"Campaign Finance Reporting Complaint Against Candidate for District 30 Senate, Timothy R. Goodwin

"I, Toni E. (Tonchi) Weaver, a resident and registered voter in South Dakota, do swear that to the best of my knowledge on this day, May 25, 2022, that the following statements are accurate and true. I submit to the Secretary of State a formal challenge to Republican candidate Timothy R. Goodwin for violations of SDCL§12-27 and urge the Secretary of State and South Dakota Attorney General to levy appropriate civil and/or criminal penalties as provided in SDCL §12- 27-29.1, and I offer these facts in support of my challenge:

"Fact #1 Candidate Timothy R. Goodwin is acting as Treasurer for his own campaign organization known as “Timothy R. Goodwin”. The committee known as “Timothy R. Goodwin” is the sole active committee for candidate Goodwin on the South Dakota Secretary of State website as of 1:32pm MDT on May 21, 2022. (Evidence: Screen capture)

"Fact #2 Candidate committee known as “Timothy R. Goodwin” has never been amended or corrected to indicate that the candidate is seeking the office of Senate in District 30. The last filed statement of the committee indicates that the committee is for the purpose of seeking the office of Representative. (Evidence- Screen capture)

"Fact #3 On March 1, 2022, candidate Timothy R. Goodwin filed with the Secretary of State an adequate number of signatures on petitions to nominate him as a candidate for State Senate in District 30. He failed, however, to file a new committee or to amend or correct the existing committee as seeking the office of Senator. (Evidence: copies of petitions)

"Fact #4 Candidate Goodwin has to date purchased billboards and campaign ads and mailed campaign flyers that bear ‘paid for by’ statements for non-existent committees. These fictitious committees include: #1 - ‘Paid for by Goodwin for Senate” #2 - “Paid for by Goodwin District 30” #3 - “Paid for by Goodwin 4 District 30” #4 - “Paid for by Tim R. Goodwin” (Evidence, photographs and hard copies)

"Fact #5 Candidate Timothy R. Goodwin maintains a website at www.timrgoodwin.com that asks potential voters visiting the site to: “Re-Elect Tim R. Goodwin, June 7, 2022 South Dakota State Senate – District 30”

"This is false and misleads potential voters to believe that Timothy R. Goodwin is the Senate incumbent when in fact he is the challenger to the current incumbent. He is currently an elected Representative in the House of Representatives. (Evidence: Screen capture)

"Fact #6 Candidate Timothy R. Goodwin lists testimonial endorsements on the same website that appear to be endorsements from an entirely different race. They include-

#1 Endorsement Pete Burkett, Custer County states that “Tim is the current state legislative representative for District 30 and he is running for re-election”. Mr. Burkett does not indicate that the candidate is running for the Senate.

#2 Endorsement Jacob Wilts, a former intern for the Republican Party House of

Representatives in 2019. Mr. Wilts states that he is “...writing this letter in support of the re- election of Representative Tim Goodwin.” It is obvious that this was an endorsement written for the 2020 primary election.

#3 Endorsement John Mills, Representative District 4, titled his statement “Re-Elect Tim Goodwin – District 30 – House”. This is clearly from a previous race and not an endorsement for the Senate. Note: Representative John Mills is currently running in District 8 and no longer represents District 4. A phone call to Representative John Mills May 25, 2022 confirms that no endorsement for District 30 Senate was made by him.

"#4 Endorsement Representative Lee Qualm, House Majority Leader makes the statement that Representative Goodwin served as a Majority Whip “for the last two years”, but Representative Goodwin has currently served a total of four years as a Majority Whip. Qualm’s statement also encourages people to “...vote for Tim Goodwin in the June 2nd primary.” That was the primary election date in 2020, and Lee Qualm was defeated in the 2020 June primary, so this, too, is a bogus endorsement. A phone call to Lee Qualm May 25, 2022 affirms that no endorsement for District 30 Senate was made by him. (Evidence: Screen captures)

"Fact #7 Candidate Timothy R. Goodwin’s campaign material and website gives the official government email address of Representative Goodwin – Tim.goodwin@sdlegislature.gov for campaign contact information even though the campaign organization lists a non-government gmail address. (Evidence: Photographs, Screen captures, Hard copies)

"Fact #8 Candidate Timothy R. Goodwin lists the House Lobby phone number (605-773-3851) as the contact number for the candidate making LRC employees de facto campaign assistants. (Evidence: Screen captures)

"Fact #9 A Pre-Primary campaign finance disclosure report for a non-existent legislative candidate committee named “Goodwin for Senate” was filed May 23, 2022 under the committee named “Timothy R. Goodwin”. The candidate name is different from the candidate’s name as it appears on the ballot. The candidate’s committee email address provided is an official email address: Tim.goodwin@sdlegislature.gov

"Fact #10 Not all PAC donations listed on page 6 of the fictitious “Goodwin for Senate” disclosure that SOS attributed to “Timothy R. Goodwin” are verifiable. A crosscheck of the PAC reports shows that PACs report donations made to the following campaign committees: “Timothy R. Goodwin” (existing); “Goodwin 4 District 30” (fictitious); “Timothy Goodwin for Senate – District 30” (fictitious); Goodwin for SD Senate” (fictitious); “Timothy Goodwin” (fictitious) and “Tim Goodwin” (fictitious). March 25, 2022

"AMENDED TO ADD-Fact #11 Candidate Timothy R. Goodwin used the official State Seal of South Dakota on the same campaign website where he asked for voters to “re-elect” him to the Senate. This is unauthorized use of a state symbol. (Evidence: Screen captures) "Remedy- The Secretary of State and South Dakota Attorney General must take immediate and appropriate action.

Dated May 26, 2022"