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Stewart D. Aaron
Lewis F. Tesser
Susan J. Walsh
Immediate Past President
James B. Kobak, Jr
October 27, 2011
BY FAX AND MAIL
Hon. Amy M. Loprest
New York City Campaign Finance Board
40 Rector Street (7th fl)
New York, NY 10006
Re: Proposed Independent Expenditure Rules
Dear Ms. Loprest:
At its regular meeting yesterday evening the Election Law Committee voted to send this letter to you regarding the “Proposed Independent Expenditure Rules for New York City Elections.”
The proposed rules raise significant concerns under the freedom of speech guarantees of the United States and New York State Constitutions for those engaging in independent political activity. The Committee urges that the Campaign Finance Board not adopt the proposed rules until there has been further discussion of these concerns.
The views expressed in this letter are those of the Election Law Committee and do not necessarily reflect those of the New York County Lawyers’ Association.