The Hicksville committee also listed separate American Express payments of $2,206 and $1,792 in 2012 for a Myrtle Beach golf fundraiser for the Mangano campaign. Yet the invitation for the fundraiser, sent by Walker on behalf of Friends of Ed Mangano, states that donations of $1,895 per individual covered round-trip airfare to Myrtle Beach, three nights at a hotel, and food and beverage costs for several meals.

The remaining cost of the fundraiser is not listed on either Mangano’s or Hicksville’s filings, which would seem to indicate expenditures missing from their respective disclosure reports. Another questionable Hicksville disbursement is $30,000 in total payments from April 2012 to July 10, 2012 to a business called KKL Associates for what is listed as “consulting” on the committee’s expenditure report.

According to the New York Department of State, KKL Associates was not a registered business until July 11, 2012, meaning that the payments were being made to a company that did not yet exist. The address listed for the business in the committee’s filing, 404 Jerusalem Ave. in Hicksville, is an apartment complex where Walker’s former special assistant, Kristen DiCerbo, lives. City & State called a number listed for DiCerbo, but received no response.

Further complicating matters is whether Hicksville’s status as a political committee precludes the club from spending such large amounts. According to the state Board of Elections, the Hicksville Republican Committee is registered as a “constituted county committee,” meaning that it can accept up to $102,300 in individual contributions and spend unlimited amounts on a Republican Party candidate.

According to state campaign finance law, any monies that political committees expend toward a given campaign must be reported by that campaign. However, Jacobs filed a complaint with the Board of Elections, which includes a cause of action stating that the Hicksville club is neither a “constituted committee” nor “a political committee specifically authorized by Mangano to aid or take part in Mangano’s campaign.”

Jacobs claims that the Hicksville club should be considered a duly constituted subcommittee of a county committee, which would place restrictions on what percentage of the contributions received could be used toward expenses related to funding a campaign, limiting the expenditure to not more than one cent per registered voter within the district where the committee is located. As this law applies to the hamlet of Hicksville- where there are over 28,000 registered voters- the maximum amount of money that could be spent would therefore be roughly $280, significantly less than the amount disbursed by the Hicksville committee.

In response to an inquiry about the legal status of Hicksville’s committee, attorney John Ryan, of Ryan, Brennan & Donnelly LLP, who represents Mangano and Walker, wrote that the Hicksville Republican Club and the Hicksville Republican Committee are “two separate and distinct entities” and that the committee is a Republican Party committee “comprised of those Election Districts within the Assembly Districts of the unincorporated area of Hicksville in the Town of Oyster Bay, New York.” Whatever its status, questions arise as to whether the committee’s expenditures are legal.

Henry Berger, a prominent state election lawyer, said that if the Hicksville club is indeed raising and spending money on behalf of Mangano, it could be considered a violation of state law. “If [Mangano is] using [the Hicksville committee] as a proxy to raise contributions that are then used to raise more money for him, it’s essentially a sham transaction,” said Berger. “If [the Hicksville committee is] making expenditures at these levels, accepting contributions for the purpose of raising money for Mangano and then making the expenditures to raise the money, it’s engaging in multiple violations of the law.”

Jacobs’ complaint also details Hicksville’s campaign finance irregularities, along with a list of $110,000 in un-itemized expenses and $70,000 in corporate contributions that exceeded the $5,000 annual limit to which corporations are restricted by law. Responding to this complaint, Ryan, on behalf of Mangano and Walker, disputes nearly every allegation made in relation to Friends of Ed Mangano and the Hicksville club’s campaign finance disclosure reports, with the sole exception being what he explains as a typographical error in the date of two payments made from the Hicksville committee to KKL Associates.

Ryan also denies that the Hicksville committee made any contributions to the campaign through the various fundraisers the club held, including the events at MetLife Stadium and Myrtle Beach. Ryan also claims that every dollar that the Mangano campaign accepted over the corporate contribution limit has been refunded to the respective companies-an adjustment that he asserts will be reflected in Friends of Mangano’s next filing. When reached by phone, a spokesman for the New York State Board of Elections declined to comment on the complaint filed by Jacobs and the response from Mangano and Walker, on the grounds that the complaint is currently under review.