BEFORE THE FEDERAL ELECTION COMMISSION

Lisa J. Stevenson Acting General Counsel Federal Election Commission 999 E Street, NW Washington, D.C. 20463

BY E-MAIL & MAIL

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December 13,2017

COMPLAINT

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Dear Ms. Stevenson:

Complainant seeks an immediate investigation into Todd Watson's failure to comply with basic disclosure requirements mandated by the Federal Election Campaign Act of 1971 (as amended) which require that he file a Statement of Candidacy or written disclosure with the same information to the Federal Election Commission.

Public records show, and an investigation will confirm, that Todd Watson is a candidate under 11 CFR 100.3 and has failed to file a Statement of Candidacy with the Federal Election Commission in violation of 11 CFR §101.1(a) and 11 CFR §102.12(a).

A. FACTS

On November 21 , 2017 at 6:00pm, Todd Watson announced his candidacy for U.S. Senate on a Facebook live page with the words "Watson for Senate" at the top of the page.' On the site, Watson is quoted as saying, "Why we're all here is, we're announcing our candidacy to be the Republican candidate to replace Senator Deb Fischer here in 2018."^ Additionally, Watson uses the Twitter handle "WatsonForSenate."^ Watson's Twitter page describes him as a 2018 Republican Candidate for U.S. Senate.^ Watson has a campaign website where he solicits donations. This website states that he is running for US Senate.^

Watson for Senate made the following expenditures in 2017^:

$1,925.00 for a radio advertisement on KLIN in Nebraska running from 11/21/17 to 12/13/17;

$1,480.00 for a radio advertisement on KRVN running from 11/22/17 to 12/7/17;

' httDs://ww\v.i'acebook.com/WtiisonfoiSriiiate1776/videos/l835513733144647/ (accessed December 11,2017). 2/4. at 1:00-1:15. 2 https:/Awitter.coin/watsoiiforsenate?lang=en. ''https://twitter.coin/watsonforsenate?lang=en. ®http://www.watsonl776.com/ (accessed December 7,2017). ® Exhibit C.

$882.00 for a radio advertisement on KTIC running from 11/22/17 to 12/07/17;

$769.90 for a radio advertisement on KNEB running from 11/22/17 to 12/07/17; and

$780.00 for a radio advertisement on KAWL running from 11/22/17 to 12/07/17.

In total, Watson for Senate spent at least $5,836.90 on radio advertisements in 2017.^ Ail of these advertisements were made public on or after the date that Watson announced his candidacy online. The broadcast documentation for all of these advertisements lists "Watson for Senate" as the advertiser.^ Watson for Senate has not disclosed any additional spending, so while it is clear that the campaign has spent more than $5,000, it is unclear what additional expenditures have been made:

A public records search indicates that, as of December 12,2017, Watson had not filed a Statement of Candidacy or sent the required written disclosure information to the Federal Election Commission. Interestingly enough, Watson has previously been a candidate for U.S. Senate, terminating the past committee on November 26^, 2014.'

B. LEGAL ARGUMENT

Federal law requires that a candidate designate a principal campaign committee within fifteen days of becoming a candidate as defined by 11 CFR §100.3.'° The candidate must designate a principal campaign committee by filing a Statement of Candidacy on FEC Form 2 or by filing a letter containing the same information." Any individual who seeks nomination for election to federal office and has received contributions or made expenditures in excess of $5,000 on election-related activity is a candidate."

Watson is a candidate under 11 CFR §100.3. Watson's expenditures exceed $5,000" and he refers to himself as a candidate for federal office on his campmgn website, on his campaign Facebook page,''' and on his Twitter page." Watson's expenditures exceeded $5,000 no later than.November 22,2017. As a candidate Watson was required to file the Statement of

'Id. »/rf. ®https://www.fec.gov/data/coinmittee/C00556977/?tab=filings. '°11 CFR §101.1(a). ''Id. '^11 CFR § 100.3; It should also be noted that Watson may not claim a "testing-the-waters" exemption from reporting requirements. See AO 2015-09 (Senate Majority PAC and House Majority PAC) ("the testing-the-waters exemption does not apply "to individuals who have decided to become candidates" 11 C.F.R. §§ 100.72(b), 100.131 (b); see also Advisory Opinion 1981 -32 (Askew) at 4 (explaining that regulation distinguishes "activities directed to an evaluation of the feasibility of one's candidacy .. . from conduct signifying that a private decision to become a candidate has been made""). " Exhibit C.

Exhibits. Exhibit A.

i

Candidacy or written disclosure within fifteen days of this date.^® A Statement of Candidacy was not filed by December 7,2017, fifteen days after the expenditures exceeded the threshold amount triggering the requirement.

Watson is a candidate and failed to file the required disclosure within the statutory period. Accordingly, the Commission should find that Watson violated 11 CFR §100.3 and should impose a civil money penalty on Watson for Senate pursuant to 11 CFR §111.43, along with other penalties that the Commission finds appropriate.

C. CONCLUSION

Based on the available information, Watson violated federal campaign finance law by failing to file the required Statement of Candidacy within the required time. We respectfully request that the Commission conduct an expedited inyestigation into this violation of federal campaign finance law and impose any and all penalties warranted by the violation, or as otherwise deemed necessary by the Commission.

Respectfully submitted.

John Paul Sabby

Lincoln, NE 68506

Subscribed and sworn before me this day of December, 2017

Not

My Commission Expires:

GENERAL NOW • Stale of Nebrasia CAITLIN HOLIMAN

My Comm. Exp. June 22.2019

11 CFR §102.12(a) C'Each candidate for Federal office shall designate in writing a political committee to serve as his or her principal campaign committee in accordance with 11 CFR 101.1 (a) no later than 15 day s after becoming a candidate. Each principal campaign committee shall register, designate a depository and report in accordance with 11 CFR parts 102,103, and 104").

EXHTBITA Of the Feopte, t or the People!

Have an account? Loa in i

Todd Watson OWatsonForSenate

2018 Republican Candidate for US Senate-Nebraska; 2014 Constitutional Candidate; US Senate-NE. Aiways Defend

. the ConstitutionI

Nebraska

watson1776.com

010 Joined November 2013

0 217 Photos and videos .

TWeets IWeets & replies Media

Todd Watson ©WatsonForSenate - Dec 6 v Do I need to take you on?;) Isn't it funny how #NEGOP iawmakers have field day with UNL free speech but aliow siienced speech at home within party?-Double standard needs to change. Do free markets and competition appiy to ideas?

Kirk Penner ©KirkPenner

2000+ fitcebook rgiii

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A Todd Watson ©WatsonForSenate • Dec 5 Nope Ann...there is not...

AnnGiulter© ©AnnCouiter Has there ever been a more easily conned group of people than Washington Republicans? How did taxes come up before infrastructure?????

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Todd Wbtson ©WatsonForSenate • Dec 5 > -Amen

Dave Rimington ©drimington Nebraska Football - While all eyes will be on Coach Frost's offense - It will be his defense that i will looking at .The West belongs to Wisconsin and it will stay there until we stop their run game. We desperately need man-eaters on DL ...I can't stress that enough

n Todd Watson ©WatsonForSenate • Dec 4 Senator Deb Fischer supports more Business Regulations and #Mandates! She voted '^'es" to fully fiind the U.S.... fb.me/J98IDxBJ

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https://twltter.coniAMat8onfor8enate7lang=an 1/5

12/7/2017 Todd Wdtson (@WataonFdtSenate) | Twitter

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Todd Watson @Wat5onForSenate • Dec 4 v I'm sorry Senator Fischer and her staff has to deal with this. Let's pray the LPD catches these people.... fb.me/P9s06Ylo

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Todd Wdtson @WatsonForSenate • Dec 3 v Tuesday's With Todd at 8pm... This week we will be talking the Trump Agenda, Truth and "Safe Spaces". Submit Your... fb.me/BieVWVgp

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Todd Watson ©WatsonForSenate - Dec 3 . v Talking Trump Agenda and Safe Spaces..on Tuesday With Todd...8PM...See you then...Submit YourQuestionsllll fb.me/8XMdcbRLIm

Q 1 U 1 1

Todd Wdtson ©Watson ForSenate • Dec 2 s/ Hank Bounds

Kevin SJuts A ©kevinsjuts \ I FILL IN THE BLANK; The player on Nebraska's current roster that will benefit !

the most from being in Scott Frost's system Is

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Todd Wbtson ©WatsonForSenate • Dec 2 v Frostyllll

I (If You Remember 1997 Strategy...You Will Be Finel)

«GBR *Huskers BNebraska #Uncoln #UNL #GOBIGED...

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Todd Watson ©WatsonForSenate Dec 2 v > Half truth. Economy will grow debt down. However the pending infrastructure bill will break camels back. CUT SPENDINGI Failed last budget..

The Hill« ©thehill JUST IN: CBO says Senate GOP tax bill would increase the deficit by $1.4 trillion hill.cm/Nllweil

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Todd Watson ©WatsonForSenate • Dec 2 v Meanwhile...Mid East and N. Korea still rumbling...

: VbsharAli «©yashar . ' BREAKING: Israel strikes Iranian base near Damascus, Syrian reports say i haaretz.com/israel-new^1....

https://twltl«r.comAwatBonfbrssnate7lang>en 2/5

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12/7/2017 Todd Watson (@WatsonFoiSenate) | Twitter

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Todd Watson @WatsonForSenate - Dec 2 v As 1 wrote In press release...these Senators can/e outs are crazy....House is sliowing more guts.

Paul NehlenO ©pnelilen . Promising DACA amnesty to get votes for this tax bill is treason. | >

I •• bit.ly/2AzARXf via @BFeitbartNews

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Todd Watson ©WatsonForSenate - Dec 2 v Then why didn't you support Senator Paul's bill that requires 1 day of review for 10 pages during Obamacare? We need consistency. ^

SenDianneFeinstein©@SenFeinstein [ . • UPDATE: Republicans rejected our motion to adjourn until Monday so

senators could read the bill they just introduced. I I

RTifyou think senators should have time to read a bill that affects every... !

Q 11

Todd Watson ©WatsonForSenate - Dec 2 v Our US Senate must stop delegating foreign policy to other nations. We need to define ourselves...

Senator Rand Paul © ©RandPaul "The United States feces a question that it seems to want to ignore: What kind of nation are we?" | • washingtontimes.com/news/2017/nov/... '

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> A Todd Watson ©WatsonForSenate • Dec'2 s/

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As we said in our press release...the problem is spending...not taxation. Debt will grow worse with infrastructure requests up next. Budget cuts were answer during last budget. #GOPOLE

Fix the Debt 9 ©FixtheDebt Thank you Sen. Corker for showing real leadership on this. #fixthedebt twitter.eom/SenBobCorker/s...

Q 11

Todd Watson ©WatsonForSenate • Dec 2 v Agree. Very Simple.

Daniel Horowitx ©RMConservative I It's very simple. There is a budget coming up. GOP controls all three branches. Fund border wall and more ICE agents, defund sanctuary cities, visas from dangerous countries, and Planned Parenthood.

Q 11

Todd Watson ©WatsonForSenate - Dec 1 \/ The 1st Job in the Constitution is to #EstablishJustice. Fail #Kateslaw The 2nd Job in the Constitution;...

https://twitter.coiTWvatsonfor8enate7lang=0n 3/5

12/7/2017 Todd Watson ((gVVMsonFoiSenate) | Twttter

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Todd Watson @WatsonForSenate • Decl v For a very long time now, the Federal Government has sought to usurp the role of the state In a number of...

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Todd Watson @WatsonForGenate • Nov 30 v *TaxRBform Know what is qoing to happen to you I fb.me/Suo36xTeP

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Todd UMson @WatsonForSenate • Nov 29 v Joe, Thx for the kind words. You are one of the few that Is not afraid of the truth...means a lot from you. ®FBblockadme thanks for doing research.. Joe..happy to meet w/ Hem'ng fen dub anytime If they want to pull out magnifying lens for Swamp/Constitutional examination:) i

Joe Herrhg @dallyherrlng

Replying to @FBblockedme @SenatorFlscher and 3 others

Todd Is a.fnend and a small govt believer. Definitely not swamp material, more like a does of bleach for the swamp

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It's time...tlm0 to hcM DC accountable. Time to utilize primary eiections as /nemrLlmitsI Senator Deb FIsclrer has made her choice, and she has sided with the Washington elite over her constituents. She has chosen to say one thing and then vote another. It is for this reason I am running, and I need your helpi

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Oo Not Let the Senate Stop Legislation On Nationai Reciprecity Coming Out of the House!

The 2nd Amendment is American citizen's #gunpermit...the bill tiiat was passed by the House of Representatives yesterday allowing #nationaireciprocity was a good thingi Unfortunately, we know the Senate is a problem for 2nd Amendment bills. Senator Cornyn, a Republican from Texas and chairman of the Whip team (Senator Fischer is on this team), has the House legislation split Into two sepa... See More

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i want to thank the Sarpy County Chamber of Commerce for the invite to their government affairs meeting tonight, i talked fbr 5 minutes and listened for4S...the ratio it should be. I appreciated the perspective offfbusiness, ffeduciation, flmiiitaiy, #heaithcare, and commissioners in the room talking through the issues of their community. Thank you fbr sharing your perspectives State Senator Sue Crawford, Mayor David P. Black, f^atrick Boyle Metropolitan Community College - South Omaha Campus, Brant Connelly, Karen Gibler, Tom Greco and more, i was impressed with the wide variety of disciplines at the same meeting.

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Gerry Mattson IVe always baen a fan of that ratio as wail. When Scott Walker want to GWU he gave roughly a 20 minute lecture and had an hour Q/A. Ifs a sign of respect in my opinion to value the questions and thoughts of others more than your own desire to be heard.

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Happening Now! Todd Watson's core platform item in 2014 and 2018 is at piay. See Todd's video on Reiigious Liberty below!

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Dava N Kalll Daprlast This man is in tha right, and tha Supreme Court, if thay rule in favor of those Sodomites, America is in more tioubie. Yesterday at 10:S0am

Watson for Senate was live. Deoember 5 at 6:01pm

Trump, Trump, and More Tnjmp....You Asked-.Todd Answers

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Kate Flea Nagger 0:00 Wishing you the best from Charioife, NC Great ad, spread it ail overt Oeoamber5at7;19pm" Edited

1 I Thank You Kate... •acembar 5 at 7:19pm

I PelUgrew 34:48 Thank you Todd... i wiii look at your site more. Evan though I'm in TN DecamberSat6:36pm

^ Watson for Senate Thanks for tuning in Decembers at 6:3epm

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- WUson ftar Senate shared Fox News's video. ! ' DeoamberS at6;43am I • •'

' President Trump Is putting iand back into ttie hands of the people! Todd Watson supports thisi Senator Fischer voted "Yes" for the govemment land

' grab of 544,000 MORE ACRES (I wlii put the recorded vote below in the comments), i believe in people stewaiding mora of the iand. Senator Rscher trusts the govemment to steward more of the iand. A vary clear difference, it

- is sad when you are from an agricultural state with some of the greatest stewards of the land (Farmers... See Mora

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'Public lands will once again be tor public use.'

President Donald J. Tnimp on Monday signed a pair of executive ciders to significantly shrink two of Utah's...

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Not slander...just the tacts. December 5 at 8;53ain

Kalhiyn Paps Not tired of WINNINGI 2 December 5 at 7:23am

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Watson for Senate _ Oecemberaaf 1i:l4um

Senator Deb Fischer supports more Business Regulations and #Mandatesi Repubacan challenger Todd Watson believes in the Constitution and more freedom.

Senator Fischer voted "Yes' to fuiiy fund the U.S. Department of Transportation fVUnconstitutionai ffELDMANDATES coming out of the Senate Committeel This is not just bad for truckers. This Is bad fOr anyone in the business of livestock. This is bad for the #Constitution.

Senator Fischer supports more Business Regulations and Mandates! | Todd Watson for US Senate Sanator Rachar suppctta mors Business Regulaticns and MandatesI by iaflpatamnnn | Dec 4,20171 Uncategcrizad 10 commants Senator Fischer...

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Jarad Krajcl How are bucking reguletions unconstitutional? Yesterday at 10:498m

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Watson for Sonata Doug Whitaker The Bill of Rights reflects the concern of James Madison end other bemers for protecting specific aspects of privacy, such as the privacy of beliefs (1 st Amendment), privacy of the home against demands that it be used to house soldiers (... See More

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Watson for Senate December 4 atSrSBem •

I'm sorry Senator Deb Fischer and her staff are forced to deal with this. Let's pray the LPD catches these people..4]uickiy. Americans have a right to "PEACEABLY" protest. Keyword "PEACEABLY". Our team sends out our prayers to the staff. It Is tough to show up to work and not be Intimidated by potential hooligans next door (we know...we've been there). These acts just show how extreme a select few have become. There is no room for this behavior in a free society. #Youarehurtingyourowncause

Vandals leave statements outside US senator's Lincoln office A vandal or vandals leu messages in large chalk letters on a sidewalk outside U.S. Sen. Deb Fischer's office In Lincoln's Haymarket District.

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lanse Merrlman If your in office you need to nerve up... our government has become disfunctional due to meny, many issues, Peopie are going to be getting crazier than that... December 5 at 3:01am

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Toriiorrow!!! Right here! 8 PIMI We will address the issues, answer your questions and tell you how you can help us Make Republicans Conservative Again! ffTuesdaysWithTodd FreedomWorks Conservative Review The Liberty Conservative Young Americans for Liberty Senator Rand Paul Congressman Thomas Massle

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Tttis Week on Tuesday Witl) Todd at Spm... We will be talking tlie Trump Agenda, Trulti, "Safe Spaces' and tite next steps to Make Republicans Conservative /Vgaini Submit Your Questions Right Herei

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For ttiose of you sutsjected to a media ttiat screens out Repulrilean cliallengers to tlie Estat)llstiment...here Is our #pres8release we sent out yesterday before #TaxRefbrm passed. You liave a better ctioice in 2018. It is not tax reform witti dspedaiinterest liandouts vs. spendalioilcs. You have a choice for lax relief, no loopholes, a level playing field, and a man that wQi make budget cuts BEFORE the priorities of tax reform and infrastructure are

-Todd ... See More

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Republican W Senate Cantfltfale Todtf Wataon Urging U8 Senate to Pass Tex Refemi

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Watson fbr Senate December 1 at 1:<>0pm •

The 1st Job in the Constitution; #EslablishJustice. Fail #Kateslaw , ,11w2M.JIObinltoCgvtl.llllMHVfNrwjrs!l^^

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• J""i^ Hannily: 'It Was San Frandsco's Sanctuary Cily Policies That Killed Kate Steinle' In his opening monologue tonight, Sean Hannity said sanctuary city laws and policies kiiiad Kate Steinle.

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1 J Watson for.SenalB https://Mww.youtub8.comrwatEh7v=r1JE1T1)PAmg Don't ; buy the lies of 2012 and 2014. Time to vote for the guy who told you the truth

that the two parties would 'kick the can*

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Watson for Senate December 1 at 5:31am •

For a very long time now, tlie Federal Government has sought to usurp tlie role of the state In a number of ways...they have encroached further and further towards eclipsing 10th amendment powers, and It must stop nowl I am a HUGE advocate of «StatesRlghtB, and will do my best once elected to keep the #govemment confined to their ffenumaratedpowersl /Nanthamendment#constltutlon //conservative Omaha, Nebraska Lincoln, Nebraska Scottsbluff, Nebraska

(Video) States' Rights: Todd Watson for US Senate

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1 • December 3 at 8:08am

Wataon for Senate Agree. My campaign advisor said Oonl make the perfect 1 the enemy of good. That was the goal as we shot an hour of content in 5 houis.

Not parfect...but you get the drill... December 3 at 8:16am

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Senate was live. -•S^i November 30 at 5:49pm •

#TaxRefbrm Know what is going to happen to you!

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Dan Holbrook, Holly Hansen Hamm, Lanse Merriman and 22 otheis Top Comments like this.

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Watson for Senate 0:00 Shawna Payne Sony-about "Hard to See" video. IVe ^ got a message into FB to improve the "Screen Visibility". However, the audto

was right on... Here is the link to calculate your own situation (as the bill stands right now)..

1 - November 30 at 6:21pm I r I Watson for Senate tttpJI or.oom/Calc

fgitenqEag- Tax Plan Calculator by Maxim Lott How the Tnimp lax plan will change YOUR taxes. Win the GOP tax plan lower your taxes or raise...

TAXPLANCALCULATOR.COM

i November 30 at 6:21pm

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watson for Senate 2:29 Help educate yourfoiiow Nebreskans Share. Help your fellow Americens...tell your Senatora to stop the "Loopholes' and Tfontrol Spending"

1 November 30 at 6:2Spm

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pftha Ptople, For the Foopfet

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$17.76 Monw Bomb

UO' Make, kefutkiieana Caneeftualiuee, ̂ geUni

Watson for Senate Poliiical Oiganeafion

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sseit WMsen for Senate Thanks Corel Wagner... November 30 at S:2Bpm

Amy Hill Harshman Count the Harehmans in ̂ 1 • November 30 at 6:36pm

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From; Brenda Colvin bcolvjn@krvr).com P Subject: Compatitive Political Info

Date: Dacambar 11,2017 at 1:34 PM To:

EXfflBIT C Hera Is the Information you raquastad for our stations:

Advartlsar: Watson For Senate Right 11«2/17-12/7/17 Station: KRVN AM, Lexington NE Total dollars: /Vppx $1,480 Station: KTIC AM, Wast Point NE Total dollars: Appx$880 Station: KNEB AM, Scottsbluff NE Total dollars: Appx$770 Station: KAWLAM, YorkNE Total dollars: Appx$780

Brenda CoMu, Executive Attbiant KRVN - Rural Radio Network Ph: 308-324-2391. Fax:308-324-5786 www.krim.corn

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