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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF 
September 2016 Grand Jury
UNITED STATES OF AMERICA, Case NoPlaintiff, 
InnizcrnEnT I
Title 18, U.S.C., Sec_. 371 ConS?Iiracy?to
DUNCAN HUNTER 1), CommIt Offenses Title 18, US. .,
MARGARET E, (2), Sec. 1343 ?W1re Fraud; TItle 18, U.S.C.,

if? 15521ii?sFEISigca??E?bi536??
Ite ecs. an
Defendants- 30114 Prohibited Use of Cam ai?i 

ContrI ut10nS' Title 18 U.S.C., Sec. 3 
Bank Fraud; Title 18, U.S.C., Sec. 2 
Aiding and Abetting

 

 

The grand jury charges at all times relevant herein:

The Integrity of the Electoral Process

1. United States citizens have a right to choose their political representatives
through free and fair elections. To ensure the integrity, accountability, and transparency of
federal elections, Congress enacted a series of laws governing campaign fundraising and
spending. Among other things, these laws strictly-regulate the use ?of funds donated to
candidates for federal of?ce, and require public disclosure of the use of those funds.

2. Campaign funds raised by candidates and Members of Congress are largely
restricted to supporting the candidate?s election (or reelection) efforts and duties in of?ce,
and cannot be used for their own or their family?s personal use or enjoyment. This
restriction helps prevent donors from enercising undue in?uence over candidates and

federal of?ceholders.

Diego 8/21/18

 






p?a

 

 

3. The prohibition against personal use of campaign funds prohibits the
disbursement of campaign funds for any expense that would exist irrespective of a
candidate?s election campaign or duties as a holderof federal of?ce. Among other such
personal expenses, candidates and Members of Congress are explicitly prohibited from
spending campaign funds on clothing, vacations, household food items, school tuition,
utilities, payments to recreational facilities, and entertainment not associated with the
election campaign. 

4. Federal law also requires regular disclosure of the receipt and disbursement of
campaign funds. Speci?cally, candidates for election (or re?election) to the US. House of
Representatives must periodically ?le public reports with the Federal Election Commission
that disclose, among other things, the total amount of their disbursements, as well
as the recipient and purpose of any expenditure totaling more than $200 (in aggregate)
during any two-year election cycle. These reports provide citizens with a record of the
expenditure of campaign funds, provide donors with a measure of accountability with
regard to the use of funds, and assist voters in making informed decisions at the polls.

5. The FEC is an independent regulatory agency of the United States whose
purpose is to enforce campaign ?nance laws in United States federal elections. Among other
things, the FEC along with the Federal Bureau of Investigation an agency of the
United States is responsible for investigating the potential impr0per use of campaign funds
by candidates for elected of?ce and Members of Congress.

Hunter Campaign Committee

6. On April 1, 2007, Defendant DUNCAN HUNTER established the Duncan D.
Hunter for Congress campaign committee (the ?Campaign?) to fund a campaign to seek the
congressional seat held by his father. At all times relevant herein, DUNCAN HUNTER
exercised authority and control over the hiring of staff for his Campaign as well as for the
expenditure ?of funds on its behalf, including through Campaign debit cards, credit cards,

and reimbursements for ?mds expended on behalf of the Campaign.

 






 

 

7. According to the Campaign?s 2007 Statement of Organization 
Form the Campaign?s original mailing address was a Post Of?ce Box in La Mesa,
California. By the end of 2008, the Campaign had established a headquarters at 9340 Fuerte
Drive, Suite 302, La Mesa, California. This headquarters was closed at the end of December

2012. At that time, a new mailing address was established at a Post Of?ce Box in El Cajon,

California.
8. Beginning in or around April 2007, the Campaign maintained an operating

bank account at North Island Credit Union in San Diego, California. On or about

February 4, 2013, the Campaign moved its operating account to the Chain Bridge Bank in

McLean, Virginia.

9. The Campaign employed a small staff (both paid and volunteer) including at
various times a Treasurer, a Fundraiser, and a Manager. Among other duties, the Treasurer
prepared ?nancial reports relating to the Campaign?s receipts and disbursements; and, with
DUNCAN HUNTER?s?authorization, ?led those reports publicly with the FEC as required.
The Treasurer also processed requests for reimbursement when a representative of the
Campaign spent personal funds for Campaign activity.

10. In addition to his Campaign staff, DUNCAN Chief of Staff in
Washington, DC. contributed to his re-election campaigns on a volunteer basis by, among
other things, helping to monitor fundraising and campaign spending. The Chief of Staff
also assisted with coordinating, DUNCAN campaign activities. I

Defendants

1. On June 3, 2008, DUNCAN HUNTER won the Republican primary to replace
his father, former ?Congressman Duncan L. Hunter, who at the time represented California? 
52nd congressional district. On November 4, 2008, DUNCAN HUNTER was elected to
Congress in the general election. He was re-elected to the same seat in 2010. As a result
of redistricting, he ran in 2012 for re?election in the neighboring 50th congressional district.

He was elected to the new seat in 2012 and re?elected in 2014 and 2016.

 






 

 

12. Defendant MARGARET HUNTER married Defendant DUNCAN HUNTER
in 1998. ?According to the Campaign?s published spending reports, MARGARET
HUNTER served as a campaign consultant on DUNCAN congressional
campaigns. Between 2010 and 2017, the Committee reported paying MARGARET

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HUNTER $116,000 for ?management services,? ?consulting,? and ?salary. During this
time, DUNCAN HUNTER also gave MARGARET HUNTER access to Campaign funds
through Campaign debit cards, credit cards, and reimbursements for funds expended on
behalf of the Campaign.
Other Individuals

13. Between 2010 and 2017, DUNCAN HUNTER and MARGARET HUNTER
(referred to collectively as ?the had personal relationships with the following
individuals:

1) i ?Individual and his Wife ?Individual were close friends with
both DUNCAN HUNTER and MARGARET HUNTER. They lived in Southern California.
In addition to socializing together as couples, DUNCAN HUNTER played golf regularly
with Individual 1A.

2) ?Individual and his wife ?Individual lived in the Washington,
DC. area and became close friends with the HUNTERS in 2013. DUNCAN HUNTER
regularly socialized with Individuals 2A and 2B at their home, at other locations around
Washington DC, in California, and on occasional trips out of town (including to visit the
HUNTERS in San Diego).

3) ?Individual became friends with DUNCAN HUNTER in around .
2008. He lived with his wife ?Individual in the Southeast. Individuals 3A and 3B
vacationed with the HUNTERS in 2011. I

4) ?Individual lived in the San Diego area and was a longtime friend

of DUNCAN HUNTER. In addition to playing golf together, Individual 4A and DUNCAN

HUNTER socialized as couples with MARGARET HUNTER and Individual 4A?s wife,

?Individual 

 






 

 

5) ?Individual 5? was a friend of DUNCAN from childhood.
He lived in the Washington, DC. area and socialized with DUNCAN HUNTER at
Individual 5?s home and at other locations around Washington, DC.

6) ?Individual 6? became friends with DUNCAN HUNTER in 2016.
Although he did not live in the Washington, DC. area, he visited occasionally and would
socialize with DUNCAN HUNTER and their mutual friends in Washington DC. They also
vacationed together at Individual 6?s home in the Northeast, in California, and elsewhere.

7) ?Individual 7? lived in the San Diego area and became close friends with
MARGARET HUNTER in around 2015. She and MARGARET HUNTER socialized
together in the San Diego area and occasionally on family trips out of town.

8). ?Individual 8? was a childhood friend of DUNCAN brother.
He lived in the Washington, DC. area.

9) ?Individual 9? lived in the San Diego area and was a close family friend
of DUNCAN HUNTER and DUNCAN father. In addition to working for the
Congressional Of?ce, Individual 9 socialized with DUNCAN HUNTER and his family
regularly, often over golf.

10) ?Individual 10? met DUNCAN HUNTER in around 2002 and they
remained friends for many years. Although Individual 10 did not live in the San Diego area,
he visited occasionally and would socialize with DUNCAN HUNTER over golf.

11) ?Individual 11? lived in the San Diego area and was friends with
DUNCAN HUNTER. Among other things, they played golf together on occasion.
12) ?Individual 12? lived in the San Diego area and was friends with

DUNCAN HUNTER. They played golf occasionally with mutual friends, including

Individual 1A. Later, Individual 12 began working with DUNCAN HUNTER.

13) ?Individual 13? lived in the San Diego area. He became friends with
DUNCAN HUNTER and they played golf together on occasion.

 



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14) ?Individual 14,? ?Individual 15,? ?Individual 16,? ?Individual 17,? and
?Individual 18? lived in the Washington, DC. area and had personal relationships with
DUNCAN HUNTER. In addition, Individual 16 worked with DUNCAN HUNTER. 

15) ?Congressman ?Congressman and ?Congressman were
personal friends with DUNCAN HUNTER.
Financial Background

 

14. Throughout the relevant period, Defendants DUNCAN HUNTER and
MARGARET HUNTER maintained both a joint checking and joint savings account. The
checking account was used as their primary bank account for paying virtually all family
bills (?the HUNTER family bank account?). The HUNTERS rarely used the joint savings
account and maintained a minimal balance in that account. DUNCAN HUNTER
maintained separate personal checking and savings accounts into which he made small
deposits for his own personal use personal bank accounts?).

15. As re?ected in his US. House of Representatives Annual Financial Disclosure
Statements, DUNCAN HUNTER had less than $1,000 in reportable assets for each of the
years 2009 through 2016. . 

16. Throughout the relevant period, the HUNTERS Spent substantially more than
they earned. They overdrew their bank account more than 1,100 times in a seven-year
period resulting in approximately $37,761 in ?overdraft? and ?insuf?cient funds? bank fees.
Their credit cards were frequently charged to the credit limit, often with ?ve-?gure
balances, resulting in approximately $24,600 in ?nance charges, interest, and other fees
related to late, over the limit, and returned payment fees.

I 17. By virtue of these delinquencies as well as noti?cations of outstanding debts
and overdue payments from their children?s school, their family dentist, and other creditors
the HUNTERS knew that many of their desired purchases could only be made by using
Campaign funds. 

 

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Count 1: Conspiracy
(18 USC 371)

18. . Paragraphs 1 through 17 of this Indictment are realleged and incorporated
herein by reference.

19. Beginning as early as December 2009 and continuing up to and including at 
least the end of 2016, within the Southern District of California and elsewhere, Defendants
DUNCAN D. HUNTER and MARGARET E. HUNTER knowingly conspired with each
other to commit offenses against the United States, to wit:

1) To knowingly and willfully convert Campaign funds to personal use by
using them to ful?ll personal commitments, obligations, and expenses that would have
existed irrespective of DUNCAN election campaign and duties as a federal
Of?ceholder, in amounts of $25,000 and more in a calendar year, in violation of Title 52,
United States Code, Section 30109(d) and 30114Cb);

2) To knowingly and with intent to defraud devise. and execute a material
scheme to defraud the Campaign, and to obtain money and property, by means of materially
false and fraudulent pretenses, representations and promises, and by intentional
concealment of material facts, and to cause interstate wire transmissions in furtherance
thereof, in violation of Title 18, United States Code, Section 1343;

To knowingly conceal, cover up, falsify, and make a false entry in a
record and document that is, an of?cial FEC ?ling with the intent to impede, obstruct,
and in?uence the investigation and proper administration of a matter within the jurisdiction
of an agency of the United States that isviolation of Title 18,
United States Code, Section 15-19; and

4) To knowingly and with intent to defraud devise and execute a material

scheme to defraud a ?nancial institution, and to obtain any of the money and funds owned

by and under the custody and control of a ?nancial institution by means of materially false
and fraudulent pretenses, representations and promises, and by intentional concealment of

material facts, in violation of Title 18, United States Code, Section 1344. 

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Goal of the Conspiracy
20. The goal of the conspiracy was for DUNCAN HUNTER and MARGARET

HUNTER to enrich themselves, and others at their direction, by converting Campaign funds
for their own personal bene?t and enjoyment, and for the personal bene?t of others with
whom the HUNTERS had personal relationships.
Manner and Means of the Conspiracv
21. In ?lrtherance of their conspiracy, and to effect its objects, Defendants
DUNCAN HUNTER and MARGARET HUNTER used the following manner and means,
among others:

1) The HUNTERS illegally converted and stole more than $250,000 in
Campaign ?lnds to purchase goods and services for their personal use and enjoyment.

2) DUNCAN HUNTER facilitated the theft of Campaign
funds by directing his Treasurer to obtain a Campaign credit card for MARGARET
at a time when she had no of?cial role with the Campaign and received no of?cial
that she would spend Campaign funds for the HUNTERS personal bene?t.

3) DUNCAN HUNTER installed MARGARET HUNTER as his paid
Campaign Manager despite the protests of his Treasurer and with full knowledge of her
long history of misuse of campaign funds, in part because as they discussed the
HUNTERS ?need[ed] the extra money? that would come from her salary.

4) The HUNTERS disregarded rules implemented by the Treasurer to track
legitimate expenses (such as not purchasing gas using Campaign funds, withdrawing cash
from ATMs, using ?petty cash? without keeping a proper record of how it was spent, and
failing to provide receipts which listed the names of donors and volunteers with whom
MARGARET HUNTER claimed to be spending Campaign funds), and, when pressed by
the Treasurer to comply, dismissed the rules as ?silly.?

i 5) DUNCAN HUNTER facilitated the theft of Campaign
funds by ignoring his Campaign staffs multiple warnings about MARGARET 
improper use of Campaign funds, accusing Campaign staff of disloyalty by ?trying to create

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some kind of paper trail on me? when they raised concerns about improper spending, and
continually refusing to remove her access to Campaign funds.

6) MARGARET HUNTER concealed and disguised the personal nature of
many of her campaign expenditures by re?isin'g to allow the Campaign Fundraiser to review
her credit Card statements and spending.

7) The HUNTERS concealed and disguised the personal nature of many of
their campaign expenditures by either falsely stating the expenses were ?campaign related?
or by falsely reporting the item or service purchased when providing information to the
Treasurer (by, for example, buying personal clothing items at a golf course so that the
purchase could be falsely reported to the Treasurer as ?balls for the wounded warriors?).

8) MARGARET HUNTER concealed and disguised her family?s use of
Campaign ?inds for personal vacations by reserving hotels and paying other personal
vacation expenses through Expedia, with the expectation that Campaign records would not
reveal the names or locations of their destinations.

9) DUNCAN HUNTER belatedly attempted to arrange supposed.
Campaign?related meetings during family vacations to conceal and disguise the fact that the
HUNTERS were using Campaign funds for personal family vacations.

10) The HUNTERS concealed and disguised the personal nature of their
family?s purchases of video games using Campaign funds by falsely claiming to a fmancial
institution that the payments were fraudulent charges and then reporting the purchases to
the EC and the public as fraudulent charges. . 

11) The HUNTERS discussed how much money was in their family bank
accounts in order to determine when it was necessary to purchase certain goods and services
with Campaign funds and to withdraw cash from Campaign accounts (discussing, for

example, that they withdrew ?petty cash all the time with [the former Treasurer] it was

great?).

 






 

 

12) The HUNTERS monitored the amount of ?cash on hand? that was
maintained by the Campaign, and would moderate their theft of Campaign funds when the
account was excessively low or depleted. 

13) . DUNCAN HUNTER facilitated the theft of Campaign
funds by giving MARGARET HUNTER his Campaign credit and'debit cards so that she
could use them to purchase a wide variety of family groceries, household items, and
personal gifts. 

I 14) The HUNTERS concealed and disguised the personal nature of many of
their Campaign expenditures by attempting to have the Campaign?s name taken off the
of?cial Campaign credit cards.

15) . The HUNTERS illegally used Campaign funds, among other things, to
purchase the following: 

Hotel rooms, airline tickets and upgrades, meals and food, and
entertainment expenses for vacations for themselves and their friends and family, including
more than $14,000 for a family Thanksgiving vacation in Italy in November 2015; more
than $6,500 for a family vacation to Hawaii in April 2015; more than $3,700 for a family
vacation to Las Vegas and Boise in July 2015; more than $2,400 for a Las Vegas couples?
vacation in August 2011; and more vacations to destinations such as Lake Tahoe,
Pittsburgh, London, and Washington 

(ii) Food and drinks for themselves and their friends and family at various
restaurants such as Mister A?s, the Capital Grille, Bellagio?Olives, Spago, Caesars Mesa
Grill, Sally?s Fish House Bar, Blue Point Coastal,?Island Prime, Harney Sushi, Lou 
Mickey?s, Del-Frisco?s Double Eagle Steak House, Jake?s Del Mar, the Studio. at the
Montage, and Sonoma Restaurant;

Household and other personal items for their family from a wide variety

of stores, such as Costco (where they spent more than $1 1,300 in Campaign funds), Walmart

(where they spent more than $5,700), Barnes Noble (where they spent more than $2,500), 
Target (where they spent more than $2,300), Michaels craft store (where they spent more

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than $2,200), and other retailers such as Aaron Brothers, Party City, World Market, Crate
Barrel, Pier 1, Penny, Sears, and Rite Aid;

(iv) Beer, wine, alcohol and groceries for themselves, their family, and
friends at. various stores, including more than $9,000 spent at Vons, Albertsons, Haggen,
and the Miramar Commissary;

Food for themselves and their children at various fast food restaurants,
including more than $3,300 spent at In Out, Carl?s Jr., Jack in the Box, Wendy?s,
McDonalds, Burger King, Taco Bell, La Salsa, Pizza Hut, Rubio?s, Domino?s Pizza,
Panda Express, Kentucky Fried Chicken, and Menchies Frozen Yogurt; -

(vi) Tobacco, personal items, and various sundries at airports kiosks and
convenience stores; and

(vii) Airline tickets and hotel rooms totaling more than $15,000 for, among
others, their children, otherrelatives, family friends, and a family pet.

16) The HUNTERS agreed to repay the Campaign for their malversation
only when, and if: the Treasurer inquired further or insisted on repayment; (ii) repayment
would avoid attention where the personal nature of the purchase was evident from ?nancial
records; the FEC highlighted what appeared to be the ?personal use of campaign funds?
and warned DUNCAN HUNTER that-it might ?consider taking further legal action;? or
(iv) the news media or DUNCAN constituents requested explanations for
expenditures that appeared to be personal on their face.

Overt Acts
22. In furtherance of the conspiracy and to effect its objects, the following overt
acts, among others, were committed on the below listed approximate dates (with all amounts
below being approximate) within the Southern District of California and elsewhere:

1) In or around late 2009, DUNCAN HUNTER requested that his

Treasurer obtain Campaign credit cards for himself and MARGARET HUNTER, to which

the Treasurer explained that these credit cards could only be used for campaign?related

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expenses, not personal expenses that would exist irrespective of DUNCAN 
campaign or office. .

2) On or about January 22 to 25, 2010, in Reno, Nevada, DUNCAN
HUNTER spent $351.04 in Campaign funds at Alamo Rent A Car so that he could drive
from Reno, Nevada to Lake Tahoe for a personal ski trip with Individual 14.

3) On or about January 25, 2010, in Incline Village, Nevada, DUNCAN
HUNTER spent $1,008.72 in Campaign?funds at the Hyatt Regency Lake Tahoe Resort,
Spa and Casino for food, drinks, and three nights lodging during a personal ski trip with
Individual 14. On this day, the HUNTER family bank account had a negative balance and
incurred six separate insuf?cient funds fees (totaling $198). Also on this same day,
DUNCAN HUNTER withdrew $20 from his personal bank account, leaving a balance of
$15.02.

4) On or about March 22, 2010, in La Mesa, California, MARGARET
HUNTER spent $85.18 in Campaign funds at Barnes Noble to purchase various

. children?s books and puzzles one of 22 separate occasions that MARGARET HUNTER

spent a total of $2,569.96 in Campaign funds at Barnes Noble primarily to purchase items
for her family and friends. In order to conceal and disguise the illegal use of Campaign
funds for personal expenses, MARGARET HUNTER falsely told the Treasurer that the
March 22, 2010 charge was for ?booklets on San Diego.?

5) On or about March 24, 2010, in Alexandria, Virginia, DUNCAN
HUNTER spent $121.34 in Campaign ?mds at the Birchmere Music Hall for food and beer
while attending a concert with Individual 14, Congressman A, and Congressman A?s date.

6) On or about March 31, 2010, in La Quinta, California, the HUNTERS
spent 1 81.12 in Campaign funds at the La Quinta Resort to reserve a room for the wedding
of their friends, Individuals 1A and 1B.

7) In or around March?April 2010, DUNCAN HUNTER met with his
Treasurer to discuss concerns that MARGARET use of the Campaign card

could be a serious problem. At the meeting, the Treasurer suggested that her credit card be

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taken away. DUNCAN HUNTER acknowledged thather use of the Campaign card could
be a serious problem, but declined to take it away.

8) On or about April 2, 2010, DUNCAN HUNTER claimed a $257.40
reimbursement from Campaign funds for driving his car on a 468?mile trip to Virginia
Beach with Individual 14, Congressman A, and Congressman A?s date despite the fact that
they did not use DUNCAN car on the trip.

9) On or about April 26, 2010, in El Cajon, California, MARGARET
HUNTER spent $64.72 in Campaign ?lnds at Albertsons one of 45 occasions between
2010 and 2016 that MARGARET HUNTER and DUNCAN HUNTER spent a total of
$6,312.81 in Campaign funds at Albertsons and Haggen Food Pharmacy primarily to
purchase groceries and other household items for the HUNTER family.

10) [On or about April 28, 2010, MARGARET HUNTER spent $226.40 in
Campaign funds at American Airlines to purchase an airline ticket for her sister.

11) On or about May 19, 2010, in Santee, California, MARGARET
HUNTER spent $307.72 in Campaign funds at Target to purchase a tablecloth, three square
pillows, ia three?piece brush set, a metal tray, four temporary shades, four window panels, a
white duck, two Punky Brewster items, a ring pop, and two ?ve?packs of ?animals.? In
order to conceal and disguise this illegal charge, HUNTER falsely told the
Treasurer that it was for ?teacher/parent supporter events.?

12) On or about May 20, 2010, in El Cajon, California, MARGARET
HUNTER spent $80 in Campaign funds at Shell Oil one of 155 different occasions
between 2010 and 2016 that MARGARET HUNTER spent a total of $8,181.57 in
Campaign funds at various gas stations in the San Diego area after she was informed by the
Treasurer that it was impermissible to charge gas directly to the Campaign.

13) On or about June 24, 2010, in Alexandria, Virginia, DUNCAN
HUNTER spent $41.75 in Campaign funds at 7+E1even to purchase personal items while

also withdrawing $20 in cash from his savings account using an ATM at the 7-Eleven,

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leaving an account balance of $0.06. On this day, the HUNTER family bank account had
a negative balance and incurred an insuf?cient funds fee.

14) On or about August 21, 2010, in Alpine, California, DUNCAN
HUNTER spent $32.31 in Campaign funds at Albertsons to purchase family groceries and
personal items, including milk, apples, beer, chewing tobacco, and a pack of cigarettes.

15) On or about August 28, 2010, in San Diego, California, DUNCAN
HUNTER spent $41.04 in Campaign funds to buy a video game at the Apple Store on the
same day he used Campaign funds to purchase a $1,199 iMac computer.

16) I On or about September 13, 2010, in San Diego, California, DUNCAN
HUNTER spent $164.29 in Campaign funds for, among other things, a round of golf and
beer at Riverwalk Golf Club with Individual 1A. When asked by the Treasurer if this
expenditure (among several others) was campaign related, DUNCAN HUNTER falsely
responded, ?Yessir- All good.?

17) On or about September 27, 2010, in San Diego, California,
MARGARET HUNTER spent $155.96 in Campaign funds at the Miramar Commissary to
purchase groceries for the HUNTER family. To conceal and disguise this illegal charge,
MARGARET HUNTER falsely informed the Treasurer that it was for ?misc. items and
docor [sic] for school-related and campaign events.?

18) In or around November 2010, DUNCAN HUNTER discussed with the
Treasurer and the Campaign Fundraiser the idea of hiring MARGARET HUNTER as the
paid Campaign Manager, but relented when the Treasurer made it clear that this would not
be a good idea.

19) On or about November 6, 2010, in San Diego, California, MARGARET
HUNTER spent $704 in Campaign ?mds at the Old Globe Theatre for seven adult and ?ve
children?s tickets to the play, ?How the Grinch Stole Christmas.? MARGARET HUNTER
later falsely described this purchase to the Treasurer as being for ?holiday gift certi?cates.?

20) On or, about November 18, 2010, DUNCAN HUNTER discussed with
the Treasurer questionable charges by MARGARET HUNTER that had been of continuing

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concern to the Treasurer; most recently, the Old Globe tickets. In order to lower suspicions
and reduce the risk of detection, DUNCAN HUNTER decided that they would use personal
funds to repay the Campaign for MARGARET purchase.

21) On or about November 19 to 22, 2010, in Pittsburgh, and
elsewhere, the HUNTERS spent $1,912.66 in Campaign funds as a birthday gift for a family
member to attend a Pittsburgh Steelers game at Heinzr Field at the invitation of Congressman
B. To conceal and disguise these illegal personal charges, the HUNTERS failed to inform
the Treasurer that they were for a football game or that a family member was one of the
attendees. When asked if the charges were campaign related, DUNCAN HUNTER falsely
confirmed, ?Yessir.? A

22) On or about December 10, 2010, in response to an email from his
Treasurer questioning a variety of charges and noting that Campaign money could not be 7
used ?for a leisure outing at which the discussion occasionally focuses on the campaign,?
DUNCAN HUNTER asked the Treasurer if he was ?trying to create some kind of paper
trail? on him.

23) On or about December 22, 2010, after the Treasurer again warned the
HUNTERS that ?campaign funds may not be used for a leisure outing? even if campaign
business is occasionally discussed, MARGARET HUNTER told the Treasurer that she

refused to provide the names of individuals she allegedly. took out for meals with Campaign

?mds because ?that?s silly.?

24) In or around late December 2010, after the Treasurer stated that he might
resign, DUNCAN HUNTER agreed to ensure that MARGARET HUNTER would not use
her Campaign credit card and he would get her to put it away in a safe place.

25) - . On or about February 5, 2011-, in San Diego and El Cajon, California,
on a date DUNCAN calendar indicated-a 7:00 am appointment for ?Personal 
Cottonwood,? DUNCAN HUNTER spent $169.24 in Campaign funds for golf at

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Cottonwood Golf Club at 6:51 am, and for a later meal at Hamey Sushi, both with

Individual 1A.

26) On or about March 15, 2011, DUNCAN HUNTER, when asked by his
Treasurer to con?rm that his credit card charges for the prior month were all Campaign-
related, responded, ?Of course they are all campaign. Why else would I charge them to the
campaign card.?

27) On or about May 17, 2011, the HUNTERS spent $103.57 in Campaign
funds to reserve a room at the Treasure Island hotel in Las Vegas, Nevada, for an upcoming
vacation with their friends, Individuals 3A and 3B.

28) On or about May 26, 2011, MARGARET HUNTER requested that the
Treasurer order her a new Campaign credit card.

?29) Beginning in about'June 2011 and continuing throughout the year, in
San Diego and elsewhere, after being informed by his Treasurer that MARGARET
HUNTER was making problematic purchases (including at grocery stores and various retail
stores), DUNCAN HUNTER allowed her to continue to use the Campaign card.

30) On or about June 9, 2011, in El Cajon, California, DUNCAN HUNTER
spent $164.63 in Campaign funds at Best Buy to purchase an iPod Nano.

31) On or about June 11, 2011, in San Diego, California, DUNCAN
HUNTER spent $110.63 in Campaign funds at the Riverwalk Golf Club to buy beer and
play golf with friends, including Individual 1A.

32) On or about June 17,2011 in La Mesa, California, DUNCAN HUNTER
spent $142.36 in Campaign funds at the Men?s Wearhouse to? ??re-cut two pairs of pants.
When this-charge was uncovered by the Treasurer, DUNCAN HUNTER falsely explained
the charge: ?Lol. Men?s warehouse was a possible semi-embarrassment that I had to let ride.
I used the wrong card, then didn?t want to explain the forced refund . . . 

33) On or about June 21, 2011, in Washington, DC, DUNCAN HUNTER
spent $162.02 in Campaign funds for a personal stay at the Liaison Capitol Hill hotel with
Individual 14. 

l6

 



about June 29, 2011, in Woodbridge, Virginia, DUNCAN
HUNTER spent $253.56 in Campaign funds for greens fees and beer at Old Hickory Golf
Club to play golf with Individual l4 and purchase clothing.

35) On or about July 3, 2011, in El Caj on, California, DUNCAN HUNTER
spent $90 in Campaign funds to play golf at Cottonwood Golf Club with Individual 1A 
one of 24 occasions between 2010 and 2016 that DUNCAN HUNTER spent a total of
$881.60 in Campaign funds at Cottonwood Golf Club for greens fees, food, and drinks
while gol?ng with family (including his father and minor children) and friends (including
Individual 1A and Individual 9).

36) On or about July- 3, 2011, in San Diego, California, DUNCAN

HUNTER spent $148.90 in Campaign funds at Sally?s Fish House and Bar to pay his half

of the bill during a personal dinner with Individuals 1A and 1B and MARGARET
HUNTER.

37) On or about July 13, 2011, in Washington, DC, MARGARET
HUNTER spent $65.19 in Campaign funds at the International Spy Museum for gifts for
the HUNTER family.

38) On or about July 24, 2011, in Del Mar, California, the HUNTERS spent
$102 in Campaign funds to purchase tickets to the Del Mar Racetrack for the following
month for a day at the races with Individuals 1A and 1B. 

39) On or about August 6 to 10, 201 1, in Las Vegas, Nevada and elsewhere,
the HUNTERS spent $2,448.27 in Campaign ?mds on a personal vacation with Individuals
3A and 3B. During this vacation, the HUNTER family bank account began incurring
insuf?cient funds fees until a check from DUNCAN parents was deposited into
the account on August 10. To conceal and disguise these illegal charges, DUNCAN
HUNTER falsely informed his Treasurer that all the charges related to this trip were
?campaign related.? Similarly, MARGARET HUNTER misled the Treasurer by describing

that the Las Vegas charges were for ?couple meals.?

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40) On or about August 18, 2011, the HUNTERS spent $1,419 in Campaign
funds ?at Southwest Airlines to purchase ?ve roundtrip tickets to Boise, Idaho for a family
vacation. To conceal and disguise these illegal charges, DUNCAN HUNTER falsely
informed his Treasurer'that these charges were ?campaign related.?

41) On or about August 20, 2011, in Del Mar, California, DUNCAN
HUNTER spent $113.73 in Campaign funds at Jake?s Del Mar to split a $227.45 tab during
a personal dinner with Individuals 1A and 1B. To conceal and disguise this illegal charge,
DUNCAN HUNTER falsely informed his Treasurer that it was ?campaign related.?

42) On or about August 21, 2011, in Del Mar, California, DUNCAN
HUNTER spent $156.22 in Campaign funds at Del Mar Racetrack to purchase food and
drinks during a day at the races with Individuals 1A and 1B. To conceal and disguise this
illegal charge, DUNCAN HUNTER falsely informed his Treasurer that it was ?campaign
related.?

- 43) On or about August 28, 2011, in Coronado, California, the HUNTERS
spent $511.03 in Campaign funds at the Hotel del Coronado for a family celebration. To
conceal and disguise these personal charges, DUNCAN HUNTER falsely informed his
Treasurer that all the charges Were ?campaign related.?

44) On or about September 5, 2011, in El Cajon, California, DUNCAN
HUNTER spent $399.06 in Campaign funds at Best Buy to purchase a Nikon CoolPix
S9100 digital camera, plus battery and SD card, which he used to photograph his upcoming
family vacation to Idaho and other events. To conceal and disguise this illegal transaction,
he falsely informed his Treasurer that the charge was for ink, paper, and computer software.

45) On or about September 12, 2011, despite opposition by his Treasurer
and individuals in his Washington, DC. of?ce, DUNCAN HUNTER hired MARGARET
HUNTER as his ?Campaign Manager? at a salary of $2,000 per month.

46) On or about September 16 to 19, 2011, in Boise, Idaho and elsewhere,
the HUNTERS spent an additional $640.05 in Campaign funds for a family vacation

centered on a family member?s participation in a dance competition.

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00

 

 

47) On or about October 22 to 24, 2011, in Los Angeles, California and
elsewhere, the HUNTERS spent $432.81 in Campaign funds for a family vacation centered
on a family member?s participation in a dance competition.

48) On or about October 24, 2011, in San Diego, California, DUNCAN
HUNTER spent $344.56 in Campaign funds at Enterprise Rent-A?Car to rent a vehicle so
that he could drive from Los Angeles International Airport for a family member?s
dance competition in Orange COunty.

49) On or about October 28, 2011, in and around Washington, DC, the
HUNTERS spent $3,754.73 in- Campaign funds for a family vacation in which the
HUNTERS ran the Marine Corps Marathon (10K course) and took their family to a fall
festival. DUNCAN HUNTER falsely informed his Treasurer that the charges associated
with this trip were ?all campaign? and MARGARET HUNTER added that they were
?during a trip to do. Meals mostly.? 

50) ,On November 16, 2011, in La Mesa, California, MARGARET
HUNTER spent $25 in Campaign funds at Vons to purchase prescription medication. To
conceal and disguise the illegal transaction, she falsely told the Treasurer that she ?[b]ought
Target gift card donation to church family.? She later changed her story and falsely claimed
the charge was for ?Applebee?s Restaurant Republican Women.? I

51) On or about November 19, 201 1, in Anaheim, California and elsewhere,
the HUNTERS spent $168.89 in Campaign funds to watch a family member compete at a
dance competition. I

52) On or about December 17, 2011, after the Treasurer reminded
DUNCAN HUNTER and MARGARET HUNTER that it was impermissible ?m mix
personal and Campaign expenses on the Amex card? speci?cally referencing charges
made at Barnes Noble, Michaels craft store, the Disney Store, Vons, Walmart, and World
Market the HUNTERS failed to reclassify or reimburse these personal expenses.

53) On or about January 11, 2012, in La Mesa, California, MARGARET
HUNTER spent $98.05 in Campaign funds at Costco one of 29 different dates between

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2010 and 2016 that MARGARET HUNTER and DUNCAN HUNTER spent a total of
$11,375.46 in Campaign funds at Costco primarily to purchase personal items for the
HUNTER family, including groceries, household items, toiletries, cosmetics, medicine and
vitamins, clothing, pet supplies, and video games. To conceal and disguise the illegal
January 11, 2012 charge, MARGARET HUNTER falsely told the Treasurer that the
January 11 purchase was for ?gift basket items for basket donation - Temecula chamber
gala auctionabout January 12, 2012, in Alpine, California, MARGARET
HUNTER spentp$918.60 in Campaign funds at Expedia to ?y her sister and two other family
members to a funeral in Tucson. To conceal and disguise the illegal charges, she! falsely
told the Treasurer that they were for a ??ight to Baltimore for NRCC winter meeting.?

55) On or about January22, 2012, MARGARET HUNTER spent $504.20
in Campaign funds to buy a roundtrip United Airlines ticket for her mother from San Diego
to Chicago. To conceal and disguise the illegal charge, she falsely told the Treasurer that
they were for a ??ight to Baltimore for NRCC winter meeting.?

56) On or about February 8 and 16, 2012, the HUNTERS spent $306.80 in
Campaign funds at United Airlines for additional charges related to a ticket for
MARGARET mother to ?y from San Diego to Chicago. In response to whether
the charge was campaign related, DUNCAN HUNTER told his Treasurer: ?Yes sir.?

57) On or about March 16, 2012, the HUNTERS spent $36.96 in Campaign
funds at United Airlines for additional charges related to a ticket for MARGARET
mother to ?y from Warsaw, Poland to Chicago. In response to whether the
charges were campaign related, DUNCAN .HUNTER told his Treasurer: ?Yes they are.?

58) On or about March 17, 2012, in San Diego, California, the HUNTERS
spent $235.72 in Campaign funds at Blue Point Coastal and the Hyatt Andaz for food and
drinks during a St. Patrick?s Day celebration with Individuals 1A and 1B.

59) On or about May 6 to 12, 2012, in Washington, DC. and elsewhere, the
HUNTERS spent approximately $10,000 in Campaign funds to pay for a family vacation

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(which included a nephew), during which time MARGARET HUNTER attended a ?First
Ladies Lunch? at the Washington Hilton. To conceal and disguise the illegal charges,
DUNCAN HUNTER told his Treasurer that the charges were ?[a]ll campaign related.?

60) On or about May, 12, 2012, in El Cajon, California, MARGARET
HUNTER spent $323.62 in Campaign funds at Party City and Von's to purchase supplies
for a family member?s birthday party.

61) In or around June 2012, DUNCAN HUNTER Continued to authorize
MARGARET expenditure of Campaign funds, even after being informed by
his Chief of Staff iof concerns about MARGARET spending on gift cards that
she claimed were for charitable donations, restaurants, and supermarkets.

62) On or about June 9, 2012, the HUNTERS spent $1,276.80 in Campaign
funds at United Airlines to ?y MARGARET sister and two other family
members from San Diego to New Orleans. In response to whether the charges were
campaign related, DUNCAN HUNTER falsely responded, ?All campaign related.?

63) On or about June 9, 2012, in San Diego, California, DUNCAN
HUNTER spent $369.08 in Campaign funds to play golf at Riverwalk Golf Club with
Individual 1A, followed by dinner at Asti Ristoranti with MARGARET HUNTER and
Individuals 1A and 1B. To conceal and disguise this illegal activity, DUNCAN HUNTER
falsely con?rmed to his Treasurer that the charges were all ?campaign related.?

64) On or about June 24, 2012, in La Mesa, California, MARGARET
HUNTER spent $46.98 in Campaign ?mds at Safeway to purchase family groceries and
alcohol. To conceal and disguise the illegal charge, MARGARET HUNTER falsely
described it to the Treasurer as being for ??owers.?

65) On or about July 10, 2012, in San Diego, California, MARGARET
HUNTER spent $259.31 in Campaign funds to take her family to the San Diego Natural
History Museum and the Prado restaurant in Balboa Park. To conceal and disguise the
illegal charges, she falsely told the Treasurer that they were for gift basket items and a meal

with supporters.

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66) On or about July 17, 2012, in La Mesa, California, MARGARET
HUNTER spent $105.28 in Campaign funds at Olive Garden to purchase one adult and two
kids? meals. To conceal and disguise the illegal transaction, she falsely told the Treasurer
that the charge was for a ?meal with 

67) On or about July 21, 2012, in Del Mar, California, DUNCAN HUNTER
spent $59.26 in Campaign funds at the Del Mar Country Club to purchase a pair of Under
Armor sherts. At this time, the HUNTERS had a negative balance in their family bank
account and had incurred six insuf?cient funds fees, one overdraft fee, and one returned
item fee (totaling $253) during the prior six days.

68) On or about July 28 to 30, 2012, in Irvine, California and elsewhere, the
HUNTERS spent more than $445 in Campaign funds to watch a family member?s dance
competition. To conceal and disguise these illegal charges, MARGART HUNTER misled
the Treasurer by claiming that they were for 3 ?Newport [Campaign] Event.?

69) On or about August 12, 2012, in Del Mar, California, DUNCAN
HUNTER spent $310.45 in Campaign funds at the Del Mar Racetrack to purchase food and
drinks while attending the races with Individuals 1A and 1B. Although he acknowledged
to his Treasurer that the entrance tickets should be paid with personal funds, DUNCAN
HUNTER falsely asserted that the food and drink charges were all ?campaign related.?

70) On or about August 29, 2012, in El Cajon, California, MARGARET
HUNTER spent $92.13 in Campaign funds at Vons to purchase family groceries and
supplies for a family member?s birthday party one of 29 different dates between 2010 and
2015 that MARGARET HUNTER and DUNCAN HUNTER spent a total of $2,928.06 in
Campaign funds at Vons primarily to purchase groceries and other household items for the
HUNTER family. To conceal the illegal August 29, 2012 purchase, MARGARET
HUNTER misled the Treasurer by saying only that it was for a ?[Campaign] get-together
[in their] home.? 

71) On or about October 10, 2012, MARGARET HUNTER spent $541.60

in Campaign funds at United Airlines to purchase a ticket for a family member?s friend to

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travel to Washington, DC, along with the HUNTER family. DUNCAN HUNTER falsely 
con?rmed to his Treasurer that the charges were campaign related.
72) On or about October 21, 2012, in El Cajon, California, MARGARET 
HUNTER spent $28.88 in Campaign funds at Panda Express to purchase food one of 200
separate occasions between 2010 and 2016 that MARGARET HUNTER spent a total of
$5,068.34 in Campaign funds at fast food restaurants such as In Out, Carl?s Jr., Jack in
the Box, Wendy?s, McDonalds, Burger King, Taco Bell, La Salsa, Pizza Hut, Domino?s
Pizza, Kentucky Fried Chicken, and Menchies Frozen Yogurt, without
documenting a legitimate campaign purpose. To conceal and disguise the illegal
October 21, 2012 charge, she told the Treasurer that it was for a ?meal on campaign go.?
73) On or about October 30, 2012, following an article in the San Diego
Reader publicizing MARGARET salary and various expense reimbursements,
DUNCAN HUNTER relieved her of her formal duties with the Campaign. Although the
Campaign was in dire ?nancial condition, and had just canceled a pre?election mailer due
to insuf?cient ?lnds, DUNCAN HUNTER continued to pay MARGARET HUNTER a
salary from Campaign funds and allowed her to keep her Campaign credit card. I
74) On or about November 23, 2012, in Lakeside, California, DUNCAN
HUNTER spent $560 in Campaign funds to play golf at the Barona Creek Golf Resort with
his father, Individual 10, and Individual 10?s father. At this time, the HUNTER family bank
account had a negative balance and had incurred three insuf?cient ~?1nds fees and one
overdraft fee-two days previously (totaling $117). I i
75) On or about December 4, 2012, in San Diego, California, MARGARET
HUNTER spent $145.46 in Campaign funds at Bloomingdale?s to purchase cosmetics for

personal use.

76) On or about December 19, 2012, after reaSSuring the Chief of Staff in
the morning that she would rein in her campaign spending and vowing that of now, I
am done with any donation item purchases related to the campaign,? MARGARET
HUNTER spent Campaign funds at World Market ($155.66, allegedly for ?holiday basket

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gift items?) and Barnes Noble ($359.57, allegedly for ?items for multiple toy
drives/childrens hospital book drive?). 

77) On or about December 22, 2012, in La Mesa, California, MARGARET
HUNTER spent $233.34 in Campaign funds at Walmart one of 48 different dates between
2010 and 2016 that MARGARET HUNTER spent a total of $5,789.30 in Campaign funds
at Walmart primarily to purchase personal items for the HUNTER family, including
groceries, household items, gifts, cosmetics, pet supplies, and games.

78) On or about December 31, 2012, after being advised that the Campaign
could not pay its outstanding bills, DUNCAN HUNTER told his Treasurer that he would
raise $11,000 to $15,000 from Campaign donors by mid?January in order to make up for
the shortfall. He also stOpped paying MARGARET salary and took away the
Campaign credit card. A

I 79) In or around February 2013, in Washington, DC, DUNCAN HUNTER
hired a new Treasurer located in Virginia. Shortly thereafter, the new Treasurer obtained a
debit card for DUNCAN Campaign use.

80) On or about April 20, 2013, in San Diego, California, DUNCAN
HUNTER spent $219.93 in Campaign funds at Island Prime during a personal dinner with
MARGARET HUNTER and Individuals 1A and 1B. To disguise the personal nature of
this illegal charge, DUNCAN HUNTER misled his Chief of Staff by describing his friend
Individual 1A as just a ?State Farm Insurance guy? who did business with churches. . 

81) On or about June 7, 2013, in Owings Mills, Maryland, DUNCAN
HUNTER spent $302.10 in Campaign fundslat Caves Valley Golf Club to purchase a jacket
for his personal use. 

82) On or about June 17, 2013, in El Cajon, California, DUNCAN
HUNTER spent $163.53 in Campaign funds at Best Buy to purchase a pair of sports
headphones for his personal use. At this time, the HUNTER family bank account had a

negative balance and incurred three insuf?cient funds fees (totaling $102).

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83) In or around July 2013, in Washington, DC, DUNCAN HUNTER
spent a total of $36 in Campaign funds for Uber rides to the residence of Individual 15.

84) On or about July 21, 2013, in San Diego, California, DUNCAN
HUNTER spent $138.19 in Campaign funds at the Apple Store to purchase iPhone
accessories for his personal use, including a camera lens for his iPhone. To conceal and
disguise this personal charge, he told his Chief of Staff that it was a ?campaign receipt.?

85) On or about November 16, 2013, in La Mesa, California, DUNCAN
HUNTER spent $100.69 in Campaign funds at Casa De Pico to take the HUNTER family
out to dinner with Individuals 1A and 1B, before they all attended a high school football
game. To conceal and disguise the illegal charge, DUNCAN HUNTER misled his Chief of
Staff by telling her that the meal was a dinner with ?volunteers/contributors."

86) On or about November 26, 2013, in San Diego, California, DUNCAN
HUNTER spent $313.05 in Campaign funds at the Apple Store to purchase iPhone camera
lenses and other accessories for his personal use.

I 87) On or about December 12, 2013, in Washington, DC, DUNCAN
HUNTER spent $238 in Campaign ?inds at Matchbox Vintage Pizza Bistro (?Matchbox?)
to watch a San Diego Chargers football game with Individual 2A and Congressman C. On
that day, the HUNTER family bank account balance was $28.16 and MARGARET
HUNTER forwarded a low balance alert to DUNCAN HUNTER and urged him to only
?take out the 

88) On or about December 13, 2013, in Reston, Virginia, DUNCAN
HUNTER spent $63.57 in Campaign funds at Best Buy to purchase a pair of gloves and a
car charger for an upcoming trip to Pittsburgh.

89) On or about December 13 to 16, 2013, in Pittsburgh, and
elsewhere, the HUNTERS spent $2,217.34 in Campaign funds to pay for a family trip to a

. Pittsburgh Steelers football game at Heinz Field (at the invitation of Congressman B):

Although DUNCAN HUNTER arranged to have a business meeting in Pittsburgh on

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Monday, he failed to inform his Chief of Staff or his Treasurer that they were using
Campaign funds primarily for a family vaCation.

90) On or about December 30, 2013, after considering the bene?ts of
bringing more money to the household on a basis, DUNCAN
HUNTER hired MARGARET HUNTER back as Campaign Manager at a salary of $2,500
per month (although the Campaign ended up actually paying her $3,000 per month).

91) On or about December 31, 2013, MARGARET HUNTER, referring to
the new salary she was about to receive, texted DUNCAN HUNTER: ?[Y]ou need the extra
money as much as I .

92) On ?or about February 10, 2014, in Washington, DC, DUNCAN
HUNTER spent a total Of $64 in Campaign funds for drinks at Hill Country BBQ and an
Uber ride while socializing with Individual 15.

93) On or about February 14, 2014, in La -Jolla, California, DUNCAN
HUNTER spent $99 in Campaign funds at Torrey Pines Golf Course to purchase golf shoes.

94) On or about March 18, 2014, in La Quinta, California, the HUNTERS
spent $1,386.48 in Campaign funds for two rooms at the La Quinta Resort Club for a
personal vacation with Individuals 1A and 1B, in connection with an event taking place at
the hotel. Toconceal and disguise that they were paying for a second hotel room for their
friends, MARGARET HUNTER misled DUNCAN Chief of Staff by claiming
that the hotel ?had issue [sic] with one room and ended up switching.?

95) On or about May 20, 2014, MARGARET HUNTER spent $261.12 in
Campaign funds at Cox Communications to pay a portion of the overdue balance on their
home cable subscription, one of ten payments totaling $3,166.06 that MARGARET
HUNTER made to Cox using Campaign ?mds to pay cable bills. To conceal and disguise
her illegal activity, MARGARET HUNTER told the Chief of Staff that the May 20, 2014
charge was a ?one time set up? fee for an ?intemet printer and fax line? (the nine additional

payments being made only after the Chief of Staff retired at the end of 2014).

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96) On or about June 28, 2014, in'Laguna Beach, California, the HUNTERS
spent $1,163.68 in Campaign funds at the Montage Resort for food and drinks with
Individuals 1A and 1B, which the HUNTERS promised would be ?our treat? because their
lodging would be provided free by the hotel. At that time, the HUNTER family bank
account had a negative balance and, during the preceding week, had incurred four separate
insuf?cient funds fees, four separate returned item fees, and one overdraft fee (totaling
$287) 

97) On or about July 8, 2014, in Washington, DC, DUNCAN HUNTER
declined Individual 2A?s offer to pay for Uber ride to his house, which
Individual 2A had extended in order to help HUNTER ?keep some of those [personal Uber
charges] off of your [Campaign] account.? Instead, that same day, DUNCAN HUNTER
spent $7.28 in Campaign ?lnds for an Uber ride to Individual 2A?s house one of
approximately 43 different dates between 2013 and 2016 that DUNCAN HUNTER spent a
total of $990.60 in Campaign funds on Uber rides to socialize with his friends including
Individual 2A, Individual 213, Individual 5, and Individual 15 and for other personal
outings.

98) On or about July 9, 2014, the HUNTERS spent $250 in Campaign funds
at United Airlines to ?y a family pet to Washington, DC. for a family vacation.

99) On or about July 13, 2014, in Farmington, DUNCAN
HUNTER spent $1,067 in Campaign funds, including $399 fora zipline ride, at the
Nemacolin Woodlands Resort for family activities that were not part of a scheduled Work
event held at the hotel. I 

100) On or about July 17, 2014, in San Diego, California, MARGARET
HUNTER obtained $201.38 from the Campaign as reimbursement for the 
share of a personal meal on July 4th with Individuals 1A and 1B at Sally?s Fish House and
Bar to celebrate Independence Day. To obtain this reimbursement, MARGARET
HUNTER misleadingly described the expense as being simply for ?meals.?

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101) On or about July 17, 2014, in San Diego, California, MARGARET
HUNTER spent $187.60 in Campaign ?mds to purchase airline tickets for a nephew to
travel roundtrip from New Orleans to San Diego. 

102) On or about October 22, 2014, in San Diego, California, DUNCAN
HUNTER spent $204.34 in Campaign funds for two greens fees, food, and drinks at the
Rancho Bernardo Golf Resort, during a personal golf outing with friends, including
Individual 1A. To conceal and disguise his illegal activity, he misled his Chief of Staff by
describing his regular golf outing with IndiVidual 1A as ?a Christian thing? with a supporter.

103) On or about November 5, 2014, in El Cajon, California, DUNCAN
HUNTER spent $138 in Campaign funds to play golf at the Sycuan Golf Resort with a
minor family member, Individual 1A, and Individual 9, although DUNCAN HUNTER told
Individual 1A he had ?nada, zip, zero? scheduled on his of?cial calendar. I

104) On or about November 12, 2014, MARGARET HUNTER spent $211
in Campaign funds at United Airlines for a variety of charges related to personal travel for
her mother and her mother?s boyfriend. To conceal and disguise these illegal charges,
MARGARET HUNTER falsely told the Chief of Staff in an email (copying to DUNCAN
HUNTER) that they were ?for campaign travel plane changes.?

105) On or about November 23, 2014, in Alpine, California, DUNCAN
HUNTER Spent $215.40 in Campaign funds at Albertsons to purchase family groceries, and
food and drinks for a family member?s youth football team?s end-of?the-season party. To
conceal and disguise their illegal activity, MARGARET HUNTER misled the Chief of Staff
(copying DUNCAN HUNTER) by saying that the transaction was for an event
contribution,? and concealing the fact that the expense actually paid for a private partyfor
the family member?s football team.

106) On or about November 28, 2014, in Coronado, California, DUNCAN
HUNTER spent $200.24 in Campaign ?mds at the Hotel del Coronado and Tent City for an

evening out with his family.

28

 


(J1 

\Doouoxm-bWNr?I

 

 

107) On .or about December 14, 2014, in Alpine, California, DUNCAN
HUNTER spent $411.19 in Campaign funds at Vons to purchase family groceries, including
air freshener, butter, chopped spinach, brownie mix, and juice.

108) On or about January 7, 2015, MARGARET HUNTER obtained $800.33
in Campaign funds by falsely claiming to the Treasurer that she paid Hyatt hotel charges
with her ?personal card because [her] camp[aign card] had ran [sic] up daily limit due to
airline purchases,? when in reality, she paid the hotel bill using her Campaign debit card
and incurred only $33.05 in incidental hotel charges on her personal card, thereby
effectively stealing $800 from the Campaign. 

109) On or about January 28, 2015, MARGARET HUNTER spent $413 in
Campaign funds at United Airlines to purchase a ticket for DUNCAN HUNTER to ?y to
Hawaii for an upcoming family vacation.

110) On or about February 15, 2015, MARGARET HUNTER told the
Treasurer really need to up the lkdaily limit to 4 or 5? on the Campaign debit card,
but after learning that the bank would not allow this change, the HUNTERS instructed the
Treasurer to instead open a credit card account in addition to their debit card.

111) On or about February 17, 2015, MARGARET HUNTER spent $60.25
in Campaign funds at Ki?s School Lunches to pay for school lunches for their family one
of 22 different occasions in 2015 and 2016 that MARGARET HUNTER spent a total of
$1,372.55 in Campaign funds at Ki?s to purchase school lunches. 

112) On or about March 8, 2015, in San Diego, California, DUNCAN
HUNTER spent a total of $258.95 in Campaign funds at Sally?s Fish House and Bar for
food and drinks with MARGARET HUNTER and Individuals about March 16, 2015, in Alpine, California, the HUNTERS spent
$19.99 in Campaign funds at Steam Games to pay for video game charges one of 82
separate occasions in 2015 that the HUNTERS spent a total of 1 ,528.68 in Campaign funds

at Steam Games on video game charges.

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OKD 00?] Lilo-b 1" 

 

 

1 14) On or about March 18, 2015, by misleading the Treasurer, MARGARET -
HUNTER requested $131.76 from the Campaign as reimbursement for a personal night out
at Blue Point Coastal (on February 28, 2015) with Individuals 4A and 4B.

115) That same day, in San Diego, California, MARGARET HUNTER
obtained an additional $438.48 from the Campaign as reimbursement for a personal night
out at Island Prime (on March 7, 2015) with Individuals 1A and 1B and Individual 2A.
MARGARET HUNTER requested and obtained reimbursement for the full check despite
the fact the friends had paid for $366.48 of the total bill. When she requested
these reimbursements, the HUNTER family bank account had a negative balance and
incurred seven insuf?cient funds fees and one returned item fee (totaling $272) during the
prior week, 

116) On or about March 20, 2015, when DUNCAN . HUNTER told
MARGARET HUNTER that he was planning ?to buy my Hawaii shorts? but had run out
of money, she counseled him to buy the shorts at a golf pro shop so that they could falsely
describe the purchase later as ?some [golf] balls for the wounded warriors.?

117) On or about March 20, 2015, MARGARET HUNTER told DUNCAN
HUNTER that he could not access any funds until the next day using his personal credit
card. Instead, she counseled him to withdraw up to $100 in ?petty cash? using his ?work
card.? She reminded him, used to do petty cash all the time with [the former
Treasurer] it was great.? 

118) Later that same day, DUNCAN HUNTER spent $199.60 in Campaign
funds at Albertsons where he bought $99.60 worth of groceries, including dog food, and
received $100 back in cash. .

119) On or about April 7, 2015, in Lahaina, Hawaii, the HUNTERS spent
$6,288.74 in Campaign funds at the Aston Kaanapali Shores resort to pay for a family
vacation.

120) On or about April 8, 2015, DUNCAN HUNTER gave MARGARET

HUNTER his new Campaign credit card (in his name) despite her prior and ongoing misuse

30

 






 

 

of campaign funds. DUNCAN HUNTER kept the Campaign debit card, which he used to
access Campaign funds ?when not with MARGARET HUNTER.

121) On 01' about April 20, 2015, MARGARET HUNTER spent $995.50 in
Campaign funds at United Airlines to buy tickets for her mother and her mother?s boyfriend
to ?y to Warsaw, Poland. MARGARET HUNTER falsely told the Treasurer that they were
related to Campaign trips to New Orleans and Kentucky.

- 122) On or about May 3, 2015, in San Diego, California, the HUNTERS spent
$869.26 in Campaign funds to pay for dinner and drinks at the Cowboy Star Restaurant 
Butcher Shop for a personal meal with the HUNTER family, Individual 1A, and
Individual 2A. 

123) On or about May 10, 2015, in Coronado, California, the HUNTERS
spent $999.68 in Campaign funds at the Hotel del Coronado to purchase tickets to a
Mother?s Day brunch for their family (including MARGARET mother) and
items at the gift shop. I

124) On 01? about June 2015, in Washington, DC, DUNCAN HUNTER
spent $202.70 in Campaign funds at Street Country Club for a personal dinner with
Individual 16, Individuals 2A and 213, and Congressman and his date.

125) On or about June 10, 2015, in El Cajon, California, MARGARET
HUNTER spent $1,137 in Campaign funds at the Center for Oral Facial Surgery to pay
an outstanding, overdue balance for family dental work.

126) On or about June 12, 2015, in Washington, DC, DUNCAN HUNTER
spent $352.60 in Campaign funds at Matchbox for, in his words, ?a nice family evening?
with his nephew, Individual 16, and Individuals 2A and 2B.

127) On or about June 13, 2015, in Davidsonville, Maryland, DUNCAN
HUNTER spent $87.69 in Campaign funds to play golf at Renditions Golf Course with
Individual 2A.

128) On or about June 29 to July 6, 2015, in Boise, Idaho, Las Vegas, Nevada,
and elsewhere, the HUNTERS spent $3,724.07 in Campaign funds to pay for a family

31

 





 

 

vacation to their nephew?s Boise wedding with a stopover in Las Vegas. At the time their
trip began, the HUNTER family bank account had a negative balance and incurred six
insuf?cient funds fees (totaling $204).

129) On or about June 30, 2015, after the Treasurer questioned a number of
charges that were made during their recent vacation in Hawaii, the HUNTERS repaid
$5,245.71 to the Campaign. The Treasurer reported this payment as ?reimbursement for
personal expenses.?

130) On or about July 8, 2015, in La Mesa, California, MARGARET
HUNTER spent $700 in Campaign funds at a local dentist toward the family?s overdue
balance of $7,258 resulting from a variety of family dental services.

131) On or about July 18, 2015, the HUNTERS spent $87.50 in Campaign
funds at Fandango to purchase tickets for a movie that same day. To conceal and disguise
this illegal payment, MARGARET HUNTER told the Treasurer that the' charge was to ?gift
ticks towards a local league football fundraiser.?

132) On or about July 19, 2015, in Alpine, California, DUNCAN HUNTER
withdrew $300 in Campaign funds from an ATM before heading to the Del Mar Racetrack
with Individuals 1A and 1B one of approximately 26 occasions in 2015 and 2016 that
DUNCAN HUNTER and MARGARET HUNTER withdrew a total of more than $4,800 in
cash from the Campaign?s accounts for primarily personal use. To conceal and disguise
their personal use of the money withdrawn on July 19, 2015, MARGARET HUNTER
falsely told the Treasurer that the ?cash was needed for various small projects events
involving volunteers.? She later falsely claimed that the cash ?was used for hardware
supplies.?

133) On or about July 19, 2015, in DellMar, California, the HUNTERS spent
$362.06 in Campaign funds for food, drinks, and tickets to the Del Mar Racetrack with their
family and Individuals 1A and 113. 

32

 






 

 

134) A On or about July 21, 2015, in Washington, DC, DUNCAN HUNTER
spent a total of $114.91 in Campaign funds on drinks at the Speakeasy above Acqua Al 2
and an Uber ride while socializing with Individual 15.

135) On or about July 26, 2015, in Alpine, California, DUNCAN HUNTER
spent $296.58 in Campaign funds at Albertsons, where he bought $196.58 in family
groceries, including dog food, milk, roasted chickens, and paper towels, and received $100
back in cash. 1

136) On or about July 29, 2015, in Chula Vista, California, MARGARET
HUNTER spent $253.62 in Campaign funds at SeaWorld?s Aquatica Family Waterpark to
entertain family members. To conceal and disguise this illegal payment, she suggested to
the Treasurer that the charges should be classi?ed as an ?educational tour? as they were
related?to a ?daylong entrance and educational meet on their issues and programs.?

137) On or about August 5, 2015, in La Mesa, California, MARGARET
HUNTER spent $700 in Campaign funds at a local dentist to continue to pay down the
family?s overdue balance. In order to conceal and disguise this illegal payment, she told
the Treasurer that part of the payment was a charitable contribution for ?Smiles for Life.?

138) On or about August 8, 2015, in Alpine, California, MARGARET
HUNTER spent $300 in Campaign funds at the local water utility after the utility threatened
to discontinue the Water service due to unpaid bills.

139) On or about August 12, 2015, in El Cajon, California, MARGARET
HUNTER spent $3,500 in Campaign funds to pay the family?s tuition bill at Christian
Uni?ed Schools one of three different dates in 2015 that MARGARET HUNTER spent a I
total of $6,150 in Campaign funds to pay tuition. To conceal and disguise these illegal
payments, the HUNTERS provided a number of con?icting explanations, including that the
payments were charitable contributions.

140) On or about August 16, 2015, in El Cajon, California, MARGARET
HUNTER spent $216.50 in Campaign funds at Dick?s Sporting Goods to purchase a pair of
running shoes and other items. To conceal and disguise this illegal charge, MARGARET

33

 






 

 

HUNTER falsely informed the Treasurer that the items were for an annual dove hunting
event involving wounded warriors and were, therefore, ?equipment related (event
supplies)? 

141) On or about August 16, 2015, in El Cajon, California, MARGARET
HUNTER spent $99.53 in Campaign funds at Regis Hair Salon for haircuts and other 
services. To conceal and disguise this illegal purchase, she falsely informed the Treasurer
that it was for ?Gift Basket Items.?

142) On or about August 17, 2015, MARGARET HUNTER spent $152.25 in
Campaign funds at to make an online purchase of cosmetics. To conceal and
disguise this illegal charge, she falsely told the Treasurer that the charge was for ?gift basket
items Boys and Girls Clubs of San Diego.?

143) On or about August 27, 2015, in San Diego, California, DUNCAN
HUNTER spent $276.84 in Campaign funds to play golf at the Riverwalk Golf Club with
Individual 10.

144) On or about September 5, 2015, in El Cajon, California, MARGARET
HUNTER spent $235.36 in Campaign at Michaels craft store one of 14 different
occasions between 2010 and 2015 that MARGARET HUNTER spent a total of $2,264 in
Campaign funds primarily to purchase decorative items, crafts, candy, children?s books, and
cooking supplies for her and the HUNTER family?s personal use.

145) On or about September 17, 2015, MARGARET HUNTER spent
$140.00 in Campaign funds at PayPal to enter a family member in a dance competition.

- 146) On or about September 24, 2015, MARGARET HUNTER spent
$402.90 in Campaign funds at Expedia to reserve two rooms at the Westin LAX during the
dance competition.

147) On or about September 26, 2015, in Anaheim, California, the
HUNTERS spent $229.44 in Campaign funds at Disneyland?s Star Trader shop on gifts,
including two Minnie Mouse Ear headbands, a Star Wars droid knit beanie, and a raglan-

sleeve black?and-gray Star Wars girls T?shirt. In order to conceal and disguise this

34

 






 

 

transaction, MARGARET HUNTER falsely informed the Treasurer that the charge was for
?food/bev.?

148) On or about September 27, 2015, in Los Angeles, California, the
HUNTERS spent $219.23 in Campaign funds at the Westin LAX for food, drinks, and
incidentals for their family during a dance competition. 

149) On or about October 6, 2015, in Alpine, California, after his Campaign
debit card was disabled, DUNCAN HUNTER retrieved his Campaign credit card from
MARGARET HUNTER but allowed her to retain access to the Campaign credit card
number for online purchases.

150) On or about October 13, 2015, MARGARET HUNTER paid $1,268 in
Campaign funds to for utilities at the family home.

151) On or about October 21, 2015, in response to a fraud alert on the
Campaign credit card relating to a number of Steam Games charges (totaling at least $119),
MARGARET HUNTER told the Treasurer that the charges were not fraudulent, asserting
that ?these should not have fallen under this card they?re personal.? She promised to ?nix
this saved card in [the] computer and pay it personal later today.?

152) On or about October 21, 2015, MARGARET HUNTER asked the
Treasurer to order her a Campaign debit card issued in her name. He complied and she
received her own Campaign debit card shortly thereafter.

153) On or about October 27 to 28, 2015, in Washington, DC, DUNCAN
HUNTER spent $42.36 in Campaign funds for an Uber ride to and from the home of
Individual l7.

154) On or about October 31, 2015, in San Diego, California, DUNCAN
HUNTER spent $223.32 in Campaign funds at Jake?s Del Mar for the portion

A of a personal dinner with Individuals 4A and 4B.

155) On or about November 13, 2015, in El Caj on, California, MARGARET
HUNTER spent $286.41 in Campaign ?mds at Macy?s to purchase a three?piece luggage

.set in advance of the family?s upcoming vacation in Italy.

35

 






 

 

156) On or'about November 19 to 29, 2015, the HUNTERS spent $14,261.33
(including airfare) in Campaign funds to pay for a family vacation to Italy.

157) On or about November 23, 2015 in an attempt to justify the use of
Campaign funds to pay for the family?s trip to Italy, DUNCAN HUNTER attempted to set
up a day tour of a US. naval facility in Italy. After Navy of?cials responded that they could
only provide a tour on a particular date, DUNCAN HUNTER said he would discussthe
proposed date with MARGARET HUNTER, then subsequently told his Chief of Staff, ?tell
the navy to go themselves [no alteration in original],? and no tour occurred.

158) In or about late 2015, to conceal the illegal use of Campaign funds to
pay for the Italy vacation, MARGARET HUNTER falsely told the Treasurer that the
various charges related to this vacation ?were mostly military/ defense meet related? despite
emailing a friend that ?Italy was amazing Truly our best family trip so far. Like that saying
?if traveling was free you?d never see me again? 

159) On or about December 13, 2015, in Coronado, California, MARGARET
HUNTER spent $291.64 in Campaign funds at the Hotel del Coronado for a family ice
skating outing. . 

160) On or about December 21, 2015, in San Diego, California, the
HUNTERS spent $677.42 in Campaign ?mds at Lou Mickey?s for food and drinks during
a personal dinner with Individuals 1A and 1B.

161) On or about January 3, 2016, in Ramona, California, DUNCAN
HUNTER spent $140.62 in Campaign funds to play golf at the Mount Woodson Golf Club
with his brother, his father, and Individual 4A.

162) On or about January 5, 2016, MARGARET HUNTER spent $835.50 in
Campaign ?mds at Event Tickets for family tickets to see Riverdance at the San Diego Civic
Theater. To conceal and disguise this illegal charge, she falsely informed the Treasurer that

it was for ?San Diego Civic Center for Republican Women Federated/Fundraising.?

36

 






 

 

163) On or about January 9, 2016, in Lakeside, California, DUNCAN
HUNTER spent $276.15 in Campaign funds to golf at the Barona Creek Golf Resort with
family members and Individual 9. .

164) On or about January 15, 2016, in San Diego, California, MARGARET
HUNTER spent $418.99 in Campaign funds to take her family and their friends to
SeaWorld.

165) On or about January 17, 2016, in Phoenix, Arizona, the HUNTERS
spent $632.53 in Campaign funds at the Arizona Grand Resort Spa for a family vacation
centered on a family member?s dance competition. 

166) On or about January 31, 2016, in Alpine, California, DUNCAN
HUNTER and his Chief of Staff discussed how to address the fact that the Campaign?s draft
2015 Year-End report to be ?led with the FEC contained more than $22,000 in Campaign
spending that could be perceived to have been converted for personal use.

167) On or about January 31, 2016, DUNCAN HUNTER authorized his
Treasurer to ?le the Campaign?s 2015 Year~End report with the FEC. Among other
personal charges, this report disclosed that 67 charges (totaling $1,302) to Steam Games
and one charge to Christian Uni?ed Schools ($1,650) were ?personal expense[s] to be
paid back.? However, the report falsely claimed as legitimate campaign expenses other
personal charges, including another $1,000 charge to Christian Uni?ed Schools (?Donation
For Local Organization Fundraiser?), $655.47 in charges to Albertsons
$2,745.94 in charges to Costco (?Of?ce Supplies? and
$1,339.86 in charges to Cox Communications (?Utilities?), $230 in
charges to Feis Productions (?Event Entertainment?), a $223.32 charge toJake?s Del Mar
$728.45 in charges to Ki?s Restaurant $394.40 in
charges to Macy?s (?Donations For Gift Baskets For Local Organizations?), $525.02 in
charges to Target (?Of?ce Supplies?), and $1,363.03 in charges to Walmart (?Of?ce
Supplies? and 

37

 



168) On or about February 1, 2016, in response to questions raised by the
Treasurer for about ten months, MARGARET HUNTER falsely claimed for the ?rst time
that the Steam Games charges were fraudulent.

169) On or about February 12 to 14, 2016, in Phoenix, Arizona,
MARGARET HUNTER spent $2,856.72 in Campaign funds to pay for a family vacation
at the Arizona Grand Resort Spa.

170) On or about February 19 to 21, 2016, in Garden Grove, California,
MARGARET HUNTER spent $961.24 in Campaign funds at the Hyatt Regency Orange
County to pay for a family vacatiOn centered on a family member?s dance competition.

171) On or about March 4, 2016, at 11:52 pm, in Washington, DC,
DUNCAN HUNTER spent $354.25 in Campaign funds for drinks at the Jack Rose Dining
Saloon while entertaining his brother at a bachelor party for Individual 8.

172) On or about March 4, 2016, in Washington, DC, DUNCAN HUNTER
spent $462.46 in Campaign funds for 30 shots of tequila and one steak at E1 Tamarindo
restaurant during Individual 8?s bachelor party.

173) On or about March 5, 2016, in Washington, DC, DUNCAN HUNTER
spent $127.56 in Campaign funds for food and drinks at Stoney?s Bar and Restaurant with
his brother.

174) On or about March 5, 2016, in Washington, DC, DUNCAN HUNTER
spent $220.63 in Campaign funds for food and drinks at Fado?s Irish Pub while watching a
televised UFC ?ght with his brother and friends, including Individual 2A and Individual 8.

175) On or about March 5, 2016, in Coronado, California, MARGARET
HUNTER spent $3 60.5 8 in Campaign funds at Emerald City Surf Shop purchasing a variety
of clothing items for personal use. .

176) On or about March 5, 2016, in La Jolla, California, MARGARET
HUNTER spent $203.20 in Campaign funds for lunch at Duke?s restaurant with a family

member and the family member?s friends.

38

 






 

 

177) On or about March 7, 2016, in Lakeside, California, MARGARET
HUNTER spent $1,200 in Campaign ?inds at the Easy Open Door Company to purchase a
garage door for the personal residence. 4 .

178) On or about March 13, 2016, MARGARET HUNTER spent $668.20 in
Campaign funds at United Airlines to purchase round-trip plane tickets for her nephew to
?y from Philadelphia to New Orleans.

179) On or about March 17, 2016, in La Mesa, California, MARGARET
HUNTER spent $271.22 in campaign funds at Best 'Buy to buy a gaming keyboard and
gaming mouse.

180) On or about March 21, 2016, in Washington, DC, DUNCAN HUNTER
spent $130.10 in Campaign funds for drinks at Busboys and Poets during a personal night
out with friends including Individuals 2A and 2B, Individual 7, and Congressman C.

181) On or about March 23, 2016, in Washington, DC, DUNCAN HUNTER
spent $865.63 in Campaign funds for a room at the Liaison Capitol Hill while Individual 7
visited from San Diego.

182) On or about March 24, 2016, in San Diego, California DUNCAN
HUNTER spent $145.55 at the Riverwalk Golf Club to play golf with Individual 1A and
lA?s friend.

183) On or about March 27, 2016, in Coronado, California, the HUNTERS
spent $669.07 in Campaign ?mds at the Hotel del Coronado for a family Easter Sunday
Brunch in the Crown Room. I

184) ?On or about March 28, 2016, in Alpine, California, MARGARET
HUNTER spent $38.20 in campaign? funds at Fandango to purchase three tickets for a movie
that same day. To conceal and disguise the illegal transaction, she falsely informed the
Treasurer that the charge was for a ?Gift bundle basket for foothills republican women
spring fashion show.?

185) On or about April 4, 2016, in El Cajon, California, MARGARET
HUNTER spent $87.73 in Campaign funds at Home Depot one of nine separate occasions

39

 






 

 

between 2012 and 2016 that MARGARET HUNTER spent a total of $1,831.63 at Home
Depot primarily to purchase personal household and decorative items.

. 186) On or about April 5, 2016, the day after the FEC inquired about 67
Steam Game charges, MARGARET HUNTER called First National Bank and falsely
reported that the video game charges were fraudulent. In this call, she insisted that no
teenagers had access to the credit card. Following this false report, the bank credited $1,3 02
to the Campaign account.

187) On or about April 5, 2016, the day after the FEC inquired about the
Christian Uni?ed School Charge, MARGARET HUNTER repaid $6,150 to the Campaign
to cover three charges she had made to the school using Campaign funds.

188) On or about April 7, 2016, after numerous articles appeared in theiSan
Diego Union Tribune and Other media outlets, the HUNTERS repaid $5,746 to the"
Campaign related to additional personal charges identi?ed in news reports.

189) On or about May 12, 2016, in Washington, DC, DUNCAN HUNTER
spent $560.90 in Campaign funds at Del Frisco?s Double Eagle Steak House for dinner and
drinks with his mother. 1 

190) On or about May 18, 2016, MARGARET HUNTER spent $265.94 in
Campaign funds with Expedia to reserve a hotel room at the Holiday Inn Express in
Picayune, Mississippi for a family vacation.

191) On or about June 24, 2016, in Washington, DC, DUNCAN HUNTER
spent $409.45 in Campaign funds at L?Hommage Bistro Francais while socializing with
Individuals 2A and 2B, Individual 6, and Congressman and his date. That same day, the
HUNTER family bank account had a negative balance and incurred two insuf?cient funds
fees.

192) On or about July 5, 2016, MARGARET HUNTER obtained $441.63

- from the Campaign as reimbursement for a July 4, 2016 personal outing at Sally?s Fish

House and Bar with the HUNTER family and Individual 7.

40'

 






 

 

193) On or about August 4, 2016, in Palm Springs, California, DUNCAN
HUNTER spent $592.63 in Campaign funds at Prime Steakhouse for dinner during a
personal gol?ng weekend with Individual 1A, Individual 11, and Individual 12.

194) On or about September 15, 2016, at 7:40 am, in Washington, DC,
DUNCAN HUNTER spent $32.27 in Campaign funds for an Uber ride from Individual 18?s
home to DUNCAN of?ce.

195) On or about October 2, 2016, in San Diego, California, the HUNTERS
spent $339.18 in Campaign funds at Blue Point Coastal for a personal night out with
Individual 7, Individual 13, and Individual 13?s wife.

196) On or about October 13, 2016, in Santa Barbara, California, DUNCAN
HUNTER spent $300 in Campaign funds to purchase two greens fees for a round of golf at
the Sandpiper Golf Club with Individual 1A (who gave DUNCAN HUNTER $150 in cash
for his share of the fees). That same day, the HUNTER family bank account had a negative
balance and incurred two separate insuf?cient funds fees.

197) On or about November 5, 2016, in San Diego, California, the
HUNTERS spent $111.18 in Campaign funds at Pinzimini restaurant for appetizers and
drinks with Individuals 1A and 113.

198) On or about November 5, 2016, in San Diego, California, the
HUNTERS spent $3 00 in Campaign funds at Searsucker restaurant during a birthday-party
for Individual 1A.

199) On or about November 8, 2016, in Alpine, California, after repeated .
questioning by the FEC and news media about certain Campaign expenditures, DUNCAN
HUNTER repaid $48,650.98 to the Campaign to offset charges the HUNTERS had made
over the past year to purchase goOds or services from 57 different merchants. DUNCAN
HUNTER characterized the repayment as being for ?unauthorized expenditures? that he
now deemed either ?personal in nature? or ?without adequate support,? and continued to
conceal more than $200,000 in personal expense the HUNTERS had illegally paid with
Campaign funds.

41

 






 

 

200) On or about December 31, 2016, in Alpine, California, DUNCAN
HUNTER authorized MARGARET HUNTER to continue receiving a salary for
purportedly being the Campaign Manager. 

Allin Violation of Title 18, United States Code, Section 371.
Counts 2-44: Wire Fraud
(18 USC 1343 .

23. Paragraphs 1 through 17 and all sub-paragraphs are realleged and incorporated
herein by reference.

24. Beginning as early as December 2009 and continuing up through and including
the end of 2016, within the Southern District of California and elsewhere, Defendants
DUNCAN HUNTER and MARGARET HUNTER, knowingly and with the intent to
defraud, devised a material scheme to defraud the Campaign and to obtain money and
property from it by means of materially false and fraudulent pretenses, representations and
promises, and by intentional concealment and omission of material facts.

25. Paragraphs 20 through ?22 and all sub-paragraphs are realleged and
incorporated herein as more fully describing the scheme to defraud the Campaign and obtain
its money and property.

Interstate Wires

26. On or about the dates listed below (Column within the Southern District
of California and elsewhere, Defendants DUNCAN HUNTER end MARGARET
HUNTER, for the purpose of executing an essential part of the aforesaid scheme to defraud,
caused to ?be transmitted by wire in interstate commerce the writings, signs, and signals

described below (Column to wit:

 

 

 

 

 

 

 

Count 
Date Item Transmitted
2 4/20/13 A $210.91 debit card payment by DUNCAN HUNTER at Island
Prime in San Diego, California.
3 4/22/13 An email from DUNCAN HUNTER to hisChief of Staff enclosing
photos of two Island Prime receipts.

 

42

 




ooqmm AWN 00 \1 ON LII UJ-N 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Count 
Date Item Transmitted

4 1 1/16/13 A $100.69 debit card payment by DUNCAN HUNTER at Casa de
Pico in La Mesa, California.

5 1 1/16/13 An email from DUNCAN HUNTER to his Chief of Staff regarding

a ?dinner with volunteers/conuibutors? at Casa de Pico.

6 12/10/13 An email from United Airlines to MARGARET HUNTER

regarding the purchase of air miles used to ?y a family member to
- the East Coast.

7 2/28/14 A text message from MARGARET HUNTER to DUNCAN
HUNTER regarding obtaining a room at the La Quinta Resort 
Club.

8 4/ 14/ 14 An email from MARGARET HUNTER to DUNCAN 
Chief of Staff regarding the ?lodging and meals? at the La Quinta

- Resort Club.

9 7/4/14 A $184.38 debit card payment by MARGARET HUNTER at
Sally?s Restaurant in San Diego, Califomia._

10 7/ 8/ 14 An electronic claim submitted by MARGARET HUNTER
requesting a $201.38 reimbursement for a meal at Sally?s
Restaurant

11 7/9/ 14 A $125 debit card payment by MARGARET HUNTER at United

. Airlines related to airfare for the pct.

12 7/ 14/ 14 An email from MARGARET HUNTER to DUNCAN 
Chief of Staff related to a payment to Cox Communications.

13 10/22/14 An email from DUNCAN HUNTER to his Chief of Staff falsely
claiming that a golf outing at the Rancho Bernardo Golf Club was
?a Christian thing? with a supporter.

14 12/2/ 14 An email from MARGARET HUNTER to DUNCAN 
Chief of Staff providing false explanations for expenses to appear
on the FEC ?ling.

15 12/ 14/ 14 A $411. 19 debit card payment by DUNCAN HUNTER at Vons in 
Alpine, California.

16 3/ 18/ 15 An electronic claim submitted by MARGARET HUNTER
requesting a $131. 76 reimbursement for a meal at Blue Point
Coastal Cuisine. 

17 3/ 18/ 15 An electronic claim submitted by MARGARET HUNTER
requesting a $438.48 reimbursement for a meal at Island Prime.

18 3/20/15 A $199.60 debit card payment by DUNCAN HUNTER at
Albertsons in Alpine, California.

19 5/3/15 An $869. 26 credit card payment by MARGARET HUNTER at

 

 

Cowboy Star 1n San Diego, California

 

 

 

43

 

 






 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Caunt 
Date Item Transmitted

20 5/09/15 An $839.84 debit card payment by MARGARET HUNTER at
Hotel Del Coronado in Coronado, California.

21 5/10/ 15 A $159.84 credit card payment by MARGARET HUNTER at
Hotel Del Coronado in Coronado, California.

22 5/26/15 An email from MARGARET HUNTER to the Treasurer providing
false explanations for campaign expenditures.

23 6/10/15 A $1,137.00 credit card payment by MARGARET HUNTER at
Center for Oral and Facial Surgery in E1 Caj on, California.

24 7/7/15 An email from MARGARET HUNTER to the Treasurer regarding
a $202.15 debit card payment at Carmine?s Las Vegas.

25 7/,1 9/ 15 An $87.50 credit card payment by MARGARET HUNTER at

Fandango, based in Los Angeles, California. 

26 7/19/15 A $159.06 credit card payment by MARGARET HUNTER at Del
Mar Race Track Restaurant in Del Mar, California.

27 7/29/ 15 A $135.99 credit card payment by MARGARET HUNTER at
Aquatica in Chula Vista, California.

28 8/5/15 A $700.00 credit card payment by MARGARET HUNTER at Jeff
Gray, DDS in La Mesa, California.

29 8/5/15 An email from MARGARET HUNTER to the Treasurer providing
false explanations for campaign expenditures.

30 8/27/15 00 debit card payment by DUNCAN HUNTER at

Riverwalk Golf Club 1n San Diego, California.

31 10/ 14/ 15 An email from MARGARET HUNTER to the Treasurer in
Alexandria, Virginia providing false explanations for campaign
expenditures.

32 10/3 1/ 15 A $223.32 credit card payment by DUNCAN HUNTER at Jake?s
Del Mar in Del Mar, California.

33 11/2/15 A $403.20 credit card payment by MARGARET HUNTER at
United Airlines based in Chicago, Illinois.

34 11/13/15 A $286.41 credit card charge by MARGARET HUNTER at
Macy?s in El Caj on, California.

35 12/ 13/ 15 A $100.00 credit card payment by MARGARET HUNTER at
Hotel Del Coronado in Coronado, California.

36 1/3/ 16 A $140.62 credit card payment by DUNCAN HUNTER at Mount
Woodson Golf Club in Ramona, California.

37 1/9/16 A $200.00 credit card payment by DUNCAN HUNTER at Barona
Resort in El Cajon, California.

3 8 1/27/16 An email from MARGARET HUNTER to the Treasurer providing

 

 

false explanations for campaign expenditures.

 

 

 

44

 

 

 OO 0\ ?11 i?A




 

. 

Date Item Transmitted
39 3/5/16 A $203.20 credit card payment by MARGARET HUNTER at 
Duke?s in La olla, California.

40 3/17/16 An email from MARGARET HUNTER to the Treasurer
requesting reimbursement for a meal at Duke?s in La Jolla,
California.

41 5/18/16 An email from Expedia to MARGARET HUNTER con?rming the
reservation of a room at the Holiday Inn Express in Picayune,
Mississippi.

42 7/5/16 An email from MARGARET HUNTER to the Treasurer
requesting reimbursement for a meal at Sally?s Restaurant in San
Diego, California. 

43 11/5/16 A $111.18 credit card payment by DUNCAN HUNTER at
Pinzimini in San Diego, California.

44 11/6/16 A $300 credit card payment by DUNCAN HUNTER at Searsucker
in San Diego, California.

 

 

 

 

 

 

 

 

 

 

 

All in violation of Title 18, United States Code, Section 1343 and 2.
Counts 45-57: Falsi?cation of Records Related to Campaign Finance
. 

27. Paragraphs 1 through 17 and all sub-paragraphs are realleged and incorporated
herein by reference. 1 

28.? On or about the dates listed below, within the Southern District of California
and elsewhere, Defendants DUNCAN HUNTER and MARGARET HUNTER knowingly
concealed, covered up, falsi?ed, and made a false entry in the record and document listed
below with the intent to impede, obstruct, and in?uence the investigation and proper
administration of matters within the jurisdiction of the Federal Election Commission and

the Federal Bureau of Investigation, and in relation to and in contemplation of such matters:

 

Count Date FEC Form 3 Report of Receipts and Disbursements

 

45 7/ 15/2013 The 2013 July Quarterly Report

 

46 1/31/2014 The 2013 Year?End Report

 

47 4/14/2014 The 2014 April Quarterly Report

 

 

 

 

 

 

 

 

48 7/15/14 The 2014 July Quarterly Report

45

 

 00 UI 




 

Count Date FEC Form 3 Report of Receipts?and Disbursements

 

49 10/15/2014 The 2014 October Quarterly Report

 

50 12/2/2014 The 2014 Post?General Election Report

 

5 1 4/15/2015 The 2015 April Quarterly Report

 

52 7/15/2015 The 2015 July Quarterly Report

 

53 10/15/2015 The 2015 October Quarterly Report

 

54 1/31/2016 The 2015 Year-End Report for 2015

 

55 4/15/2016 The 2016 April Quarterly Report

 

56 10/15/2016 The 2016 October Quarterly Report

 

 

 

 

 

57 12/8/2016 The 2016 Post-General Election Report

 

 

 

All in Violation of Title 18, United States Code, Sections 1519 and 2.
Count 58: Prohibited Use of Campaign Contributions
(52 USC 30109(d) 30114Cb)(1) 18 USC 2)

29. Paragraphs 1 through 17 and all sub-paragraphs are realleged and incorporated
herein by reference.

30. In the calendar year 2014, within the Southern District of California and
elsewhere, Defendants DUNCAN HUNTER and MARGARET HUNTER knowingly and
will?illy converted $25,000 and more of Campaign ?lnds to their personal use by using
them to ful?ll personal commitments, obligations, and expenses that would have existed
irrespective of defendant DUNCAN election campaign or duties as a holder of
federal of?ce.

All in Violation of Title 52, United States Code, Sections 30109(d) and 30114(b)(1), and
Title 18, United States Code, Section 2.
4 Count 59: Prohibited Use of Campaign Contributions
(52 USC 30109(d) 30114(b)(1) 18 USC 2)
31. Paragraphs 1through 17 and all sub-paragraphs are realleged and incorporated

herein by reference.

46

 






 

 

32. In the calendar year 2015, within the Southern District of California and
elsewhere, Defendants DUNCAN HUNTER and MARGARET HUNTER knowingly and
will?illy converted $25,000 and more of Campaign funds to their personal use by using
them to ful?ll personal commitments, obligations, and expenses that would have existed
irrespective of defendant DUNCAN election campaign or duties as a holder of
federal of?ce.

All in Violation of Title 52, United States Code, Sections 30109(d) and 30114(b)(l), and
Title 18, United States Code, Section 2.

Count 60: Prohibited Use of Campaign Contributions

(52 USC 30109(d) 30114(b)(l)& 18 USC 2)

33. Paragraphs 1 through 17 and all sub-paragraphs are realleged and incorporated
herein by reference.

34. In the calendar year 2016, within the Southern District of California and
elsewhere, Defendants DUNCAN HUNTER and MARGARET HUNTER knowingly and
willfully converted $25,000 and more of Campaign funds to their personal use by using
them to ?il?ll personal commitments, obligations, and expenses that would have existed
irrespective of defendant DUNCAN election campaign or duties as a holder of
federal of?ce.

All in Violation of Title 52, United States Code, Sections 30109(d) and 30114(b)(l), and

Title 18, United States Code, Section 2. .

DATED: August 21, 2018.
or'eperson

ADAM L. BRAVERMAN
Unlted States Attorney

MARK-CO VER
PHILLIP L.B. HALPERN
Assistant US. Attorneys

 

 

 

 

 

47