Office of Lawyer Regulation March 12, 2025
110 East Main Street P.O. Box 1648
Madison, WI 53701-1648
I, Julie Saunders-Seegers, allege for this SCR complaint the following:
The Susan Crawford of Wisconsin (“SCW”) registered campaign committee is using fictitious names to fund its campaign. In this fraudulent scheme, 1,397 real citizens' names are being used without their knowledge or permission. The total amount is $63,903.63 and is comprised of over 2,179 transactions. This allegation is conservative and not exhaustive. The SCR violations are listed at the end of this complaint.
I request a full investigation be conducted on SCW. Several Wisconsin campaign finance statutes have been violated including, but not limited to:
1) 11.1303(1) No disbursement may be made anonymously and no contribution or disbursement may be made in a fictitious name or by one person or organization in the name of another.
2) 11.1204 Unlawful political contributions.
(1) Subject to sub. (2), no person may, directly or indirectly, make any contribution other than from funds or property belonging to the person. No person may, directly or indirectly, give funds or property to another person for the purpose of making a contribution in other than the first person's name.
(3) No person may intentionally receive or accept any contribution made in violation of this chapter.
3) 11.1201 False reports and statements. No person may prepare or submit a false report or statement to a filing officer under this chapter.
There is more than enough reasonable suspicion that justifies opening a full investigation into SCW. Evidence in this complaint strongly shows that the recorded donors may not be the actual sources of these funds. These people are known as Smurfs, and the scheme is known as Smurfing. See https://www.investopedia.com/terms/s/s/smurf.asp for a concise explanation. The SCW campaign must ensure that every suspicious donation listed is legitimate and originates from the stated donor. Per Chapter 11 ignorance cannot be a defense for accepting illegal donations. § 11.1400(7),(8).
Smurfs are a) over the age of 65, b) largely have occupations recorded as: unemployed, not employed, retired, unknown, or none, c) have extraordinarily high number of contributions. These transactions are being electronically executed using computer bots. Bots are a kind of computer algorithm.
See “Exhibit A, tab Crawford Smurf Sample” a sampling of SCW identified Smurfs (using real people’s names and addresses without their knowledge). Part of their scheme is to mix legitimate contributions with fictitious ones.
David J Mahoney, the SCW treasurer listed on the CF-1 form and Park Bank, 33 E Main St., Madison, WI is the financial institution listed under “depository information”. The financial platforms used to deposit funds into the SCW campaign are in question. SCW uses ActBlue Express as a contribution processor, see https://www.crawfordforwi.com/ . Another platform SCW is using is also ActBlue but on a different platform:
https://secure.actblue.com/donate/sc-ads-240611-search?
refcode=SC_ATA_ADS_Search_D2D_240612_Launch_Keywords_Wisconsin_Contextual_Headline_Text&ga d_source=1&gclid=CjwKCAiAm67BhBlEiwAEVftNrnhTkepYmNtWfbV6tMD0_YECOUDQpULsJEQZWpAhjwPFrqBbvkjxoCLL4QAvD_BwE
ActBlue is under investigation by The House Administration Committee headed by US Congressman Brian Steil for not having adequate financial controls. Twenty (20) U.S. Attorneys General are also investigating ActBlue for not verifying that the merchant card(s) used to make donations are legally tracked back to the legal owner of the name and address. ActBlue has only recently required CVV codes, but only for new donors, which is the 3-digit number on the back of the credit or debit card. It is one security measure to prevent fraudulent activity. This leaves the over 300,000 Smurfed names used at the FEC and state levels still unchecked to make sure the names and the addresses used are tied back to legitimate bank accounts.
ActBlue, which Susan Crawford uses for funding her campaign, is collapsing due to criminal money laundering where 20 State Attorney Generals have opened an investigation into them. An article came out on this new development just days ago:
https://www.nytimes.com/2025/03/05/us/politics/actblue-democrat-fundraising-resignations.html
With this and the attached Exhibit A and Exhibit documents, I have shown reasonable suspicion these contributions are not being made to SCW by the provided names/addresses but by someone using these names and addresses fictitiously. Mark Jennerjohn, elderly and disabled, on video, proves he never gave the number of contributions to the FEC, the State ETHICS Commission, nor to the Susan Crawford campaign. Susan Crawford’s law license must be revoked.
Julie Saunders-Seegers Electronically Signed By: Julie Saunders-Seegers March 12, 2025
Enclosures: Crawford Exhibit A, 3 tabs
References: https://www.fec.gov , https://ethics.wi.gov/Pages/CampaignFinance/CampaignFinance.aspx , https://electionwatch.info/
Exhibit B, Mark Jennerjohn
Following is just one example of over 1,000 Smurfs used to boost the Crawford campaign. His name is Mark Jennerjohn, Appleton, WI (age 66). Recorded at the FEC since 1/1/2019 is 7,313 transactions, and 764 to various state of WI politicians and PACS, to total 8,077 in a six-year period.
“Exhibit A, tab Jennerjohn Fed & State" shows 196 combined state and federal contributions made by Mark Jennerjohn to various state and federal politicians and PACs since 6/1/2024 (the date Crawford announced her Candidacy for Supreme Court). The total is $25,379. That would be $2,819 per month (nine-month period). Please note the transactions dates; many on the same day and consecutive days in a row.
- Breaking down the state and federal donations even further,
o Mark Jennerjohn supposedly made 21 donations to Democratic Party of WI Federal PAC between 6/1/24 and 1/29/25 to total $1,199.
o Mark Jennerjohn supposedly made 33 donations directly to Susan Crawford to total $3,135
- Donations to WI politicians include 29 times to Janet for Justice, also a Supreme Court race in 2024, to total $2,960. 47 donations were made to Josh Kaul in 2018 to total $527.
- On Thursday, April 6, 2023, a Private Investigator was hired by ElectionWatch, visited Mr. Jennerjohn. This is an excerpt from the PI report: “The subject stated he is disabled, not clothed, but would speak to the investigator at the front door. Upon speaking to the subject regarding his political donation history, he denied making 7,878 donations as well as the dollar amount reported, $93,168. The subject scoffed at the amount and stated, “look where I’m living!” The subject referred to the modest, run-down, small apartment on the second floor of a modest converted home. He stated he donates $5 at times but could never afford to donate over $90,000 in the last 7 years.” This report along with recorded video of Mr. Jennerjohn is available.
- Wisconsin 915 donations attributed to Mr. Jennerjohn between 7/14/2016 and 6/30/2023 total $24,714.28. The daily patterns show a computer bot is doing these transactions, not a human being.
-Federal 5,659 transactions (that don’t include blank transaction lines) attributed to Mr. Jennerjohn between 6/3/2017 to 12/30/2022 total $90,772.
The data on the attached excel spreadsheet(s) includes information from official open sources. An email from Open Secrets who reports heavily on campaign contributions, reported to me that the average number of contributions, for a person making such political contributions, is 4.2 donations per donor per candidate per election cycle (two years). Or thus 2.1 per year. In support, per the FEC contributors who are making political contributions make on average 1.4 contributions per year. This means it is unusual to have 1,397 unique donors contribute to SCW in excess of two times and also contribute to the Federal campaigns more than 1.4 contributions per year. This is one fact showing a reasonable suspicion.
SCW has 21,681 unique donors comprised of 30,287 donations. 43% of the unique donors are from out of state. It is common to see Smurfs’ who live in other states being used in local Wisconsin elections as there are 300,000 Smurfs to choose from according our estimations. Compare the 42% out of state to her Republican opponent’s 3% out of state donations.
Individual Contributions Between 6/10/24 and 2/17/2025
Whereby, I further allege SCR Violations by Susan Crawford of:
1. Misconduct and Dishonesty (SCR 20:8.4)
SCR 20:8.4(c): It is professional misconduct for a lawyer to engage in conduct involving dishonesty, fraud, deceit, or misrepresentation.
o The complaint alleges that Crawford’s campaign engaged in "smurfing," using fictitious names for donations, which would constitute fraud, misrepresentation, identity theft, money laundering, bank fraud, wire fraud, mail fraud
SCR 20:8.4(b): A lawyer shall not commit a criminal act that reflects adversely on the lawyer’s honesty, trustworthiness, or fitness as a lawyer.
o If campaign finance laws were violated, and if those violations are criminal in nature, it indicates professional misconduct.
SCR 20:8.4(f): A lawyer shall not violate a statute, supreme court rule, or decision regulating the conduct of lawyers.
o Wisconsin campaign finance laws prohibit contributions under fictitious names and fraudulent reporting. Crawford, a licensed attorney, whether she was aware of it or not (per Chapter 11 of Wis. State Statutes) she violated this rule. And multiple times over in the hundreds of times.
2. Candor Toward the Tribunal and Public Misrepresentation (SCR 20:3.3 & 20:7.1)
SCR 20:3.3(a)(1): A lawyer shall not knowingly make a false statement of fact or law to a tribunal.
o Crawford’s campaign filed false finance reports with the Wisconsin Ethics Commission, this was misleading the tribunal (i.e., a regulatory body).
SCR 20:7.1: A lawyer shall not make a false or misleading communication about the lawyer’s services.
o Crawford allowed fraudulent contributions (again, whether she knew or not is immaterial) to be reported; she has misled the public about the legitimacy of her campaign funding.
3. Responsibility for Nonlawyer Assistants (SCR 20:5.3)
SCR 20:5.3(b): A lawyer with managerial authority over nonlawyers shall make reasonable efforts to ensure that the person’s conduct is compatible with the lawyer’s professional obligations.
o Crawford’s campaign staff engaged in fraudulent activities under her supervision, she had a duty to prevent such conduct.
4. Unlawful Transactions and Conflicts of Interest (SCR 20:1.15 & 20:1.8)
SCR 20:1.15: Safekeeping of property and handling of trust accounts.
o Crawford had or should have had direct control over campaign finances and knowingly participated in laundering funds, she (her campaign with her at the top) mishandled money in a manner violating ethical financial practices.
o
SCR 20:1.8(k): A lawyer shall not engage in conduct that results in the lawyer improperly benefiting from a transaction.
o Illicit funds were funneled into her campaign for personal or professional gain, this constitutes an improper financial transaction.
