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A Civil Union

John Gooding, Felix Donovan, Andrew Passarello and Justin Pen reveal why the USU election still hasn’t officially been called.


A formal complaint lodged by University of Sydney Union (USU) Board candidate Cameron Caccamo against fellow candidate Liam Carrigan has forced Returning Officer Miiko Kumar to hold off declaring the 2014 USU election, pending an investigation into Carrigan’s campaign expenditure due to be resolved this Monday.

Complaints lodged against candidates following the close of polls is not uncommon.

Caccamo’s complaint, spanning three pages and 1,175 words, alleges that Carrigan’s campaign made “use of unauthorised campaign t-shirts” and failed to account for the full cost of printed campaign materials.


The complaint asserts a campaigner for Carrigan made use of an undeclared campaign t-shirt, constituting a breach of Regulation 17.11.1 (e), which provides that “the distribution of any publication which in any way comments on the election and which does not carry on it the name and the Access Card Number of the member of the USU who authorises it and takes responsibility for its contents.”

The complaint includes a photograph of the unauthorised shirt. It continues to suggest that “a single t-shirt purchased at a retail price along with the materials required to affix the design might cost in the vicinity or upwards of $20 per shirt.”

“I am willing and able to produce affidavits in my name and in those of others that will attest to the fact that the front of the shirt mimicked almost identically [the “Carrigan for Change”] design”, Caccamo writes. “I am willing to produce affadavits [sic] that Mr Carrigan was regularly in thwe [sic] vicinity of the campaigner wearing the undeclared t-shirt throughout the day.”

Caccamo further alleges that Carrigan “was certainly aware of the expenditure” and that Carrigan’s failure to declare the expenditure should be “characterised as a deliberate falsification of the expenditure declaration and be met with automatic disqualification from the election.”

The complaint alleges that Carrigan’s provisional and final expenditure statements make no mention of the unauthorised shirt in question.

In a sizeable counter-submission, running six pages and 2,694 words, Carrigan acknowledges that while an unauthorized campaign t-shirt was used he asserts it should not constitute electoral disqualification.

Carrigan’s first challenge concerns the interpretation of Regulation 17.11.1 (e). Citing the Cambridge Online Dictionary, Carrigan asserts that “A t-shirt is not a publication, it is an item of clothing and as such, is not subject to regulation 17.11.1 (e)”.

Contesting Caccamo’s claims concerning Carrigan’s expenditure reports, Carrigan asserts he did not “incur the expenditure” or “cause [expenditure] to be incurred” in the production of the t-shirt.

The response further asserts that Carrigan did not request the t-shirt be produced, was unaware that it was produced, and was unaware that it would be worn on the day of the election. The response confers “the individual shown in the pictures has attested” to this set of facts.

On the t-shirt itself, Carrigan’s response describes Caccamo’s estimated costing of the t-shirt as “entirely vexatious” and “reproachable”.

“At most, the cost of this shirt should be $7.80, the cost of the other campaign shirts I actually did incur the expenditure of”, writes Carrigan.

Carrigan continues to note that ‘the “T-Shirt” in question is an old shirt’ and should be costed as an everyday item, if it were to be held against him. Carrigan raises that its “poor quality”, difference in colour, hand-drawn design, and that “individual that produced it has submitted to me that it was just an old shirt she had at home” is evidence to the point.


Caccamo also suggests that “irregularities around [Carrigan’s] purchases of paper and printing” may have led him to breach the $750 spending cap. Caccamo makes two complaints with regards to printing. Displaying a remarkable knowledge of certain brands of paper, Caccamo firstly questions Carrigan’s assertion that the paper he used to print his How-To-Vote material was Reflex Gold, writing that “[Reflex] paper I can assure you bears no resemblance in texture or tone to that upon which Mr Carrigan’s campaign material was printed.” He suggests that Carrigan may have have used a more expensive brand of paper for printing his campaign materials.

More serious is Caccamo’s accusation that an error in printing may have led Carrigan to breach the spending cap. During the campaign, Carrigan submitted a declaration to the Returning Officer stating that Officeworks had made a mistake during the printing of his How-To-Vote cards. He wrote then that Officeworks had “inadvertently reversed the ratio” of his preferences, and that he would therefore not use these cards on Election Day.

Caccamo, in his complaint, argues that the Returning Officer cannot assume that Officeworks made the printing error, and speculates that there is a “possibility that Mr Carrigan had simply altered his wishes” in regards to preference deals. Caccamo says that the cost of the mistaken printing therefore “ought to be included in Mr Carrigan’s final account of expenses”.

In his response to the complaint, Carrigan notes that he handed the first set of How-To-Votes to the Returning Officer, and that it is therefore certain that he did not use them in the campaign. He writes that this is in line with an existing precedent in USU elections, wherein “the Returning Officer has allowed candidates to hand in materials they weren’t using and not have them costed”.


While only candidates in the USU elections are permitted to submit complaints to the Returning Officer after polling has closed, Honi Soit has obtained evidence that several factional heavyweights are orchestrating the dispute over election results.

Analysis of the metadata in the original Microsoft Word document submitted by Caccamo to the Returning Officer reveals that the “creator” field of the document is listed as “Robby Magyar”.

Pictured: advanced forensic metadata analysis by Honi Soit.
Pictured: advanced forensic metadata analysis by Honi Soit.

Magyar was the campaign manager for Alisha Aitken-Radburn, who came second in the elections after Carrigan. He is also a candidate in the forthcoming elections for President of the USU Board. Both Magyar and Aitken-Radburn are members of Labor Right political faction Student Unity.

When asked if Unity made any contribution to Caccamo’s complaint, Magyar told Honi that “as far as I know, no member of Unity had any involvement in Cameron’s complaint”.

Caccamo told Honi that “I may have sought the advice of other individuals” but that “I was the one who submitted [the complaint]”.

Patrick Massarani, also a member of Student Unity, has since contacted Honi and admitted to assisting Caccamo in authoring the complaint.

Carrigan’s campaign was co-managed by Indie factional elder Rhys Pogonoski and Indie Board Director Tara Waniganayaka, who is one of Magyar’s rivals in the presidential election. Carrigan said his response to the complaint was contributed to by the “core” of his campaign. Carrigan is likely to vote for Waniganayaka in the presidential election, and his disqualification would constitute a significant blow to Waniganayaka’s chances of beating Magyar to the USU presidency.

Correction: This article originally asserted that Carrigan’s response stated he was unaware that the shirt was worn on campaign day.