9

FEDERAL ELECTION COMMISSION -%AsMI%ktTC% cr u.'

THIS IS THE BEIJI% OF MUR # 2697

DATE FILMNED E9 , CRIERA NO. -2.1 m

. : .. th e# .. .. . 14:47 off, Groeber, at al. TE 31 9? P. 2

cn -Nov

Baron3 TUl FIDUmAL UTIOK COmxlUZOl

OCIPfJtUNAT: Loraine Miller iome Address: c/o Attorney Kevin m. oexeefe 704 Wild Walnut 906 Olive 8treet, Suite 300 pMancheter, NO. St. Louis, 63101 63021

RES-U11 -1 Bridgeton Air Defense, Inc. 12561 Colburne SENSITIVE St. Louis, Missouri 63044

Bridgeton Air Defense Political Action Committee Wilfried AMelt, Treasurer 14810 Woodford way St. Louis, Missouri 63044 Johtn Joseph Klobnak 12740 Lasdale t. rouis, issoturi 63044 John B. TaYloT 12748 Karburn St. Lolis, Misuri 63044

flinirnk WIrranto, Jr. O1. Wubhrtar La. FRi. Pat*Ar, mtssourj 63376 "'tiueena Aauinat orn r/n 1756f1 C.Alhnurne Rt. honnm. NtiSanlri 63044J and ./n .1 Vodbriarh r-n. Rt. taters. Minnnori 63376

A Ifl-I" IAIT WEXoI

Rtnts nf Mtmmisri I I 88 C'.nmtv of pt. rnuim I

Comes ntw rnrxiA Mmir. of lawful ame and duly sworn up her oath, and deposes and states as follows; 1. I am a resident of the 2nd Congrossional District of the State of Missouri. 2. Congresswoman is a candidate for reelection to the office of Representative for the 2nd Congressional District of Missouri in the November 3, 1992 general election. 3. To my personal knowledge and based on statements made by residents of the 2nd Congressional District and copies of the appended materials viewed by me, copies of the material attached hereto as Exhibit No. 1 and incorporated herein by reference were distributed to members of the public throughout the 2nd Congressional District in St. Louis and St. Charles counties since late September, 1992, including, but not limited to: Kirkwood High School on October 13, 1992; placement on vehicles at various parking lots in St. Louis and St. Charles counties during the past weeks; distribution to patrons at several shopping centers in St. Louis and St. Charles counties on at least three occasions, to wit: October 3rd, 10th and 17th, 1992; distribution at various places of employment within the 2nd Congressional District; placement in residential mailboxes in portions of St. Charles County within the said District on various recent dates, and other occasions unknown to me. 4. The material attached as Exhibit No. 1 expressly advocates the defeat of Congresswoman Horn in the November 3rd general election. 5. Based on statements made Respondent Taylor and by persons CN in attendance at a meeting held on or about October 18, 1992 in the City of Bridgeton, Missouri, Respondent John B. Taylor is a leader of the organization identified on Exhibit 1 1 as "Citizens Against Horn" and is responsible, at least in part, for directing the activities of that organization with respect to advocating the CD defeat of Congresswoman Joan Kelly Horn in the November 3rd general election.

C')6. On the same bases as the foregoing, "Citizens Against Horn" has caused at least 100,000 copies of Exhibit No. 1 to be printed and produced, has distributed the materials as described above, will continue to produce and distribute the same or similar ('Y~ materials and threatens to make further expenditures, as that term is defined in 2 Usc S 431(9) and 11 CFR 100.8, for printed or broadcast communications expressly advocating the defeat of Congresswoman Horn. 7. Based on listings in the Greater St. Louis telephone directory, the phone numbers printed at the bottom of Exhibit No. 1 are those of Respondent Bridgeton Air Defense, Inc. and Respondent Dominick Ferranto Jr. Based on the use of their telephone numbers on Exhibit No. 1, I believe that Respondents Bridgeton Air Defense, Inc. and Ferranto are affiliated with and responsible for the activities of "Citizens Against Horn", including payment for and production and distribution of Exhibit No. 1 and the provision of financial support and in kind expenditures in support of the activities of "Citizens Against Horn." 8. Respondent Bridgeton Air Defense Political Action Committee registered as political committee with the Federal Election Commission on or about August 22, 1990. Respondent Wilfried Adelt is listed as the treasurer of Respondent Bridgeton Air Defense. Respondent Bridgeton Air Defense Political Action Committee has not filed periodic or pre-election reports of receipts and disbursements as required by law. Nor has said Respondent filed any report of expenditures for communications advocating the defeat of Congresswoman Horn. 9. Based on statements made by Respondent John Joseph Klobnak, Respondent Klobnak claims to have prepared materials for broadcast advertisements and communications expressly advocating the defeat of Congresswoman Horn and intends to cause Respondents Bridgeton Air Defense Inc. (of which Respondent Klobnak is a member of the Board of Directors), Bridgeton Air Defense Political Action Committee, "Citizens Against Horn" (of which Respondent Klobnak claims to be a leader) and other organizations and persons not known to me to purchase broadcast time in order to disseminate those communications prior to the November 3, 1992 general election.

10. The activities of Respondents are illegal and in violation of the provisions of The Federal Election Campaign Act in the following respects:

A. Exhibit No. 1 fails to comply with the requirements for the identification of persons and committees associated with payment for political communications. B. Pre-election reports regarding these expenditures have not been filed as required by law by either "Citizens Against Horn" or Bridgeton Air Defense Political Action Committee and its treasurer, Respondent Adelt.

C. "Citizens Against Horn" and Respondents Taylor and Klobnak have not complied with the special reporting requirements for independent expenditures within twenty days of an election.

D. "Citizens Against Horn" has failed to register as a political committee within the time allowed by law. E. All of the Respondents have failed to comply with the requirements for reporting contributions and independent expenditures for communications advocating the defeat of Congresswoman Horn.

F. Bridgeton Air Defense Political Action Comittee has not filed reports of receipts and expenditures as required by law. G. Bridgeton Air Defense, Inc. is organized as a not- for-profit corporation under the laws of the State of Missouri and claims to be exempt from Federal income tax under section 501(c) (4) of the Internal Revenue Code, yet, if the information provided to Complainant as recounted above is correct, it is using its resources and making, at least, in kind contributions for the purpose of paying for communications advocating the defeat of Congresswoman Horn, contrary to both the Federal Election Campaign Act and the Internal Revenue Code.

Because these violations are continuing, and due to the immediacy of the November 3rd election and the potential for irreparable harm if the electorate is mislead by the actions described, Complainant prays, in addition to other remedies, that the Commission immediately initiate injunctive action to prohibit TI- violations by Respondents or any "connected organization" associated with or responsible for the violations described. CN

Complain-ant

Subscribed and Sworn to before me this day of October, 1992.

My Commission Expires: SExhibit No. I

JUST SAY NO TO HORN, NOVEMBER 3 Missouri Second District Voter Alert IF YOU HAVEN'T READ ANYTHING ELs. -READ THIS!!

Ten Reasons Why Joan Kelly Horn Should Not Be Re-ekcW To Congr-

As residents of the 2nd Congr esional District, we have endured two years of non-leadership from liberal, big-spender Joan Kelly Horn. Her total inability to grasp even the simplest issues has produced nothing more than a YESPERSONto Vince Schoemehl and and other cronies, who are manipulating our lives. Here are ten reasons why you should not waste your vote on November 3:

1. HEY BIG SPENDER. while talking out of both sides of her mouth about stopping wasteful govcrmnent spending, Horn has consistently voted In favor of more spending to the tune of $3.5 trillion. She introduced a bill to balanoe the Federal budget and then voted against it when told to do so by Gephardt. 2. HOGS AT THE TROUGH? Joa beat by calling him a *hog', but who is the true porker? Horn (S129,500) and her huvnhnd a prlmi -at UMSL ($0)000) rae nm it quarter afa milnim bucks slurping at the public trough. Just like the paychecks at your house, right? (3.2nd AMENDMENT VIOLATOR: Horn has consistently voted to ban frearnn, incuding sbomguns, rifles and handguns used for hunting, self defense an target shooting. even in Olympic competition. She has conistently votl asainst deer hunting C%_ 4. LIVING IN LADUE: while espousing family values. Horn always fails to talk about the fact that she and her crrent husband we told by the City of Ladue, toje nrrian it thing .in Yes, she was 0% the on who was in the new-papers S. POLITICAL REWARDS: after Joan endorsd Vim Schoenehl for Govuror, Horn's son was one of the frst to sell-out to the airport. epte rmpeated cns to reveal how much he gW. Joan has ruse CD And Sdomrneb's airport went to court to keep the rords smled. 6. VOTED AGAINST JOBS AT MAC: In dditio. to the space static. projat Horn has repetmdly this region's

7. LET'S BE FRANK ABOUT THE MAIL Horn and Gphard have both bo identfied by the National Taxpayers Union, a national spending wat group in Washington, as two of the country's -ia qmdend on posta paid by the taxpayers. Horn says she Sped25 per address when de really sped S.59 per distct addrm (Post-Dispatch 3/24194 8. NO GULF: Horn was one of the few who voaO ,Parsa Gu"War- 9. LIED ABOUT CHECKS: Joan said she didn't bounce any checks at the House Bank and then had to own up to it when caught. 10. LEFT COAST LIBERALS:.Why are some of , Rd m,4stu ! Jane_ Fond? We sure don't need them in the 2nd District.

LET'S GET SCHOEMEHL AND GEPHARDT OUT OF THE 2ND DISTRICT

PAID FOR BY CITIZENS AGAINST HORN FEDERAL ELECTION COMMISSION WASH1%Cr0% DC 204f6 November 19, 1992

Kevin M. O'Keefe, Esq. Uthoff, Graeber, Bobinette & O'Keefe 906 Olive Street, Suite 300 St. Louis, MO 63101 RE: MUR 3687

Dear Mr. O'Keefe: This letter acknowledges receipt on November 12, 1992, of a complaint you filed on behalf of your client, Loraine Miller, alleging possible violations of the Federal Election Campaign '0 Act of 1971, as amended ("the Act"), by Bridgeton Air Defense, Inc., Bridgeton Air Defense Political Action Committee and Wilfried Adelt, as treasurer, Citizens Against Horn and Dominick Ferranto Jr., as treasurer, John B. Taylor and John Joseph Klobnak. The respondents will be notified of this complaint 04 within five days. CX You will be notified as soon as the Federal Election Commission takes final action on your complaint. Should you receive any additional information in this matter, please forward it to the Office of the General Counsel. Such information must be sworn to in the same manner as the original complaint. We have numbered this matter KUR 3687. Please refer to this number in all future correspondence. For your (7 information, we have attached a brief description of the Commission's procedures for handling complaints. Sincerely,

ti-sa E. Klein Assistant General Counsel

Enclosure Procedures FEDERAL ELECTION COMMISSION WASHINGTON. D C 20M43

November 19, 1992

Bridgeton Air Defense, Inc. c/o Tom Fehrenbacher, Registered Agent 12030 Franclair Bridgeton, MO 63044 RE: MUR 3687

Dear Mr. Fehrenbacher: The Federal Election Commission received a complaint which indicates that Bridgeton Air Defense, Inc. ("Bridgeton") may have violated the Federal Election Campaign Act of 1971, as amended ("the Act"). A copy of the complaint is enclosed. We have numbered this matter MUR 3687. Please refer to this number in all future correspondence.

NUnder the Act, Bridgeton has the opportunity to demonstrate in writing that no action should be taken against it in this 0matter. Please submit any factual or legal materials which you believe are relevant to the Commission's analysis of this matter. Where appropriate, statements should be submitted under oath. Your response, which should be addressed to the General Counsel's Office, must be submitted within 15 days of receipt of this letter. If no response is received within 15 days, the Commission may take further action based on the available C information. nThis matter will remain confidential in accordance with r - 2 U.S.C. S 437g(a)(4)(B) and S 437g(a)(12)(A) unless you notify the Commission in writing that you wish the matter to be made public. If you intend to be represented by counsel in this matter, please advise the Commission by completing the enclosed form stating the name, address and telephone number of such counsel, and authorizing such counsel to receive any notifications and other communications from the Commission. 0 0

Bridgeton Air Defense, Inc. Page 2

If you have any questions, please contact Dawn N. Odrovski, the attorney assigned to this matter, at (202) 219-3400. For your information, we have enclosed a brief description of the Comission's procedures for handling complaints.

Sincerely,

eisa E. Klein Assistant General Counsel Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement

cc: John Joseph Klobnak, Director Bridgeton Air Defense, Inc. C1 FEDERAL ELECTION COMMISSION WASHINCTON D C 2V4b

November 19, 1992

Wilfried Adelt, Treasurer Bridgeton Air Defense Political Action Committee 14810 Woodford Way Bridgeton, MO 63044 RE: MUR 3687

Dear Mr. Adelt: The Federal Election Commission received a complaint which indicates that Bridgeton Air Defense Political Action Committee ("Committee") and you, as treasurer, may have violated the Federal Election Campaign Act of 1971, as amended ("the Act"). A copy of the complaint is enclosed. We have numbered this matter MUR 3687. Please refer to this number in all future (N correspondence. Under the Act, you have the opportunity to demonstrate in writing that no action should be taken against the Committee or you, as treasurer, in this matter. Please submit any factual or legal materials which you believe are relevant to the Commission's analysis of this matter. Where appropriate, statements should be submitted under oath. Your response, which should be addressed to the General Counsel's Office, must be C? submitted within 15 days of receipt of this letter. If no response is received within 15 days, the Commission may take further action based on the available information. This matter will remain confidential in accordance with 2 U.S.C. S 437g(a)(4)(B) and S 437g(a)(12)(A) unless you notify the Commission in writing that you wish the matter to be made public. If you intend to be represented by counsel in this matter, please advise the Commission by completing the enclosed form stating the name, address and telephone number of such counsel, and authorizing such counsel to receive any notifications and other communications from the Commission. Wilfried Adelt, Treasurer Bridgeton Air Defense Political Action Committee Page 2 If you have any questions, please contact Dawn P. Odrowski, the attorney assigned to this matter, at (202) 219-3400. For your information, we have enclosed a brief description of the Commission's procedures for handling complaints.

Sincerely,

-'risa E. Klein Assistant General Counsel Enclosures 1. Complaint 2. Procedures C 3. Designation of Counsel Statement

CN FEDERAL ELECTION COMMISSION WASHINGTON, DC 0461

November 19, 1992

Dominick Ferranto, Jr., Treasurer Citizens Against Horn 613 Woodbriar Lane St. Peters, MO 63376

RE: MUR 3687

Dear Mr. Ferranto: The Federal Election Commission received a complaint which indicates that Citizens Against Horn ("Committee") and you, as -- treasurer, may have violated the Federal Election Campaign Act of 1971, as amended ("the Act"). A copy of the complaint is enclosed. We have numbered this matter MUR 3687. Please refer to this number in all future correspondence.

04 Under the Act, you have the opportunity to demonstrate in writing that no action should be taken against the Committee and Oh you, as treasurer, in this matter. Please submit any factual or legal materials which you believe are relevant to the Oh Commission's analysis of this matter. Where appropriate, statements should be submitted under oath. Your response, which should be addressed to the General Counsel's Office, must be submitted within 15 days of receipt of this letter. If no response is received within 15 days, the Commission may take C' further action based on the available information. This matter will remain confidential in accordance with 2 U.S.C. 5 437g(a)(4)(B) and 5 437g(a)(12)(A) unless you notify the Commission in writing that you wish the matter to be made public. If you intend to be represented by counsel in this matter, please advise the Commission by completing the enclosed form stating the name, address and telephone number of such counsel, and authorizing such counsel to receive any notifications and other communications from the Commission. Doinick Ferranto, Jr., Treasurer Citizens Against Horn Page 2

If you have any questions, please contact Dawn M. Odrowski, the attorney assigned to this matter, at (202) 219-3400. For your information, we have enclosed a brief description of the Commission's procedures for handling complaints. Sincerely,

AI-a E. Klein Assistant General Counsel Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement FEDERAL ELECTION COMMISSION WASHINGTON D C 20I*3 November 19, 1992

John Joseph Klobnak 12740 Lonsdale St. Louis, MO 63044

RE: MUR 3687

Dear Mr. Klobnak: The Federal Election Commission received a complaint which indicates that you may have violated the Federal Election Campaign Act of 1971, as amended ("the Act"). A copy of the matter MUR 3687. complaint is enclosed. We have numbered this Please refer to this number in all future correspondence. Under the Act, you have the opportunity to demonstrate in CJ writing that no action should be taken against you in this which you matter. Please submit any factual or legal materials believe are relevant to the Commission's analysis of this matter. Where appropriate, statements should be submitted under oath. Your response, which should be addressed to the General C. Counsel's Office, must be submitted within 15 days of receipt of this letter. If no response is received within 15 days, the NT Commission may take further action based on the available inforsation. C- This matter will remain confidential in accordance with 2 U.S.C. S 437g(a)(4)(B) and 5 437g(a)(12)(A) unless you notify the Commission in writing that you wish the matter to be made public. If you intend to be represented by counsel in this matter, please advise the Commission by completing the enclosed form stating the name, address and telephone number of such counsel, and authorizing such counsel to receive any notifications and other communications from the Commission. John Joseph Klobnak Page 2 If you have any questions, please contact Dawn M. Odrowski, the attorney assigned to this matter, at (202) 219-3400. For your information, we have enclosed a brief description of the Commission's procedures for handling complaints. Sincerely,

L sa E. Klein Assistant General Counsel Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement

NO CN ON FEDERAL ELECTION COMMISSION WASHINCTON, DC -04NB November 19, 1992

John B. Taylor 12748 Marburn St. Louis, MO 63044

RE: MUR 3687

Dear Mr. Taylor: The Federal Election Commission received a complaint which indicates that you may have violated the Federal Election Campaign Act of 1971, as amended ("the Act"). A copy of the matter MUR 3687. )complaint is enclosed. We have numbered this Please refer to this number in all future correspondence. Under the Act, you have the opportunity to demonstrate in writing that no action should be taken against you in this matter. Please submit any factual or legal materials which you C J believe are relevant to the Commission's analysis of this under 01 matter. Where appropriate, statements should be submitted response, which should be addressed to the General oath. Your of Counsel's Office, must be submitted within 15 days of receipt within 15 days, the CD this letter. If no response is received Commission may take further action based on the available 4q, information. C- This matter will remain confidential in accordance with notify 2 U.S.C. S 437g(a)(4)(B) and S 437g(a)(12)(A) unless you the Commission in writing that you wish the matter to be made public. If you intend to be represented by counsel in this matter, please advise the Commission by completing the enclosed form stating the name, address and telephone number of such counsel, and authorizing such counsel to receive any notifications and other communications from the Commission. John B. Taylor Page 2

If you have any questions, please contact Dawn N. Odrowski, the attorney assigned to this matter, at (202) 219-3400. For your information, we have enclosed a brief description of the Commission's procedures for handling complaints.

Sincerely,

(Li' E. Klein ASsistant General Counsel Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement

C 10"t

'.0

Bridgeton Air Defensce . Poli cal Xction Comniee (BADPAC)

Federal Election CommusiO" Tienera) (otmcifs Office Washington IX' 20463 2 November 1992 Attn: IUsa E. Klein

Re MUR 3687, Your letter 19 Nov 92 Enclosed: Report of Receipts and Disbunements

C De Mrs. Kein: I receivd yor ltat and I was shocked aboM the senoquness of in 1, Ujoioned in that kttCr. 04 The Bridgeton Air Defes Poif Actim Commiu (BADPAC) was faued inAp 1990 by a lo" anos-ood p dis opposed I a plmhied o d SL o1 Axis ao iro cow Cily of Bklgo iea ItabmIood groa- C( -oftium thrdeatened to lose dkuiI bom d the qualy of fe, cdod thiev 1 %id011a Air Defense." The S fixd wide supot im m I order to expmd as' in &e po"ia arm, it was fob &A we dsmki fkm a Ni A Action Coos. AiktlcreabliuheigaaM formin 1990, the ' ofown s "b" is probably beat reflcded in ou fmmci hi". The total ~ kXXD of amr BADPAC (Lia 19 of Fedra Form) was 1990 S2517.66 1991 $1213.51 1992 $ 335.73 This decline of BADPAC is offoet by the involvement of the City of Bridgelon a is now a.Mve fighti the anport eVawio plan.

Being a lay prmn volunteaing my time for a cau as the tewamer of BADPAC, I admit that I probably did not ful1M aD the requrd reportbg. However, I did aD ft reor honestly and to the best of my knowlege. This is especially tu in view or ae mI ly smaH financial power of only $335.73 for dis year.

Now to the charges: Congres women Horn was openly supporfing the arort expansion into Bridgeton. NatuaAy, this ccd outage in our community. But BADPAC can not be made responsible for actiom done by p&t citizmu, even when spported by a civie organization like Bridgeton Air Defense. B ADPAC has not financed any of te charged items. B ADPAC has not spent a petmy in support of the 'Cidzs against Ham". It mde Madabe that a pofitical candidat is desperat to ftht for h~ibr rcdccion. Rep. Horn, who lost the ekcton, wa obvwusly not aware dha BADPACs womd was $335, a fraction of the legal fees she and Ms. M a srnt to saw her 0og .sinlseat.

Please let me know whether this response satisfies your needs. I do not have the time and the means to afford a leg repreocntativc.

Treasurer of B ADPAC 14810 Woodford Way Bridgeton, Mo 63044 Phone (314) 739-5117

CN

ON0, REPO9 AND DtSBUVMENTS For Ow Then A"n uthOr~z CofmfMft (Summary pae) C Of I4t0?74 110O 9z I VIL2IED H AKLU . SRIE06TON AIR DEFENSE POLITICA ed 2 FEE INNTIFICATIO N NUMBER s.ACTION CNNITTEE (FKA ADAC £410 WOODFORD WAY C 0044 7 BIDGETON ST LOUIS NO 63044 3 Ths committee qlualified as a rond icMe committee OUl NG THIS Repon. Period on

III I I 4. TYPE OF REPORT

l a Ari 15 Quarterly Repor, Mof,1tiv ReCor* Cue Or Peybar 2C J,'e 2' 11); , 20 j;ty '5 Quarterly Repol Mac' 20 J, 2C N rnoer 20 Apfi 2C Aigus! 2C D"moer r Ocooer '5 Quartlerly Repor May 20 Septenmoer 20 January 31

January 31 Year End Report Twefth day report preceding . Type ol Eec! o"

Jjly 3! Mod Year Report Non-eeorion Year Only) election on in the State of

VTheeth day report following the General Election or

Terrmnation Report 3 #*V 92 inte State of ______0%

7 (bi is this RPot an Amienirnent YES V. NO SUMMIARY COLUMN A COLUM S This Psded Condr Ye,..-M "0 Covering Perid JI fZ Im.. ho

(a) Cash on Hand Jam . 9 2...... 2$ooeP

(b Cash on Hand at Bepvwog F ...... 0 (cl Total Rlecoop (from ln e 19) ...... $ d Subtotal (add Lines 6(b) & 6(c) or Column A and bri gs) 6 ) a for 8 ) ...... $ $ Total Disburse e (from LM30) ...... 3 7f0. $ 7 $ / f s".q $ I (5.M Cash on Handl at Clos of ePorPig Peo (subbd Line 7 rom brie 60d) 9. Debts ad Ob6geOon Od TO to Coywifte $ $Fwr ~ imw s t: (Itenize &I on ScheLdule C wandor Sch e D)...... Fr N Commission 10. Debt and Obbgabons Owed BY the Ckltvmiise $99 EShet NW (Iterize aN on Schekie C awndor Schex e 0) ...... $W . DC 20463 Report adto the best ot my knowbidge and b~- it is tru. Toll Faw WO424-9630 1 Me*f~ that I have exanined Ona tLoc202-376-3120 and compe, Type or Prnt Name of Treasurer 14810MU16 WOOOFORD H. A WAY Y

Sgnature of Treasurer "- U 63044 USA iDate

NOTE: Submssion of false. erroneous, or xnpiet iinformation may subl: the person signing this Report to the penakltes of 2 U.S. C §437g FEC FORM DETAILED SUMMARY O MCBP AND oIwUMSEMENTS PAGE 2, FEC FOM 3X (risedI 1'91I "c'06""' Belvire,41.... IFeci P44 [REPORTRM giswCOERo ERIOD- * gTO:_r 1; 1

T~ITA1 Ti Pro cosw 1.F19ceipte I

1 Contnbutions tother than Oans) From a indivduai Persons Other Than Political Comrmitees -t I Itemized use Sc'ieule A) N Uniternized JI Total (add, arE V1), D Polical Party Comrrtees Other Politcal Commiees ,suc as PACs OC' d Total Contrbtions, add a Il. b arx 32s5 2 Transfers From AffhbteotOer Pafiy Commtees. '3 All Loans Receive '4 Loan Repayments Receve '5 Offsets To Operating Expenditures (Refunds. Rebates etc. 16 Refunds of Contribubons Made to Federal CrXafes and Other PI Commmees 17 Other Federal ReceMis (Dividends Interest. etc.. 10.73 1073 18 Twsfers from Nonfederal Account for Joint A vty . .. 19 Total Receipts .add l 1d. 12, 13. 14. 15. 16,17. ard 9)8) • f-~73 C) 20 Total Federal Rece gs .suTaCt kne 18 from ne

21 Opwatw -xent a Shared Fedva r-Federal Aarvey (from Sdet 14) 01% n. N Fed ral Shi......

c Toto Ops sr Exp i...... I ..., r . . . ,(Add a.,a.. a d b)) )P 22 2Transfo7 Mrs ~ lo Fo Af S..O h.. in...... w Party Corrn...iSssI...... n a.... n....0).. . 23. CofbUons IDFedera CandiaCmmiils awd 01w P ~ca ra ...... 24 Independent Exo (miber (use* k e 1...)...... 25, CoordinW Expenihim Madb by Party Commmt (2 U.S.C 441ad)) (urn Sdisdi F) . 26. Loan R@pm mew Mad ...... 27 Lo a nMade ...... es ...... 28 Refus4.o C rb s To: .. a. mdmdpPuw01w Than Palikal CIm ...... b Po c lParty C v o rd ...... c Otwe Politcal CoMwuil (such a PACs) ...... d. Total CordSb*on Rekwuds ...... AWa.b aWc) 0 29, Other Disbursene b...... 30 Total DiSbUrsement ...... L.....I...... (add 21c, 22. 23. 24. 25. 26 27. 28d. and 29) jo 7 31 Total Federal Dibusemnts ...... '1....-.(sAubdIm l"n 21 a iifrom Wie 30) *

32 Total Contibuion (othe tn lans~from line li d) ...... 325>-

...... 33 Total Contibution Rlefunds (from "in28d) 32r.- 34. Net Conibuton (othe tha iciaris)(suiw lne 33 from 32) ...... ~2I~

35. Total Federal Operating Expenditures ...... (add 21 a, and 21 b) % 0 0 36. Offsets to Operating Expenditures (from lne 15) ...... _____ 0 __ 0 17 Im ('lmaoimn Fwwwvi ,m bm ~I ~ I p 147 met 11m- m Pynanefft *&a& Wo fu 1110M3M D. I 9 7 Js separate schedulewS PAGEI -- OFII SCHEDULE A ITEMIZED RECEIPTS Detailed Summary Page FOR LINE NUMBER I for each category of the I14 " Any onfotation copied from Rich ephost end Statements may not be sold or used by any pderson for the PurpOse of SOliciting contributions or for commercal i .pea. other Oen using the naoe and addres of any political committee to solicit contributions from such committee. AM OF WOWTTVE Jim Fuel) OR IMEWW #4* bmev6 04c I - I A. Ful Ne. Mailing Addem ad ZIP Code Name of Employer Date (month. Amount of Each 74ac TAYLOQ day, year) RL(exept this PerlcJd SIte of"M,0 ISO&3

Receipt For Primary Geneva to-Date S - e .t 7Other ispec~fy P1Af 4 )A Aggregte 'ea S. Full Name, Mailing Addres and ZIP Code Name of Empov-er Date (mon,, Af'runt o' Eacr) dav, ypa'' F.Mo't =Jjt 'h'5 Pw~f'(1(

Occupation

Receipt For _J Primary General 7 Other 'specify Aggregate Year-to-ate > S

C. Full Name.Iw iling Add and ZIP Code Name of Employer Date imonth. Amount of Eaci day. year) Feceiot thi, Per nor

c:upetion Receipt For: L Primary General) f--" Other (specify): Agregete Yewr-o-Dete $

D. Full Nowe. 111111 g Addeme Oed ZIP Code Name of Employer Date (month. Amount of Each day, vo) Receipt this Period

Occuption Receipt For. r __ General

E. Fu tluiue. 11111" Ad m land ZIP Cede Name of Employer Date (month, Amount of Each day. vee) Receipt this Period

V) Other (specify): AWet Veer-to-Oat., S' ______Occupation Generl Receip fFor: I th er Isp eili): Li IPrik'nL_. A.,..= . Y.- to .. ,as

F. IFall Nwlw, Mak A OW ZIP Code Name of Employer Data (month. Amount of Each tV day, veow) Receipt this Period

Occupat ion Receip For: I Primary H_]Gerw,

0. Full Nam. MKiling Admin md ZIP Ced Name of Employer Date (month, Amount of Each d y. year) Recipt this Period

Occupetion Receipt For: LiPrimary L General F-i Other (specify): Ag ete Yer-to-Date -> S

hIN TOTAL of Receipts This Pop (optional) ...... $ 30C7 TOTAL This Period teast pop this line number only) ...... 9 PAGE OF schedu I@($) F I NME ITEMIZED DISBURSEMENTS forUsil eachseparate category of the PAGE OF SCHEDULE B etailed Summary Page

Any ,nform ion copied from such ReportS nd Statements may committeenot be sold toor solicitused by contributions nv parson forfrom the such purpose committee of soliciting contributions or for commercial purnas, political

NAME OP COMITTEE (in Full) Mit DEFEA,,"sv PAC ~ReDACE0, Date (month. Amount of Each Purpose of Disbursement Dayeao sI Amount of Eich ay, year) Disbursement This Period IA. FullKi Mas. ilW-1(Mitinst AddmO RotO and ZIP Cofi Mv Zq, riv;.c ev'. Disbursement fo P Generai Iq4~ $ 2#5'so6 ~7Other 'speCify' Uate imontn. Arm~urit o' ~aCn Purpose p1 Disbursement f Purpose of Disbursement Date (month.r ADisb unt o PEacro B.Full Name, Mailing Addres and ZIP Code daCly, yea I Disbursement This Period]

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7---;,tL1 0. 1.. 2 11:388LL J. oE Y 0L01 OCT 14 ' INJO N p."

PiLican I. Action Co.i,,.t,..e .

MoMUM mw, NlL 0 VAW~tm, D.C 3 lmm . Cu,,,o

N E W S R 3 L E A S E o br 14,, 1992

VFW-PAC INDORSES JOAN KELLY NO WABIMlgOON, D*C.--The Board of Directors of the Vterans of Foreign Wer Political Action COmittee (VP-PAM) today annoced rW VF-PAC Ia endorsemnt of joan Xely Norn in her bid for re- -elect£on to Nismouri' a Second Congmional Dfittrat, Untedn tte 0ouseN of Repsetative..

C, according to John m. Carny, _--_er--Chef of the 2.2. mixllon amber Voteraum of reign Wtas, ohe Ip.t . of the VP- PIAC is to uppot Congrsional candLdate w dmastmae thet ~. ap t for vetcen rights and national 0ea 1LI y i m adat r,:- by the "wteta Of 1b%*ign Wars ational conventio. 9b 9 Dora If t') " Ord on etragmn' rights and a strong AmerJca maes ber .a.---i- kof the VrP-PAC e,.o-umt.'

Organied in 1979, to advance the purposes of the V ers -Of ForeiLgn Wars through political action in foderMl elections 1 the WM-PAC in an Integral part of the TW. The VIW Political Action Committee is non-partisan and Le Oupported through volunteer contributions from VFW and Auxiliaxy mmbers 6

-30-

I. AFFIDAVIT OF JOHN JOSEPH KLOBNAK

State of Missouri I ] SS. ' County of St. Louis I

Comes now John Joseph Klobnak, of lawful age and having been first duly sworn upoir- his oath, deposes and states as follows: E C,, 1. My name is John Joseph Klobnak. I am a resident of the 2nd Congressional District, St. Louis County, Missouri. My address is 12740 Lonsdale, Bridgeton, Missouri 63044.

2. 1 am one of the Respondents in Matter MUR 3687 before the Federal Election Commission, being a Complaint filed by a Lorraine Miller. Upon information and belief, Lorraine Miller is or was an employee of Representative Joan Kelly Horn or of her re-election campaign.

3. 1 am a director of Bridgeton Air Defense, Inc. ("BAD"), a Missouri not-for-profit corporation. To the best of my knowledge, information and belief no funds of BAD have been exp-ded for or on behalf of any group know as "Citizens Against Horn" or for my other political activity relative to Matter MUR 3687. Respondent further states that he did not peronally contribute any funds to any group known as "Citizens Against Hon" aor is he a *leader" of any such group.

4. I am neither an officer nor a director of the Bridgeton Air Defemse Political Action Committee and have no knowledge of its receipts and disbursements or whether it has filed reports with the Federal Election Conmission.

5. The Respondent is unable to address the allegations contained in PMarmphs 3, 4, 5, 6, 7 and 8 of Mrs. Miller's Complaint filed in Matter MUR 3687 for the reason that those allegations are not directed to this Respondent.

6. With respect to Paragraph 9 of Mrs. Miller's Complaint, this Respondent states that he never made any such statements to Mrs. Miller, nor has he ever met Mrs. Miller. Whether Respondent claimed to have prepared materials for broadcast advertisemnents and communications expressly advocating the defeat of Mrs. Horn is irrelevant since this Respondent neither prqre any such materials, nor did he cause any such materials to be preaed, nor did he have any knowledge of any such materials having been prepared or broadcast in the Greater St. Louis area. 9 S

Fed&l Elecktm Commiuio Pap 2 December 3, 1992 MUR 3687

7. Complaintant's Complaint is frivolous and should be dismissed as such for the reawu that the Complaint was apparently filed on November 12, 1992, nine days after the November 3rd election, thereby making the relief requested by Complainant impossible. Futher, Complainant obviously meant only to annoy and harass this Respondent in that the Respondent knew or should have known that no broadcast advertisements allegedly prepared by this Respondent were aired in the Greater St. Louis area prior to the November 3 election.

Because of the fact that this Respondent did not perform any of the acts complained of by Complainant in her Complaint, Respondent, John Joseph Klobnak respectfully requests that he be dismissed as a Respondent herein and that Matter MUR 3687 be closed as it pertains to him.

John Joseph Klobnak

Subscribed and sworn to before me this 6 ber, 1992. C\1

o,, Notary Public

My Commission Expires: "T' I:OBERT v. v Y NOTARY PURL!- SIAT- (,: W. COMM: ,iCr" E '-z 4'3193 CITY OF ZT. LOUIS 0.

MTf "M Of OKGEATION OF COtWS9,

NAME OF COMMSLz Robert W. May

ADDRESSS -- ;4;p1 rrz6m 3At- . St. Louis, MO 63105

TELEPONE: 314) 721-031

C0 The above-named individual is hereby designated as my -- counsel and is authorized to receive anT notif'cation, and othec ccmaun cati ons fr= the Cci~3Son and to act on my behalf oN beifoe the C0o=isicin.

Date

RESPONDENT* S NAM: John J. Klobnak

ADDRESS: 12740 Lonsdale

Bridet3, MO 63044_

TELPHONZ: ROME( )

BUSINESS( 314 ) 434-6900 06-C -71 (n

-4- 114j~1 ~i ~ $ ~ MAY A BERNE AIIOr 4tCY AT LAW ~' i r miuiu urn 7 7 SON0CWOfU AVEUEU DEC10 ~ 31A1'SL I LOUIS (LAVYTON). U1ubUo 610Mo ?TUM40NE (914) 7114081 PACISMILE: (314) 7111.740

0ONRT W. MAY* OLWSCOUNillO IN U1109CU A ILL.INOIS RINARD ft. NERNE* December 7, 1992

Via Facsimile (202) 219-3923 and Regular Mail

Federal Election Commission Washington, D.C. 20463

Attn: Dawn M. Odrowski, Esq.

Re: MUR 3687

Dear Ms. Odrowski: The undersigned represents John Joseph Klobnak, one of the Respondents in the above matter. Per my conversation of today with Lisa Klein, I am enclosing herewith a Statement of Designation of Counsel which has been executed by Mr. Klobnak together with Mr. Klobnak's Affidavit in response to the Complaint in the above matter. M1. Klein advised that it would be acceptable to file the enclosed by facsimile, following up with the original documents by regular mail. If you have any questions in regard to the enclosed, please call. Thank you for your courtesy and cooperation.

Sincerely,

MAY W.

Robert W. May

RWM/tno Enclosures cc: Mr. John J. Klobnak 9 1 7

AFFIDAVIT OF JOHN B. TAYLOR 9 31A,19L! UEC 10 9 31 '9Z

State of Missouri ) ) SS. County of St. Louis )

NO

Comes now John B. Taylor, of lawful age and having been first duly sworn upon his oath, deposes and states as follows: C. 1. My name is John B. Taylor. I am a resident of the 2nd Congressional District, St. Louis County, Missouri. My address is 12748 Marburn Lane, - Bridgeton, Missouri 63044. 17

2. I am one of the Respondents in Matter MUR 3687 before the Federal Election '" Comission being a Complaint filed by a Loraine Miller. Upon information and belief, Loraine Miller is or was an employee of Representative Joan Kelly Horn or of her re-election campaign.

3. I am a director of Bridgeton Air Defense, Inc. ("BAD"), a Missouri not-for-profit corporation. To the best of my knovledge, no funds of BAD were CN expended for or on behalf of any group known as "Citizens Against Horn" or for any political activity relative to matter PER 3687. Respondent further states 'that he did not personally contribute any funds to any group known as "Citizens Against Horn" nor is he a leader of any such group. o. 4. I am neither an officer nor a director of The Bridgeton Air Defense Political Action Comittee and have no knowledge of its receipts and 0. disbursements or whether it has filed reports with the Federal Election Comission.

5. This respondent is unable to address the allegations contained in paragraphs 3,4,6,7,8 and 9 of Ms. Miller's Complaint filed in Matter MR 3687 c for the reason that these allegations are not directed to this Respondent.

6. With respect to Paragraph 5 of Ms. Miller's Complaint, this Respondent states that he never made any such statements to Ms. Miller, nor has he ever met Ms. Miller.

Because of the fact that this Respondent did not perform any of the acts complained of by Complainant in her Complaint, Respondent, John B. Taylor respectfully requests that he be dismissed as a Respondent herein and that Matter MUR 3687 be closed as it pertains to him.

Subscribed and sworn to before me this day of December, 1992

Not& Public ,

My Commission Expires: JOAN J. DEVINE. NOTARY PUBLIC STATE OF MISSOURI, ST CHARLES COUNTY MY COMMISSION EXPIRES APRIL 9, 1994 (I (7 t

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'j* /o 0.00, xl9-V__ f / '~2A4iA a 41 ,A,6 AfraaD&t TIA a. FEMRENBACHR0 for BRIDGETON AIR DEFENSE, INC.

State of Missouri ) ) SS. County of St. Louis )

Comes now Thomas R. Fehrenbacher, of lawful age and having been first duly sworn upon his oath, deposes and states as follows:

1. My name is Thomas R.Fehrenbacher. I am a resident of the 2nd Congressional district, St. Louis County, Missouri. My address is 12030 Franclar, Bridgeton, Missouri 63044.

2. I am responding for Bridgeton Air Defense, Inc. in Matter MUR 3687 before the Federal Election Commission being a Complaint filed by Loraine Miller. Upon information and belief, Loraine Miller is or was an employee of Representative Joan Kelly Horn or of her re-election campaign.

3. I am a director of Bridgeton Air Defense, Inc.("BAIv'), a Missouri not-for-profit corporation. To the best of my knowledqe, no funds of BAD were expended for or on behalf of any group known as "Citizens Against Horn" or for any political activity relative to MUR 3687.

4. This respondent for the Bridgeton Air Defense, Inc. is unable to CN address the allegations contained in paragraphs 3,4,5 and 6 of Ms. Miller's Complaint filed in Matter MUR 3687 for the reason that these NO allegations are not directed to the Bridgeton Air Defense. 5. With respect to Paragraph 7 of Ms. Miller's Complaint, the use of the 0 Bridgeton Air Defense telephone number at the bottom of Exhibit No. 1 was not sanctioned by the Bridgeton Air Defense and no arrangements vere made O to cover any calls. The Bridgeton Air Defense is a volunteer organization and the office is staffed by a volunteer from 9:00a.m. to noon, Monday CD through Friday. The Bridgeton Air Defense was not affiliated with nor

. provided any finances in support of the activities of "Citizen's Against Horn".

6. With respect to Paragraph 8 of Ms. Miller's Complaint, as Director of n Bridgeton Air Defense, I have no knowledge of the reporting activity of the Bridgeton Air Defense Political Action Committee.

7. With respect to Paragraph 9 of Ms. Miller's Complaint, as Director of the Bridgeton Air Defense this Respondent states that the Bridgeton Air Defense did not make any expenditures to purchase broadcast time.

Because of the fact that the Bridgeton Air Defense did not perform any of the acts complained of by Complainant in her Complaint, Respondent Thomas R. Fehrenbacher for the Bridgeton Air Defense respectfully requests that the Bridgeton Air Defense be dismissed as a Respondent herein and that Matter MUR 3687 be closed as it pertains to the Bridgeton Air Defense.

Thomas R. Fehrenbacher

Subscribed and sworn to before me this ___-day of December, 1992.

Notry P 6 ic,"

My Commission Expires: FEDERAL ELECTION COMMISSION WASHINGT0%, DC 2t046

December 22, 1992

Mr. Dominick Ferranto, Jr., Treasurer Citizens Against Horn 61.3 Woodbriar Lane St. Peters, MO 63376

RE: MUR 3687 Dear Mr. Ferranto:

This is to acknowledge receipt on December 10, 1992, of your letter dated December 3, which was enclosed with your response to the complaint in HUR 3687. In your letter, you ask whether you have grounds for a complaint based on a phone call CN you received from someone seeking information regarding a flier paid for by Citizens Against Horn who failed to identify NO herself, or based on a news release issued by the Veterans of Foreign Wars PAC endorsing Joan Kelly Horn, a copy of which is (%4 attached to your letter together with notes of phone conversations you had with individuals from the VFW. The Federal Election Campaign Act of 1971, as amended ("the Act") and Commission Regulations require that the contents of a complaint meet certain specific requirements. One of these requirements is that a complaint be sworn to and signed in the presence of a notary public and notaized. Your letter did not contain a notarization on your signature and was not properly C7 sworn to. Therefore, we are not statutorily empowered to proceed with the handling of a compliance action unless all the statutory requirements are fulfilled. See 2 U.S.C. 5 437g. In order to file a legally sufficient complaint, you must swear before a notary that the contents of your complaint are true to the best of your knowledge and the notary must represent as part of the jurat that such swearing occurred. The preferred

form is "Subscribed and sworn to before me on this ___day of __F_ 19 ." A statement by the notary that the comlint was sworn to and subscribed before him or her also will be sufficient.

Enclosed is a Commission brochure entitled "Filing a Complaint." I hope this material will be helpful to you should you wish to file a legally sufficient complaint with the Commission. Please remember, though, that the Federal Election Commission has jurisdiction only over matters relating to campaign financing as set forth in the Act and Chapters 95 and 96 of Title 26, United States Code. The acts described in your letter do not appear to relate to campaign financing. However, Mr. Dominick Ferranto, Jr. Page 2

Please feel free to tile a legally believe sufficient complaint if you the matters described in, and attached do constitute a violation tot your letter of the Act or Chapters 95 and 96 of Title 26, United States Code and review the Commission will be glad to the matter as a complaint. For of the Act your convenience, copies and Commission Regulations are enclosed. If you have any questions concerning this matter, contact me at (202) 219-3400. please

Sincerely,

~lein Assistant General Counsel Enclosure Brochure Act Regulations MUR # 3 6 87 ADDITIONAL DOCUMENTS WILL BE ADDED TO THIS FILE AS THEY BECOME AVAILABLE. PLEASE CHECK FOR ADDITIONAL MICROFILM LOCATIONS.

0% FEDERAL ELECTION COMMISSION %%11 ,41%1,' k% C)( 2fl14

I I S 7I.TE &C6tiJo% At1Lig/u

DATE F LED 10Aq /q3CAERA NO. f f

CMllRN44N ____ Press

?3 1OIL~I13G DOCWUUTATZOU KU MOlD TO ~m .u~c mmmD zu cr~om awa ~fL.

.. ,: , , .. . ,, - -. . •

* f** : . if"

i~~r FOR TUE FOLLOWING DOCURUDI1TS PERTINEINT TO TUI8 CASK

1. Memo, General Counsel to the Commission, dated September 22, 1992, Subject: Priority System Report. See Reel 354, pages 1590-94. 2. Memo, General Counsel to the Commission, dated April 14, 1993, Subject: Enforcement Priority System. ~See Reel 354, pages 1595-1620. , 3. Certification of Commission vote, dated April 28. 1993. '; : See Reel 354, pages 1621-22. i ~4.General Counsel's Report, in the Ratter of Uaf-t -_rvnt__ i! Priority, dated December 3, 1993. Se__ee Reel 354, pages 1623-1740. 5. Certification of Coimlsmion vote, dated Der , 1993. ) See Reel 354, pages 1741-1746. "

0.w Kevin N. 0Oleefe, Isq. Uthoff, Orseber, Iobinette & O'Keefe 906 Olive Street, Suite 300 St. Louis, NO 63101

RE: MUR 3687 Dear Nr. O'Keefe: On Novmber 12, 1992, the Federal Election Commssion received a complaint you filed on behalf of your client, Loraine Miller, allegtnq certain violations of the Federal Election C egn Act of 1971, as amnded ( °the Act') Ateg co "ta thenx ci rcuseo of this tor, ttezmme th~e to exerciSe ito prs 'sga 'd retilon

Sincettly,

Dawn N. Odrowski Attorney Attachment Narrative

Date the Commission voted to close the file: _E 0919C likD3!ro AXE DEVllS3, INC. 3? AL. This complaint alleges that Respondents distributed a flt expressly advocating the defeat of Congresswomen Joan Kelly Rorn without the appropriate disclaimr; that the individual or entity who paid for the flier failed to report the expenses associated with it; that Respondent Bridgeton Air Defense PAC (SADPAC) and Citizens Against Rorn (CANl) failed to file reports and to register in a timely manner, respectively; and that Respondent Dridgeton Air Defense, Inc., a non-profit corporation connected to DADPAC, may have spent corporate funds to defeat the Congresswoman. CAR asserts it spent less than $1,000 on the flier. BADPAC filed a report covering the period between January 1 and November 22, 1992, the date of its response. BADPAC was formed by a neighborhood group opposed to a planned airport expansion and its activity has declined since the City of Bridgeton began actively fighting the airport expansion. BADPAC's current reports reflect its declining activity; as of December 31, it had $170 cash on hand. This matter involves inexperienced players, no substantial amounts, and no significant issues relative to the other issues pending before the Commission. Also, there is no indication of any serious intent to violate the FECA. g AL EWko tII4 £OM#S%#O

Vay a Derno 7777 onhom Avenue, Suite 2102 St. Louis, NO 63105

RE: MUIR 3687 John Eloboak

Dear Mr. Nay: On November 19, 1992. the Federal Election Commission notified your client, John Elobuak, of a complaint alleging certain violations of the Federal Election Campaign Act of 1971, as aded. A copy of the complaint was enclosed with that 0 notification. ~After considering the circmemtances of this mtutter, the If) omIgesiont has determined tO .xereim.-its prosecutoriaZ retion and. to th no attires agmiust Joh Llobak. 5ee stt-4 r mtter. ..

po sibl2. le. the file may he.p3,----on he pubic reoftd ttor 0 to rmipt of flar additiml mt!rii3*, any permssible ' mabissioss wil b e d to the public record whe receiwed. If you have any questions. plem ontact me et (203) 219-3400.

Sincerely,

Dwn N. Odrovski Attorney Attachment Narrative

Date the commission voted to close the file: v 91 3| .i This complaint alleges that Respondents distributed a fl&~g expressly advocating the defeat of Congresswomen Joan Kelly Ua without the appropriate disclaimer; that the individual or who paid for the flier failed to report the expenses associae 4 with it; that Respondent Bridgeton Air Defense PAC (SADAc)nd ! Citizens Against Horn (CAl) failed to file reports and to register in a timely manner, respectively; and that Respondent Bridgeton Air Defense, Inc., a non-profit corporation connected to SADPAC, may have spent corporate funds to defeat the Congressvoman. CAR asserts it spent less than $1,000 on the flier. SADPAC report filed a covering the period between January 1 and November 22, 1992, the date of its response. BADPAC was forrmed by a neighborhood group opposed to a planned airport expansion and its activity has declined since the City of Bridgeton began actively fighting the airport expansion. BADPAC's current reports reflect its declining activity; as of December 31, it had $170 cash on hand.

I% This matter involves inexperienced players, no substantial amounts, and no ec) significant issues relative to the other issues pending before the Commission. Also, there is no indication of " any serious intent to violate the FECA. • i' ' L "* ...... ' ~iq~C ~Sb3

bominick( itisensAa& Ferranto,tnst Horn Jr., 'reasutet 613 woodbr tat Lane St. Peters, NO 63376

33E: RUit 3687 Citisens Against Horn and Donick Ferranto, Jr., as treasurer

Dear Mr. Ferranto: notifiedOn NovemberCitisens 19,Agleiat 1992, Mornthe andFederal you, 3lectionas treasuter, Commission of a complaint a11llein certain violations of the Federal Blection Caml8aigln Act of 1971, a aiiomened. A copy of the complaint, was encloedwith that notification.

to receipt of ot submaissioos wit, l be Men to .

219-3400.If you have ant questions,. pl.ecott me~at (203)

Sincerely,

Dawn N. Odrovski Attorney

AttachmentNarrative

Date the Comission voted to close the file: ;'F r '" misruAIa DUVI3, INC. 3?AL This complaint alleges that Respondents distributed a 124. expressly advocating the defeat of Congresswomen without Joan Kelly %t the appropriat, disclaimer; that the individual or who paid for the flier failed to report the expenses with asaociatbd it; that Respondent Bridgeton Air Defense PAC (SADPAC) and Citizens Against Horn (CAR) failed to file reports in a timely and to register manner, respectively; and that Respondent Bridgeton Air Defense, Inc., a non-profit corporation connected may have spent to SADPAC, corporate funds to defeat the Congresswoman. CAR asserts it spent less than $1,000 on the flier. BADPAC report covering filed a the period between January 1 and November 22, 1992, the date of its response. BADPAC neighborhood was formed by a group opposed to a planned airport expansion and its activity has declined since the City of Bridgeton fighting began actively the airport expansion. BADPAC's current reports its declining reflect activity; as of December 31, it had $170 cash on hand.

This matter involves inexperienced players, no substantial amounts, and no significant issues relative to pending before the other issues the Comission. Also, there is no indication of any serious intent to violate the FECA. #1) ,i "ON COMMISSION

on Alt Defense Political " onCmi ttee 14010 Woodford Way Sridgton, nO 63044

RE: NUlR 3687 Bridgeton Air Defense Political Action Committee and Wilfried Adelt, as treasurer Dear, Rr. M elt: On November 19. 1992, the Federal Election Commission ntfied Fou of a co mplaint alleging certain violations of the redeI .e!tioacammpi Act of 1971. as amended. A copy of the cdp._u ei •eme__e vh that notification.

tO exercise its p OmecetiZ Fqetion --i ...... ,...... nst the Bridg ton Air Deftmem i ga treasurer. See attached_ j is, mw public. Zatx4nt i,I

!) ':: :, * Ii e-paed onc,t onpbMe rioord t ",l o

'= r :as the public record lmb4 o asama a

If you have any questions, please contact -e at (202) 219-3400. Sincerely,

Dawn N. Odrovaki Attorney Attachment Narrative

Date the Commission voted to close the file: i [ i i[ i i This complaint alleges that Respondents distributed a ii!i expressly advocating the defeat of Congresswomen Joan Kellj j ) I without the appropriate discIlmer; that the individual or who paid for the flier failed to report the expenses associEn-p4 with it; that Respondent Bridgeton Air Defense PAC (SADPAC) sad4 Citizens Against Hoarn (CABl) failed to file reports and to regittr in a timely manner, respectively; and that Respondent Bridgeton Air Defense, Inc., a non-profit corporation connected to SADPAC, may have spent corporate funds to defeat the Congresswoman. C~ll asserts it spent less than $1,000 on the flier. BADPAC filed a report covering the period between January 1 and November 22, 1992. the date of its response. BADIAC was formed by a neighborhood group opposed to a planned airport expansion and its activity has declined since the City of Bridgeton began actively fighting the airport expansion. BADPAC's current reports reflect its declining activity; as of December 31, it had $170 cash on hand. This matter involves inexperienced players, no substantial amounts, and no significant issues relative to the other issues pending before the Commission. Also, there is no indication of any serious intent to violate the 13CA. : FED:ERAL ELECTION COMMISSION :!

WASHINGTON~i D.C )0*3. J

~h 5om.'aylor 12748 Sarburn Lane eridgeton, NO 63044

RE: NUR 3687/ John B. 'Taylor Dear Mr. 'Taylor: On November 19, 1992, the Federal Election Commission notified you of a complaint alleging certain violations of the Federal Election Campaign Act of 1971, as amended. A copy of the complaint was enclosed with that notification. After considering the circumstances of this matter, the Commission has determined to exercise its prosecutorial discretlon and to take no action maanst you. See attached narrative. Acordingly, the Commission closed it8 file in this Setter. WhHo uofideuntiality provisions of 2 U.S.c. $ 437 4a) fli longe apply a d this netter is now public. In n addis tb .e ftie must be plee on the pb,i¢ rU._o.

s miioewill be added tO the public reoord wheg-w oeiwd.

If you have any questions, please contact mJe at (2302) 21P-3400. Sincerely,

Dawn Nq. Odrowski Attorney Attatchment Narrative

Date the Commission voted to close the file: + ,' j ,:jY

Z~GONAIl D3 133, INC. 3? AL.

1 expresslyThis advocatingcomplaint allegesthe defeat that ofRespondents Congresswomen distributed Joan Kelly a tlterI rn vithout the appropriate disclaimer; that the individual or entity who paid for th. flier failed to report the expenses associated vith it; that Respondent Bridgeton Air Defense PAC (BADPAC) and Citizens Against Horn (CAN) failed to file reports and to register in a timely manner, respectively; and that Respondent Bridgeton Air Defense, Inc., a non-profit corporation connected to BADPAC, may have spent corporate funds to defeat the Congresswoman. CAN asserts it spent less than $1,000 on the flier. BADPAC filed a report covering the period between January 1 and November 22, 1992, the date of its response. BADPAC was formed by a neighborhood group opposed to a planned airport expansion and its activity has declined since the City of Bridgeton began actively fighting the airport expansion. BADPAC'S current reports reflect its declining activity; as of December 31, it had $170 cash on hand. This matter involves inexperienced players, no substantial amounts, and no significant issues relative to the other issues pending before the Comission. Also, there is no indication of any serious intent to violate the F3CA. VEDC L ELCINCM SIO . " ~WAS,INCION. DC. 4-,3

ftdgeton Air Defense0 Xnc. c/o thomas a. Fehrenbachero Registered Agent 12030 Franclai r Bridgeton, NO 63044 RE: NUN 3687 Bridgeton Air Defense, Inc.

Dear Hr. Feherenbacher: On November 19, 1992, the Federal Election Commission notified you of a complaint alleging certain violations of the Federal Election Campaign Act of 1971, as amended. A copy of the complaint vas enclosed with that notification. After considering the circumstances of this mtter, the Commission has determined to ewe reise its prosecutottal ae~cretion adto take no action aJ~sit Rridgetoa &ar'Dou. 2nlc. See4H attachbed narrative. Accordlngly, the Com Is@on €1clse i.'|ts ]le in this matter.

!hyoofdemt ae eti tyons ofas€oWtECt I 4t3E02)a

matetDayst.epprow owi pne~bl.Ui 1 th fie' e Attorney rcod t* ttahetto ora~ia s.4. pI~ Narraisvie 1b d ote~li so m eevd

Date the Commission voted to close the file: ' AIR DKUWS e ?NC. 3? AL.

This complaint alleges that Respondents distributed a fZt O*r expressly advocating the defeat of Congressvomen Joan Kelly II without the appropriate disclaimer; that the individual or ' ,) vho paid for the flier failed to report the expenses assoctgleedi with it; that Respondent Bridgeton Air Defense PAC (SADPAC) air~ Citizens Against Horn (CAR) failed to file reports and to register in a timely manner, respectively; and that Respondent Bridgeton Air Defense, Inc., a non-profit corporation connected to BADPAC, may have spent corporate funds to defeat the Congressvoman. CAR asserts it spent less than $1,000 on the flier. BADPAC filed a report covering the period between January 1 and November 22, 1992, the date of its response. BADPAC was formed by a neighborhood group opposed to a planned airport expansion and its activity has declined since the City of Bridgeton began actively fighting the airport expansion. BADPAC's current reports reflect its declining activity; as of December 31, it had $170 cash on hand. This matter involves inexperienced players, no substantial amounts, and no significant issues relative to the other issues pending before the Comission. Also, there is no indication of any serious intent to violate the FECA.

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