A spokesman for Giuliani denied any coordination with the initiative effort – the Campaign for Equal Representation – or the Take Initiative America committee. “This is completely independent from our campaign,” said Jarrod Agen, “and frankly it’s not an initiative that serves our campaign’s best interests.” Democrats also accused the Giuliani campaign of trying to conceal Singer’s identity. Under California law, the Campaign for Equal Representation was required to disclose its true source of funding. It identified Take Initiative America, which was created Sept. 11, but Hurth, the lawyer behind the committee, refused to disclose where the $175,000 came from. “We know that Singer intended his money to be used for the effort in California,” Harrison said, “so, clearly, TIA was nothing more than a pass-through. “In California, that’s considered money laundering.” Lehane said he’s convinced Giuliani’s campaign was behind the effort. He noted that Charles Bell, a partner with Hiltachk’s firm, gave $1,300 to Giuliani’s campaign days before the initiative was filed; Hurth had given $2,000 to Giuliani; his spokesman, Jonathan Wilcox, was a spokesman for former California GOP candidate Bill Simon; Simon himself is a co-chairman for Giuliani’s California campaign and a policy adviser. “When you went through all these folks, virtually every road ultimately led back to Giuliani,” Lehane said. “The one conclusion that one could safely draw is that it was the Giuliani campaign that was ultimately behind this.” Giuliani, in a statement last week, said he would have had no reason to be behind the initiative. “As far as I’m concerned, you can leave it the way it is,” he said. “In fact, in some ways you might consider, I think that this is a state I can win. That might actually favor some of the other Republican candidates who might have a more difficult time winning this state. I think this is a state that I’ve got a 50-50 chance of winning. So as far as I’m concerned, I wouldn’t mind leaving it that way.”160Want local news?Sign up for the Localist and stay informed Something went wrong. Please try again.subscribeCongratulations! You’re all set! Singer’s disclosure that he’d contributed to the group came a day after top campaign officials for the GOP-backed electoral initiative resigned in protest after the lawyer in charge of Take Initiative America refused to divulge the donors. Although the initiative effort appears dead – in part because funding never materialized beyond Singer’s contribution – the alleged violations are serious, said Chris Lehane, spokesman for the Democratic group. “We want to get to the bottom of this,” he said at a San Francisco press conference. Singer’s contribution, said James Harrison, the attorney who filed the complaint, raises questions about potential money laundering, illegal coordination between a candidate and an independent committee, and whether federal contribution limits were exceeded. “As an agent of Giuliani’s, Singer would be prohibited from soliciting or directing a contribution in excess of $2,300,” said Harrison, who works with San Leandro-based Remcho, Johansen & Purcell, a firm specializing in election law. “We’d like the FEC to determine what Giuliani knew, when he knew it, what conversations he and Singer had about the contribution and how TIA was created. Whose idea was it? How did it come about?” SACRAMENTO – A Democratic group filed formal complaints Monday with the Federal Election Commission and the U.S. Justice Department, accusing GOP presidential candidate Rudy Giuliani of money laundering and violating campaign laws. In the complaint, Californians for Fair Election Reform accuse Giuliani, through his friend Paul Singer, of establishing a “front” organization to solicit illegal donations to support a ballot measure that would overturn California’s winner-take-all system of allocating electoral votes. Such a change would provide the Republican presidential nominee a chance to pick up roughly 20 electoral votes by dividing them up by congressional districts. Singer, a hedge-fund billionaire and a policy adviser and regional finance director for Giuliani, revealed last week that he was the sole contributor to the committee, Take Initiative America, which donated $175,000 to the ballot measure.