‘STATEMENT OF SALLY KRISEL, DEPUTY DIRECTOR,
HAMILTON COUNTY BOARD OF ELECTIONS
September 19, 2018
I'd lke to start by apologizing to the Director and to the Board Chair and Board
members for not speakingup immediately about my role in the redaction of the memo
line on copies of four checks that were included in a campaign finance report filed by
the Friends of Aftab Pureval. My understanding of the law was and is that it is,
permissible to redact notations on the memo lines of checks. My mistake was not
insisting that the campaign's representative herself perform the redaction, but instead |
did the redaction. | now see that was an error in judgment. The redactions were done
before the additional pages containing the redactions were stamp-filed.
(On August 1", when Sarah Topy, a representative from Friends for Aftab Pureval, came
to file additional documents for their 2018 Semi Annual campaign finance report that
had been filed the day before, I met with her in my office. Sarah asked me whether
Ohio election law prohibited redaction of the memo line on a check that was part of the
candidate's fling. Based on my experience for almost twenty years at the Board with
‘campaign finance filings, | said redactions were not prohibited as long as the purpose of
the check was simultaneously reported on Form 31-8 in the purpose column in the filed
documents, In this case it was. She indicated that the committee wanted to redact the
‘memo line on four check copies. | had in front of me the file-stamped copy of the July
31st 2018 Semi Annual report and the additional papers that the committee was
planning to file that day. | verified that the purpose of each check copy had been
reported on the filing the day before. | used the marker that | had in hand to redact the
four lines as a courtesy to Sarah Topy. It would have been better to hand the marker to
‘Sarah to redact the four memo lines. | did notice that the committee had made other
redactions in the papers prasented on August 1".
In my experience, | have seen other types of redactions. It is not the policy or practice
of our Board to alter any campaign finance reports once they are filed. In this case, the
conversation and redaction took place before Sarah left my office and filed the added
reports. Board staff members meet with candidates and treasurers of committees on a
regular basis to advise and assist them in filings in order to make campaign finance
reports compliant with state and local requirements. As stated, the offical
documentation was formaly stamp-filed and received by our campaign finance staff
after the redactions were made.
Page 20f2“The Friends of Aftab Pureval committee reports were the subject of several public
record requests by Mr. Brian Shrive, There were many telephone and email contacts
between Mr. Shrive, the Director, our campaign finance staff, and me over several
months involving publi: record requests and follow up questions. As with all pul
record requests, we reolied in a prompt manner.
Mr. Shrive originally asked about the redactions after he received a copy of the filed
‘follow up report on August 1" and | told him that the redactions were made before the
report was filed. On August 17" | asked one of our campaign finance staff to contact
‘the Ohio Secretary of state's office. She wrote to the Ohio Secretary of State's office, “If
a committee submits checks with the memo line redacted, is that something we would
‘question the committee about and have them resubmit the documents without the
redaction?” Katie Zvolanek, Director of Campaign Finance & Administrative Counsel at
‘the Secretary of State's Office, replied, “There is not statute that says it can’t be reacted,
Ultimately itis up to the Board if that suffices as verification. Just remember to be
consistent. Our office would most likely not ask about that.” Mr. Shrive again raised the
issue on September 14” and I repeated to the Director that the redactions were made
before the report was filed. | regret that on September 14” and again on September
17° | did not immediately speak up and make clear that although the redactions were
made before the report was filed, it was | that made the redactions at the request of
‘Sarah Topy.
| spoke up on the afternoon of September 17 when the Director was asked to sign an
affidavit attesting to the fact that: 1) it was not the Board policy to redact the memo
lines on checks filed with the Board; and, 2) no Board staff member did the redaction on
‘the memo lines on the checks on the Friends of Aftab Pureval reports. 1 told the
Director and Board legal counsel that the affidavit could not be signed because it was
not correct and then met with Board legal counsel separately and told him that | made
‘the redactions. | then called the Board Chair, the Director and the other Democratic
Board member explaining that | did the redactions before the report was filed, at the
request of Sarah Topy and with my understanding that the memo lines were not
required, The Director informed the remaining Board members.
| was afraid that if| spoke up | would embarrass the office because | did the redactions
instead of insisting that Sarah make the redactions. It’s now clear that | did embarrass
‘the office, the Director, the Board, its Chair and the other members, and for doing that |
am truly sorry and apovogize.
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