MUR808200116
Roy Luckett, Esq. 

Federal Election Commission 

Office of Complaints Examination 

 & Legal Administration 

December 30, 2022 

Page 2 

involvement, Ms. Dupree is also active within the community, having served on the board of a 

number of not for profits. Ms. Dupree is a committed, caring and considerate individual who 

takes her financial responsibilities and civic involvement very seriously. 

 As part of Ms. Dupree’s professional services, she has served as treasurer for various 

state and federal campaigns and political action committees (PACs). In connection with 

undertaking this responsibility, Ms. Dupree familiarized herself with the applicable laws and 

regulations establishing the duties and responsibilities as treasurer and she takes great pains to 

ensure compliance therewith. From March 2020 to approximately July 2022, Ms. Dupree served 

as treasurer for Wingman PAC. Wingman PAC is a federally registered independent expenditure 

only committee (Super PAC) formed under Federal Election Campaign Act of 1971 in March of 

2020. 

WINGMAN PAC CONTRIBUTIONS AND REPORTING

 As treasurer for Wingman PAC, Ms. Dupree is responsible for the preparation and filing 

of reports relating to contributions received and expenditures made by the Super PAC. These 

reports were generated pursuant to 52 U.S.C. § 30104. Contributions made to Wingman PAC 

were subject to 52 U.S.C. § 30102(b) and the identification of the contributors’ requirements 

associated therewith. Under Ms. Dupree’s direction and supervision, Reports of Receipts and 

Disbursements (FEC Form 3Xs) were filed on behalf of Wingman PAC, the timing of which 

would be subject to the particular phase of the election cycle which was ongoing at that time. 

 At all times applicable to Ms. Dupree’s service as treasurer for Wingman PAC, she was 

cognizant of, and sensitive to, certain restrictions which may apply to contributions directed to 

the Super PAC. As such, confirmation of the identity of the donor/contributor was confirmed in 

accordance with the standards governing same. Ms. Dupree was aware of 52 U.S.C. § 30122 

(prohibiting certain contributions in name of another) as well as 11 C.F.R. § 110.4, which 

addresses both contributions in the name of another as well as contributions made by foreign 

nationals. These sections prohibit a person from knowingly accepting a contribution made by 

one person in the name of another. Had Ms. Dupree been made aware of any contributions 

directed to Wingman PAC which fell into these categories, they would have been rejected by 

Ms. Dupree and returned to the donor/contributor. 

 One of the contributions received by Wingman PAC was from an organization known as 

Grow United, Inc. Ms. Dupree was not involved with the creation of Grow United, Inc., nor was 

she aware of the creation or use of Grow United, Inc. for any improper purpose. At some point, 

Ms. Dupree was made aware that Wingman PAC had received a contribution via wire transfer 

MUR808200117
Roy Luckett, Esq. 

Federal Election Commission 

Office of Complaints Examination 

 & Legal Administration 

December 30, 2022 

Page 3 

from Grow United, Inc. There was nothing unusual about this transaction and Ms. Dupree did 

not know or have any reason to know or suspect that Grow United, Inc. was a “straw person” 

created solely for the purpose of obfuscating the true identity of other contributors to Wingman 

PAC. 

 In connection with receiving the Grow United, Inc. contribution, Ms. Dupree’s office 

confirmed the wire transfer came from Grow United, Inc., which had an address in Denver, 

Colorado. Thus, Ms. Dupree confirmed the domestic nature of the donor as well as the source of 

the funds (coming from a Grow United account). Such is the extent of due diligence required by 

a treasurer in these types of situations. 

 Ms. Dupree prepared and filed FEC Form 3X for Wingman PAC on December 3, 2020. 

It included Schedule A – Itemized Receipts that listed the Grow United, Inc. contribution on 

page 6 of 16 of the report. Within that disclosure section, Grow United, Inc. was identified with 

a mailing address of 1550 Larrimore Street, #176, Denver, Colorado 80202. The amount 

received from Grow United, Inc. was accurately reflected as $100,000. The date of receipt of the 

Grow United, Inc. contribution was reflected as October 27, 2020. The reporting coverage 

period was October 1, 2020 through November 23, 2020, and as such, the Grow United, Inc. 

contribution was timely and appropriately disclosed pursuant to all applicable reporting 

requirements. 

ALLEGED VIOLATIONS

 The Complaint against Ms. Dupree was filed by Noah Bookbinder on behalf of Citizens 

for Responsibility and Ethics in Washington. In addition to Ms. Dupree and Wingman PAC,1 15 

other individuals and entities were identified, as well as a number of “unknown respondents.” 

The allegations involving Wingman PAC stem from assertions directed towards Grow United, 

Inc. Mr. Bookbinder alleges (primarily citing to investigative work of news agencies) that Grow 

United, Inc. was created to act as a straw person to create a layer of separation between actual 

donors and the receipt of funds by a political action committee/candidate. Grow United, Inc. is 

referred to in Mr. Bookbinder’s Complaint as a “conduit entity.” 

 Mr. Bookbinder’s Complaint is styled in the form of a civil pleading, with Count II being 

applicable to Wingman PAC and Ms. Dupree (among others). Despite the length of the 

1

 Ms. Dupree is no longer the treasurer of Wingman PAC. Wingman PAC is being represented by separate counsel 

and will be filing a response to the Complaint on its own behalf. 

MUR808200118
Roy Luckett, Esq. 

Federal Election Commission 

Office of Complaints Examination 

 & Legal Administration 

December 30, 2022 

Page 4 

Complaint, no factual predicate was provided which would actually support the allegations 

contained in paragraphs 73 through 75, which state in a totally conclusory fashion that Wingman 

PAC through Ms. Dupree “knowingly accepted a contribution made by one person in the name 

of another.” Paragraph 75 further alleges that Ms. Dupree “failed to report the identities of the 

true source or sources of contributions and the identities of each conduit for the contributions 

falsely attributed to Grow United.” These allegations are based on an assumed premise by Mr. 

Bookbinder that Ms. Dupree was either part of the conduit consultant scheme (described 

throughout the Complaint) and/or affirmatively knew that Grow United, Inc. was a conduit entity 

created solely for the purpose of hiding the true identity of campaign/political action committee 

donors or contributors. In order for the commission to find reason-to-believe against Ms. 

Dupree, the Complaint must provide evidence to show that at the time Ms. Dupree accepted the 

contribution on behalf of Wingman PAC, she knew that the contribution from Grow United, Inc. 

was from another donor. 

 Simply put, Ms. Dupree had absolutely no knowledge that Grow United, Inc. was created 

for any improper purpose or, in particular, that Grow United, Inc. was purportedly used as a 

“conduit entity” to obscure the identity of the “true donors” and the Complaint offers no 

evidence to this effect. Ms. Dupree was not aware of who contributed to Grow United, Inc., nor 

was the investigation of same part of her duties or responsibilities as treasurer for Wingman 

PAC. Ms. Dupree was not involved in the creation of Grow United, Inc., did not assist in 

soliciting funds on Grow United, Inc.’s behalf nor did she serve in any executive or 

administrative role whatsoever for that entity. There was no duty or obligation as set forth under 

federal law for Ms. Dupree to have demanded some sort of accounting from Grow United, Inc. 

prior to accepting funds into the account of Wingman PAC. Additionally, there was no 

requirement under federal law for Ms. Dupree to conduct any type of investigation or audit of 

Grow United, Inc. other than to confirm that the source of the donation made in Grow United, 

Inc.’s name came from a Grow United, Inc. account and that Grow United, Inc. was in fact a real 

corporation organized under U.S. law. As explained above, this is exactly what Ms. Dupree did. 

 There are no prohibitions against Super PACs such as Wingman PAC accepting funds 

from not for profits like Grow United, Inc. Ms. Dupree had no reason to believe that Grow 

United, Inc. was created or existed for any improper purpose and no information was 

communicated to her about the Grow United, Inc. contribution which raised, or should have 

raised, any index of concern.2

 Ms. Dupree has no knowledge of the factual allegations raised by 

Mr. Bookbinder in his Complaint regarding the creation or make up of Grow United, Inc. With 

that said, even if those allegations prove to be correct, it still would not create an FEC violation 

2

 Furthermore, there is no meaningful factual support set forth in the Complaint to suggest this occurred either. 

MUR808200119
Roy Luckett, Esq. 

Federal Election Commission 

Office of Complaints Examination 

 & Legal Administration 

December 30, 2022 

Page 5 

issue for Ms. Dupree, as Ms. Dupree was wholly without knowledge as to those matters and had 

no reason or obligation to inquire beyond the steps described above to confirm the identity of the 

$100,000 in funds received by Wingman PAC which were purportedly (and then ultimately 

confirmed) made by Grow United, Inc. 

REQUEST FOR DISMISSAL

 Given the nature of the allegations raised in the Complaint and the response provided 

above, we would kindly request that the FEC dismiss that portion of the subject Complaint 

directed to Ms. Dupree or that this matter be closed with a finding that there is no reason to 

believe that the Complaint sets forth a possible Federal Election Campaign Act violation against 

Ms. Dupree as (former) Treasurer for Wingman PAC. Once again, the Complainant provides no 

reasoning or evidence to support their assertion that Ms. Dupree knowingly accepted a 

contribution from Grow United, Inc. that she knew to be from other individuals. Reason-tobelieve is no “rubber stamp”3

 – complaints based on mere speculation or conclusory statements 

have not, and should not, be the basis for an investigation,4 especially when accompanied by a 

direct refutation.5

 Thus, a finding of no reason-to-believe is appropriate. To the extent any 

additional information is required of Ms. Dupree prior to reaching these conclusions, please 

contact our office and we will do our best to facilitate same. 

 Respectfully submitted, 

 Charles M. Meltz 

 Laura M. Kelly 

CJM/LMK:meo 

Enclosure 

14580:60 

3

 Statement of Reasons by Vice Chairman Allen Dickerson and Commission James “Trey” Trainor III at 3, MURs 

7427, 7497, 7524, 7553, 7560, 7621, 7654, 7660 and 7558 (NRA, et. al). 4 Id.; see also Statement of Reasons of Comm’rs Mason, Sandstrom, Smith and Thomas at 1, MUR 4960 (Clinton) 

(Dec. 21, 2000). 

5 Id. at 2. 

MUR808200120
MUR808200121