Nsw Icac Exhibit Nsw Icac Exhibit Nsw Icac Exhibit Nsw Icac Exhibit Nsw Icac Exhibit Nsw Icac Exhibit '

Home , Bruce Hawker, Kaila Murnain, Matt Thistlethwaite, Sam Dastyari, State Labor Party

NSW ICAC EXHIBIT NSW ICAC EXHIBIT NSW ICAC EXHIBIT NSW ICAC EXHIBIT NSW ICAC EXHIBIT NSW ICAC EXHIBIT ' ,. PRN E18/0093/AS-04-067/PR-0001

INDEPENDENT COMMISSION AGAINST CORRUPTION

OPERATION AERO

WITNESS STATEMENT OF IAN LYALL ROBERTSON AO

1. I am the National Managing Partner of Holding Redlich.

2. I make this statement in connection with the public inquiry conducted by the Independent Commission Against Corruption titled "Operation Aero".

3. Exhibited to me at the time of signing this statement and marked with the letters "ILR-1" is a bundle of documents.

- My Background

4. I was born in Melbourne on 31 May 1956. My tertiary education was at the University of Melbourne. I graduated with degrees in Law and Commerce in 1979. I was admitted to legal practice in Victoria in 1980 and in New South Wales in 1994.

s. I have been a partner of the law firm Holding Redlich since 1 July 1990. In April 1994, I relocated to Sydney to establish the Sydney office of Holding Redlich, which opened on 2 May 1994. I have been the Sydney Managing Partner of Holding Redlich since that date.

6. On 1 July 2015, I was appointed as the firm's National Managing Partner. In April 2019, I was re-elected as National Managing Partner for a second four-year term, which commenced on 1 July 2019.

7. I am not and never have been a member of the Australian Labor Party. I am not involved - in any aspect of the activities of NSW Labor other than as a legal adviser. Holding Redlich is not a member of Labor Lawyers.

Advising the NSW Branch of the Australian Labor Party

8. I first commenced performing legal work for the NSW Branch of the Australian Labor Party (NSW Labor) in about 2008. I understand that I was initially recommended to NSW Labor by a client of the firm, Bruce Hawker, of the political consultancy Hawker Britton. The General Secretary of NSW Labor at that time was Matt Thistlethwaite. I do not recall having many dealings with him.

9. Through the firm's legal work for NSW Labor, I have received instructions from, had professional dealings with and provided advice to a number of persons holding the role of NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 Page 2

General Secretary of NSW Labor from time to time. Those persons are, in order, Mr Thistlethwaite, Mr Sam Dastyari, Mr Jamie Clements and Ms Kaila Murnain.

10. I have also received instructions from and had professional dealings with the current Assistant State Secretary Mr Pat Garcia, the former Governance Director, Ms Julie Sibraa, the current Governance Director Mr Glenn Bacic, and occasionally the President of NSW Labor, Mr Mark Lennon.

11. Initially, the volume of work that Holding Redlich performed for NSW Labor was relatively moderate but over the years the amount of work increased.

Ms Kaila Murnain

12. Ms Kaila Murnain was appointed General Secretary of NSW Labor in or around January - 2016. She succeeded Mr Clements. Prior to her appointment as General Secretary, Ms Murnain had been the Assistant General Secretary of NSW Labor. I had limited dealings with Ms Murnain while she was the Assistant General Secretary. Most of my dealings with NSW Labor before Ms Murnain's appointment as General Secretary were with Mr Clements and after Ms Murnain's appointment as General Secretary, we were in regular contact.

The events surrounding Friday 16 September 2016

13. During the week commencing Monday 12 September 2016, I was advising NSW Labor on a number of issues. In addition, I was to commence three weeks' annual leave overseas on Sunday 18 September 2016 and I was in the course of preparing to do that.

14. One of the issues concerned whether payments made by the Yuhu Group and by the Top Education Institute on behalf of Senator Dastyari (as he then was) had contravened - internal party rules. There were media reports that Mr Dastyari's conduct had breached the NSW Rules and the National Rules of the Labor Party.

15. On Wednesday 14 September 2016 at 8:12PM, I received an email from Pat Garcia attaching an article in the Sydney Morning Herald about Senator Dastyari. At page 1 of Exhibit ILR-1 is a copy of that email.

16. On Thursday 15 September 2016 at 5:38PM, I sent an email to Ms Murnain containing advice on the question of whether Senator Dastyari had breached the NSW Labor Rules and the ALP National Constitution. At page 5 of Exhibit ILR-1 is a copy of that email.

17. On Friday 16 September 2016 at 4:45PM, I telephoned Sarah Butler (Sarah), an employee of the firm, who was on annual leave at that time. Sarah is a solicitor and NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 Page 3

senior associate of the firm who has assisted me with ALP matters since 2013. At page 153 of Exhibit ILR-1 is a record of that phone call. I have caused to be marked on that document the identity of certain persons whose phone numbers are recorded therein.

18. On Friday 16 September 2016 at 4:48PM, I received an email from Ms Murnain setting out the definition of a "property developer" under the Election Funding, Expenditure and Disclosures Act 1981 (NSW). At page 7 of Exhibit ILR-1 is a copy of that email.

19. On Friday 16 September 2016 at 4:49PM, I telephoned Ms Murnain. I have reviewed my phone records for that day. My belief is that I joined Ms Murnain to my call with Sarah as described in paragraph 17 above. My belief is that Ms Murnain provided instructions requesting urgent advice concerning a trip made by State MP, Mr Nick Lalich. At page 153 of Exhibit I LR-1 is a record of that phone call.

20. On Friday 16 September 2016 at 5:04PM, I telephoned Sarah. I do not have a - recollection of that discussion and nor do I have a file note of it. My belief, however, is that we discussed the advice requested by Ms Murnain. At page 153 of Exhibit ILR-1 is a record of that phone call.

21. I obtained assistance in the drafting of the advice to which I refer in paragraph 19 from Sarah. On Friday 16 September 2016 at 7:04PM, I received an email from Sarah containing a draft advice. At page 8 of Exhibit ILR-1 is a copy of that email.

22. On Friday 16 September 2016 at 7:09PM, 7:12PM, 7:49PM and 7:52PM, I telephoned my wife. At page 153 of Exhibit ILR-1 is a record of those phone calls.

23. On Friday 16 September 2016 at 8.05PM, I sent an email to Sarah to say that no further - work needed to be done on the draft advice that evening. That email was sent from my iPhone or my iPad. I know that because the signature block is different. Emails sent from my work computer contain a signature block with the Holding Redlich logo. It is my practice to send emails from my iPhone or iPad when I am not proximate to my work computer. I believe I sent this email after I had arrived home. At page 13 of Exhibit ILR- 1 is a copy of that email.

24. On Saturday 17 September 2016 at 11 :50AM, I sent an email to Ms Murnain containing my advice in relation to Mr Lalich MP. The email was copied to Mr Chris Willis, who was Mr Foley's Chief of Staff. The first line of that email refers to my telephone conversations with Ms Murnain "yesterday afternoon and evening." I added the words "and evening" to the draft prepared by Sarah to reflect the conversation with Ms Murnain on the evening of Friday 16 September 2016. At page 14 of Exhibit ILR-1 is a copy of that email. NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 Page 4

25. On Saturday 17 September 2016 at 12:29PM, I sent an email to Ms Murnain containing further advice in relation to whether Senator Dastyari had breached the ALP's Code of Conduct for Fundraising in the ALP National Constitution. At page 17 of Exhibit ILR-1 is a copy of that email.

26. On Saturday 17 September 2016 at 1 :25PM, I sent an email to my assistant, Liz Georgiou, requesting that she "put in 10 units of time on the ALP General file ... on Friday - telephone conversations and meeting with Ms K Murnain concerning political donation issues." At page 19 of Exhibit ILR-1 is a copy of that email.

27. On Saturday 17 September 2016 at 3:33PM, I received an email from Ms Murnain attaching the decision in Borsak v Cheung [2006] NSWADT 5. At page 20 of Exhibit ILR-1 is a copy of that email.

28. On Saturday 17 September 2016 at 4:28PM, I sent an email to Ms Murnain containing my - advice as to whether NSW Labor should make an urgent application to the NSW Supreme Court to restrain counting of the vote for the position of the Mayor of Fairfield. At page 43 of Exhibit ILR-1 is a copy of that email.

29. I exchanged further email correspondence with Ms Murnain on the afternoon of Saturday 17 September 2016. Those emails were from:

(a) Pat Garcia to Ms Murnain and me at 4:34PM with the subject line "Fwd: dai le". At page 44 of Exhibit ILR-1 is a copy of that email.

(b) Ms Murnain to me at 4:35PM with the subject line "Re: Residency issue in Fairfield". At page 47 of Exhibit ILR-1 is a copy of that email.

(c) me to Ms Murnain and Mr Garcia at 4:42PM with the subject line "FW: dai le". At - page 49 of Exhibit ILR-1 is a copy of that email.

30. On 20 September 2016, the Daily Telegraph published an article written by Andrew Clennell with the headline "Nick Lalich: NSW Labor MP referred to Electoral Commission over trip to China". At page 52 of Exhibit ILR-1 is a copy of that article.

31. On 30 September 2016, I authorised a tax invoice to be prepared relating to advice provided to "ALP NSW Branch" and I sent that tax invoice to Ms Murnain on Wednesday 5 October 2016 while I was in London on holiday. That invoice records the following entry on 16 September 2016: "Telephone discussions and meeting with Ms K Murnain concerning political donation issues; Drafting email of advice to Ms K Murnain regarding NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 Page 5

political donations." At page 54 of Exhibit ILR-1 is a copy of that tax invoice. At page 67 of Exhibit ILR-1 is a copy of my email to Ms Murnain.

32. Prior to issuing the tax invoice referred to above, I reviewed a copy of the prebill information from Holding Redlich's billing system. The prebill information for the tax invoice contains Sarah's handwriting. It was my practice at that time, and remains my practice now, to request that Sarah review the prebill information and mark up any proposed changes for my approval. The prebill information includes time entry records that in accordance with my usual practice for ALP NSW matters are not itemised on the final tax invoice. The relevant prebill information records that I billed one hour on 16 September 2016 in relation to "Telephone discussions and meeting with Ms K Murnain concerning political donation issues." At page 59 of Exhibit ILR-1 is a copy of the prebill information. - Ms Murnain's Allegations 33. The substance of the allegation made by Ms Murnain is to the effect that:

(a) Ms Murnain alleges that we met on the evening of Friday 16 September 2016 at my office at the MLC Centre (the Alleged Meeting);

(b) Ms Murnain alleges that Ms Murnain told me that she had met with Ernest Wong;

(c) Ms Murnain alleges that Ms Murnain told me that Ernest Wong had told her that someone who said that they had donated money to the ALP had not in fact made the donation;

(d) Ms Murnain alleges that Ms Murnain told me that Mr Huang, a property developer, rather than the purported donor, had donated a large sum of money, of $100,000, to - ALP NSW;

(e) Ms Murnain alleges that I said to Ms Murnain:

(i) was Mr Wong telling the truth?;

(ii) did Mr Wong have any evidence?;

(iii) did Mr Wong give her any evidence that it happened? [and she said, "no he didn't"];

(iv) forget the meeting with me;

(v) do not diarise the meeting;

(vi) forget the conversation with Mr Wong; NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 Page 6

(vii) I would not charge her for the meeting;

(viii) I would not invoice the party for my time;

(ix) she should not talk about it with anyone;

(x) there is no need to do anything from here;

(xi) do not record this meeting;

(xii) do not put it in your diary;

(xiii) forget the conversation with Ernest happened;

(xiv) I will not be billing you for this; and

(xv) literally don't tell anyone about it;

(together with (b) to (e) above, the Alleged Conversation).

- 34. I respond to Ms Murnain's allegations as follows.

The Alleged Meeting

35. I do not have an independent recollection of a meeting with Ms Murnain on the evening of Friday 16 September 2016. My belief is, however, that such a meeting occurred based on my review of contemporaneous records. In particular, I refer to the time entry in the Holding Redlich tax invoice dated 30 September 2016, which refers to a meeting with Ms Murnain on 16 September 2016 (I refer to paragraph 31 above). I also rely on the further contemporaneous records noted below.

36. I have obtained from MLC building management a record of the use of my security access card at the MLC Centre on Friday 16 September 2016. It is my understanding that those records show that my security card was used to access the Level 65 lifts to Holding Redlich from the foyer at 7: 19PM on 16 September 2016. At page 11 of Exhibit ILR-1 is - a copy of that record. 37. I have seen Exhibit 173, which is a screenshot of an SMS message from Ms Murnain's phone to my phone on 16 September 2016. According to that exhibit, at 7:18PM, I received an SMS message from Ms Murnain to the effect that she was "at the top of the escalators". I believe that is a reference to the escalators leading into the MLC Centre from the corner of King Street and Castlereagh Street. At that time of the evening, access to the MLC Centre is restricted. The front doors of the MLC Centre, which face the corner of King Street and Castlereagh Street, may be opened by pressing a button on the inside of the building. Any person wishing to enter the MLC Centre after hours must be met at the front doors and escorted inside. NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 Page 7

38. It was my practice in 2016 to delete SMS messages shortly after receipt and it remains my practice now. As a result, I no longer have a record of the SMS message from Ms Murnain to me that is recorded in Exhibit 173.

39. I have also obtained Cabcharge records for Friday 16 September 2016. Those Cabcharge records indicate that I arrived home at Edgecliff at about 7:54 PM on Friday 16 September 2016. It takes approximately 15-20 minutes to drive from the MLC Centre to my house in Edgecliff on a Friday evening. At page 12 of Exhibit ILR-1 is a copy of that record.

40. From my review of the contemporaneous records described above, I believe that my meeting with Ms Murnain on the evening of Friday 16 September 2016 commenced at approximately 7:20PM and lasted for a short period before I left my office to go home. - The Alleged Conversation 41. I deny the Alleged Conversation.

42. I deny that the Alleged Conversation took place, on Friday 16 September 2016 or at any other time.

43. I deny that Ms Murnain told me that she had met with Ernest Wong.

44. I deny that Ms Murnain told me that Ernest Wong had told her that someone who said that they had donated money to the ALP had not in fact made the donation.

45. I deny that Ms Murnain told me that Mr Huang, a property developer, rather than the purported donor, had donated a large sum of money, of $100,000, to ALP NSW.

46. I deny that I said to Ms Murnain: - (i) was Mr Wong telling the truth?; (ii) did Mr Wong have any evidence?;

(iii) did Mr Wong give her any evidence that it happened? [and she said, "no he didn't"];

(iv) forget the meeting with me;

(v) do not diarise the meeting;

(vi) forget the conversation with Mr Wong;

(vii) I would not charge her for the meeting;

(viii) I would not invoice the party for my time;

(ix) she should not talk about it with anyone; NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 Page 8

(x) there is no need to do anything from here;

(xi) do not record this meeting;

(xii) do not put it in your diary;

(xiii) forget the conversation with Ernest happened;

(xiv) I will not be billing you for this; and

(xv) literally don't tell anyone about it.

47. I have never in my career as a solicitor ever given advice to the effect alleged by Ms Murnain.

48. I have never in my career ever counselled a client to cover up unlawful conduct.

49. I have reviewed my emails with Ms Murnain in the days before and the days following Friday 16 September 2019.

50. On the evening of Friday 16 September 2016, I was working on an advice concerning whether Mr Lalich MP had breached the State electoral donation laws by accepting a donation from a property developer to pay for overseas travel to China. I had also provided advice to Ms Murnain a day earlier about Senator Dastyari.

51. My belief is that when I met with Ms Murnain on the evening of Friday 16 September 2016, we discussed:

(a) the advice I was working on concerning Mr Lalich MP; and

(b) the advice I had given to Ms Murnain in relation to the position of Senator Dastyari.

The Notices to Produce issued by the Electoral Commission NSW in December 2016 - 52. On Thursday 8 December 2016 at 11 :46AM, Ms Murnain sent an email to Sarah and me attaching notices to produce issued by the Electoral Commission NSW. This was the first time that I became aware that the Electoral Commission NSW was investigating the ALP (NSW) about cash donations made at the Chinese Friends of Labor (CFOL) dinner in March 2015. It was also the first time that I had seen a reference to or heard about the CFOL dinner. At page 68 of Exhibit ILR-1 is a copy of that email.

53. On Friday 16 December 2016 at 5:17PM, I received an email from Ms Sibraa with the proposed response of NSW Labor to the questions in the notices to produce and the documents which NSW Labor intended to produce in response to the notices. At page 79 of Exhibit ILR-1 is a copy of that email and the attachments. A copy of my daily time sheet for Friday 16 December 2016 is at page 125 of Exhibit ILR-1. NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 Page 9

54. Ms Sibraa was appointed as the Governance Director of NSW Labor in early 2016. She had been a senior advisor to Labor parliamentarians in NSW including several ministers, including the Treasurer of NSW. I considered Ms Sibraa to be highly intelligent, capable, experienced and mature. My experience was that Ms Sibraa as the Governance Director had the responsibility for response to regulatory inquiries on behalf of ALP NSW. As at 8 December 2016 my experience from my dealings with Ms Sibraa was that Ms Sibraa was responsible for responding to regulatory notices and subpoenas for production, that she prepared her response based on inquiries she had made of relevant staff within ALP NSW, and that she dealt with regulatory notices and subpoenas for production, and the responses to them, thoroughly and efficiently.

55. I do not now recall reviewing the notices to produce or the proposed answers prepared by Ms Sibraa. My belief is, however, that my review would have been cursory. My records indicate that I did not question the accuracy of the answers to the Electoral Commission's - questions, or question the accuracy of the information contained within the documents provided. With the benefit of hindsight, I should have. My belief is that Ms Sibraa had prepared the responses to the regulatory notices, including the answers to the questions asked, from information provided to her by staff of NSW Labor. Ms Sibraa was the Governance Director and she had sent the email on 16 December 2016 enclosing the responses to the regulatory notices.

56. On Monday 19 December 2016 at 8:13AM, I sent an email to Sarah stating I thought the documents proposed to be disclosed to the Electoral Commission and the answers to the questions appeared to be okay. I requested Sarah to check them also and if she was satisfied with them to inform Ms Sibraa accordingly. Sarah replied to my email at 8:20AM. 9 At pages 126-128 of Exhibit ILR-1 is a copy of those emails.

57. On Monday 19 December 2016 at 3:27PM, Sarah sent an email to Ms Sibraa confirming that the documents were fine to be sent to the Electoral Commission. At page 130 of Exhibit ILR-1 is a copy of those emails.

58. A copy of my daily time sheet for Monday 19 December 2016 is at page 132 of Exhibit ILR-1.

59. On Tuesday 20 December 2016 at 9:40AM, Ms Murnain sent an email to me attaching a copy of the letters she had signed and sent to the Electoral Commission on behalf of NSW Labor and Country Labor. At page 133 of Exhibit ILR-1 is a copy of those emails. NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 Page 10

60. On Thursday 22 December 2016, I authorised a tax invoice to be prepared on behalf of the firm relating to advice provided to "ALP NSW Branch". That invoice records the following entry on 19 December 2016: "Review of Chinese Friends of Labor documents to be produced to NSW Electoral Commission." At page 144 of Exhibit ILR-1 is a copy of that tax invoice.

61. A copy of the prebill information for the tax invoice referred to above is at page 147 of Exhibit ILR-1. The handwriting on that document is Sarah's. I refer to my practice in relation to prebills as described in paragraph 32 above. -

- NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001

INDEPENDENT COMMISSION AGAINST CORRUPTION

OPERATION AERO

EXHIBIT LIST TO STATEMENT OF IAN LYALL ROBERTSON AO

1. Wednesday Email from Pat Garcia (PG) to Ian Robertson (IR} ILR-1, p 1 14.9.2016 with subject line "Article"

8:12PM

2. Thursday Email from IR to Kaila Murnain (KM) with subject ILR-1, p 5 15.9.2016 line "Receipt of money by Members of Parliament"

5:38PM

- 3. Friday Email from KM to IR with no subject line ILR-1, p 7 16.9.2016

4:48PM

4. Friday Email from Sarah Butler (SB) to IR with subject ILR-1, p 8 16.9.2016 line "Email to NSW ALP re Nick Lalich MP"

7:04PM

5. Friday MLC Centre building management records for ILR ILR-1, p 11 16.9.2016 security pass

7:19PM

6. Friday Cabcharge record ILR-1, p 12 16.9.2016

7:54PM

- 7. Friday Email from IR to SB with subject line "RE: Nick ILR-1,p13 16.9.2016 Lalich MP"

8:05PM

8. Saturday Email from IR to KM with subject line "Gift made to ILR-1, p 14 17.9.2016 a State MP"

11:50AM

9. Saturday Email from IR to KM with subject line "Receipt of ILR-1,p17 17.9.2016 money by Members of Parliament - Further Advice" 12:29PM

10. Saturday Email from IR to Liz Georgiou with subject line ILR-1,p19 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001

- 2 -

17.9.2016 "Additional time"

1:25PM

11. Saturday Email from KM to IR with subject line "Fwd: Borsak ILR-1, p 20 17.9.2016 v Cheung [2006] NSWADT 5

3:33PM

12. Saturday Email from IR to KM with subject line "Residency ILR-1, p 43 17.9.2016 issue in Fairfield"

4:28PM

13. Saturday Email from PG to IR with subject line "Fwd: dai le" ILR-1, p 44 17.9.2016

4:34PM

14. Saturday Email from KM to IR with subject line "Re: ILR-1, p47 - 17.9.2016 Residency issue in Fairfield" 4:35PM

15. Monday Email from IR to KM and PG with subject line "FW: ILR-1, p 49 19.9.2016 dai le"

4:42PM

16. Tuesday Daily Telegraph publishes "Nick Lalich: NSW ILR-1, p 52 20.9.2016 Labor MP referred to Electoral Commission over trip to China 12:00AM

17. Friday Holding Redlich tax invoice issued to ALP NSW ILR-1, p 54 30.9.2016 Branch regarding General Commercial and Legal Advice

18. Friday Holding Redlich prebill information ILR-1, p 59 30.9.2016

19. Wednesday Email from IR to KM with subject line "Holding ILR-1, p 67 - 5.10.2016 Redlich Tax Invoice - September 2016"

7:13PM

20. Thursday Email from KM to IR and SB with the subject line ILR-1, p 68 8.12.2016 "FW: Peter Smithers, Electoral Commission NSW - 11:46 AM Notices to Produce (Information and Documents) issued under s110A (1) (a) & (b) of the Election Funding, Expenditure and Disclosures Act 1981"

21. Friday Email from Julie Sibraa (JS) to IR and SB with ILR-1, p 79 16.12.2016 subject line "Notices to Produce (information and documents) issued under s 11 0A(1 )(a) & (b) of the 5:17PM Election Funding, Expenditure and Disclosures Act 1981"

2 .------NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001

- 3 -

22. Friday Holding Redlich daily timesheet for IR ILR-1, p 125 16.12.2016

23. Monday Email from IR to SB with subject line "FW: Notices ILR-1, p 126-127 19.12.2016 to Produce (information and documents) issued under s 11 0A(1 )(a) & (b) of the Election Funding, 8:13 AM Expenditure and Disclosures Act 1981"

24. Monday Email from SB to IR ILR-1, p 128 19.12.2016

8:20AM

25. Monday Email from SB to JS with subject line "Notices to ILR-1, p 130 19.12.2016 Produce (information and documents) issued under s 11 0A(1 )(a) & (b) of the Election Funding, 3:27PM Expenditure and Disclosures Act 1981"

26. Monday Holding Redlich daily timesheet for IR ILR-1, p 132 19.12.2016

- 27. Tuesday Email from KM to IR with subject line "Letters" ILR-1, p 133 20.12.2016

9:40AM

28. Thursday Holding Redlich tax invoice issued to ALP NSW ILR-1, p 144 22.12.2016 Branch regarding General Commercial and Legal Advice

29. Thursday Holding Redlich prebill information ILR-1, p 147 22.12.2016

30. IR mobile phone records for 6-17 September 2016 ILR-1, p 152-153 -

3 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 001

From: Pat Garcia Sent: Wednesday, 14 September 2016 8:12 PM To: Ian Robertson Subject: Article

htt12:/Lwww.smh.com.au/federal-polltics/potitical-news/sam-dasty_ari-may-have-brnken-federal-and-nsw labor-garty-rules-on-donations-20160907-gra9,s¥.html_

This email has been scanned by the Symantec Email Security.cloud service. For more information please visit http://www.symanteccloud.com -

1 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 002

EXCL•sSl'JC POLITICS FEDERAL Sam Dastyari may have brol

By James Massola Updated September 7, 2016 - 4.53pm, first published at 1.28pm

Embattled Labor Party senator Sam Dastyari appears to have broken federal and state Labor Party rules on political donations by allowing Chinese donors to make payments on his behalf for travel and legal bills.

The NSW Labor Senator also pulled out of a University of Queensland lecture he was scheduled to deliver on Wednesday evening as pressure mounted for him to quit. His appearance was cancelled without explanation, but young Liberals had been planning a protest at the event.

The revelations about possible Labor rule breaches - disputed by the NSW branch - ramped up pressure on the powerbroker senator to step aside, or for Labor leader Bill Shorten to reverse course and sack him.

They could could also prompt Labor's powerful national executive body to examine Senator Dastyari's actions.

Senator Sam Dastyari speaks to the media on Tuesday about the donations scandal. WOLTER PEETERS NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 003 The federal ALP's national platform contains a code of conduct for fundraising, first adopted in 1994, that all MPs are bound by.

The platform states that: "Members of the Parliament or candidates should not accept money or services on the party's or their own behalf, above the amount of $3000 from any one source. Donations that are accepted must be held in appropriate Labor Party central banking accounts styled in the form: Australian Labor Party Campaign Account."

Fairfax Media revealed in March 2015 that the Yuhu Group had paid a legal bill for Senator"f>astyarifn Tate 2014 worth about $5000.

Senator Dastyari confirmed during a press conference on Tuesday that the $5000 figure was "very close to the mark".

As well as the $5000 Yuhu payment, Senator Dastyari's decision to ask the Chinese government-linked Top Education Institute to pay a $1,670 bill - revealed by Fairf~x Medi~ la~ ~ee~ - appears to have breached NSW Labor Party ruTes.

Among other things the rules state all donations targeted for election campaigns or "in general, support the ALP'' must be deposited with the ALP.

But a spokesman for the NSW Labor general secretary Kaila Mumain claimed legal advice "suggests' there had been no breach because the candidate pledge only applied to fundraising for the purposes of an election campaign or for the ALP.

Comment has been sought from Senator Dastyari and Labor national secretary George Wright.

Several senior Labor sources told Fairfax Media the matters should be referred to either the state administrative body or national executive and that Senator Dastyari appeared to have committed a breach.

"He is clearly outside the code of conduct and it should be a matter for the national executive," one fom1er member of the federal executive said.

"His behaviour was highly inappropriate. It was also stupid."

A former member of the NSW administrative committee said it was "a fair interpretation of the rules" to suggest Senator Dastyari had breached the NSW candidate's pledge.

Former New South Wales premier Kristina Keneally - who worked with Senator Dastyari - said it was "time for Sam to get out of the way" and step down from the frontbench and as manager of opposition business in the Senate.

"When you do an explain and apologise press conference you have to have an explanation and he didn't. So he has to take himself out of the equation. My advice is he should take his lumps and go to the backbench."

Senator Dastyari attempted to put to bed the furore over donations on Tuesday in a lengthy press conference in which he admitted making a mistake 22 times but failed to answer one key question - why he had asked donors pay those travel and legal bills. NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 004 Treasurer Scott M01Tison led the calls from government for the Labor senator to step aside. "I resign" is what he should say. That's what he has to say. And he won't say that. So Bill Shorten must order his walk to the pavilion on this issue; he said.

- wth Nathanael Cooper

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James Massola . f 't# 1111 il>" • James Masso la is south-east Asia correspondent based in Jakarta. He was previously chief political correspondent, based in Canberra. He has been a Walkley and Quills finalist on three occasions, won a Kennedy Award for - outstanding foreign correspondent and is the author of The Great Cave Rescue. El

- NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 005

Liz Georgiou

From: Ian.Robertson@ Sent: Thursday, 15 September 2016 5:38 PM To: Kaila@ Cc: Pat@ Sarah.Butler@ Subject: Receipt of money by Members of Parliament [HR-SYD.F!D276823]

Dear Kaila,

We have, as requested, considered the position under the NSW Labor Rules and the ALP National Constitution in respect of a Member of Parliament receiving money from a donor by having the donor pay an account for legal fees or other expenses on his behalf.

Kind regards,

Ian Robertson I Partner ~ HOLDING REDLICH

Level 65, MLC Centre, 19 Martin Place, Sydney NSW 2000 Australia - -

' • ~ ••• I ; L: • • • LflW';)<:Mngc, Holding Redlich requests that all documents are sent to us electronically as PDF or Microsoft Word files

1 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 006

This email (Including any attachments) is conlldentlal and may be subject !0 legal pr0fesslonal privilege. CIiek here for more information and for advice on what to do If you have received this email by mistake.

2 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 007

Liz Georgiou

From: Kaila Murnain Sent: Friday, 16 September 2016 4:48 PM To: Ian Robertson

(1) Each of the following persons is a "property developer" for the purposes of this Division:

(a) a corporation engaged In a business that regularly involves the making of relevant planning applications by or on behalf of the corporation in connection with the residential or commercial development of land, with the ultimate purpose of the sale or lease of the land for profit,

(b) a person who is a close associate of a corporation referred to in paragraph (a).

(2) Any activity engaged in by a corporation for the dominant purpose of providing commercial premises at which the corporation or a related body corporate of the corporation will carry on business Is to be disregarded for the purpose of determining whether the corporation is a property developer unless that business Involves the sale or leasing of a substantial part of the premises.

Kaila Murnain GENERAL SECRETARY - Australian Labor Party (NSW Branch)

neyNSW2000

A.Y111 ·,··. 11 ~ Im www.nswlabor.org.au

This email has been scanned by the Symantec Email Security.cloud service. For more information please visit http://www.symanteccloud.com -

1 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 008

Liz Georgiou

From: Sarah Butler Sent: Friday, 16 September2016 7:04 PM To: Ian Robertson Subject: Nick Lalich MP Attachments: Email to NSW ALP re Nick Lalich MP vw .doc

Hi Ian

I am having a few issues with my remote access to File Site, so I have drafted the email in the attached Word document.

Please let me know If you have any comments or questions.

I am happy to spend some more time on this later tonight, but I have to head to dinner now so I thought I should send this to you fn the interests of time.

Kind regards,

Sarah > > NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 009

PRIVATE AND CONFIDENTIAL LEGAL ADVICE

Dear Kaila

Further to our telephone conversation this afternoon, as requested we have further considered the potential issues arising in relation to the trip taken by Nick Lalich MP in 2014 and paid for by the Managing Director of ABC Tissues, Henry Ngai.

Mr Ngal's status as a property developer

As you know, a property developer is a prohibited donor under section 96GAA of the Election Funding, Expenditure and Disclosures Act 1981 (NSW) (EFED Act). A property developer under is defined under section 96GB of the EFED Act as:

(o) a corporation engaged in a business that regularly involves the making of relevant planning opplicotions by or on behalf of the corporation in connection with the residential or commercial development of land, with the ultimate purpose af the sale or lease of the land for profit, {b) o person who is a close associate of a corporation referred to in paragraph {a).

- Accordingly, If Mr Ngai is considered a "close associateu of a property developer, it is unlawful for an elected member to receive a political donation from him. For completeness, we note that section 96GB(3) of the EFED Act provides that a "close associate" of a property developer is each of the following:

(a) a director or officer of the corporation or the spa use af such a director or officer, (b) o related body corporate of the corporation, (c) a person whose voting power In the corporation or a related body corporate of the corporation is greater than 2096 or the spouse of such a person, {d) if the corporation or a related body corporate of the corporation is o stapled entity in relation to a stapled security-the other stapled entity in relation to that stapled security, (e) if the corporation Is a trustee, manager or responsible entity in relation to a trust-a person who holds more thon 20% of the units in the trust (in the case of o unit trust) or is a beneficiary of the trust (In the case of o discretionary trust).

We understand that the ALP (NSW} is conducting due diligence in relation to the status of ABC Tissues as a property developer and Mr Ngai as a close associate of any property developer, including ABC Tissues if relevant. We would be happy to advise on this issue further once the ALP - (NSW) has received more information. A gift to an Individual in a private capacity is not a gift

We note that if the payment for the trip was made in a private capacity by Mr Ngai and Mr Lalich did not use the trip for a purpose relating to an election or his duties as an elected member, the payment for the trip will not constitute a gift. Accordingly, the payment for the trip would not be a political donation. Specifically, section 85(4)(a) provides that:

a gift to an individual that was made in a private capacity to the individual for his or her personal use and that the individual has not used, and does not intend to use, solely or substantially for o purpose related to an election or to his or her duties as an elected member... NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 010

We do not have sufficient information to provide definitive advice regarding whether section 85(4)(a) of the EFED Act will apply in these circumstances. However, we are of the preliminary view that it is unlikely that the payment for the trip will be caught by section 85(4)(a) of the EFED Act because, as we understand it, Mr Lalich made the trip primarily in his capacity as MP.

The payment for the trip was likely a political donations

We are of the view that the payment for the trip is likely a political donation, as it constitutes a gift made for the benefit of an elected member under section 85(1)(b} of the EFED Act.

As you know, the cap for political donations to or for the benefit of an elected member is $2,000 under section 95A of the EFED Act (to be indexed according to when in 2014 the payment was made: http://www.e lecti ons.nsw .gov .a u/fd/ po litica I_do nations/caps_ o n_po Utica I_donations}.

It is unlawful under section 95B of the EFED Act for a person to receive a political donation if the donation exceeds the applicable cap. Accordingly, if the payment for the trip was in excess of the relevant cap, it was unlawful for Mr Lalich to receive that gift. - Offences relating to caps and penalty for breach The maximum penalty for breach of section 95B of the EFED Act is 400 penalty units (being $44,000) or imprisonment for 2 years, or both (section 96HA of the EFED Act).

However, in order to be guilty of an offence under section 95B of the EFED Act, the person must have been, at the time of the act, aware of the facts that result in the act being unlawful. Accordingly, in order to have committed an offence, Mr Lalich must have been aware that the payment for his trip was in excess of the applicable cap.

We hope that above advice is sufficient for your present purposes. Please contact us if you wish to discuss any of the above in further detail.

Kind regards,

Ian. NSW ICAC EXHIBIT e, PRN E18/0093/AS-04-067/PR-0001 - Printed: 28/08/2019 7:26:27 PM ICY. Printed By: Security

...... 0 ...... 3697051I User Ian R.~bertson (UN8362) Floor Unlocked Level 65 ( I116/09/2016 7:19:22 PM Ilian Robertson !scHINDLER HU I 3696391! User Ian Robertson (UN8362) Floor Unlocked Level 65 ( !116/09/2016 6:42:06 PM Ilian Robertson ISCHINDLER HU I

ICTr)r,J t(: i:'I;;;GX. www.incontrol.co.nz Page: 18 of 19 tl,,.,.,i NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 012

Account: 09553090 Period: 2016 - 10 Page 2 of 3 HOLDING REDLICH - SYDNEY --,.·------··-··-·····--·------·-----·---7 DOMESTIC ELECTRONICJ.RANS_ACTIONS .. ______, Card Number Name Taxi Fare

- NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 013

Ian Robertson

From: Ian Robertson Sent: Friday, 16 September 2016 8:05 PM To: Sarah Butler Subject: Re: Nick Lalich MP

I'm sure that will do for tonight. Thank you for your help. Kind regards, Ian

Ian Robertson Partner, Holding Redlich, Lawyers, Australia.

[email protected] www.holdingredlich.com.

> On 16 Sep 2016, at 7:03 PM, Sarah Butler >Hi Ian > - > I am having a few issues with my remote access to File Site, so I have drafted the email in the attached Word document. > > Please let me know if you have any comments or questions. > > I am happy to spend some more time on this later tonight, but I have to head to dinner now so I thought I should send this to you in the interests of time. > > Kind regards, > > Sarah > - NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 014

~~Liz Georgiou~~

~~From: Ian.Robertson Sent: Saturday, 17 September 2016 11:50 AM To: Kaila Cc: chris.willis Pat Sarah.Butler Subject: Gift made to a State MP [HR-SYD.FID276823]~~

~~PRIVATE AND CONFIDENTIAL LEGAL ADVICE~~

~~Dear Kaila~~

Further to our telephone conversations yesterday afternoon and evening, we have as requested further considered the potential issues arising in relation to the trip taken by a State MP In 2014 and paid for by the Managing Director of ABC Tissues, Henry Ngai or an entity associated with him.

~~Mr Ngai's status as a property developer~~

As you know, a property developer is a prohibited donor under section 96GAA of the Election Funding, Expenditure and Disclosures Act 1981 (NSW) (EFED Act). A property developer is defined under section 96GB of the EFED Act as:

(a) a corporation engaged in a business that regularly involves the making of relevant planning applications by ar on behalf of the corporation in connection with the residential or commercial development of land, with the ultimate. purpose of the sale or lease of the land for profit, {b) a person who is a close associate of a corporation referred to in paragraph (a).

Accordingly, if Mr Ngai is considered a "close associate" of a property developer, it is unlawful for an elected member to receive a political donation from him. For completeness, we note that section 96GB(3) of the EFED Act provides that a "close associate" of a property developer is each of the following:

(o) o director or officer of the corporation or the spouse of such a director or officer, (b) o related body corporate of the corporation, (c) o person whose voting power in the corporation or a related body corporate of the corporation Is greater than 20% or the spouse of such a person, (d) if the corporation or a related body corporate of the corporation is o stapled entity in relation to a stapled security-the other stapled entity in relation to that stapled security, (e) if the corporation is a trustee, manager or responsible entity in relation too trust-a person who holds more than 2096 of the units in the trust {In the case of o unit trust) or is a beneficiary of the trust (in the case of o - discretionary trust).

We understand that the ALP (NSW) Is conducting due diligence in relation to the status of ABC 1issues and other companies of which Mr Ngai is a director to ascertain whether any of them are property developers within the meaning of the EFED Act. We would be happy to advise on this issue further once the ALP (NSW) has received more information.

~~A gift to an Individual in a private capacity is not a gift~~

We note that if the payment for the trip was made in a private capacity by Mr Ngai and the State MP did not use the trip for a purpose relating to an election or his duties as an elected member, the payment for the trip will not constitute a gift. Accordingly, the payment for the trip would not be a political donation. Specifically, section 85(4)(a) provides that: NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 015

a gift ta an individual that was made in a private capacity to the individual for his or her personal use and that the individual has not used, and does not Intend ta use, solely or substantially for a purpose related to an election or to his or her duties as an elected member...

We do not have sufficient information to provide definitive advice regarding whether section 85{4)(a) of the EFED Act will apply in these circumstances. However, we are of the preliminary view that it is unlikely that the payment for the trip will fall within the exemption in section 85(4)(a) of the EFED Act because, as we understand It, the State MP made the trip primarily in his capacity as an MP and that is why Mr Ngai or an entity associated with him paid for it.

~~The payment for the trip was most likely a political donations~~

~~We are of the view that the payment for the trip is most likely a politica I donation, as it constitutes a gift made for the benefit of an elected member under section SS(l)(b) of the EFED Act.~~

As you know, the cap for political donations to or for the benefit of an elected member is $2,000 under section 95A of the EFED Act (to be indexed according to when in 2014 the payment was made: http://www.elections.nsw.gov.au/fd/polltical_donations/caps_on_political_donations).

It is unlawful under section 958 of the EFED Act for a person to receive a political donation if the donation exceeds the applicable cap. Accordingly, if the payment for the trip was in excess of the relevant cap, it was unlawful for the - State MP to receive that gift. Offences relating to caps and penalty for breach

~~The maximum penalty for breach of section 958 of the EFED Act is 400 penalty units {being $44,000) or imprisonment for 2 years, or both (section 96HA of the EFED Act).~~

However, in order to be guilty of an offence under section 958 of the EFED Act, the person must have been, at the time of the act, aware of the facts that result in the act being unlawful. Accordingly, in order to have committed an offence, the State MP must have been aware that the payment for his trip was In excess of the applicable cap or was from a property developer.

We hope that the above advice is sufficient for your present purposes. Please contact us if you wish to discuss any of the above in further detail. I will be out of Australia on leave from tomorrow afternoon but my colleague Sarah Butler is available. Sarah's mobile number is

~~Kind regards,~~

~~Ian.~~

~~Ian Robertson I Partner ij HOLDING REDLICH~~

~~Sydney • Melbourne • Brisbane Lov,5"~~~~-~I!~ Holdlng Redlich requests that all documents are sent ta us electronically as PDF or Microsoft Word files~~

~~2 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 016~~

This email (Including any attachments) Is confidential and may be subject to legal professional privilege. Cljck here for more infom,ation and for advice on what to do If you have received this email by mistake.

~~3 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 017~~

~~Liz Georgiou~~

From: [email protected] Sent: Saturday, 17 September201612:29 PM To: Kaila Cc: Pat••••••: Sarah.Butler Subject: Receipt of money by Members of Parliament - Further Advice [HR-SYD.FID276823]

~~Confidential~~

~~Dear Kaila,~~

Further to my email (below) ofThursday two of my Victorian colleagues who are also experienced in advising the ALP on rules matters have given further consideration to the issue of the ALP's "Code of Conduct for Fund raising" in the ALP National Constitution.

~~Ian.~~

~~Ian Robertson I Partner ~ HOLDING REDLICH~~

Sydney • Melboume • Brisbane Lr,,v '7Y,Chl'I ngc Holding Redlich requests that all documents are sent to us electronically as PDF or Microsoft Word flies NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 018

~~From: [email protected] Sent: Thursday, 15 September 2016 5:38 PM To: Kaila Cc: Pat Sarah.Butler Subject: Receipt of money by Members of Parliament [HR-SYD.F!D276823]~~

~~Dear Kalla,~~

~~Ian Robertson I Partner ~ HOLDING REDLfCH~~

~~Level 65, MLC centre, 19 Martin Place, sydney NSW 2000 Australia~~

~~Sydney • Melbourne • Brisbane u,1119~11~nc" Holding Redlich requests that all documents are sent to us electronfcally as PDF or Microsoft Word flies~~

This email (including any attachments) Is confidential and may be subject to legal professional priv~ege. Click here for more Information and for advice on what to do If you have received this email by mistake. This email (incillding any attachments) is confldentlal and may be subject to legal professlonai privilege. Click here for more information and for advice on what lo do if you have received this email by mistake.

~~2 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 019~~

~~Liz Georgiou~~

~~From: Ian Robertson Sent: Saturday, 17 September 2016 1 :25 PM To: Liz Georgiou Subject: Additional time~~

~~Hi Liz~~

~~/ 1Please put in 10 units of time on the ALP General file 14 66 0005 on Friday - telephone conversations and meeting · with Ms K Murnain concerning political donation issues.~~

~~Many thanks, Ian.~~

~~Ian Robertson Partner, Holding Redlich, Lawyers, Australia.~~

~~;-.... [email protected]~~

~~h .11w.holdingredlich.com.~~

~~1 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 020~~

~~Liz Georgiou~~

~~From: Kaila Murnain~~

~~Pat will brief you on this one.~~

~~Thank you Kaila~~

~~Sent from my iPhone~~

~~- Borsak v Cheung [2006] NSWADT 5 CITATION: This decision has been amended. Please see the end of the decision for a list of the amendments.~~

- NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 ------~-~---~-~- NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 043

~~Liz Georgiou~~

~~From: lan.Robertso~ Sent: Satur~016 4:28 PM To: Kaila ...... Cc: Pat~~

~~Dear Kaila,~~

~~As you know my urgent advice has been sought by Pat Garcia this afternoon -~~

~~Kind regards,~~

~~Ian.~~

~~- Ian Robertson I Partner ~ HOLDING REDLICH~~

~~Sydney . Melbourne , Brisbane L~V113,/CCIH11lgO Holding Redlich requests that all documents are sent to us electronically as PDF or Microsoft Word files~~

This email (including any attachments) Is conridentlal and may be subject to legal professional privilege. Click hare for more information and for advice on what to do if you have received this email by mistake.

~~1 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 044~~

~~Liz Georgiou~~

~~From: Pat Garcia Sent: Saturday, 17 September 2016 4:34 PM To: Ian Robertson; Kaila Murnain Subject: Fwd: dai le Attachments: [Untitled].pdf; ATT00001.htm~~

~~- NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001~~

~~2 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 046~~

~~13/09/2016 New..Local digital edition- Fairfield Advance - 17 Aug 2016- Page#3~~

~~WEDNESOAY, AUGUST 17. 2(111, I FAlRFID.llADVAtlCE.COM.All NEWS 03 Mayoral rivals hit back in puppetmaster claim~~

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Jk!lll~l~al ,\lnlli;lrn1!I'. wi1l,rm:i., t.<,~·,11·,u:ifl':U !\:ii\\' 1t:.lf. ;tl1 l) mi ();, ~\111. 1hi1~· :J.rP '"11::d.ii,- llnl\-4. ~IM.•ffl ~r Ill w:a!lo n!.lll;! }'n11-. .. ,~~, l!W \",<>t1,· ,hr•'it, llm ., "'[n1uv:holar.1 lw111:r•AW• c1tt1rlld,':Jtr nr-N1~d "' l~ l'li• 11, "'!:nr.d ni;.~r."l1\1Ul'S.t~l"' •

~~1Up:flneY.5local.1"1B'Mipaperdirect.com'epaper/llewer.aspx 1/2 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 047~~

~~Liz Georgiou~~

~~From: Kaila Murnain~~

~~Thank you- appreciate it~~

~~Sent from my !Phone~~

~~On 17 Sep 2016, at 4:28 PM, Ian Robertson~~

~~Dear Kaila, - As you know my urgent advice has been sought by Pat Garcia this afternoon~~

~~Kind regards,~~

~~Jan.~~

~~Ian Robertson j Partner~~

~~Level 65, MLC ceotre, 19 Martin Place, Sydney NSW 2D00 Australia~~

~~Sydney. Melbourne. Brlsbaoe Holding Redllch requests that all documents are sent to us electronically as PDF or Microsoft Word flies NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 048~~

~~2 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 049~~

~~Liz Georgiou~~

~~From: Sent: To: Cc: Subject: Attachments:~~

~~It would appear that~~

~~Kind regards,~~

~~Ian.~~

~~From: Pat Garcia Sent: Saturday, 17 September 2016 4:34 PM To: Ian Robertson~~

~~13/09/2016 Ne....sLocaJ digital edition· Fairfield ACMlnce • 17 Aug 2016 • Page #3~~

~~WEONESMV, AUGUST 17, 2016 I FAllflD.DADVANC££OM.AU NEWS 03 Mayoral rivals hit back ,'I in puppetmaster claim ~· 1 ,...,,._.,.1.11,o,p ...... ~~~

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»ft1111P"III tihe\lhl n;,~ ~ny ~t:.ol! h\"Nt H She Is 1.a1:1n, it 1~i :lw )1¢!plj• k• tk-Vt~ d11 \!i~llil ti'> ~);;; ,,.k-L'llan ,r. .~ W)',ldlJhtttJ;t;trl1Jally lv);n1• i!.1 01~!Wf<'h HCl bUI ft.lit. $};e, •!',,i:,!~m d,l} \\'b«~l:er t 'm :..x.,l CC\.fO:nwnt n.rt-t,, Wat,; ll•t«I '11th•~• l.i!M'r,,I Poi.-· :-~~dnrl}' u5'.'d 1hr- l-:'lh'flecfd ~olan \\'01'tbY l!J:'C})\~~r'U Ihm,-;_ "' tf1 ~:)11>;.\' ,I b.'lnhi\••lirm 1f:t lht< i1:l'u1.mm!idmc •.:\U.Lei.nt~1ru, \\:·e« rt~lb.,;-~, in ltt."tduue,: ttt Asian popWtlon In A NSW" Ll!ti•t':ll Purty .tl"l0.'1. 1':tm ..u:.;.ld 00 ln tbt• o,tt,'l'ft h: f'>ltllfld Wo,t, :t c-oc~nr-1:1"r&1id fit.1}\~lttwr~~ Falrlltld to get elected .'fJOk:tSWOt'HID $:lh! a:t Llb· re.rm t'.',f owning. :1 n•11:ld\'1~ro • bm.C:-MoUu,.»f:ttc; tlu J\·!t>t •t!:1-rnw~•h~~" .t::ntl conmtun ...:-,,1 P.u,r c;.m!id.,lff \txar"' hi!\'i~d hl~s.vt n!l!~tt~;; ,o O.tl-.~tl: Htll. ~ty1,.•\\'flt$. t~~J¼te:ll f.'lf)UI; rm rn.1r r.t0p, +U".i. ~C'I .,-:,: u:irl :.ht.•1~ W""Jl" !WU t-:..11'1'1 a\FJm hN! uh~~i:."111& "-"!:}:. m~. rhi:tt :,he, rcsitk,;,. m [)u,hrll:h 1M,.-t.:,,ur 1h:11 a..._""Sr.'t m..-..•1 :.~ M~d :.!;-: uf tt-✓, l.,:)C-al ;~.,.,1,. p:wk-.'!r. at ll1Jtw:tl', Jhll." l;~11" hi+'i ·"*--"' is t;-ikl.;·,G '1d,.;.mt:1~ :IJ~t$.rih\'M1Mt. iaJ1( "~i•mmntH>a:t~:m~ ltt•·, ,11-d r:rL.,,.wl),l;":il~bs...-:n.r..F:1!l0• iWIO~ ~bJlott nw .. !.Ir ;.Ii~ ~-\tli.lil ~1atl"~iwt lU "'F1.1lt,;,1...:m1,.'. tlw~ '-·lt•tm~ hy }i(Y.('11.ti:~l .-::1nd1d~t,--> ..iti.: ti~l~-Cnt:.ndl \",i,101'.lkl;t:l;"ii:'l«' t·,· Lll- J!!',t\\· 1t1;. i."t C.;lm, f;•~rf.:,t4f hii,lt"i dt-l'h;I<(},'" ..:timtn.: li.l h::tu. th+. 11;1t"l-.V ii-: rfttndir.;i; tr. t}..-f ;,lh•~· m;.>nn1: ~;,r~~1r.a1~ iuqolr,. l:U'tHf,G omc~,., > ()~~ ~,~t-.,i.. rr-cvt-d tb:tt 1tw \i'.i-• ?lt~~b!<-! "Cili•nlAAllmt DAI\':,: l1 ~ al,,;t'F,.s..,~I -~ cli.Jmk;.;~J:h10:'tr1 li!r ),n,tu:: ''lf' ~l",.ttn~ ttjJj.'flW.,Jtlt.tH•I).' rd :t"tC"ul t1Wt<:1!1W:-ltf ~If.'\',.. fr ~1,,Jh:,10 :;n1d :,e tK<• 1}\\-1: lMliH,'-t11,unhi~\w:UL Wilhn\l"'! f;.;,\'t1-l·,u7'1:i>tH ~,S\\' .<.",ir. n.U ., im [b? i·,:u. t11P_\.' :It¥ ~hpl/11' rh.. n,;. Ut\'00 Cr ,~ "• .,!Ii nt.m~ >·n1r; •·)ff 1-:1:~' 1.''i(+"' ~1\1'~~ U:)f ,l "lt.m\\•t,o,j:n:1,t\.\'ill:N1W ~:nmUd.·-.u•• nl'Nlrri f~t h~ 1-li~ t,1 ~::t~d it!- :i. rmutin:1~it ..

~~11tp://MV.slocal.newspaperdirect.com'epaper/\Aw.er.aspx 1(2 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 052~~

Nick Lalich: NSW Labor MP referred to Electoral Commission over trip to China EXCLUSIVE: LABOR MP Nick Lalich referred to Electoral Commission, over a developer spending thousands on him for travel to China. EXCLUSIVE Andrew Clermell. State Political Edi1or The Da!lv Teleqraph Subscriber only I September 20, 2016 12:00arn

CABRAMATIA Labor MP Nick Lalich has been referred to the NSW Electoral Commission by his leader, Luke Foley, after The Daily Telegraph inquired over a developer spending thousands on Mr Lalich for travel and accommodation for a trip to China.

Mr Foley told The Daily Telegraph last night he would send the matter to the Electoral - Commission for "clarification" as to whether the 2013 gift was a donation, which could be illegal under electoral laws.

~~"I expect the highest standards of conduct from my MPs and take these allegations sedously," Mr Foley said.~~

~~"In the interests of the party and to ensure trust in parliamentarians remains intact I have asked the member to refer the matter to the Electoral Commission for clarification."~~

~~The trip to China in 2013 was with a Henry Ngai to "clistrilJutc hearing aids". But Mr Ngai also owns several development companies.~~

In his pecuniary interest register, Mr Lalich wrote: "At the invitation of Mr Henry Ngai, owner of the ABC Tissues Hearing Xpress, I travelled to China to assist him with distributing hearing aids to the underprivileged people in the province of Henau. - "Travel was undertaken from the 6th April 2014 to the 18th of April 2014. "All airline travel costs were paid by ABC Tissue Hearing Xpress and accommodation was paid on a shared basis."

~~A company search of Mr Ngai's interests show that he has development coinpanies based in NSW called New South Wales Properties Development Pty Ltd and Golden Property Pty Ltd.~~

~~Mr Ngai said he had attempted to develop in NSW but had yet to do so but had developed in Perth and Brisbane. NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 053 Page 2~~

Mr Lalich said last night: "I complied with the regulations and declared on the public record that my expenses were paid by ABC Hearing Express when I volunteered in a personal capacity to help distribute hearing aids in China.

"AB it was a charitable organisation and not a development company, I didn't believe there was anything wrong in making the tlip. However, in order to remove any doubt I have been asked by the Labor Leader to write to the NSW Electoral Commission asldng them to clarify the matter."

~~Mr Lalich said he had given "and fitted hundreds of hearing aids to underprivileged hearing-impaired children and adults in China.~~

~~"It was a very emotional and moving experience to be able to help these people."~~

The issue comes on the heels of Federal Labor MP Sam Dastyari resigning from the frontbench over a donation from a Chinese company for travel in China, despite the - donation being within the rules. NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 054 H HOLDING REDLICH

~~Tax Invoice ABN 15 364 527 724~~

~~30 September 2016~~

~~ALP NSW Branch Invoice Level 9, Labour Council Building Contact 377~383 Sussex Street Direct line SYDNEY NSW 2000 Email Our ref~~

~~General Commercial and Legal Advice~~

~~Professional fees for the period up to and including 25 September 2016 as per $18,687.11 attached schedule of professional fees~~

~~Plus GST $1,868.71 - Total amount owing for fees and expenses including GST $20,555.82~~

~~With compliments Holding Redlich HoLcJiJ ~ecll; UL~~

This invoice ls payable within 14 days Liability limited by a scheme approved under Professional Standards Legislation - Sydney. Melbourne. Brisbane tevel 14 60 Castlereagh Street GPO Box 411.l! Sydney NSW 2001 T www.holdingredlich.com

~~FIie number: ILR:14660005 Payor: 57953:ALP NSW Branch Tax Invoice; 438198 Amount due: S 20,SSS.82 Email remittance advice to: [email protected]~~

How ta pay: by mail: Detach this section and mail your cheque to: credit card payments Accounu Department, Cill + 612 8083 0388 to pay via Mastercard or Visa Holding Redllch, GPO Bax 4118, Sydney NSW 2001 quote ref: 438198

~~A Direct .,_Deposit~~

Telephone and Internet Banking - BPAY Ccntact vaur b1nk,,cr1dil: unfon or bUi!dirc sorltl)! to m1k1 this payment. ftOl'l'l yaur cheque. savin1s.. d1bi1 0rcredll 01d •«cur,.\, Moi-fnfo:www.bpav.com..au NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 055 Tax Invoice 438198 / Page 2 of 5

~~Fees Schedule Detailed schedule of professional fees Date Description 30/08/16~~

~~31/08/16~~

~~01/09/16~~

~~02/09/16~~

~~07/09/16~~

~~08/09/16~~

~~09/09/16~~

~~- 15/09/16~~

16/09/16 Telephone discussions and meeting with Ms K Murnain concerning political donation Issues; Drafting email of advice to Ms K Murnain regarding political donations. 17/09/16 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 056 Tax invoice 438198 / Page 3 of 5

~~Fees Schedule Detailed schedule of professional fees Date Description 19/09/16~~

~~20/09/16~~

~~21/09/16 22/09/16~~

~~23/09/16~~

~~25/09/16 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 057~~

~~Tax invoice 438198 / Page 4 of 5~~

~~Fees Schedule Detailed schedule of professional fees~~

~~Date Description~~

~~Total Fees $20,763.45 Less 10% discount $18,687.11~~

~~Fee Earner Summary~~

~~Billable Hours Rate~~

~~Partner 5.00 Partner 13.50 Senior Associate 28.00 - Graduate 6.30~~

~~- NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 058 Tax invoice 438198 / Page 5 of 5~~

~~Your rights in relation to legal costs Leger/ Profession Act 2004 (NSWJ~~

~~The following avenues are available to you If you are not happy with this bill:~~

~~• requesting an itemised bill;~~

~~• discussing your concerns with us;~~

~~• having our costs assessed;~~

~~• applying to set aside our costs agreement.~~

~~There may be other avenues available in your State or Territory, such as mediation.~~

For more information about your rights, please read the fact sheet titted Your right to challenge legcrl costs. You can ask us for a copy, or obtain it from your local Law Society or Law Institute (or download it from their website).

~~Interest on unpaid amounts~~

If you do not pay our account within 30 days of receiving it, we may charge interest on the unpaid amount at the Cash Rate Target, as at the date our bill was Issued, Increased by 2 percentage points. The Cash Rate Target means the percentage {or maximum percentage) stated by the Reserve Bank of Australia as the Cash Rate Target. NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 059 HOLDING REDLICH

Prebill Information Prebill: 465774 Prebill Print Date: 29/09/16 Prebill created DcJte: 29/09/16 Client Number: 57953 Session Number: 261307 Cllent Name: ALP NSW Branch Matter Number: 14660005 Prebill crecJted by: Georgiou, Uz(LZG)

~~Matter Name: General Commercial and Legal Advice~~

Partner Responsible: ILR Fees Billed to date: $190,616 BUling Resp (MFE}: ILR Fee Estimate: $0 Last Bill Date: 30/08/16 Total Matter AR: $0 Available Trust: $0.00 (refer to trust - summary below) Payor: 57953 : ALP NSW Branch Payor Address: ALP NSW Branch Level 9, Labour Council Building 377-383 Sussex Street SYDNEY NSW 2000

PLEASE NOTE: If the PAYOR or ADDRESS details above are not EXACTLY as you Legend require for the tax invoice, DO NOT proceed to edits. Deselect this pre bill and T = Transfer contact your local Finance representative to action changes/amendments. S = Split W/0 = Write Off

~~Fee Summary Base To Bill Lawyer Name Lawyer Base Hours Amount Amount~~

~~Greg Wrobel GJW S.00~~

~~- Ian Robertson ILR 13.50~~

~~Sarah Butler SLB 28.00~~

~~Yunsi Feng YXF 6.30~~

~~Total Fees $20,763.45 $20,763.45 ,__ _,, ~···- -·--· ·••·~ i~:{~~) l:t,J~J t-. .;C>l· 11, , I") k -th <2Uf~~

~~I I• / .1 I I '. ,,,,;t/ V'L/"'.~ .••-/ fi:J'. ' . ',, ) Ct•'l-Y>Ov'h t- 7 . J 'I /,l/::I._I,,\ .·~~

~~Par.e lof 8 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 060 H HOLDING REDLICH~~

~~Disbursement Summary~~

~~Date Description Amount~~

~~Total Disbursements $0.00~~

~~Trust Summary~~

~~Transfer Amount~~

~~Trust Balance: 2 - Holding Redlich Trust No. 2 $0.00 - Transfer to bill for ALP NSW Branch~~

~~Pa~~ 2of 8 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 061 H HOLDING REDLICH~~

~~Period of Account up to: 29 September 2016~~

~~Fee Detail To Bill To Bill Time Id Date lawyer Description Hours Amount~~

~~4985488 30/08/16 SLB~~

~~4991934 31/08/16 ILR~~

~~4991365 31/08/16 SLB~~

~~4991347 01/09/16 SLB~~

~~- 4991940 02/09/16 ILR 4989627 02/09/16 SLB~~

~~4994110 07/09/16 ILR~~

~~Page 3 of 8 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 062 H HOLDING REDLICI-I~~

~~Fee Detail To BIii To Bill Time Id Date lawyer Description Hours Amount 4994468 07/09/16~~

~~4995230 08/09/16 ILR~~

~~- 4996288 08/09/16 SLB~~

~~4997096 09/09/16 ,,,--ILR casneJ "-t. 4997101 09/09/16 ILR~~

~~4996274 09/09/16~~

~~5003635 15/09/16 ILR~~

~~5003669 16/09/16 ILR Telephone discussions and meeting with Ms K Murnain concerning political donation issues. 1.00 607.50~~

~~Page 4 of 8 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 063 ij HOLDING REDLlCH~~

~~Fee Detail To Bill To Bill Time Id Date Lawyer Description Hours Amount~~

5006002 16/09/16 SLB / Drafting email of advice to Ms K \() Murnain ~eg,arding ,a-tr-lp-ta~~n._:~tan; ,LMP: tjC, \ I t,co.J C(;ord)\.\_J,./ fl ,,. /r-elephone.attendance. .upm.1 .. MsJ< \/... Mumainl 1.20 367.20 j 5003550 17/09/16 GJW

~~- 5003818 19/09/16~~

~~5005982 19/09/16 SLB~~

~~5004447 19/09/16~~

~~Pa Be 5 of 8 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 064 H HOLDING REDLICH~~

~~Fee Detail To Bill To Bill Time Id Date Lawyer Description Hours Amount~~

~~5005754 20/09/16 GJW~~

~~5011491 20/09/16 ILR~~

~~5010358 20/09/16 SLB -~~

~~5006275 20/09/16 YXF~~

~~5006648 21/09/16 GJW~~

~~5008351 22/09/16 GJW - S010315 22/09/16 SLB~~

~~Pace Gal 8 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 065 H HOLDING REDLICH~~

~~Fee Detail To Bill To BIii Time Id Date Lawyer Description Hours Amount~~

~~5008453 22/09/16 YXF~~

~~5009061 23/09/16 GJW~~

~~5011496 23/09/16 ILR~~

~~5010290 23/09/16 5LB~~

~~- 5009565 23/09/16 YXF~~

~~5011501 25/09/16 ILR~~

~~Par,.: 7 of 8 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 066 H HOLDING REDLICH~~

~~Fee Detail To Bill To Bill Time Id Date Lawyer Description Hours Amount~~

~~5010277 25/09/16 SLB~~

~~- Matter Summary Total to Bill Total Fees $20,763.45~~

~~Total Disbursements $0.00~~

~~GST $2,076.35~~

~~Total Amount $22,839.80~~

~~AUTHORISATION~~

~~Partner~~

~~Executive Committee~~

~~Pase 8 of s NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 067~~

~~Liz Georgiou~~

~~From: Ian.Robertson Sent Wednesday, 5 . . .. . ~ To: l~~

~~Hi Kalla~~

~~I am attaching our account for the considerable volume of work that we performed for the ALP (NSW) in September, including for our general commercial and legal advice in relation to: -~~

~~a paid-for trip taken by an MP in 2014 and whether that trip constitutes a donation under the Election Funding Expenditures and Disclosures Act 1981 (NSW);~~

As you know, we apply a discount of 10% to our usual hourly rates for work we do for the ALP (NSW) (and we don't, of course, charge for every phone call and email). In addition, this month we have applied a further discount of 10% to bring the bill to under $20K before GST.

~~Please contact me if you or your colleagues require any additional information.~~

~~Kind regards,~~

~~Ian.~~

~~- Ian Robertson I Partner H HOLDING REDLICH Level 65, MLC Centre, 19 Martin Place, Sydney NSW 2000 Australia GPO Box 4118, Sydney NSW 2001~~

~~Sydney. Melbourne • Brisbane Lawty:,~~?.~.~:~~

This email (Including any attachments) is confidential and may be subject to legal professional privilege. Click here for more Information and for advice on what to do if you have received this email by mistake. NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 068

~~Liz Georgiou~~

From: Kaila Murnain Sent: Thursday, 8 December 2016 11:46 AM To: Ian Robertson; Sarah Butler Cc: Julie Sibraa Subject: FW: Peter Smithers, Electoral Commission NSW - Notices to Produce (Information and Documents) issued under s 11 0A (1) (a) & (b) of the Election Funding, Expenditure and Disclosures Act 1981 EC0000628 & EC0000629 Attachments: 08122016092406-0001.pdf; ATT00001.htm

~~Kaila Murnain GENERAL SECRETARY Australian Labor Party (NSW Branch)~~

~~Level 9, 377·383 Sussex St, Sydney NSW 2000~~

~~Cl www.nswlabor.org.au~~

From: Julie Sibraa Sent: Thursday, 8 December 2016 11:28 AM To: Maggie Wang< Cc: Kaila Murnain < Subject: FW: Peter Smithers, Electoral Commission NSW - Notices to Produce (Information and Documents) issued under sll0A (1) (a) & (b) of the Election Funding, Expenditure and Disclosures Act 1981 EC0000628 & EC0000629

From: Ellyse Harding Sent: Thursday, 8 December 2016 10:34 AM To: Julie Sibraa < Subject: Fwd: Peter Smithers, Electoral Commission NSW - Notices to Produce {Information and Documents) issued ( under sllOA {1) (a} & {b) of the Election Funding, Expenditure and Disclosures Act 1981 EC0000628 & EC0000629 See attached - Kind Regards, Ellyse Harding Executive Officer NSWLabor

~~Begin forwarded message:~~

From: "Executive Assistant" > To: "OMS" Cc: "Ellyse Harding" < Subject: Peter Smithers, Electoral Commission NSW - Notices to Produce (Information and Documents) issued under sllOA (1) (a) & (b) of the Election Funding, Expenditure and Disclosures Act 1981 EC0000628 & EC0000629

~~1 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 069~~

~~Rebecca Leary Executive Assistant to Pat Garcia & Rose Jackson (Part Time: Alternate Wednesday's, Thursday & Friday) Australian Labor Party (NSW Branch)~~

~~I W: www.nswlabor.org.au A: Level 9, 377 Sussex Street, Sydney NSW 2000~~

~~-----Original Message---- From: ApeosPort-V C7775 T Sent: Thursday, 8 December 2 To: Rebecca Leary •• Subject: Scan Data from FX-D6B2EA Number of Images: 9 Attachment File Type: PDF~~

~~Device Name: ApeosPort-V C7775 T2 Device Location:~~

~~This email has been scanned by the Symantec Email Security.cloud service. For more information please visit http://www.symanteccloud.com -{~~

~~2 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 070~~

~~Our Ref: 2016/74~~

~~Australian Labor Party (NSW Branch) ('ALP') Level 9, 377-383 Sussex Street SYDNEY NSW 2000~~

~~6 December 2016~~

~~To: The Proper Officer~~

~~Notices to Produce (Information and Documents) issued under s110A(1)(a)&(b) of the Election Funding, Expenditure and Disclosures Act 1981~~

The New South Wales Electoral Commission ("the Commission") is a statutory body responsible for regulating and enforcing compliance with the Parliamentary Electorates and - Elections Act 1912 ("PEE Act"), Election Funding, Expenditure and Disclosures Act 1981 ("EFEO Act") and the Lobbying of Government Officials Act2011 ("LOGO Act") (collectively referred to hereafter as "the Acts"). The Commission is responsible for undertaking investigations where it is satisfied on reasonable grounds that one or more of the Acts may be, are or have been, contravened.

I enclose two (2) notices, bearing the Commission's barcode numbers EC0000628 (lnformation)and EC0000629 (Documents) issued under s110A(1)(a)&(b) of the EFED Act. You will see that it requires you to produce certain information and documents in relation to cash political donations made at a function called the 'Chinese Community Dinner' - 'Chinese Friends of Labor' held at The Eight Modern Chinese Restaurant on 12 March 2015. The Commission is investigating whether a number of donations made by individuals, were made for and on behalf of other person/s, which may constitute a breach of the EFED Act. Further details are set out in the notice.

~~Attached to and forming part of this correspondence is information relating to the requirements of section i 1OA as well as penalty provisions for failure to comply.~~

~~For the purposes of the enclosed notices, a list of definitions is attached.~~

You should read the notice carefully and it necessary, seek legal advice regarding the - requirements of the notice. The information contained within this notice and supplied by you in response to the notice is to remain confidential.

~~If you have any questions about the notice, please call Peter SMITHERS of 9290-5260.~~

~~Yours Sincerely~~

~~Peter SMITHERS Senior Investigator/ Inspector Funding, Disclosure & Compliance (Encl.)~~

~~1 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 \ ' 071~~

~~ELECTION FUNDING, EXPENDITURE AND DISCLOSURES ACT 1981 Section 110A - Power to require provision of documents and information~~

~~(1) The Electoral Commission may, by notice in writing to a person, require the person:~~

~~(a) to provide such information as the Electoral Commission reasonably requires for the purposes of the enforcement of this Act, or~~

(b) to produce to the Electoral Commission, at the place and time specified in the notice, any document that the Electoral Commission reasonably requires for the purposes of the enforcement of this Act, or

~~{c) to answer questions about any matters In respect of which information is reasonably required for the purposes of the enforcement of this Act, or~~

(d) to attend al a specified place and time to answer questions under this section if attendance at that place is reasonably required in order that the questions can be properly put and - answered. (2) The place and time at which a person may be required to produce a document, or to attend and answer questions, Is to be a place and time nominated by the Electoral Commission that is reasonable in the circumstances.

(3) A notice under this section that requires a person to produce a document may only require a person to produce existing documents that are in the person's possession or that are within the person's power to obtain lawfully.

~~(4) The Electoral Commission may take copies of any documents provided under this section.~~

{5) if the Electoral Commission has reason to believe that any documents provided under this section are evidence of an offence against this Act or the regulations, the Electoral Commission may retain the documents until proceedings for the offence have been heard and determined.

~~(6) A person who, without reasonable excuse, falls to comply with a requirement made of the person under this section Is guilty of an offence. Maximum penalty: 200 penalty units.~~

(7) A person who provides any document or information, or answers any question, in purported compliance with a requirement made under this section, knowing that the document, information or answer is false or misleading in a material particular, is guilty of an offence. Maximum penalty: 400 penalty units or Imprisonment for 2 years, or both.

~~(8) A function conferred on the Electoral Commission by this section may be exercised by any person authorised by the Electoral Commission to exercise its functions under this section:~~

~~(a) who is employed in the Public Service, or~~

~~(b) who Is not so employed but is subject to the control and direction of the Electoral Commission in relation to any function under this section.~~

~~2 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 , . 072~~

~~DEFINITIONS~~

Please note, for the purposes of the enclosed notice(s), the following terms have the following meaning pursuant to sections 4 and 84 of the Election Funding, Expenditure and Disclosures Act 1981, section 3 of the Election Funding, Expenditure and Disclosures Regulation 2009, section 3 of the Parliamentary Electorates and Bections Act 1912 and section 3 ot the Lobbying of Government Officials Act2011.

~~"Amend" includes: a) Alter, omit, add or substitute.~~

~~"Books" includes: a) A register; and b) Financial reports or financial records, however compiled, recorded or stored; c) And a document; and d) Banker's books; and e) Any other record of information~~

"Bankers books" includes: - a) Books of a bank, building society or credit union; b) Cheques, orders for payment of money, bills of exchange or promissory notes In the possession or under the control of a bank, building society or credit union.

"Candidate": In relation to an election, means a person nominated as a candidate at the election in accordance with the PEE Act or In accordance with the Local Government Act 1993 {as the case requires) and includes a person applying for registration as, or registered as, a candidate In the Register of Candidates for the election.

~~"Commissioner" means: The Electoral Commissioner for New South Wales appointed under the PEE Act and includes a person duly acting as the Electoral Commission.~~

~~"Declaration" includes: a) A disclosure made in accordance with Part 6 of the EFED Act.~~

"Documenr includes: a) Anything on which there is writing, or b) Anything on which there are marks, figures, symbols or perforations having a meaning for persons qualified to interpret them, or c) Anything from which sounds, images or writings can be reproduced with or without the aid of - anything else, or d) A map, plan, drawing or photograph.

~~"Donor" means: A person who makes a gift.~~

"Elected Member'' means: a) A member of Parliament; b) A counclllor (including the mayor) of the council of a local government area, and includes a person who, during any period after ceasing to be a member of Parliament or a councillor, Is entitled to remuneration as such a member or councillor.

~~"Elector" means: Any person whose name appears on a roll.~~

~~3 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 073~~

"Electoral Expenditure" means: Expenditure for or in connection with promoting or opposing, directly or indirectly, a party or the election of a candidate or candidates or for the purpose of influencing, directly or indirectly, the voting at an election.

"Financial records" includes: a) Invoices, receipts, orders for the payment of money, bills of exchange, cheques, promissory notes and vouchers; and b) Documents of prime entry; and c) Working papers and other documents needed to explain: i. The methods by which financial statements are made up; and ii. Adjustments to be made in preparing financial statements.

~~"Financial Year" means: Year ending 30 June.~~

"Gift'' means: Any disposition of property made by a person to another person, otherwise than by will, being a disposition made without consideration in money or money's worth or with inadequate consideration, and Includes the provision of a service (other than volunteer labour) for no - consideration or for inadequate consideration. "Government Official" Includes: a) A Minister or Parliamentary Secretary; b) A staff member of a Minister or Parliamentary Secretary (including a staff member In an electorate office); c) The head of a Public Service agency; d) A person employed in the Public Service of New South Wales, the Transport Service of New South Wales or any other service of the Crown; e) An individual who is engaged under a contract to provide services to or on behalf of the Public Service of New South Wales, the Transport Service of New South Wales or any other service of the Crown; and f) A member (however expressed) of, or of the governing body of, a statutory body.

"Inspector" means: a) A person who is employed under Chapter 1 A of the Public Sector Employment and Management Act 2002 in the Government Service, or b) A person who is not so employed but is subject to the control and direction of the Electoral Commission in relation to any function under this section, and who is appointed by the Electoral Commission as an inspector for the purposes of this section.

"Lobbyist" means: a) A third-party lobbyist, or - b) Any other individual or body that lobbies Government officials (including an individual engaged to undertake lobbying for a third-party lobbyist).

~~"Major Political Donor" means: An entity or other person (not being a party, elected member, group or candidate) who makes a reportable political donation of or exceeding $1000.~~

"Official Agent" includes: a) In relation to an elected member of Parliament who is a member of a registered party- the party agent of the party; b) In relation to any other elected member who is a candidate or member of a group - the official agent of the candidate or group; c) In relation to a State election candidate who is a member of a registered party- the party agent of the party;

~~4 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 074~~

d) In relation to a State election group whose members are all members of a registered party the party agent of the party; e) In relation to a candidate or group of a class specified in the regulations - the Electoral Commission or a government agency so specified; f) In relation to any other candidate or group - the official agent registered in the Register of Official Agents for that candidate or group; g) In relation to an elected member for whom an official agent, appointed by the member under section 46A of the EFED Act, is registered in the Register of Official Agents - that official agent; h) In relation to a third-party campaigner for whom an official agent, appointed by the campaigner under section 46B of the EFED Act, is registered in the Register of Official Agents - that official agent; and i) In any other case - a person (including the elected member, candidate or third-party campaigner concerned) designated by the Electoral Commissioner.

"Party" means: A body or organisation, incorporated or unincorporated, having as one of its objects or activities the promotion of the election to Parllament or a local council of a candidate or candidates endorsed by it or by a body or organisation of which it forms a part.

"Political Donation" includes: a) A gift made to or for the benefit of a party; b) A gift made to or for the benefit of an elected member; c) A gift made to or for the benefit of a candidate or a group of candidates; and - d) A gift made to or for the benefit of an entity or other person (not being a party, elected member, group or candidate), the whole or part of which was used or is intended to be used by the entity or person: a. To enable the entity or person to make, directly or indirectly, a political donation or to incur electoral expenditure, or b. To reimburse the entity or person for making, directly or indirectly, a political donation or incurring electoral expenditure.

"Prohibited Donor" includes: a) A property developer; or b) A tobacco industry business entity; or c) A liquor or gambling industry business entity, and includes any industry representative organisation if the majority of Its members are such prohibited donors.

"Registered Party" means: A party registered under Part 4A of the Parliamentary Electorates and Elections Act 1912, being a party which stated in its application for registration that it wished to be registered for the purposes of this Act.

~~"Related Body Corporate" - has the same meaning as in the Corporations Act 2001 of the Commonwealth. "Scheme" includes: a) An arrangement, an understanding or a course of conduct.~~

"Third-Party Lobbyist" means: An individual or body carrying on the business (generally for money or other valuable consideration) of lobbying Government officials on behalf of another individual or body; and: a. Includes an individual or body Included in this definition by the regulations, but b. Does not include an individual or body excluded from this definition by the regulations.

~~5 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 ' ' 075 mil ~~rd~illiilil ffl EC0000628~~

~~Notice issued to an organisation pursuant to Section 110A(1 )(a) of the Election Funding, Expenditure and Disclosures Act 1981~~

~~To: The Proper Officer Australian Labor Party (N~W SranCh) ('ALP') Level 9, 377-383 Sussex Street SYDNEY NSW 2000~~

The New South Wales Electoral Commission ("the Commission") is a statutory body responsible for regulating and enforcing compliance with the ParliamentaryElectorates and ElectiQ[?S Act 1912 ("PEE Act"), Election Funding, Expenditure and Disclosures Act - 1981 ("EFED Act") and the Lobbying of Government Officials Act 2011 ("LOGO Act"). I, Peter SMITHERS, have reason to suspect that cash political donations made at a function called the 'Chinese Community Dinner' - 'Chinese Friends of Labor' held at The Eight Modern Chinese Restaurant on 12 March 2015, were made for and on behalf of other person/s, and deposited into an ALP bank account, in contravention of section 96HB(1) of the EFED Act

l am authorised by the Commission to issue notices under s. 11 OA of the EFED Act. This notice is issued to you pursuant to that section, because I have reason to suspect that you are able to provide information reg~rding the ca~hpoljtical. donc¾tions1;1ade at a function called either the 'ChineseC9mmunity Dinner' or 'Chinese Friends of Labor' ('the fundraisirig dinner') held at The Eight Modern Chinese Restaurant on 12 March 2015. The Commission is investigating whether a number of donations made at the fundraising dinner by certain individuals, were made for and on behalf of other person/s.

It is an offence to provide any document or information or answer· any questions in purported compliance with a requirement of this notice, knowing that the document or information or answer is false or mislei':lding in a material particular. It is also an offence to fail to comply with a requirement of this notice, without reasonable excuse.

~~EC0000528 • Page 1 of 2~~

~~\ V'IV../W\elactions:,nsw,gov,att NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 076~~

~~YOU ARE REQUIRED BY THIS NOTICE TO PRODUCE THE FOLLOWING INFORMATION~~

Financial records maintained by the Commission indicate that $50,000 consisting of 10 x $5000 individual donations ('the donations') were handed to the ALP on 9 April 2015. The donations derived from the "Chinese Friends of Labor- NSW Labor Chinese" (function) launch on 12 March 2015. 1. Please provide the name/s of the person/s who handed the donations to the ALP on 9 April 2015?

~~2. Please advise as ~P w9at form the donations we.r~ provided to the ALP on 9 April 2015 (i.e. 9ash, cheque, EFT, or by any other means)?~~

~~3. Please advise if the person/s who handed the donation~'to the ALP on 9 April 8015 (as per point 1 aboge), were iss~ed with a for!],~1 receipt from the ALP for that transaction?~~

4. Please advise if the person/s who hanged the donations to ALP on 9 April 2015 (as per point1 above), .also supplied the ALP with a breakdown of the names and addresses of the individuals whose donations made up the donation?

5. Please advise the na111~/~ ~fthe person/~. who depositt1d(the donation into the ALP NSW.State Campaign Account ·~ .. eomrn~nwealth Bank Account numbered 290611314646 (Chinatown branch) on 9 Aprif2015?

~~You are require~Uo provide the documents refe.rrJid fo in this notice to: To: Senior lnvestigat~r Peter SftlllT\;IE.RS~~

~~By: 10.00AM~~

~~On: Tuesday 20 December 2016~~

~~At: NSW Electoral Commission, Level 25, 201 Kent Street, Sydney NSW 2000.~~

~~If you have any questions about this notice, please call Peter SMITHERS on (02) 9290-5260.~~

~~Thank you for your assistance regarding this matter.~~

~~Peter SMITHERS Senior Investigator/ Inspector 6 December 2016~~

~~EC0000628 • Page 2 of 2~~

~~WW'N, e tections .nsw.gov.a u NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 077 electoral lllii iiifliii 11! commission Nsw EC0000629~~

~~Notice issued to an organisation pursuant to Section 110A(1 )(b) of the Election Funding, Expenditure and Disclosures Act 1981~~

~~To: The Proper Officer Australian Labor Party (NSW Branch) ('ALP') Level 9, 377-383 Sussex Street SYDNEY NSW 2000~~

The New South Wales Electoral Commission ("the Commission") is a statutory body responsible for regulating and enforcing compliance with the Parliamentary Electorates and Elections Act 1912 ("PEE Act"), Election Funding, Expenditure and Disclosures Act - 1981 ("EFED Act") and the Lobbying of, (3overnment0fficials Act 2011 ("LOGO Act"). I, Peter SMITHERS, have reason to suspect that cash political donations made at a function called the 'Chinese Community Dinner' - 'Chinese Friends of Labor' held at The Eight Modern Chinese Restaurant on 12 March 2015, were made for and on behalf of other person/s and deposited into an ALP bank account, in contravention of section 96H8(1) of the EFED Act.

I am authorised by the Commission to issue notices under s. 11 0A of the EFED Act. Tbis notice is issued to you pursuant to thatsection, because I have reason to suspect that you are able to provide documents regarding the cash political donations made at a function called either the 'Chinese Community Dinner' or 'Chinese Friends of Labor' ('the fundraising dinner? held at The Eight Modern Chinese Restaurant on 12 March 2015. The Commission is investigating whether a number of donations made at the fundraising dinner by certain individuals, were made for and on behalf of other person/s.

It is an offence to provide any document or information or answer any questions in purported compliance with a requirement of thi!> notice, know[ ng that the document or information or answer is false or misleading in a material particular. It is also an offence to fail to comply with a requirement of this notice, without reasonable excuse.

~~EC0000629 · Page l of 2~~

~~w·w'w, r:i!ect.i ons _nsv1,gov, au NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 078~~

~~YOU ARE REQUIRED BY THIS NOTICE TO PRODUCE THE FOLLOWING DOCUMENTS~~

Financial records maintained by the Commission indicate that $50,000 consisting of 10 x $5000 individual donations ('the donations') were handed to the ALP on 9 April 2015. The donations derived from the "Chinese Friends of Labor - NSW Labor Chinese" (function) launch on 12 March 2015. 1. Please provide a copy of the receipt !ss.. u~d by the ALP, to the person/s who handed the donationstg theALP on 9 April 2015.

2. Please provided .a copy of the deposit slip ofthetran~action from 9 April 2015, whf:!feby, the donations were deposited into the ALP NSW State Campaign Account - Commonwealth Bank Account numbered - 200611314646 (Chinatown Branch)., 3. Ple~se/provide a copy of anY and all do.cumentation that,~as provided either to. or by, the petson/s who hand~d the donations to the ALP on 9 April 2015.

~~You are required to provid~;the pocuments .referred to in this notice to:~~

~~To: .~enior lnvestigator:{?~tefSMITHER~ "' ', ,,, .. ',,,'•-,-,-·"'"·'", ·.. ·, ·.. ,., . ,\ By: 10:'00AM~~

~~On: Tu~sday 20 December 2016~~

~~At: NSW Ele'c:t~~

~~If you have any questions about this notice, please call Peter SMITHERS on (02) 9290-5260. - Thank you for your assistance regarding this matter.~~

~~Peter SMITHERS Senior Investigator/ Inspector 6 December 2016~~

~~EC0000629 - Page 2 of 2~~

~~10 i Kent NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 079~~

1 e From: Julie Slbraa Sent: Friday, 16 Dec To: Ian Robertson ; Sarah Butler Cc: Kaila Murnain Subject: Notices to Pro uce n ormat1on and Documents) issued under sllOA(l)(a)&(b} of the Election Funding, Expenditure and Disclosures Act 1981

~~Hi Ian and Sarah~~

With respect to the Notices to Produce (information and Documents) issued under s110A(l)(a)&(b) of the Election Funding, Expenditure and Disclosures Act 1981 sent to us In relation to the Chinese Friends of Labor Dinner, I have put together a brief, draft response and attached documents that we have.

Can you please have a look at them and let me know your thoughts. The letter states the Commission is Investigating whether a number of donations made by individuals were made for and behalf of other person/s.

~~The response is due on Tuesday 20 December at 10am.~~

~~Regards NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 080~~

~~Julie~~

~~Julie Sibraa Governance Director Australian Labor Party (NSW Branch)~~

~~P:•••• 11 W: www.nswlabor.org.au -IT: @NSWLabor I F: NSWLabor I A: Level 9,377 Sussex Street, Sydney NSW 2000~~

~~This email has been scanned by the Symantec Email Security.cloud service. For more information please visit http://www.svmanteccloud.com~~

This email (including any attachments) Is confidential and may be subject to legal professional privilege. CJick here for more information and for advice on •what to do if you have received this email by mistake .

~~2 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 081~~

~~Peter Smithers Senior Investigator/Inspector Funding, Disclosure & Compliance Electoral Commission NSW 25/201 Kent Street Sydney NSW 2000~~

~~19 December 2016~~

~~Dear Mr Smithers~~

~~Re: Notices issued under s110A(1)(a) and (b) of the Electoral Funding, Expenditure and Disclosures Act 1981~~

~~In accordance with the above Notices issued on 6 December 2016 addressed to the Australian Labor Party (NSW Branch), I attach the requested information and documents.~~

~~Should you have any further questions, please contact Julie Sibraa on 9207 2013.~~

~~Regards~~

~~Kaila Murnain GENERAL SECRETARY NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 082~~

~~Notice issued pursuant to Section 110A (1) (a) of the Election Funding, Expenditure and Disclosures Act 1981~~

~~Question 1~~

~~Please provide the name/s of the persons who handed the donations to the ALP on 9 April 2015~~

~~Response~~

~~Kenrick Cheah~~

~~Question 2~~

~~Please advise as to what form the donations were provided to the ALP on 9 April 2015 (i.e. cash, cheque, EFT, or by any other means).~~

~~Response~~

~~Cash~~

~~Question 3~~

~~Please advise if the person/s who handed the donations to the ALP on 9 April 2015 (as per point 1 above) were issued with a formal receipt from the ALP for that transaction.~~

~~Response~~

~~No - Kenrick Cheah is an employee of the ALP and attended the dinner.~~

~~Question 4~~

Please advise if the person/s who handed the donations to the ALP on 9 April 2015 also supplied the ALP with a breakdown of the names and addresses of the individuals whose donations made up the donations.

~~Response~~

~~Yes~~

~~(. Question 5~~

~~- Please advise the name/s of the persons who deposited the donation into the ALP NSW State Campaign Account - Commonwealth Bank Account numbered 200611314646 (Chinatown Branch) on 9 April 2015.~~

~~Response~~

~~Jenny Zhao -Accounts Assistant~~

~~Notice issued pursuant to Section 110A (1) (b} of the Election Funding, Expenditure and Disclosures Act 1981~~

~~Question 1~~

~~Please provide a copy of the receipt issued by the ALP to the person/s who handed the donations to the ALP on 9 April 2015 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 083~~

~~Response N/A~~

~~Question 2~~

Please provide a copy of the deposit slip of the transaction from 9 April 2015 whereby the donations were deposited into the ALP NSW State Campaign Account - Commonwealth Bank Account numbered 200611314646 (Chinatown Branch).

~~Response~~

~~See attachment 1: Deposit slip copy~~

~~See attachment 2: Copy of Bank Statement~~

~~Question 3~~

~~Please provide a copy of any and all documentation that was provided either to or by the persons who handed the donations to the ALP on 9 April 2015.~~

~~Response~~

~~See attachment 3: Copies of donation declaration forms and invoices. NSW ICAC EXHIBIT • ~ PRN E18/0093/AS-04-067/PR-0001 Attachment 1.~~

~~. _.. ,·. ,.. ·.~ .. ; i!:'~~

f,~ ~------·'?~awer ------___ ··-· ___ :Bank----·-- _ ~---- ___I _!3ranch ---··-~-- ______Amount -~~-P._4?Sit _ • "------•.. i ---·- ----~------•· •---~------'----- ! "----·---___,1 ______._ •• --... ~------.. ·------" parlk:1110,,; of chequ,:s. Pn,cceds of i:haques, "'1libt cred~ 10 the a01'..ou111, 8n! not m!ilblc until ~ Plcuc ro!crlo }"OI" _, Wms 111'-II ce>

~~·",_ ~: NSW ICAC EXHIBIT e,.-- ~ PRN E18/0093/AS-04-067/PR-0001~~

~~Attachment 2.~~

~~ComnonwealthBank ConmBiz Transaction History C'..ommonwealth Bank of Au:'ilralla •~~

~~Report from 09/04/2015 Opening balance $160,720.39 Report to 09/04/2015 Closing balance $212,305.39 Currency AUD~~

Account name: ALP NSW State Campaign Account 0 00 (J1 Account number: 200611314646 Date Transaction Detail Debit Credit Balance 09/04/2015 CBA CREDIT GARDE 5.00 212,305.39 5353109292091550 09/04/2015 Direct Credit 037541 RAY 1,000.00 212,300.39 WHITE TRUST SHIVAS MITC8-2 09/04/2015 Cash Dep Branch 50,000.00 211.300.39 Chinatown 09/04/2015 Direct Credit 403697 580.00 161,300.39 AMEX GR 580.00 9796975746 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 086

~~Peter Smithers Senior Investigator/Inspector Funding, Disclosure & Compliance Electoral Commission NSW 25/201 Kent Street Sydney NSW 2000~~

~~19 December 2016~~

~~Dear Mr Smithers • Re: Notices issued under sllOA(l)(a) and {b) of the Electoral Funding, Expenditure and Disclosures Act 1981~~

~~In accordance with the above Notices issued on 6 December 2016 addressed to the Australian Labor Party (Country Labor), I attach the requested information and documents.~~

~~Should you have any further questions, please contact Julie Sibraa on 9207 2013.~~

~~Regards~~

~~Kaila Murnain GENERAL SECRETARY NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 087~~

~~Notice issued pursuant to Section 110A (1) (a) of the Election Funding, Expenditure and Disclosures Act 1981~~

~~Question 1~~

~~Please provide the name/s of the persons who handed the donations to the CLP on 9 April 2015~~

~~Response~~

~~Kenrick Cheah~~

~~Question 2~~

~~Please advise as to what form the donations were provided to the CLP on 9 Aprll 2015 (i.e. cash, cheque, EFT, or by any other means).~~

~~Response~~

~~Cash~~

~~Question 3~~

~~Please advise if the person/s who handed the donations to the CLP on 9 April 2015 (as per point 1 above) were issued with a formal receipt from the CLP for that transaction.~~

~~Response~~

~~No - Kenrick Cheah is an employee of the ALP and attended the dinner.~~

~~Question 4~~

Please advise if the person/s who handed the donations to the CLP on 9 April 2015 also supplied the CLP with a breakdown of the names and addresses of the individuals whose donations made up the donations.

~~Response~~

~~Yes~~

~~Question 5~~

~~Please advise the name/s of the persons who deposited the donation into the ALP NSW- Country Labor Account - Commonwealth Bank Account numbered 200014091448 (Chinatown Branch) on 9 April 2015.~~

~~Response~~

~~Jenny Zhao -Accounts Assistant~~

~~Notice issued pursuant to Section 110A (1) (b) of the Election Funding, Expenditure and Disclosures Act 1981~~

~~Question 1~~

~~Please provide a copy of the receipt issued by the CLP to the person/s who handed the donations to the CLP on 9 April 2015~~

~~Response NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 088~~

~~N/A~~

~~Question 2~~

Please provide a copy of the deposit slip of the transaction from 9 April 2015 whereby the donations were deposited into the ALP NSW-Country Labor Account - Commonwealth Bank Account numbered 200014091448 (Chinatown Branch).

~~Response~~

~~See attachment 1: Deposit slip copy~~

~~See attachment 2: Copy of Bank Statement~~

~~Question 3~~

~~Please provide a copy of any and all documentation that was provided either to or by the persons who handed the donations to the CLP on 9 April 2015.~~

~~Response~~

~~See attachment 3: Copies of donation declaration forms and invoices. NSW ICAC EXHIBIT -r"' ~ PRN E18/0093/AS-04-067/PR-0001~~

~~Attachment 1~~

Please fill in the following partlcu!ars of cheques. Proceeds of cheques, whilst credited to the account, are not available until cleared. Please refer to your account terms and conditions for details. Dr~wer ______Bank Branch Amount Deposit

~~2 • l~~

~~3 -~~ 4 5~~

~(O Teller Use r-- ...... ------·1 ~~- 0 ,_.r 'f 1- V '-..._,... Date [ { 1-f:._ __ . ::__J m]l 5100 ,;J ! /{ ; '····n 00 (0 co (/j ~ $50 ·-'·-.\.,,. tvo! ' 1- .=qd .... PLACE SYDNEY NSW. Notes c::,C $20 ! i -st Coin w tll C\I $10 s en ..- u • ;~' .... ~ t?!' Agent Number Of applicable} Merchant ~ ~ B $5 Sum Env ______~---- Cheques ______Account Name s 01 ~g{C: .... Oro c-tupli~.i.'..t~ -::!t?.pU,:::ati!:• ~?Jp1:c~:.~- cli:.~;i::.st..:r ~~t?H~e~ ~u;;n¥ab: _Lt:;::Uc;~t-= .. ?~~ic::;::i!~ .~k:;1ftc:at:J ~~!lJfic.::_'io ~J;Ji.. Ev rAUSTat;> Ctt\?fl<::~t? ~~ ~.. .,. . . @EZ ~-•--·;.,..-,. ..!' ..... i:_,,l; ..... r-;w·r~ [pt·-!·•!·""..-'"' f." .... -ic~l-& d~;;tuc:f?tf!.• ¢H.Jt~,~C.titof' u(.:;~n'!;:!:l\e -ctu~~t.C3i~ du~t-:cai~ ,-.~rp.hc:$':to tir.:.ph• ..,, {..I, l.,C--(.1 e __.- ,f~O[!J ~§[A~..;&:;:~iyjPl.l~G.1"-$~§;JJJ.:l~;J;; ~1.;p[l,;,n.:, tlu;-:,'i~;;:a...; dq,!l;::~~$ -1!..:;,Hilc.:21~ C:.!\:'"ll•..':,r,t,;) -::iupficul;.;., Ct?!Jl~::.1-e dq-;t..ca1;;. -dupli• .. -- . .., ...... ~ ...... , ~ .. ,.. -,~~- ·-· NSW ICAC EXHIBIT -I""" ~ PRN E18/0093/AS-04-067/PR-0001

~~Attachment 2~~

~~ComnonwealthBank ConmBiz Transaction History (',ammonweallh Bank of Australia •~~

~~Report from 09/04/2015 Opening balance $8,046.90 Report to 09/04/2015 Closing balance $58,046.90 Currency AUD~~

~~0 (0 Account name: ALP NSW - COUNTRY LABORS 0 Account number: 200014091448 Date Transaction Detail Debit Credit Balance 09/04/2015 Cash Dep Branch 50,000.00 58,046.90 Chinatown~~

~~No. of transactions 0 1 Total debits $0.00 Total credits $50,000.00 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 091~~

~~Tax Invoice~~

Australian Labor Party New South Wales 9111 Floor, 377-383 Sussex St Sydney PO Box K408 HGyinarkct NSW 1240 Tax Invoice Number 00040918 Telephone: (02) 9207 2000 Facsimile: (02) 9264 2574 Email: [email protected] ADN 36 192 855 036 Date 9/04/2015

~~Tax Invoice To: MAY HO YEE~~

~~Customer Customer's Reference ABN~~

~~Description~~

~~DONATION TO CHINESE FRIENDS OF LABOR - NSW LABOR CHINESE LAUNCH $5,000.00 12 MARCH 2015~~

I have not breached the donation cap, being $5,000 for a party and $2,000 for a candidate for year 2014/2015. Major Political Donor (an individual who makes a reportable political donoation or multiple donations of or exceeding $1,000 in one financial year) MUST lodge their returns with EFA at year end. This invoice will be treated as a receipt when payment is made in full.

~~Tranter Details; Subtotal $5,000.00 Account Name: ALP NSW State Campaign Account BSB: GST $0.00 Bank Account No: Paid To Date $5,000.00 Balance Due $0.00 NSW ICAC EXHIBIT~~

PRN E18/0093/AS-04-067/PR-0001~•'- ~~ .... . /"':~ /' :\"'...... ' l?.e.5er\ra.·tc'..0V\.- fcn•--W\.- Plea.Se send me Total S Chinese Friends of Labor presents 0 Tickets-@ $80 per person D Tickets - @ $800 for table of 10 D Tickets - @ $2000 for VIP table 0 Tickots - @ $5000 for WIP tab!e t~ I am unebJa to attE.IJCI but ;voutl /ilfJ to make a dcn...'Tfk:n

~~N?.me: Mc~ l-\o Ye.E Organisation:~~

~~iWlllw:WI!~~

~~~ao~~

~~0 (0 00"" D Organisation I\.)~~

~~D Visa D Mastercard D Jl 0 D!ners 1111111 I 11DJ Name on Card Expiry Date I I I Signature Date I I ::;igr.ature uate~~

Ic:cnfrm !rat ltlis cknalioo trot made by or oo oohalf o/ a 'JJrmbited llonor' (being a 'pn:ip;rty ~·.'tooacto ir.!U5lly lllsine. enti\y' CJ 'iqu,;nr gaml:li/JJ lnduslry busiless enlil.'/). Cf a'close IISSLX:iate' of a 'Jlellil:iled dolii!r', as defhEd in Cmi:n 4A of Pa.16 ottt-.e Elocool1 Fuoor.g, Exp,ooue il!d o~kt 1001 (NSV,?. I also oo::lose Ihave rn eXceeded Iha $SOCO cap 1"'11ch IC3l1 doni!!e to this Ca.rxi:tate. Signature , , Date I -- • ,, T f - :::.;,cc::::.: I I NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 093

~~Tax Invoice~~

Australian Labor Party New South Wales 9111 Floor, 377-383 Sussex SI Sydney PO 13ox K408 Haymnrkel NSW 12.40 Tax Invoice Number 00040917 Tclepltonc: (02) 9207 2000 Facsimile: {02) 9264 2574 Email: [email protected] ABN 36 192 &55 036 Date 9/04/2015

~~Tax Invoice To: WEISHI~~

~~Customer Customer's Reference ABN~~

~~Description DONATION TO CHINESE FRIENDS OF LABOR~ NSW LABOR CHINESE LAUNCH $5,000.00 12 MARCH 2015~~

By accepting this invoice, I declare that: This amount will be used to incur State campaign expenses. I am an individual on the electoral roll or a business registered in Australia. This payment is not made by or on behalf of a 'prohibited donor' (a 'property developer', an associate of a tobacco, liquor or gambling industry) I have not breached the donation cap, being $5,000 for a party and $2,000 for a candidate for year 2014/2015. Major Political Donor (an individual who makes a reportable political donoation or multiple donations of or exceeding $1,000 in one financial year) MUST lodge their returns with EFA at year end. This invoice will be treated as a receipt when payment is made in full.

Tranter Details: Subtotal $5,000.00 Account Name: ALP NSW State Campaign Account BSB: GST $0.00 Bank Account No: Paid To Date $5,000.00 Balance Due $0.00 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 ·~ ,:. ~ ·'· -'.... )·jt?<:t."Y •· ' -.

'R:e.5erv~+i.oV\- f CJt'"IN\- Pk'aseserome Total S Chinese Friends of Labor presents 0 Tickets - @ S80 per person D Tlci«.>ts - @ $600 for table of 10 D Tickets - @ $2000 for VIP table D Tickets - @ ssooo ror wr P table ~ ~ f am unabe ID atte7dbut wou!cf li

~~0 (0 D Organisation .i:..~~

~~ease debit my credit cerd D Mastercard D Amex D Diners ~~I I I I 11 l I I 1~11~1 ~I I Name on Card Expiry Date I I I Signature Date --I I :signature Llate~~

lo:r,fnn diatUlis clomtloo isr.-otmi!de byorona:llatol'a 'prmill!al dim' O)eing a 'plq)a'iy ~.'!cbacro industJy tusiness enlity' or 'kjur or !jill11lli~ lrll'.t.isny lllUe$ emity), er a 'dose associate' of a 'Jm1Ned dor,or', as def11c-d ii ~ 4A or Part 6 of lhe Elect!on Funding, Expem:!~.re illd Disr..loolreskt 1981 ~1',?.I also ooc:looc l hal'i! nc! e>:cecded Ille $5CXXl rap v.tir.h l Cllll lblal:e 1D 1his Candmte. Signat...-e Date I =2??3%i~- l 13f1/3 v-tr 1lis document wil be a lax inva,ce ror GST purposes when you rreke ful payment. Pieaso retain a copy for your records. ALP NSW Brandl ABN 36 192 855 036 NSW ICAC EXHIBIT PRN E18/0093/AS-04-067/PR-0001 095

~~Tax Invoice~~

Australian Labor Party New South Wales 9th Floor, 3 77-383 Sussex St Sydney PO Box K408 Haymarket NSW 1240 Tax Invoice Number 00040916 Telephone: (02) 9207 2000 Facsimile: {02) 9264 2S74 Email: fmance@,nswalp.com ABN 36 192 855 036 Date 9/04/2015

~~Tax Invoice To: EMPEROR'S GARDEN PTY LTD~~

~~Customer Customer's 82 001 623 767 Reference ABN • JONATHAN YEE~~

~~Description DONATION TO CHINESE FRIENDS OF LABOR - NSW LABOR CHINESE LAUNCH $5,000.00 12 MARCH 2015~~

(

By accepting this invoice, I declare that: • This amount will be used to incur State campaign expenses. I am an individual on the electoral roll or a business registered in Australia. This payment Is not made by or on behalf of a 'prohibited donor' (a 'property developer', an associate of a tobacco, liquor or gambling industry) I have not breached the donation cap, being $5,000 for a party and $2,000 for a candidate for year 2014/2015. Major Political Donor (an individual who makes a reportable political donoation or multiple donations of or exceeding $1,000 in one financial year) MUST lodge their returns with EFA at year end. This invoice will be treated as a receipt when payment is made in full.

Tranfer Details: Subtotal $5,000.00 Account Name: ALP NSW State Campaign Account BSB: GST $0.00 Bank Account No: Paid To Date $5,000.00 Balance Due $0.00 NSW ICAC EXHIBIT ... PRN E18/0093/AS-04-067/PR-0001~ ✓ 1 ~ v',.-1',/ ·• {;:? ~ :(,.,· .. ... -~ ' . INV I TAT ION Re.5e..--v.'.i-ti.cl'\.- for""""" Rease send me Tela! S Chinese Friends of Labor presents D Tick.els - @ sao per person I I D Tickets - @ saoo for table of 10 I ! D ~ - @S2000 for VIP table I I ~cl

~~Name: Organisation: cwipev-er 's. C)6-v-&..~ ?/ L ABNJappicable): ?;U,0 /62°$ -:,-6+~~