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oH BD DB
April 6, 2018
Via E1 ress Mi
Mr. Omar Ashmawy
Staff Director and Chief Counsel
Office of Congressional Ethies
425 3+ Street, S.W.
Suite 1110
Washington, DC 20024
Re: Violations of Law and House Rules by U.S. Representative Ron DeSantis
Dear Mr. Ashmawy:
1am writing pursuant to Rule 3(A) of the OCE Rules for The Conduct of Investigations,
to bring to the attention of the Office Information indicating that Rep. DeSantis (R.-FL), the
Florida Representative in their Sixth District, may have violated Rule XXIII (3.4).
Recently, when redistricting gerrymandered Rep. DeSantis out of the 6» District, Rep
DeSantis relocated his main residence to a condominium located at 80 Surfview Drive. Unit 802,
Palm Coast, Florida 32137. At the time of Rep. DeSantis’s occupancy, the specific
condominium was owned by Matt Connell. William Connell, John Connell, Kent Stermon and
John Go, Jr. Kent Stermon and Matt Connell are the CEO and COO, respectively, and founders
of Total Military Management. Total Military Management (TMM) is a Jacksonville-based
‘company that provides logistic relocation services for the Department of Defense (DoD).
According to the company’s website, “Currently TMM coordinates more DoD moves than any
other single entity.”
Kent Stermon, Matt Connell, as well as a political action committee (Total Military
Management Inc. Political Action Committee, also known as Military Move PAC) directly
connected to Total Military Management, consistently engaged in significant contributions to
both of Rep. DeSantis's House of Representatives campaigns. According to Federal records, they
contributed nearly $60,000.00 to Rep. DeSantis’s campaigns. They also spent an average of
‘$50,000.00 per year in lobbying with a high mark of $190.000 in 2015.
10761 Southwest 104th Street
Miami, Florida 33176
305-598-1133 Office
305-785-5577 Mobile
Richard@rubentaw.net Mr. Omar Ashmawy
Page 2
April 6, 2018
The fair market value of the condominium that Rep. DeSantis rented from the owners of
‘TMM lists at approximately $385,000.00. Rep. DeSantis's spokesman has stated that a $2,000.00
‘monthly rental was paid for the condominium for a total of five months, The rental price for
units similar to Rep. DeSantis’s condominium, were rented out at over $2,000.00 per month,
based on research I conducted. A Realtor we spoke with suggested a unit like Rep. DeSantis’s
should rent for $2,500 to $2,800 a month, and possibly more during the summer months, Based
on my investigation, the amount Rep. DeSantis paid appears to be well below the expected
monthly rent for a two-bedroom, beach front condominium in Palm Coast,
I believe that Rep. DeSantis's potential ethics violation is similar in nature to the ethics
allegations currently facing Administrator Scott Pruitt, head of the Environmental Protection
Agency. Itis alleged that Mr. Pruitt rented a home in Washington DC, which was partly owned
by a lobbyist, whose firm had business with the Environmental Protection Agency during 2017,
at well below perceived fair market value.
[am troubled that Rep. DeSantis was potentially gifted, by a close campaign contributor
and lobbyist, a condominium to reside in, at well below fair market value. 1, as well as all of
Rep. DeSantis's past, current and future constituents, are led to question what exactly Rep.
DeSantis promised these campaign contributors and lobbyists in exchange for receiving such a
sweetheart deal. As Rep. DeSantis is currently running for Governor of Florida, I believe that
these issues should be investigated as swiftly and as thoroughly as possible, within reason. 1
respectfully ask the Office of Congressional Ethics to investigate this potentially questionable
and unethical conduct committed by Rep. DeSantis and the above-mentioned lobbyists,
Thank you in advance for your help with this matter.
Very truly yours,
Richard Lee Ruben
RLR/mr
