March 1, 2004

Office of the General Counsel

Federal Election Commission

999 E Street, N.W.

Washington, D.C. 20463

Re: Complaint against John Kerry for President, Inc.

Dear Sir/Madam:

Judicial Watch respectfully submits this sworn complaint against the John Kerry for President, Inc. Committee for failing to report a campaign contribution that appears to be in excess of legal limits.

A review of the reports John Kerry for President, Inc. (“the Committee”) submitted to the Federal Election Commission (“the Commission”) indicates that the Committee received $850,000 in unsecured loans from the candidate, including $100,000 identified as “personal funds.” See Exhibit 1.

The Committee also reports receiving $5,539,965.80 from the candidate in proceeds from secured loans. Id.

A loan guarantor is considered a contributor, subject to campaign contribution limits, until the loan is repaid. 11 C.F.R. § 100.52. This regulation applies to a spouse as well as any other related or unrelated individual.

A Boston Herald news article published on February 25, 2004 reports that the official City of Boston property assessment value of the home John Kerry shares with his wife is $6.6 million as of January 1, 2003. See Exhibit 2.

The Committee received $5,539,965.80 in loans secured at least in part by the value of the Kerry family home, of which Mr. Kerry could at best have an undivided interest of approximately $3.3 million, depending on the form in which the property is held. 11 C.F.R. § 100.52(b)(4).

This evidence suggests the Committee failed to report a campaign contribution from Mr. Kerry’s spouse, to the extent that her property rights in the Kerry family home or any other jointly held property are pledged as collateral for any or all of the secured loans received by the Committee. It also suggests that her contribution is in excess of the $2,000 maximum aggregate campaign allowed by law.

Judicial Watch is a non-profit, public interest legal watchdog and educational organization that obtains and analyzes information required by law to be gathered by government agencies such as the Commission. Judicial Watch disseminates this information to its supporters and the general public through monthly newsletters, daily and weekly radio programs, a twice weekly television program, and a sophisticated Internet website, among other means. The purpose of Judicial Watch’s efforts is to educate, stimulate, and inform public discussion about important issues of public policy, including government corruption, abuses of power, and violations of law by public officials. The obtaining, analysis, and dissemination of such information is an integral part of Judicial Watch’s purpose and function as a non-profit, public interest watchdog organization. In fact, it is one of the central reasons why Judicial Watch exists.

Accordingly, Judicial Watch respectfully requests that the Commission immediately commence an investigation into this apparent reporting violation and require the Committee to report Mrs. Kerry’s contribution properly and otherwise conform its conduct to the law.

Sincerely,

JUDICIAL WATCH, INC.

Thomas J. Fitton

President

DISTRICT OF COLUMBIA )

) ss:

CITY OF WASHINGTON )

Sworn to and subscribed before me this ___ day of March, 2004 in Washington, DC.

__________________________

Notary Public