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“People who have more money should be free to buy more cars, more homes, more vacations, and more gizmos than the rest of us. They should not be able to buy more democracy." -Bill Moyers |
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December 15, 2005 Attorney General Bill Lockyer
We're writing to request that your office investigate possible money laundering of campaign contributions and violation of California's campaign contribution limits as set forth in Proposition 34, by Brent Wilkes of Poway, California. Brent Wilkes is the owner of Wilkes Corporation and affiliated companies ADCS Inc., Group W Advisors, Group W Transportation, Perfect Wave Technologies, Pure Aqua Technologies, Archer Defense, and others. Justice Department officials and Wilkes' attorney Michael Lipman have identified Mr. Wilkes as co-conspirator #1 in the indictment against former congressman Randy Cunningham. That indictment and Cunningham's subsequent plea agreement paint a bleak picture of Brent Wilkes' regard for the law. According to Cunningham, prosecutors, and the documentation produced, Wilkes bribed a sitting congressman to obtain millions of dollars worth of government contracts. These bribes took multiple forms according to the indictment, including two checks for $100,000 that Cunningham deposited in his personal account, a $525,000 payment to a third party to pay off the mortgage on Cunningham's home, and $11,116.50 to a different third party to pay off a portion of the mortgage on Cunningham's boat. In addition to the more than $600,000 in bribes, Wilkes also sought influence with elected officials through campaign contributions from himself, his companies, his employees, and their political action committees. In the last five years, these contributions have totaled at least $185,855 at the state level alone, the vast majority of which has gone to California candidates. At the federal level, the contributions total upwards of half a million dollars more. An analysis of these campaign contributions to a number of California and federal candidates suggests the strong possibility that Wilkes laundered contributions through his employees or coerced his employees into making political contributions. On numerous occasions, Wilkes and/or his employees made the same contribution to the same candidate on the same day, including: - On June 26, 2003, Brent Wilkes and seven of
his employees (Steven Nelson, Jeffrey Wilkes, Marilyn Wilkes,
Regina Wilkes, Melissa Dollaghan, Joel Combs, Max Gelwix) each
contributed $2,000 to presidential candidate George Bush. The combined contributions to each of these candidates exceeds the relevant legal limit for contributions from one individual. Other candidates who have received contributions from multiple Wilkes employees include Charlene Zettel, 2002 candidate for California's 36th Senate District; Richard Riordan, 2002 candidate for governor; Greg Stein, 2002 candidate for the 75th California Assembly District; Kevin McCarthy, 2002 candidate for the 32nd California Assembly District; and Mark Wyland, 2002 candidate for the 74th California Assembly District. Mr. Wilkes did not limit his efforts to procure government contracts to the federal government. His company ADCS has bid on two contracts for document conversion for the state of California, and is eligible for additional contracts. Additional facts suggest possible money laundering or coercion: -From April 2002 to October 2003, Wilkes' employee Max Gelwix made at least $45,000 in contributions to the same candidates and committees as his boss. These contributions include $5,000 to California gubernatorial candidate Arnold Schwarzenegger on September 9, 3003, the same day Brent Wilkes contributed $21,200 - the legal limit - to Schwarzenegger. Three weeks later, Gelwix made an additional $5,000 contribution to Schwarzenegger. Prior to his employment by Wilkes, Gelwix had not made a single contribution at the federal level, nor any contribution at the state level that we can find. These facts raise the strong possibility that Mr. Wilkes paid Max Gelwix to make the contributions, forced Gelwix to make contributions, or reimbursed Gelwix for his contributions. -The pattern of campaign contributions above is very similar to a scheme currently being investigated by the Justice Department and state officials in Ohio. In that case, Tom Noe allegedly funneled campaign contributions to federal and state officials, including the campaigns of President Bush and four justices of the Ohio Supreme Court, through intermediaries in order to evade the relevant campaign contribution limits. Both Wilkes and Noe are Bush Pioneers, a designation which denotes that a person successfully raised more than $100,000 for President Bush's campaign. Being a Bush Pioneer offers exclusive perks to those few who achieve that status, including a great deal of access to both the Administration and to various high-level political officials around the country. The contributions allegedly funneled by Noe did not in and of themselves raise suspicions, but when authorities began to investigate Mr. Noe's actions related to other charges, the scheme was uncovered. Such may also be the case with Mr. Wilkes. In sum, we believe that the facts surrounding the political contributions made by Mr. Wilkes, his companies and employees strongly suggest the possibility that Mr. Wilkes either laundered campaign contributions through his employees or coerced them into making those campaign contributions. We ask you and your office to investigate this matter promptly, or, if your office is not the appropriate jurisdiction, we ask you to forward this letter along to the appropriate authorities.
Respectfully,
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