The Wyoming Republican Party says Laramie-based political groups broke state election law in three complaints filed with the Wyoming Secretary of State's Office, two of which have since been referred to the Wyoming Attorney General's Office for review.

"We believe there may be probable violations of W.S. 22-25-102 and W.S. 22-25-110," writes Deputy Secretary of State Karen L. Wheeler in a referral letter to Wyoming Attorney General Peter Michael dated Nov. 1.

The complaints stem from mailers sent to Albany County voters over the last several weeks as well as online candidate endorsements.

In the mailers, separate groups called the Wyoming Hunters and Anglers Alliance and Women Lead Wyoming endorse Democratic candidates in state House and Senate races based on the issues of public land transfers and the gender wage gap, respectively. The groups also posted candidate endorsements on their respective websites.

Some of the mailers support Mary Throne in House District 11, Cathy Connolly in House District 13, Sergio Maldonado in House District 33, Amy Simpson in House District 41, Charles Pelkey in House District 45, Ken Chestek in House District 46, Jackie Freeze in House District 48, Dan Neal in House District 56 and Narina Nunez in Senate District 10.

In one complaint, the GOP says the Wyoming Hunters and Anglers Alliance -- a group which has no members, only a board of directors -- violated state election code by directly assisting several candidates through the mailers and endorsing candidates on its website.

The organization is registered as a nonprofit corporation for public benefit, and the GOP says the group's direct or indirect support of candidates is a violation of state statute. Records for the group on the Secretary of State's website include a tax delinquency notice from Sept. 2.

As for Women Lead Wyoming, the GOP complaint says the group is not a legal entity, but a project of Forward Wyoming Advocacy -- which is also a registered nonprofit corporation filed as a public benefit organization -- and Forward Wyoming Advocacy, not Women Lead Wyoming, as listed on the mailer, paid for the advertising.

No record of Women Lead Wyoming could be found by searching the Secretary of State's website.

"That was obviously odd to us," says Wyoming GOP Chair Matt Micheli. "How could a non-entity, something that is legal fiction that doesn't exist, pay for anything?"

A domain look-up service identifies ELLA WY, LLC as the registrant organization for Women Lead Wyoming's website. The registrant address listed for Women Lead Wyoming is the same address listed for ELLA's principal office, 369 N. 4th St. in Laramie.

Wyoming Hunters and Angler's Alliance shares the same address, according to current data from the Wyoming Secretary of State's Office.

Forward Wyoming Advocacy also listed that address in its initial filing with the Wyoming Secretary of State's Office, dated Nov. 17, 2015.

ELLA, on its website, identifies as "Wyoming's Premier Organizational Development and Consulting Service," and lists "getting a website up and running" as one of the services it provides.

The group says it also acts as campaign management for at least six Democratic candidates including Nunez, Pelkey and Neal, according to the most recent GOP complaint, dated Nov. 2.

The GOP complaint cites the website registration details, candidate management and shared office space as evidence that ELLA is behind the mailings, along with Forward Wyoming Advocacy, though neither group is listed on the campaign materials sent out to Albany County voters.

"It appears certain to us that 'Women Lead Wyoming' is a fictitious organization that is back [sic] by Forward Wyoming Advocacy and ELLA WY, LLC," the GOP writes in its complaint, signed by Mitchell Edwards, legal counsel for the state party. "We believe these groups have improperly assisted candidates for legislative office and have sent out advertising in violation of Wyoming's campaign practice and finance laws."

"Forward Wyoming Advocacy has reported that it is an 'umbrella organization' which accepts and administers funds, is legally responsible for the funds, and approves all political activities," Edwards says in the most recent GOP complaint, filed Wednesday. "

Wyoming Statute 22-25-110 requires "the communications media using the campaign advertising shall print or announce the name of the candidate, organization or committee paying for the advertising."

Essentially, the GOP claims the groups represent themselves as separate entities although they were run out of the same office -- with Wyoming Hunters and Anglers Alliance, Women Lead Wyoming and Forward Wyoming Advocacy having recently moved -- with some members working for multiple groups, leading the GOP to believe the independent expenditures on campaign advertising in question were made in consultation with candidates.

Pelkey is listed as the registered agent for both the Wyoming Hunters and Anglers Alliance and Forward Wyoming Advocacy.

Forward Wyoming Advocacy, like the Wyoming Hunters and Anglers Alliance, has no members, per its filing with the Secretary of State's Office -- just a board of directors. The group filed with the Wyoming Secretary of State's Office for the first time on Nov. 17, 2015.

Wyoming Hunters and Anglers Alliance submitted its initial filing Sept. 17, 2015.

The GOP also alleges that "at least some of the Democratic candidates who have been assisted by Forward Wyoming Advocacy and ELLA WY, LLC through the fictitious 'Women Lead Wyoming' have done so through direct consultation with the group" -- which, if true, would be a violation of state statute.

In the complaint regarding Women Lead Wyoming, Edwards claims that money Democratic candidates paid to ELLA WY, LLC for consulting services is evidence of illegal consultation, essentially arguing that Women Lead Wyoming is a front for ELLA to provide campaign assistance to paying candidates.

The complaint alleges that Nunez paid ELLA $4,000, Simpson paid $4,000, Neal paid $2,000 and Pelkey paid $500 in the current election cycle, all for consulting services. Chestek says he also paid ELLA for consulting.

"There appears to be an intentional misleading of the public as to who is behind these mailings," the GOP complaint concludes.

In a press release dated Oct. 24, Stein says the GOP's claims regarding illegal coordination with candidates are false and her organization complies with state statute.

"Their assertion is completely false. Women Lead Wyoming is not the same as ELLA, it is a project of ours and we contract with ELLA for help with things like data management and web design," Stein said.

Regarding the mailers, however, Stein said the advertisements sent out bearing the name 'Women Lead Wyoming' did not meet the requirements set by state law.

"We realize that this failed to strictly follow the requirements of WY Statute 22-25-110 that requires campaign literature to 'announce the name of the candidate, organization or committee paying for the advertising," Stein said in the press release.

The release goes on to say Forward Wyoming Advocacy pays for Women Lead Wyoming, including the mailer.

The GOP says it amounts to an admission, but the groups tried to "spin it as a miscommunication.'"

"Instead of correcting the issue, they sent out a second mailer and other web-based campaign advertising in an intentional disregard of the law," the complaint states, citing Wyoming Statute 22-25-109.

For his part, Chestek says he did not illegally consult with any group and furthermore was not aware of Women Lead Wyoming or Wyoming Hunters and Anglers until the mailers became a news story.

"I don't know what ELLA's role in that was," Chestek says. "I can speculate, but I'll let them speak for themselves because they know what they did, and I don't."

Chestek says he used a voter list provided by ELLA to go door-to-door and talk to voters beginning in June.

"ELLA gets the data from the Secretary of State and adds some of its own information," Chestek says. "It's a data set that's pretty well-refined. I need to know who I want to go out and talk to and where I find these people."

Chestek ran uncontested in the primary, but says he used ELLA's services to get a head start on the general election.

"There are several thousand doors I need to knock on, and I can't do them all in two months," Chestek says. "So I wanted to get started early, and I was really working on the general election with the data they were providing me way back in June."

Chestek on Oct. 20 posted on his campaign's Facebook page that the mailers sent out endorsing him over Republican candidate Bill Haley based on Haley's "wanting to seize your public lands" were not approved or endorsed by himself or his campaign, and in fact contained information about Haley's position that is patently false.

"I'm in favor of keeping public lands in public hands, and actually, so is Bill Haley," Chestek says. "But the mailer started off by saying 'Bill Haley wants to seize your public lands and his positions on these are cowardly,' -- those are the exact words -- both of which are not true."

"I had no idea who these people were, why they were sending it, who paid for it -- none of that was clear to me," Chestek says. "Even though theoretically it was supporting me, it was a misrepresentation nonetheless and I don't like that kind of campaigning."

Chestek says he also reached out to Haley to explain he was not affiliated with the mailers in any way.

Mailers statement

But despite Chestek's rebuke of the mailers regarding himself and Haley, Wyoming Democratic Party Chair Ana Cuprill says the bigger story is that the mailers contained accurate information.

"There's really nothing incorrect about what those mailers pointed out," Cuprill says. "The candidates that were not endorsed by those organizations, they really did say what they said and they really do stand for selling off public lands. On the women's case, they don't really care about women's issues and the wage gap."

Cuprill says the state party has nothing to do with any of the groups mentioned or the mailers in question. She also says she believes the GOP allegations won't hold any water.

"They know what they're doing. They know how to legally accomplish what they want to do as far as supporting candidates," Cuprill says of the groups. "This might be the first time that we're looking at them in Wyoming, but they've existed for a long time around the states."

As far as data services and field organizers, Cuprill says the party can't always provide those means for candidates.

"We appreciate that an organization like that exists here in Wyoming to help candidates win and get to the legislature and work on laws that will really make an impact in Wyoming for the people of Wyoming," Cuprill says. "I just don't see any merit at all in what the GOP is saying. I think they're concerned about their races."

Chris Bell, executive director of ELLA WY, LLC, declined to comment Wednesday.

Sydney Stein, executive director of Forward Wyoming Advocacy, did not return a request seeking comment Wednesday.

Meanwhile, the Attorney General's Office will review the complaints. Attorney General Peter Michael did not immediately return an email seeking comment Wednesday.

"It is clear to us that the efforts and actions of Forward Wyoming Advocacy, ELLA WY, LLC, and the members, directors, employees, and agents of those entities, as well some [sic] of the candidates themselves is intended to circumvent the transparency and integrity the campaign law demands," the GOP writes in its complaint filed Wednesday.

"The groups and their activities are a web of deception, spun by common players," the complaint concludes.

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