Guam Del. Michael San Nicolas' former chief of staff filed a formal complaint with the Guam Election Commission Friday afternoon, offering attachments supposedly supporting the allegations he previously made in interviews with reporters nearly a week ago.

John Paul Manuel also added a new allegation in his formal complaint, stating: "Mr. San Nicolas received a $10,000 donation" from a Guam Korean Chamber of Commerce official. The Guam Daily Post is not naming the official pending his comment.

"Mr. San Nicolas conducted multiple small-dollar fundraisers to circumvent the rule that requires campaigns to issue receipts and keep records of contributions of more than $250. A chat conveying the transaction is attached here as attachment C," the complaint states.

Manuel also led the senatorial and congressional campaigns for San Nicolas. In the complaint, Manuel accused San Nicolas of forging his father's signature on campaign fund checks without the knowledge of the congressman's father.

As he previously alleged, Manuel provided the GEC with hotel bookings in Philippine resorts where Manuel alleged San Nicolas stayed with a woman whom he later hired as a key congressional staffer.

Manuel's complaint also alleges San Nicolas paid personal expenses with his credit card and then used campaign funds to pay off his credit card balances.

"To conceal the activities ... Mr. San Nicolas kept his FEC campaign finance records vague. Often, he disbursed campaign funds to himself and intentionally did not identify a purpose as those forms required," the complaint alleges. 

The FEC refers to the Federal Election Commission.

"As the FEC records will show, included here as an attachment, the FEC has already identified questionable entries," Manuel contends, with the tag “Memo code false.”  

San Nicolas hasn't responded to The Guam Daily Post's requests for comment, but he has posted a message on Facebook.  

"As to the nature of the recent allegations in local media, my office maintains absolute professionalism, and we welcome any formal complaints to be filed as we trust the outcome of the federal due process system will reveal that none of these have any basis," San Nicolas stated on social media on Wednesday. Manuel's initial allegations, also first posted on social media, began Saturday.

The delegate alleges the recent allegations stem from the actions of a number of various local government officials who, according to San Nicolas, "are under an active FBI investigation that was initiated in December 2018 or January."  

San Nicolas said he filed the complaint with the FBI because of an alleged threat. "During this period, my office was contacted and threatened to take certain actions in order to avoid political attacks," San Nicolas wrote in his post on his Facebook page.

"We refused, and I immediately engaged the FBI. The investigation is ongoing, to include the recent actions taken against me and my family these past several days."

San Nicolas didn't name any of the "various local government officials" whom he described as being under a federal investigation.

FEC reports show San Nicolas' campaign declared having received $16,715 in contributions and $4,967 in "loans" to the campaign from January to June 2019. In that same period, the campaign also reported a $19,173 disbursement to San Nicolas for "candidate loan repayments."

Between the 2017 and 2018 campaign, San Nicolas' campaign reported having received $88,164 in contributions, and disbursements that included $44,296.15 in "loan repayments" to San Nicolas and $43,422 in operating expenses.