citing the News Herald

as reporting that "Stahl has been working on personal business from his county office", and by

falsely citing the News Herald article as the source for the statement that "Stahl's using County

resources to increase profits for his personal insurance business."

19. R.C. 3517.21(B)(10) makes it unlawful to "post, publish, circulate, distribute, or

otherwise disseminate a false statement concerning a candidate, either knowing the same to be

false or with reckless disregard of whether it was false or not, if the statement is designed to

promote the election, nomination, or defeat of the candidate."

20. Respondents violated R.C. 3517.21(B)(10) by falsely stating: (a) that "Mark

StahPs using taxpayer money for his own personal gain," (b) that "Mark Stahl . . . profited on

your dime," (c) that "Stahl's using County resources to increase profits for his personal insurance

business", (d) that "Port Clinton News Herald, 9/28/12 is the source of this last statement, and (e)

that the News Herald stated that "Stahl has been working on personal business from his county

office."

WHEREFORE, Complainant requests that Respondents be found in violation of R.C.

3517.21(B)(8) and (10) and that they be appropriately sanctioned.

Further Affiant sayeth naught.

Mark W./tahl

Sworn to and subscribed in my presence this 29lh day o^\October, 2012

TNotary Public

DONALD CARL BfiEV, AttornwJttllWNOTARY PUBLIC, STATE OF OHIO

My commo

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