July 8, 2019

Notary Division
Maryland Office of the Secretary of State
16 Francis St.
Annapolis, MD 21401

Re: Complaint against Maryland Notary Public Shallon Nadeau Hartke.

Dear Sir or Madam:

The Foundation for Accountability and Civic Trust (FACT) is a nonprofit organization
dedicated to promoting accountability, ethics, and transparency in government and civic arenas.
We achieve this mission by hanging a lantern over public officials who put their own interests
over the interests of the public good.

“A notary public is an officer of the State [and] . . . in the exercise of duties is held to the
same high standards of public trust as other appointed and elected State officials.”1 FACT writes
today to inform you of publicly filed documents that appear to contain irregularities in the
execution and notarization of the documents, including documents notarized with no signatures
at all or suspected false or forged signatures. All these documents were purported to be notarized
by Shallon Nadeau Hartke, and if so, are evidence of an apparent pattern of misconduct in
administrating her notarial duties—a violation of these high standards of the public trust.

Based on the information provided herein, we request that your office investigate and if
appropriate, impose any necessary penalties on any individuals involved in the misconduct,
including removing Hartke from her office of notary public if appropriate.

Summary of Facts

Shallon Nadeau Hartke is a notary public under the laws of Maryland in Montgomery
County.2 State filings available to the general public demonstrate that Hartke has routinely
notarized and prepared documents for the Foundation for Moral Law (FML). FML is a non-

1
Office of the Secretary of State, Handbook for Maryland Notaries Public, at 2 (Aug. 2018), available at
https://sos.maryland.gov/Documents/NotaryManual.pdf.
2
Applicant ID 23102 (see https://sos.maryland.gov/Notary/Pages/NotarySearch.aspx).

www.factdc.org • 1717 K Street NW, Suite 900, Washington, D.C., 20006 • Phone (202) 787-5860
profit organization headquartered in Montgomery, Alabama widely known for controversies
related to its founder, Roy Moore.3

(i) Hartke notarized misspelled signatures attributed to Adelaide Morris.

Adelaide Morris has served as the Chief Financial Officer of FML for various periods
over the last decade. As the Chief Financial Officer of FML, Adelaide Morris has been
responsible for signing numerous state filings required from charitable organizations.

Importantly, in seven separate FML filings notarized on the same day,4 Hartke notarized
signatures attributed to “Adalade Morris” despite the fact that Morris’ first name is, in fact,
“Adelaide.” Public records and other publicly accessible information indicate that “Adalade” is
an incorrect spelling of Morris’ name.5 Moreover, in subsequent FML filings that were notarized
by Hartke, “Adalaide” Morris was listed as a Board Member or Staff. 6 Unless Morris mistakenly
misspelled her own name fourteen7 separate times within the same day, the only reasonable
conclusion is that Adelaide Morris did not appear before Hartke and sign the documents.

Accordingly, these documents indicate the signatures may have been false or forged. An
investigation is required to determine whether Hartke notarized the signature of a person who did
not appear before her and maintained the required registry.

(ii) Hartke notarized signatures of persons who did not affix their signatures.

On November 15, 2018, Ms. Hartke prepared and submitted FML’s Certification Form as
required by Maryland law.8 Included in this submission was FML’s 2017 Unified Registration
Statement for Charitable Organizations. On the fourth page of this document, Hartke affixed her
notary stamp to an apparent affirmation by Kayla Moore and Jessie Deem stating that the
information contained in the URS was “true, correct, and complete.”

3
Shawn Boburg and Robert O’Harrow Jr., Undisclosed Deal Guaranteed Roy Moore $180,000 A Year for
Part-Time Work At Charity, Washington Post, Oct. 11, 2017, available at
https://www.washingtonpost.com/investigations/undisclosed-deal-guaranteed-roy-moore-180000-a-year-for-
part-time-work-at-charity/2017/10/11/5f56679e-a9de-11e7-850e-
2bdd1236be5d_story.html?utm_term=.186d901a3a8c; see also,
https://www.washingtonpost.com/opinions/more-about-roy-moore-and-the-charity-that-paid-
him/2017/10/20/c0a37cfa-b373-11e7-9b93-b97043e57a22_story.html?utm_term=.8aca4a99c272.
4
Exhibit A.
5
For instance, official property records for the county of Conecuh, Alabama return results for “Adelaide”
Morris, but there are no official property records for the county of Conecuh, Alabama for an “Adalade”
Morris. Exhibit B.
6
Foundation for Moral Law, Unified Registration Statement for Charitable Organizations, State of West
Virginia, Fiscal Year 2016, attached as Exhibit C.
7
All seven filings include two fields for inputting each name: one field for printing the respective name, the
second field for signing the respective name.
8
Md. Code, Bus. Reg., § 6-408 (2019).

www.factdc.org • 1717 K Street NW, Suite 900, Washington, D.C., 20006 • Phone (202) 787-5860
(Foundation for Moral Law, Unified Registration Statement for Charitable Organizations, Maryland Office of the Secretary of State, Fiscal Year
2017, attached as Exhibit D.)

Moore and Deem did not sign this affirmation. Their two names were simply typed in
the appropriate fields, without any evidence of their appearance or knowledge. Hartke,
performing an official notarial act, seemingly authenticated two signatures attributed to people
who did not give their signature.
Your office’s Handbook for Maryland Notaries Public makes clear that short form
affidavits “must be signed by the person(s) making the oath or affirmation in the presence of the
notary.”9 Notarizing a short form affidavit without a signature would put Hartke in direct
violation of guidance issued by your office.
(iii) Hartke notarized signatures by Roy Moore and Rich Hobson that appear on their face to be
forged.

In the course of her work preparing and notarizing documents for FML, Hartke has also
been involved with filings that appear to be signed by Roy Moore and Rich Hobson. Within
these filings, there are noticeable stylistic differences between the signatures of Moore and
Hobson when compared with their signatures in other publicly available documents filed by
FML. Specifically, signatures attributed to Roy Moore and Rich Hobson appear to have taken on
a radically different form in documents notarized by Hartke in 2011 and after.

9
Handbook for Maryland Notaries Public, § 33, at 8 (emphasis added).

www.factdc.org • 1717 K Street NW, Suite 900, Washington, D.C., 20006 • Phone (202) 787-5860
 In state FML documents filed before Hartke’s involvement in 2011, signatures by both
Roy Moore and Rich Hobson demonstrate consistent yet authentic styles:

(Foundation For Moral Law, Annual Filing for Charitable Organizations, New York State Department Of Law,
Fiscal Year 2006.)

(Foundation For Moral Law, Form PC, The Commonwealth Of Massachusetts Office Of The Attorney General,
Fiscal Year 2006.)

(Foundation For Moral Law, Annual Filing For Charitable Organizations, New York State Department Of Law,
Fiscal Year 2007.)

(Foundation For Moral Law, Annual Filing For Charitable Organizations, New York State Department Of Law,
Fiscal Year 2009.)

www.factdc.org • 1717 K Street NW, Suite 900, Washington, D.C., 20006 • Phone (202) 787-5860
 In stark contrast, public filings prepared or notarized by Hartke include signatures that are
radically different from the above-referenced signatures by the same individuals. Despite these
clear stylistic differences, the signatures are nevertheless attributed to Roy Moore and Rich
Hobson.

(Foundation for Moral Law, Annual Filing for Charitable Organizations, Fiscal Year 2011, NY Attorney
General.10)

(Foundation for Moral Law, Unified Registration Statement for Charitable Organizations, Fiscal Year 2011, Attorney
General of California (Filed Dec. 12, 2012).)

10
In section (1)(g), the email listed has been connected to Hartke in other filings, indicating she prepared the
document. See, e.g., Exhibit E.

www.factdc.org • 1717 K Street NW, Suite 900, Washington, D.C., 20006 • Phone (202) 787-5860
(Foundation for Moral Law, Unified Registration Statement for Charitable Organizations, Fiscal Year 2011, North
Carolina Secretary of State (Filed Dec. 11, 2012).)

(Foundation for Moral Law, Unified Registration Statement For Charitable Organizations, Fiscal Year 2011.)

The radically different changes in signatures made by Moore and Hobson, in conjunction
with notarized signatures that were misspelled and attributed to Adelaide Morris and notarization
of documents with no signatures, is evidence of a pattern of signatures forged within FML filings
purportedly prepared and notarized by Hartke.

Requested Remedial Action

Given the issues raised by the information herein, it is imperative that your office
immediately investigate the irregularities in the execution and notarization of the documents and
the results of the investigation deem appropriate, remove Hartke from her office immediately.
Under state law, your office has the authority to remove or suspend notaries.11 Guidance issued
by your office specifies that notaries may be removed or suspended from office for
incompetency or misconduct, which the irregularities in the execution and notarization of FML

11
Md. Code, State Govt., § 18-104(b)(1) (2019).

www.factdc.org • 1717 K Street NW, Suite 900, Washington, D.C., 20006 • Phone (202) 787-5860
filings demonstrate have likely occurred.12 Your office has also made clear that notaries public
may not notarize the signature of a person who has not appeared before them.13 In numerous
state filings, including one filed with your office’s Charities and Legal Services Division,14 it
appears that is what occurred.
Forging signatures or knowingly notarizing forged signatures carries grave consequences
for the public trust, along with consequences for the legal and evidentiary reliance on notarized
documents. To demonstrate the importance of maintaining public trust, your office has made
clear that notaries public may face criminal liability for “[u]nlawfully, falsely and corruptly
affixing… a notarial seal, to any deed, warrant, or other writing.”15 Accordingly, we ask you to
uphold the public trust by immediately investigating and imposing the appropriate consequences.

Respectfully submitted,

Kendra Arnold
Executive Director, Foundation for Accountability & Civic Trust

12
Handbook for Maryland Notaries Public, § 56, at 16.
13
Secretary of State, Duties and Responsibilities of a Notary Public in Maryland,
https://sos.maryland.gov/Notary/Pages/Duties.aspx, at section 2.
14
Exhibit D.
15
Handbook for Maryland Notaries Public, § 57, at 16. Notaries public are subject to criminal penalties for
“[m]isconduct in office by improperly performing duties imposed by law.” Id.

www.factdc.org • 1717 K Street NW, Suite 900, Washington, D.C., 20006 • Phone (202) 787-5860
 Exhibit A

(Foundation for Moral Law, Annual Registration Renewal Fee Report, Attorney General Of California, Fiscal Year 2014.)

(Foundation for Moral Law, Annual Filing For Charitable Organizations, New York State Department Of Law, Fiscal Year 2014.)
(Foundation for Moral Law, Unified Registration Statement For Charitable Organizations, Fiscal Year 2014.)

(Foundation for Moral Law, Unified Registration Statement for Charitable Organizations, New Hampshire Attorney General Charitable Trusts
Unit, Fiscal Year 2014.)

(Foundation for Moral Law, Unified Registration Statement for Charitable Organizations, State of Utah Department of Commerce, Fiscal Year
2014, application dated November 2015.)
(Foundation for Moral Law, Unified Registration Statement for Charitable Organizations, State of Utah Department of Commerce, Fiscal Year
2014, application dated June 2017.)

(Foundation for Moral Law, Unified Registration Statement for Charitable Organizations, State of West Virginia, Fiscal Year 2012.)
Exhibit C
Exhibit D
Exhibit E