FEDERAL ELECTION COMMISSION ~A'~~iCC)(-DC044,1
THIS IS T' BEGIIj OF MR #
DATE FILMD l / 7,g CEWRA NO,
CAMERAMAN rcge 6'( 40 9. F Daniel E. Williams 19 Complainant Wi 91 i O' Idaho State Democratic Party P.O. Box 445 Boise, ID 83701 (208) 336-1815
BEFORE THE FEDERAL ELECTION COMMISSION
DANIEL E. WILLIAMS, ) ) Complainant, ) v. ) COMPLAINT DIRK KEMPTHORNE,) KEMPTHORNE FOR SENATE, STEVEN SYMMS, ) SYMMS FOR SENATE,, Respondents.) ) ) STATE OF IDAHO ) County of Ada ) Complainant, DANIEL E. WILLIAMS, deposes and says pursuant to 11 C.F.R. 111.4: 1. Complainant Daniel E. Williams is a citizen of the State of Idaho and is Chief Legal Counsel of the Idaho State Democratic Party.
2. Respondent Kempthorne for Senate ("Kempthorne Committee") is the principal campaign committee of Respondent Dirk Kempthorne, who is the Republican nominee for the United States Senate from Idaho.
COMPLAINT - 1 3. Respondent Symms for Senate ("Syms Committee") is the principal campaign committee of Respondent Steven Symms, who is the retiring Republican United States Senator from Idaho. 4. Respondents have violated the Federal Election Campaign Act of 1971, as amended ("FECA"), 2 U.S.C. SS 431, at eg., and related Federal Election Commission regulations, 11 C.F.R. 100, at seg., by failing to report various in-kind contributions made by the Symms Committee to the Kempthorne Committee. The Kempthorne Committee has also accepted more than the contribution limit from the Symms Committee. Respondents' specific violations are set forth in paragraphs 6 through 16 below. 5. On August 7, 1991, Respondent Steven Symms announced that
he would not run for reelection to the United States Senate in
1992. On August 14, 1991, Respondent Dirk Kempthorne announced that he would run as a Republican candidate for the United States Senate in 1992. On September 17, 1991, Kempthorne filed his "Statement of Candidacy" and on September 20, 1991, filed his "Statement of Organization." Senator Symms has stated publicly that he would aid Kempthorne in his bid for the United States
Senate. The Symms Committee has contributed the maximum legal eNl contribution of $2000 to the Kempthorne Committee. 6. Upon information and belief, Respondents have failed to report in-kind contributions to the Kempthorne Committee by the Symms Committee for rent payments made by the Symms Committee on behalf of the Kempthorne Committee. The Kempthorne Committee's
COMPLAINT - 2 76*
campaign office is located in the former Hoff Building, 802 W. Bannock Street, Boise, Idaho in Suite LP 102. The Symms Committee's campaign office was in the same suite of the same location. FEC reports demonstrate that the Symms Committee paid $500 per month in rent for the suite. During September and October, 1991, the Symms Committee paid $500 for the suite, while the Kempthorne Committee paid just $100 for use of the same suite. Beginning November, 1991, the Symms Committee discontinued payments and the Kempthorne Committee began paying the full $500 (see table at Exhibit A). 7. Upon information and belief, Respondents have failed to report in-kind contributions to the Kempthorne Committee by the Symms Committee for office equipment, which failures include the CN following: a. computers and printers, At no time has the Kempthorne Committee reported purchase or lease of computers or computer printers. Yet, the Kempthorne Committee has reported purchase of computer supplies (see table at Exhibit B).
b. t At no time has the Kempthorne Committee reported purchase or lease of a telefax machine, yet a telefax number appears on pre-primary May 1992 stationery (see Exhibit C). c. c At no time has the Kempthorne Committee reported purchase or lease of copiers. Yet, a photograph appearing in Th Idaho Statesman on August 2, 1992, depicts the Kempthorne Committee's press secretary making copies on a copier in the Kempthorne campaign office (see Exhibit D). 8. In July, 1992, an individual saw that certain office equipment in the Kempthorne Committee headquarters still had Symms
COMPLAINT - 3 bumper stickers on them. Upon information and belief, said office equipment belonged to the Syms Committee. Such bumper stickers have been removed.
9. Upon information and belief, Respondents have failed to report the contribution of a telephone line to the Kempthorne
Committee by the Symms Committee. The telephone number listed as Symms for Senate in Boise, Idaho (208-344-1776) (see Exhibit E) and paid for by the Symms Committee rings to an internal line of the Kempthorne Committee. A June 29, 1992, fundraising letter still lists the above telephone number as the Symms Committee number (see Exhibit F). 10. Despite beginning his official campaign on August 14, 1991, upon information and belief Respondents Kempthorne and the Kempthorne Committee failed to disclose either employee salaries or in-kind contributions reflecting employee time until November, 1991. 11. As of November, 1991, the Kempthorne Committee reported hiring three employees, Julie Harwood, Peter Moloney and Pat Nelson. Until November, 1991, all three employees were employed by the Symms Committee, despite Senator Symms announcement in early August, 1991, that he was not running. 12. Upon information and belief, the three employees performed work for the Kempthorne Committee while still on salary with the Symms Committee. At no time has the Symms Committee listed such employee time as a contribution to Kempthorne, nor has
COMPLAINT - 4 6*
the Kempthorne Committee acknowledged receipt of such in-kind contributions of employee time. 13. During the August through November, 1991, period, the Kempthorne Committee maintained a campaign office and telephone. The Kempthorne Committee also made bulk mailings (See Exhibit G), which described a significant level of campaign activity, requiring staff. 14. On September 30, 1991, for example, while still on the Symms Committee payroll, Julie Harwood signed a Bulk Mail Permit with the U.S. Postal Service on behalf of the Kempthorne Committee (see Exhibit H). 15. The salaries paid to the three employees by Respondents are attached in a table at Exhibit I. C\: 16. The above in-kind contributions to the Kempthorne
Committee by the Symms Committee not only remain unreported, but exceed the maximum contribution of $2000 already donated as a cash contribution to the Kempthorne Committee by the Symms Committee. WHEREFORE, Complainant requests: 1. That the General Counsel recommend to the Federal Election Commission that it should find that Respondents have committed violations of FECA and applicable regulations; 2. That the Commission determine that Respondents have committed violations of FECA and applicable regulations; 3. That an investigation, including an audit, be conducted by the Commission;
COMPLAINT - 5 4. Enter into a prompt conciliation with the Respondents to remedy the violations alleged in this Complaint and ensure that no further violations occur; 5. Impose any and penalties appropriate for the violations indicated. DATED this 18th day of Au st, 1992.
Daniel E. Willias SUBSCRIBED AND SWORN bef ore me this 18th day of August,, 1992.
Notary Public for Idaho Residing at Meridian, Idaho My Commission Expires: 3/4/93
COMPLAINT - 6 Rent
July August September October November December 1991 1991 1991 1991 1991 1991 Sy $500 $500 $500 $500 Campign~______Kempthorne $100 $100 $500 $500 Campailgn ......
S(urces:
- January 31 Year End Federal Election Report of 1991 for the Steve Symms For Senate Committee
- January 31 Year End Federal Election Report of 1991 for the Dirk Kempthorne Senate '92 Committee 9.
Computer Disbursements:
Purpose of Amount Date Billing Party DisburSe nt Supplies $ 185.75 4/27/92 Idaho Computer and Supply Computer $ 196.61 3/24/92 Idaho Computer and Supply Supplies Computer $ 139.25 2/24/92 Computer Concepts Supplies I Computer $ 178.50 2/24/92 Idaho Computer and Supply Supplies Computer $ 144.25 1/2/92 Computer Concepts Supplies Computer $ 106.25 1/2/92 KRB Enterprises Repairs Computer $ 99.75 12/5/91 Computer Specialties Supplies Computer $ 60.00 12/2/91 KRB Enterprises Repairs Computer $ 110.00 11/25/91 Computer Concepts Supplies Equipment $ 9.98 11/20/91 Computer Concepts Parts Computer $ 99.75 11/7/91 Computer Specialties Supplies Computer $ 88.20 11/1/91 Computer Concepts Supplies c Computer $ 90.55 10/21/91 Computer Concepts Supplies
Total of Computer and Computer Supply Disbursements = $1508.84
Sources:
- January 31 Year End Federal Election Report of 1991 for the Dirk Kempthorne Senate '92 Committee
- April 15 Quarterly Federal Election Report of 1992 for the Dirk Kempthorne Senate '92 Committee
- Twelfth Day Report Preceding Primary Federal Election Report of 1992 for the Dirk Kempthorne Senate '92 Committee Deer kilao rhem: Thmiy s phnry al1aotin day I Mdmho. And, I need yost help. Sask for your support I the p my eds., Mya .
As the Republcan nominee far the Unind 91e Sen te,J..I cm gina t the Incumbene Congreemen Richard Stang. In this ie geneira elsato The daho voUs have been teing methyU rt
They want to sos som new with soreme Ieas.going to Washington, D.C. They ted! me: "The same old people wih UVie me oid *wd be, going beck agin Iaf te anmow to
My record as Mayor of Boise has been one of change. In the sx yws I've been at City Ha, wqv goen some things done, we've made m changes. Idhoane we proud of their capitl city now, which wasn't always the case.
So, if you went to n some chame rnwL NIfyou waM to send someone to Washington D.C., with som new ideas, someone not tied to the sas quo, then I need mw vat In the orknery dlon nod
There's anaher remn why I need yow s uppo hinOft else on. The idaho pnmy elealon day, May 26, tes on the Tuseday rgh lr the MIody Memorb My holfdy tifs y . You know the MemrleDy lngweekendl v hae foim heeding fur the Ines aind eams In *o Ulad the bea thin CN on their mndswil bevtw in nsprumry el0111n.
Votur tumos on May 26 ould be vary low. Lt of fbtes w have Ju retured from a treewday hoay weekend and Just wMn't remember to show up at the pa"s
I need your coo mndlen thayoull maef a spWiel ut to remmber to go to your poling pl ned Tuesday and y vote Inthe powrimy eleadon - rand
Peope aN oa the coury wE be wching t primry Ica anng to pi *mne spin on IL The po ad expwW in Wslngt D.C. wE wa to declare the likly Novmbnr winner bNed on the - vote.
And the media wil report that incumbert Dick Stalings Is a shoo-in in November N ha get one more vote than I do In the primay election. But you can be the key to geding the Iemptime ampaign off toa shon dert Jul by showi up and cailing your bald so I win a big prmmy voe nawl Tueeday.
When I announced In Fbruy tha I woud baa cadidfte f the United States Sena, I said t was because I am -ed up with the feal w wf
In Washington, ow derald gov mmel seems br uable to bce our nioWspoble md seie upon our great pruii C se n sid, siot in grkd4ook as special isrses speak wih a louder voice than our ctzen Wn e
(208) 336-0092 - P.O. BOX 1866 - BOISE, IDAHO 83701 - FAX: 336-21S4 /heM m cm O. A dt wolue,.,o, lHowo aid Avm am kWoc ww --- ...... 1 w -- Y, as we me we m ...... _ rmL lindPpv i hI 60 fK NUNN P and MIN DOUNCIaN moM NKOMOle I 81AkIn in m n i repeetng ple
The 01M yes hicnbeuwt Demoem grg mn nannl for * sthlos - Rhd Stmng - coe I'm no quelkd because Weam - a
Well, If there's some school Ifo fda buM r.m n Moim.
If I'm supposed to go beck t1r and become Como110 wiu the 01tus quo, and Jut go along to go aong, thnw I'm not going. We need chawu, Dick 9Wtnins the Incumbe Congreman, I we nded by the special b1iset groups from Washlngon, D.C. Thewrw al lkt on keeni the go"_a Stamn s has ovr $1s,0 In his wr dhsk mod of Ittom big unions w d ashngtn D.C., obby groups.He's prepaed o buy a whole l o1 dho ado and tolwleon a We've relee- d--- o- aw "E"------ow-. . -' Whkch Is okay by me. " The poeru speciIal equimInhem mWW don cm mch for my message of chang
So. I nd Wvmw hmL Nof only do I ned your o nes ieedy, be I nd your wlencheW as
'N I ned you to p for a radfobaem' ad or a lew od. I need tw you ti soend my pi n a ch k for ltas o buy a olevilion spot or amo for OWO udek wil buy a nmdf a&d
Relly, any mwAd d hels If INm or w n e1l If you went to olmae 9m Cenpuss mo muoh me I do, I you nmlo vry fo unda 11e grid-lock that hm ground or go m n to a hmn, then maela speeleo ~ to ro Inhnes Tusmd y pilmuy elecdo IWe neied change.
Oft Kw*"luino
PS: If you're going to be gone nsa Tuvefty - tUm"n a Vwes day weekend hfe mning&longer - plem vote by abseraee ballot. Jue go to your ohOft Mieek bears eneo elIDay w eend and ask to vote by eW2 2 bmn One VOSS re nma k a m m&
PPS: I've enclosed a reply envelops to mme esy sNd heck to themm'a Ifyoul juatwks the word t or the wod "radlOon th ou ilde of the einvelop, rl' know asmdly wl you wes us to do with your ooablo. Itwe ro o R CAREERS TV Ppoi* took risk In omlg campalg By Marianne Flagg Journalis ve into The Idaho Statesman quently mo helped n public rel ations move. Th To the vie~ker ioerd it home, KTVB jobs. But Sni he likes. ('hannel 7 he had night reporter Mark SO knowing r] assembly - Snider mig:ht ha,,- he.job." seemed the no job seculn Dav. : ... • .....- 1'n0ummI aflto i' Wrter. The sty eating yond Elect]- l~q a .in ,,ps and :l:r.,-'d, for Nov 3. "Th his rep dinner C e " " Stme vi ww.-r,. m'ict have h-en roll of the dc I ha d -ulTprised sx .okc ago when The ob ha edeadlines Snider turned Snide annrr:nr,,d that he was r into Snider sa: !'aving the ztatnon to become a risk-taker. some- line is fu, press secretir fc-r D,.rk Kempth. thing he was omtbe. ing night. ',rn.,'s U ' ,'ite campaign fore "'I play t safe for so lor ': - .dor 1-:e shock,,d That's %h\'th ai Qa to go to rLIt'h a toug h!ec-o ql h was and go hi T he m ,+ deiel ... . . ,*! r .m a ,. S.V ~xpi 5::i . ! "'It a-rr. ' . i":t K (a, ,i r)-, bv diffhcL w a - '"f. Peop Stuart Wonrr. 'dso S'atesra, I*m happi " ' 'i p oe wtt mv ,,,ntr,- Cause~- at lei :n M....ar Srider s Press secetary for D rk the minds of sr)rn.e Kempthorne ith. IYi s carmpaign Despite I couldn't m:ss" r)-rnalists. leaVir.vl tunttv reporting for a political press job the work, Kempthorne "'I'm -eenz a lot of the state. offered Snider the is like jilting Luke Skvwalker different i lob about a for I've been to places I didn't know week after the pri- a fling with the Dark Side likens itu mary. existed I'm meeting tons Snider wondered if of I'm sti Snider visited the press. people friends in Oregon secretary post would "taint" says. "I d while he mulled him "I'd done as much as [ could the offer. "I made for future news jobs at changed r up my mind driving requiring Channel 7. It was time back from that all-important patina of objec- for a informatic Oregon. Then change. I'm not knocking Chan- I got home and tivity. He decided the risk was clear, con( changed my mind. nel 7. It was a great place to I stayed up one worth the opportunity to see first. Not one night writing my resignation to work." road, Snid, hand how the political process career p]E Channel 7." changes,As often quality-of-life happens in career works. issues What ho ,I THE REST OF THE STORY "That whole thing about Careers/ ,1 leading abohemian life, MOM CUWt , 1111n oesn i exist now." Ifyou Woot telephone trucks to get repaired about r into "lM. While they were getting repaired, Jules Abramovitz CC= I had the day changed his career off to go to the Kobe ecmmn library and read," Abramovitz re- calls. "That was a terrific job I N Look In the Yelowp started stitutions and is a safe. whole- teaching piano seriously." some for prolmsiiona oere He place to raise their children. emigrated to Israel with his Abramovitz selo. Bie... family doesn't regret his They lived there five vaned travels. W Take a slx-wWesi Bo -. years "'For the first time I decid. He says wistfully that State Unlversity Outrefth ed to try my hand his ad- at playing pi- ventures aren't readily course called Career Plaming ann professionally, I available got a -.ob as a to today's young people. for the '90s. It cosat $r9 and (-oc'ktail pianist in a hotel iobbv " "'When I went off to starts Sept. 24. Call 3851974. . . "The He learned thousands Paris to AD of jazz seek adventures, you could N Take a Community Edmc. standards and lounge get a favorites. hotel room in the student such as 'Moon River. quarter for 75 cents a night Abramovitz began and sit over a exist now. singing to glass of wine for a nickel. like to teacd keep himself entertained And Abramovitz advocates that "Nn- you'd sing in bars with people peo- at it and I ei Iadv was liztening. anvwav ple do what they love. If they can "T'he.o.\bratmcv:tze >,-. "That whole thing about "If you ha . Israe& lead- make' a living at it. all the better. ,nu a bohemian l,'e. that doesn't it's worth ta A., n.,vo d to it,:se ',,I!#- "i've found what I like to do. I Up.
. I , .!- 1: . 1r I "ANDE:,:t}"-RS,- ON :.'..'.,rt
U N V A L
Most Of our guests travel lO00s of miles t famous Sun Valley and stay at its only small Inn. You can do so in a few short i *,Av-32-234 Ta Cablevision Of Id&ao State TTC Offke M 6901 W mew Boise-- 376- Ilnc 180 NAncestr AvBoise - 322- Cntuto BUSINESS d41!=W -3WO -642S * TCT 26OE Amit RdBoise.- 343-6400 . Cont SowM Carl It CPA 32376SS T D V.s.Av Boise .------. 336-4244 TATE M =opny51 EStat Eagle.939-6666 Taiboy Robert W REN Swett8W01 InsuranceW Emeral BoiseManagers ------7--- TIN Inc atty Rent <-- ...... 467-2253 .. 6 81SWWashington Boise. .. 344-7811 1661lShorer o 343-5988 Falrvlew! SWIM & RUN SHOP RMes2269 SScyene Wy Bo ... S N._" TJ INTERNATIONAL 336-9246 1 1020F; % Bose 362-4717 514 N16 Boise -38-1LOS 3_ EParer w Bise -- 34- 37" -4k,P 336-0SS2 t is Pa Swiss Sewing Center T.Mau14N uleeB..s- 515Visti a 6453 Fairview AvBotse -...---- - T TALKING BALLOON 377-3788 JHand DoneShoppe Boise-- 344"0233 5l20WFrankfinRdBoise Swiss Tanning Salon TJ's Portrait World -...... ---. 342-5100 &-e .. 376-2132 5155 Glenwood Boise ------322-1022 46 E arview AvMerdn ------888-1667 mmin T Js Yankee Dog 512 Grove Boise .... 343-5648 Tallman Hap Stockman's Supply 362-2400 TJTInc 703NWashingtoinA Inc 4410 Overland Rd -...... 344- 7873 Tai i alss Tamarack TV RCA Servicenter Taylorab Kwl Emmett ---- Star Tel No- -286-7032 Craig TJT Inc 703 NWashntoniA 5273 Cinden n Tel No- -888-6655 Blvd Grdn Cy-....----. 322-4445 Taylor Dallar Emmett - ose Tel No- -336-7447 Tamura &Assoc 499 WMain Boise 1 .- 344-2154 TJT Inc ... 343-2931 726. rSystei, s "VS 141 NWashington Av Tandy Corp Taylor Finley iLLAGE CHEESE Em tt-..-.-.- Star Tel No- -286-7314 See Radio Shack-A Division 362-1763 T &L Merchandising And Of Tandy 6164tW Ere Demo Corp Taylor Haroh Service ..---...... 336-8303 Tandy Electronic Service E a BOOSfE T T L COf Idaho Inc Center 3700 MillRd kano,- MORSTEL NO- 355 N0rcard Boise .375-6559 Bo, -.. 343-7991 -345-4210 4888 Aerorca Boise ...... ----...... 345-7266 Taylor Jack I kInc TANDY LEATHER 285 NOrcard 375-5589 Taylor Jack F TM L INC 120E 40 Grd Cy ------....342-6833 Tangles - ---.--... 343-7366 TMS Training Media Services TanE rarcSStyling d Salon NHam SWISSAIR- 32E F ranklin RdVerdi...... 8873959 ...... _7"95 Taylor, Cc Bose-...... 377-9312 Tanner Marc 1810 Jack I 345-3781 Sales Office TNR Auto Frame I Uni Body S 2 N4 Boise 384-00038 TA1L1810 N raml Toll Free Dial 151 Then ---- 800 238-03S 1027Lusk 336-9531 Passenger Reservations TAYLO 9os ..--- . 336-5830 TN 4010T Auto WGowen Slvage Rd Bois...... 362-4211 1 TUGrlMOAT NICK- (-7 901NC9r ures- 10945s Toll Free Dial 1 A Then ..... 800 221-4750 :urtS R Then -- O 638-9933 Sylvan Learning Center 4M W Emerald Billing --- Boise--...... 345-390 iHNo Aftwe 88-2249 Symetric Styling Salon 0 TN TINSURED QOGOLDIN RULE DRAl' R 606 EBoiseAv Boise -. 34-0297 TAYLOR U( TOWING- 142Btfii Rd * 378-2751 SYMMONDS JEFFREY B g"a TARGET 3Gro-oC,-- 336-3S98 surgery-ce vogery-vaScu Towing Service TAYLOR ROI sugey-- 3821 Overtar Of 3901 WGowen RdBose ---- 362-M777 BUIO(-SU3ARU-SAAS-A Taylor Tom C *se 336-2901 Appointmen 999NCurtis RdBoise 378-283 Day Or Night Call GOLDEN RULE DEALER- Bookkeeping S Insurance 362-2777 Buick3W3 Main ----- Bols e 3 - 7200 Barrist Store Lot 3901 WGowen RdBoise 362-4418 343-75514 35 400 999 N Cur d Rd Boise 378-M3; Taylor Toppe If No Answer Call Parts-Service-Leasing 343-5400 25 N10 Bo. 383-09710 401OWGowen RdBoise - 362-4211 Dose 342-5449 Synwm For Senate From Nampa-Caldwel - 459-1343 Taylor Wlllar Toll Free In Idaho Dial 1 s - 37S-1330 $02w nock tBoise 34W1776 ThTUNITEDTRUCKUNES... Craig RDD SYMM Then -00 223-7247 I& 11WMct&4-Stve smawm. - -- "_3WI'77 40 SColeRdBoise 362-2875 2903 Bogius F 3n3-444 SFax Line - 362-1977 Tea Houe Re TP&S o5SEa4 sl Boise- 342-2225 1534E 1 Mer m 11O~0m"- ,1 TA R Coa'vtructo 1406 E lM-dn - W-2= Teacth-A-Tot Tr's Cinpeiae M-0024 3457 NMa* C )8-1237 ITSCncret 11978 UstRk Moe Sevn11e 166-086 Tel-WhItwo 343-750 TBo F irOFalrvl Boi-377425 C400VLDZN Jerry Tu RULE DIAU ThonaWd 2't n 9cse-336-461 TVAnd=UDctrh 4090WState I 8101lFairsiew Av Boise 37-TVDOC TAS M T UUM I M OrDial 378-8362 l-A TEALEY'S L TV VCR & MIcrowave 479W Main B 2109 SPwinngerDr Don's - 376-6053 331OWSwtM BO se - 336-7009 t-3' 70F*aiUWti Bise---- 3-"1 TW M & Parts-Servc 336-709 TEWPER2399 SOrcha Tol Free nida o Dial 1 Teat Adonna A Then -O-- 8 666-8376 Construction Servk Group - 345-5457 Teter Kris Bo SGlOmOe'rRdSutCBoise Tec-Pac 62; m SYSTEM SEVEN Manufacturing Servic Group -342-3525 5107 Overand RdBoise---- 345-8002 5*To,*SWn em-M3771950 TAKEROCK n -342-611117 BREWPUB & Sysems And S kasu GRILL 7M Fulton Boise----- 342-0944 IRdBose - 345-4703 Bo %rsaAvBoise 4---4-9W Takinan Richrd 1614 430 -344 -9434 Taco Bell1- 1420 Broada AvBoise - 376-5762 - 384-0744 3652177 Fairview AwBoise 378-4SM 3 WSate ... .. 38se354-1234 Ls(,- Taco John'*-- 1Q -' se - 376-30S T-SHIRTS PLUS 338-1522 350 4 M;*aukee Boise . 322-1118 287WStte -...... 345-3721 Ofc 1111 S-Oroad Boise---- 336-1709 t-Zers Shirt Shop 151o EI meran- 118111"$87 ----- 345-9400 T & A CAFE 11o N11 Boise- 345-4" 1323 Bro"aay AvBoise -..--. 342-6616 se..... 376-7242 TA Construction 7000 Fairv wAv Boise - 322-6061 9007 wossy Cup Boise...... 362-2641 1473 SFive mile Rd- ..... 375-0214 ...... -...... 336-3636 Taco Time Boise Towne Square hartered TAS Trucking 350 N Miaukee Boise -.-. 322-1707 Taco -- 345-9400 2415 elAvenue NortihEt Time Broadway Av 0w -Ma-Bose 336-3636 Nampa h-- 110 BroadwayAv Boise ---- 336-7472 Meridian Tel No- -888-4205 Taco Time 345-0006 TC Mac Construction Co 4 Overland 690 vewldRdBO C'"s 2117 N13 Boise - - - 336-0443 se... 377-0391 7 338-6312 TCPRINTING Taco Time State Street ;e 34S-7533 532o WEmeriad 1106 WState Boise - - 344-3288 Boise 375-8059 T co Time Visht P T CI Y The Countrys Best Avenue 342-2706 405 VI AuBoise 343-0932 Yogurt- Tao Time Wet 1vBoise 322-6753 FlaorUne 373-822 Fairview Av roo t-- 344-7271 Or 7965 FairviewAv Boise 376-3282 Dial T 378-TCBY Tactical Edge Inc lose Towne Swore BoW e - 323-8677 se-^- 6109 Overland RdBois e 327-0301 34S-O960 ll BroadwayAv Boise 334-337 Taft School er Ii Cy-392-4915 7103 Ovewland RdBoise 3722 Anderson Boise- 338-35OO 323-1904 Tgart Jeff Ball Bonds - 322-4747 1517 NMilwaukee Bois 376-4600 T4e 1Video Productlo P rkcenter Mail 32-4914 Boise 338-1317 511w Main BOs e-... 344-9498 190 WState Boise 384-0994 Talbert Stables ,se-- 3V7-0294 694OWStae Boise- 1675 WKuna RdKuna 922-4055 - S3-4800 Talbot's 415 EPar Center Blvd Boise -- 344-4202
m bI
S SENATOR FOR VAHO
Box 471 Boise, kho 83701 * m44-1776 June 29, 1992
The prima-., election is over and in less than five tnrint's you and I will cnoose a persoti to fL. Lre zeat i±ii vacace n .iL y . I've got to tell you, I have mixed feelings about not being on the ballot - ABOUT NOT BEING ABLE TO STAND UP ON THE SENATE FLOOR AND GO TOE-TO-TOE WITH THE LEFT-LEANING DEMOCRATS, THE SOCIAL DO-GOODERS, AND THE UNILATERAL DISARMAMENT CROWD. The other day, while I was in a drugstore back home in Caldwell, I overheard a guy say something like: "Well, this year either Senate CN candidate will be OK. They're both pretty conservative." That stunned me! Nothing could be further from the TRUTH! Hearing that prompted me to sit down and write this letter to you O as one of the key backers of Dirk. I'll be right up-front. I'd like you to once again support Dirk Kempthorne in two ways:
1) By sitting down and writing out a check for as much as you can afford. 2) By spreading the information I'm sharing with you in this letter around to your friends and neighbors. I wouldn't ask you to do these things if I didn't think it was absolutely necessary. I don't like asking for money. If you're like most Idahoans, it's hard enough just making the mortgage payment, much less contributing to every political candidate that comes along. And... I wouldn't ask you to support a man without you knowing -- beyond a shadow of a doubt -- that he shares your values and will fight for you and your family in the U.S. Senate. There's one more thing you should know. The conversation I overheard in the drugstore made me think of this. YOU NEED TO KNOW THAT THE MAN YOU ELECT IS HIS OWN MAN. I stayed out of the Senate Primary. I didn't want to be accused of (over) trying to pick my hlsor. But now that itftr, and Republicans have picked Dirk, I am going to do everything in my power to make sure he wins!
First of all, that guy I overheard in the drugstore was wrong - DEAD WRONGI There is only one conservative in the Senate race and his name is DIRK KEMPTHORNEI
Stallings doesn't seem to know what he is, or where he stands. He wears more masks than you'll see on Halloween. If he has beliefs or principles, they change faster than Idaho weatherl Dirk kind of reminds me of me - 20 years ago. Oh... he may not be as brash and maybe not as controversial, but, he knows where he stands and has the guts to stand up and fight for what he believes. I saw a newspaper tabloid the other day quoting Dirk. He said, "If there is one reason, above all others, why I want to be the next Idaho Senator, it is because I'm also fed up with the federal government! "
That's enough for me. But where does he stand on the issues important to you? Here's some of Dirk's quotes I've picked up: * STATE'S RIGHTS - "We need more decisions at home and less decrees from Washington D.C." * FEDERAL BUDGET - "The idea of tax and tax, and spend and spend is - ; absolutely out of control. I will be a tenacious fighter for a Balanced Budget Amendment. * AGRICULTURE- "The Idaho farmer can compete with any farmer in the world, but not with foreign treasuries. That's why unfair competition.. .must be countered.* * WATER - "The assault on our water will have to be fought - and won - in the United States Senate, where every state is on equal footing with two Senators. My position on outside control of our water is C simple. Not one dropl" * GUN CONTROL - *I fully support.. .the right of the people to keep and bear arms. And this is just the beginning. Dirk has well thought out stands based on coaon sense, sound beliefs and conservative principles. But Dirk is only half the story. What about Richard Stallings? What do we get if Stallings is able to masquerade his way into the Senate.
FIRST OF ALL, YOU GET A GUY WHO WILL OWE HIS SENATE FUTURE TO THE DEMOCRAT MAJORITY LEADER, GEORGE MITCHELLI THIIS1 RE MNOUGM TO RUJICT STALLINGS!
I know George Mitchell. George Mitchell is a friend of mine. But George Mitchell is no friend of Idaho! It vao George Mitchell, along with Ted Kennedy, Howard Metzenbaum and Joe Biden who led the charg on the so-called crime/gun control bill. A few of us have been able to bottle up that bill because it's nothing but a gun control bill.
It is George Mitchell who wants to spend YOUR tax dollars for political campaigns.
It's Georg e Mitchell who caters to the every whim of the Sierra Club, the Wilderness Society and the other radical environmental groups. (The so-called Clean Air Act was George Mitchell's doing.) It was Mitchell who called up and pushed through, over my opposition, a Nevada wilderness bill that sets a terrible precedent for giving away western states' water rights (Richard voted FOR this bill in the House)! And... it was George Mitchell who PERSOALLY tried (but failed) to KILL my PRIVATE PROPERTY RIGHTS ACT! GEORGE MITCHELL WILL DECIDE ON WHICH COMM4ITTEES RICHARD STALLINGS SITS - HE WILL DECIDE IF STALLINGS' BILLS SEE DAYLIGHT - HE WILL DECIDE IF STALLINGS IS A PLAYER OR A BYSTANDER. I know how the Senate works. If Stallings is to be a success, he's going to have to make some deals with Mitchell. What is he willing to trade for? What is a choice commnittee assignment worth? What will Mitchell demand from Richard?
It's true Dirk will have to work with Republican leader, Bob Dole. 0\ But there's a huge difference between Bob Dole and George Mitchell. Dole is from Kansas and understands Western issues. Dirk Keinpthorne (N and Bob Dole will make a good team.
Even without the wMitchell Connection." Stallings would be an unmitigated disaster in the U.S. Senate. I've watched Richard over the years he's been in the House. His record isn't very pretty. Since he's been in the House, he's voted for spending bills V~totaling $79,720,407,027 MORE than the President asked for. THT' NEARLY 80 BILLION DOLLARS! (Or about $1,235 for every family in America!)
In the House Richard was all over the map on Western issues like water rights and private property.
Clear back in 1987 when we were trying to finally settle the Swan Falls water debate, Richard was trying to 0... satisfy the environmentalists." While others like then Attorney General Jim Jones and Jim McClure worked to add language to Stallings' bill protecting water rights, Richard was trying to "satisfy" the environmentalists!
(over)
------In 1988 when Richa introduced his bill to Omct the City of Rocks, he left out a provision to protect Idaho's water rights. Senator McClure came to the rescue again. Then, in 1989 Richard voted AGAINST state water rights TWICE in the Nevada Wilderness bill. Idahoans and Nevadans alike were outraged! And what about Private Property? Richard is like a ping-pong ball. First he supported H.R. 1330, the Wetlands Bill, sponsored by Congressman Jimmuy Hayes of Louisiana. Wow, all of a sudden, he opposes it. This bill would provide just compensation to property owners whose rights are literally *taken" by the federal government. I really get frustrated with his lack of action (or interest) in my bill, the PRIVATE PROPERTY RIGHTS ACT. He says he's for it, but if he is, it's hard to tell! I have repeatedly asked him to step up his efforts on behalf of Idaho property owners. So far he's like talking to a brick wall. IF RICHARD MAKES IT TO THE SENATE, WHAT DO YOU SUPPOSE HIS BOSS, SENATOR MITCHELL WILL TELL HIM TO DO ON PRIVATE PROPERTY RIGHTS? (It was Mitchell who fought tooth and nail but failed to stop my bill in the Senate).
In less than FIVE months we're going to elect a Senator who will serve for SIX years. We can't afford to send George Mitchell another loyal follower. We need Dirk Kempthorne. He'll go back there and make a difference. But he needs your help. Stallings is raising money like mad. I'm sure Mitchell is steering as much PAC money Richard's way as possible. Will you join me in doing the three things I asked? First, write a check. Second, make copies of this letter and circulate it amongst your friends. Finally, make sure you vote for Kempthorne in November. I'm not going to be on the ballot, but that doesn't mean I'm through fighting! Dirk will go to Washington and take over where I left off. I'm going ta do everything in my power to help him. Will you join me?
If you will, we'll elect a strong, capable, independent Senator who will fight for you... and not another whipping boy for Senator Mitchell.
Yours for a free society,
UNITED STATES SENATOR
Ab A S D i& E4* Sot- October 10, 1991
CAM.PAIZN 24N x8UZ.i rzURl
DIRUC xvcZSIPWHOMM FORa SEN4ATOR
too riuw ]s tO.LSoIUC, auv~lao €mw. s
More than 500 new supporters have signed on with the Kempthorne campaign following a mid-September statewide mailing. And those supporters are backing their commitment to the campaign with their wallets and pocketbooks.
In the first three weeks following the mailing, campaign contributions have cm in at a pace that will most likely make this initial fundraising effort the most successful letter of its kind in Idaho campaign history.
aitaAM 5UX CKUIxTTU 5 Rs AI-7vx_-ID
In less. than five weeks, the initial Kmthorne Statewide Support Comittee was formed with an impressive list of over 160 names representing every part of the state, and virtually every walk of life.
The support continues to swell from Idaho's Rain Streets to C7 country crossroads. "Everyday, mor& and more folks are signing up for the team. It's an encouraging sign to see our campaign off to such a great start and continaing to gain mioam," Kenpthorne 011 sLd.
~X-ISOW- AMO RIUNIN Dirk w and his wife Patricia hit the campaign trail NT runnlng. After attending the Region V7I barbecue in Idaho Falls with PaL and their two children, it was off to Coeur d'Alene where Dlrxk rallied support at the Idaho Rining Association conventio Fr Couz d' Alene, Dirk hooked up with the family in Twin Fal for evets is Twin and Sun Valley. A
An Dirk meets with large groups, his speeches focus on the local perspective that he' Ill bring to Washington, D.C. -- building on the them that the United States Senate needs a few good mayors; mayors who have been trained to balance a budget annually, mayors who undeostand. the effects mandates, edicts and regulations from the federal goverrment will have on small towns in states like Idaho.
Moat any evening you'll find-Dirk and Pat talking about the issues in people's homes. Receptions hosted by Kempthorne supporters are giving people an opportunity to hear directly from the Candidate and his wife without any analysis or editorial comments from the media. The receptions have also become an effective fundraising tool for the campaign, allowing new contrUtors to donate -- even if It's only a smll amount.
COMMTISJfOWS ARE MOT MX DEuCSE PkiO 6"yOAK KENFTN4OANG 5NA3 92 U. S. Senate Cay o lrnewants to talk taxes with the people of Idaho. A1% his intention to run for the Senate. Kempthorne said W : take his record of fiscal responsibility to Washimgtom, D.C. to help get the federal deficit under control and curb the tax a spend mentality currently held by Congress. "Before we ca turn this runaway train around we must f irst stop the trai, meptlons said.
"For every dollar met IdAhoan Pay in taxes, 61 cents ends up going straight to Washington, D.C., and yet Congress can't balance a budget. instead, my Dortsilc opponent and others In Congress continually raise the debt limit, and ask for more money. "Less than 10 cents of your tax dollar goes to local government, and yet that's the fund that pays for police and fire protection, schools, parks, libraries, and the road system. It's the things that we touch every day. It's where we live, and yet local governments balance their budgets every year." Kemthorne said he will support a balanced Budget Amendment. and i.ne-itea veto authority for the hresident, but he will not vote to raise the debt limit anymore. "we have to live within our means as a governent. We citizens have to do it every year."
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BULK RATE )irk Kempthorne Ui S POSTAGE PAI1 Senate '92 BOSE ) 63?W - i -- "OE- PERIT NO '59 :zz --A a 9C r 00 CLW O zV
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MJu ie Harvood
Aug.- Sept. Oct. RNoy. Dec.- an. l.70 mar. Apr.- 1991 1991 1991 1991, 1991 1 1992 :A,992 -1992 1i992 Symms $1830 $1830 $1830 campaign Kempthorne $915 $2747 $916 $1833 $1861 $2791 Campaign
Peter Moloney
Aug. Sept. Oct. Nov. Dec. Jan. Feb. Mar. Apr. 1991 1991 1991 1991 1991 1992 1992 1992 1992 ymms $946 $946 $1618 ICampaign "Kempthorne $473 $1421 $473 $946 $960 $1440 ampaign --
-N -Rat Nelson
Aug. Sept. Oct. Nov. Dec. Ja. Fob. War. Apr. 1991 1991 1991 1991 1991 1992 1992. 1992 1992 I p $658 $582 $730 campaign , ______
Kempthorne $364 $659 $105 $246 $216 $404 Sampaign
Sources:
- January 31 Year End Federal Election Report of 1991 for the Steve Symms For Senate Committee
- January 31 Year End Federal Election Report of 1991 for the Dirk Kempthorne Senate '92 Committee - April 15 Quarterly Federal Election Report of 1992 for the Dirk Kempthorne '92 Committee FEDERAL ELECTION COMMISSION
August 25, 1992
Daniel E. Williams Idaho State Democratic Party P.O. Box 445 Boise, Idaho 83701
RE: MUR 3594 Dear Mr. Williams:
This letter acknoviedges receipt on August 19, 1992, of your complaint alleging possible violations of the Federal Election Campaign Act of 1971, as amended (Othe Act"), by Dirk Kempthorne, Steve Symas, Dirk Kempthorne Senate *92 and Sharon L. Allen, as treasurer, Symas for Senate Committee and Richard L. Buxton, as treasurer, Julie Harvood, Peter Noloney and Pat Nelson. The respondents will be notified of this complaint vithin five days.
You vill be notified as soon as the Federal glectlon Commission takes final action on your complaint. Should you Qreceive any additional Information In this matter, ploase forvard It to the Office of the General Counsel. Such Information must be sworn to In the same manner as the original rcomplaint. We have numbered this matter HUR 3584. Please refer to this imumber In all future correspondence. For your information, ve have attached a brief description of the Commission's procedures for handling complaints.
SincereL
Jonathan A. Bernstein Assistant General Counsel
Enclosure Procedures FEDERAL ELECTION COMMISSION
'"%ASM~N(T(N [) ( 21)4#0
August 25, 1992
Sharon L. Allen, Treasurer Dirk Kempthorne Senate '92 P.O. Box 1866 Boise, Idaho 83701
RE: MUR 3584 Dear Ms. Allen:
The Federal Election Commission received a complaint vhich Indicates that the Dirk Kempthorne Senate '92 Committee ('Committeem) and you, as treasurer, may have violated the Federal Election Campaign Act of 1971, as amended (Othe Act"). A copy of the complaint Is enclosed. We have numbered this matter MUR 3584. Please refer to this number In all future correspondence.
Under the Act, you have the opportunity to demonstrate in vriting that no action should be taken against the Committee and 0- you, as treasurer, In this matter. Please submit any factual or legal materials which you believe are relevant to the C. Commission's analysis of this matter. Where appropriate, statements should be submitted under oath. Your response, which Dshould 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 Information. rn This matter vill remain confidential In accordance with 2 U.S.C. 9 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 authorising such counsel to receive any notifications and other communications from the Commission. Sbaron L. Allen Page 2
If you have any questions, Zanfardino, please contact Richard the staff member assigned to this matter, at (202) 219-3690. For your Information, ve have enclosed a brief description of the Commission's procedures for handling complaints.
Sincerely,
Jonathan A. Bernstein Assistant General Counsel
Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement
C) 0Q1
01 FEDERAL ELECTION COMMISSION
August 25, 1992
Dirk Kempthorne 2211 Cornhusk Court Boise, Idaho 83706
RE: MUR 3584
Dear Hr. Kempthorne:
The Federal Election Commission received a complaint vhich Indicates that you may have violated the Federal Election Campaign Act of 1971, as amended ("the ActO). A copy of the complaint Is enclosed. We have numbered this matter HUR 3584. 0Please refer to this number In all future correspondence. C Under the Act, you have the opportunity to demonstrate In vriting that no action should be taken against you in this matter. Please submit any factual or legal materlals vhich you believe are relevant to the Commission's analysis of this matter. Where appropriate, statements should be submitted under C oath. Your response, vhich should be addressed to the General Counsel's Office, must be submitted within IS days of receipt of this letter. If no response is received vithln 15 days, the Commission may take further action based on the available Information.
This matter vill remain confidential In accordance vith 02 U.S.C. 5 437g(a)(4)(9) and 9 437g(a)(12)(A) unless you notify the Commrsslon in vriting that you vish 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 authorising such counsel to receive any notifications and other communications from the Commission. S. em
Dirk Kempthorne Page 2
If you have any questions, please contact Richard Zanfardlno, the staff member assigned to this matter, at (202) 219-3690. For your Information, we have enclosed a brief description of the Commission's procedures for handling complaints.
Sincerely,
Jonathan A. Bernstein Assistant General Counsel
Enclosures O1. Complaint 2. Procedures 3. Designation of Counsel Statement CN C
C FEDERAL ELECTION COMMISSION
A%ASH I%(" M%P 1) ( 2f044 1
August 25, 1992
Richard L. Buxton, Treasurer Symms for Senate Committee P.O. Box 471 Boise, Idaho 83701
RE: MUR 3584
Dear Mr. Buxton:
The Federal Election Commission received a complaint which 7-NIndicates that the Symms for Senate Committee ("Committeeo) and you, as treasurer, may have violated the Federal Blectlon Campaign Act of 1971, as amended (Othe ActO). A copy of the complaint Is enclosed. We have numbered this matter NUB 3584. Please refer to this number In all future correspondence. all Under the Act, you have the opportunity to demonstrate In vriting that no action should be taken against the Committee and you, as treasurer, In this matter. Please submit any factual or Clegal materials which you believe are relevant to the Commission's analysis of this matter. Where appropriate, statements should be submitted under oath. Your response, whlch should be addressed to the General Counsel's Office, must be submitted vithin 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.
Thls matter will remain confidential in accordance with 2 U.S.C. S 437g(a)(4)(B) and I 437g(a)(12)(A) unless you notify the Commission In wrltlng that you vish 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. lichard L. Buxton Page 2
If you have any questions, please contact Richard Zanfardino, the staff member assigned to this matter, at (202) 219-3690. For your Information, ye have enclosed a brief description of the Commission's procedures for handling complaints.
Sincerely,_
Jonathan A. Bernstein Assistant General Counsel
Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement CN
C FEDERAL ELECTION COMMISSION .AkHI1%(,r0% D( 2114fil
August 25, 1992
Steve Symms P.O. Box 471 Boise, Idaho 83701
RE: KUR 3584
Dear Mr. Symms:
The Federal Election Commission received a complaint which Indicates that you may have violated the Federal Election CN Campaign Act of 1971, as amended (*the Act"). A copy of the complaint is enclosed. Ve have numbered this matter HU 3584. Please refer to this number In all future correspondence.
Under the Act, you have the opportunity t, demonstrate In vriting that no action should be taken against you in this matter. Please submit any factual or legal materials which you tbelieve 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 C' this letter. If no response is received within IS days, the Commission may take further action based on the available Information.
This matter will remain confidential In accordance w1th 2 U.S.C. 9 437g(a)(4)(B) and 9 437g(a)(12)(A) unless you notify the Commission In writing that you vsh 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. Steve Synma Page 2
If you have any questions, please contact Richard Zanfardino, the staff member assigned to this matter, at (202) 219-3690. For your information, ve have enclosed a brief description of the Commission's procedures for handling complaints.
Sincerely,
Jonathan A. Bernstein Assistant General Counsel
Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement
C o0. FEDERAL ELECTION COMMISSION
August 25, 1992
Julie Harwood 8723 San Marino Drive Boise, Idaho 83712
RE: MUR 3548
Dear Mr. Harvood:
The Federal Election Commission received a complaint vhich Indicates that you may have violated the Federal Election Campaign Act of 1971, as amended (=the ActO). A copy of the complaint Is enclosed. We have numbered this matter HUR 3548. Please refer to this number In all future correspondence.
Under the Act, you have the opportunity to demonstrate in CN writing that no action should be taken against you In this matter. Please submit any factual or legal materials which you believe are relevant to the Commission's analysis of this 0 1 matter. Where appropriate, statements should be submitted under oath. Your response, which should be addressed to the General 0Counsel's Office, must be submitted within 15 days of receipt of this letter. If no response is received within IS days, the Commission may take further action based on the available Information. o This matter vill remain confidential In accordance with 2 U.S.C. 9 437g(a)(4)(D) and 9 437g(a)(12)(A) unless you notify Mthe 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. ". 11 -- '. - F'17W- rm17MM :M- M? 7 - , . - " - ,r 'I: 1 -1 1'...
Julie Harvood Page 2
If you have any questions, please contact Richard (202) Zanfardino. the staff member assigned to this matter, at brief 219-3690. For your information, we have enclosed a description of the Commission's procedures for handling complaints. Sincerely,
Jonathan A. Bernstein Assistant General Counsel
Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement
CN C
0 FEDERAL ELECTION COMMISSION
. ',d 4INl(, I ( )% {) C 2CC4bDI
August 25, 1992
Peter Moloney 4931 Sorrento Boise, Idaho 83704
RE: MUR 34
Dear Mr. Moloney:
The Federal Election Commis1on received a complaint vhich Indicates that you may have violated the Federal Election Campaign Act of 1971, as amended (*the Acto). A copy of the complaint Is enclosed. We have numbered this matter NUR 3548. \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 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 Information. This matter will remain confidential In accordance with CN 2 U.S.C. 9 437g(a)(4)(B) and I 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 stat-ing the name, address and telephone number of such counsel, and authorizing such counsel to receive any notifications and other communications from the Commission. es e
Peter Moloney Page 2
If you have any questions, please contact Rlchard Zanfardino, the staff member assigned to this matter, at (202) 219-3690. For your information, ye have enclosed a brief description of the Commission's procedures for handling complaints.
Sincerely,,
/ -
Jonathan A. Bernstein Assistant General Counsel
Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement
C0 IL,1 - . - I..t-; . ... V 4- SMF- 3 1 , - -_ -. . - .. . I.., r, -- , . . I.. . . ! 1. 1 - --
FEDERAL ELECTION COMMISSION
August 25, 1992
Pat Nelson 3349 Chickory Way Boise, Idaho
RE: MUR 35 I Dear Mr. Nelson:
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 complaint Is enclosed. We have numbered this matter MUR 3548. C J Please refer to this number In all future correspondence.
C) 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 vhich you 01% believe are relevant to the Commission's analysis of this matter. Where appropriate, statements should be submitted under Coath. 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 1S days, the Commission may take further action based on the available Information. M) This matter will remain confidential in accordance with rK 2 U.S.C. S 437g(a)(4)(8) and I 437g(a)(12)(A) unless you notify the Commfsslon 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. Pat Nelson Page 2 If you have any questions, Please contact Zanfardino, the staff Richard member assigned to this 219-3690. For your matter, at (202) Information, ve have enclosed description of the Commissionis a brief procedures for handling complaints.
Sincerely,
Jonathan A. Bernstein Assistant General Counsel Enclosures I. Complaint 2. Procedures 3. Designation of Counsel Statement
0C% q
P.O. U34x445 FEDERAL Boise. I) 83701 S. i.Phi (208) 136-iM!5 I ) STATE DI \TIC PARTY !L :,:,.Toll Free inldaho I M0 42-SDP(47:17) r iPFAX 1208336-117
EXECUTIVE COMiITTEE Daniel E. Williams W, Chief Lega Counsel
August 26, 1992
General Counsel Federal Election Commission 999 E Street, N.W. Washington, D.C. 20463 . -
- - RE: Williams v. Kempthorne, et al. -) --
J > Dear Counsel:
This letter represents an Addendum to the Complaht : filed August 18, 1992, and captioned Daniel E. Willias, : Complainant, vs. Dirk Kempthorne, Kempthorne for Senate, z Steven Symms, Symms for Senate, Respondents. I provide this addendum to provide additional information and confirmation of the matters set forth in the original Complaint. The Federal Election Commission must act to bring
SL+ Respondents into compliance with applicable laws. The additional evidence discussed below establishes conclusively 1. i, that the Kempthorne and Symms Comittees have violated the S Federal Election Campaign Act and F.E.C. regulations. Such t... violations cannot be attributed simply to sloppy reporting or commonplace administrative errors. Rather, they evidence S . an utter disregard for minimum reporting requirements and contribution limits. The F.E.C. should take all necessary steps to correct this situation as soon as possible, including ordering an audit of the books and records of the Kempthorne and Symms Committees to insure that the public record accurately 1F +l reflects the activities of the Committees. The F.E.C. should require the Kempthorne Committee to refund to the Symms committee the full amount of undisclosed in-kind contributions and should require the Symms Committee to file continuing F.E.C. reports at the same time that the to file. FXF (1ITI VE DIRECTOR Kempthorne Committee is required I F- _ ,
FI\AN\'IAL tA\AGE R
E \EI TIVE S ECRETAR
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Ix<~ ~,,, ~ ~.; ~.tj, ~' ~.. ",<: x! i:V171 t,,r Ta\x t whc ot-' tI!lr tht: Ilctrniqwrjtlc Party. Thank vou. General Counsel Federal Election Commission August 26, 1992 Page 2 Further Evidenoe ond Admissions of Violations. 1. According to news reports following the filing of the original Complaint (see Associated Press report attached as Exhibit A), an individual named Kelly Beale, who operates KRB Enterprises and provides computer services to the Kempthorne Committee, confirmed that the computer equipment used by Kempthorne came from the Symms Committee and other sources. 2. At first, the Kempthorne campaign called the evidence of violations in the original Complaint "baseless and false." Yet, Kempthorne's campaign manager, Phil Reberer, who previously worked on Symms Senate staff at the same time as he ran the Kempthorne campaign, admitted in a news report (see The Spokesman-Review report attached as Exhibit B), that the Kempthorne computer system came from the Symms operation. Reberger also admits that there was "value received and given." 3. Taking depreciation into account, a conservative estimate of the value of the computer equipment and printers supplied to the Kempthorne campaign by the Symms operation is $4,250.00.
4. The Kempthorne campaign has not denied that the Symms Committee employees identified in the original Complaint performed work on behalf of the Kempthorne campaign. The three staff members were paid by the Symms Committee for three months after Symms announced he would not run for reelection. The filings already on record in the original Complaint indicate a high level of Kempthorne activity during the relevant time period. By the Symms Committee's own reports, the value of these employees' time totalled $10,970.00. 5. Just as the Symms employee time represented an unreported in-kind donation, so too did the staff's use of the Symms campaign office represent an in-kind contribution. As set forth in Exhibit A to the original Complaint, the value of the Symms office for the relevant period was approximately $1,250.00. 6. On this record, the minimal amount of unreported in- kind contributions made to the Kempthorne Committee by the Symms operation is $16,470.00. Conclusion Respondents are not new to federal election law requirements. Kempthorne's campaign manager, Phil Reberger, is a veteran of federal elections (See Exhibit B). The Kempthorne and Symms Committees' failure to provide the complete disclosure required by federal law does a disservice to the voters of Idaho, who must rely on F.E.C. reports for reliable information about the campaign activities of federal candidates. General Counsel Federal Election Commission August 26, 1992 Page 3 On the basis of the foregoing, Complainant asks that the Commission take the following actions: 1. Conduct a prompt investigation, including an audit, oj - all the violations evidenced in the original Complaint-
2. Enter into a prompt conciliation with the Respondents to remedy the violations evidenced in the original Complaint and confirmed in this Addendum; 3. Require, as a necessary part of the conciliation, thatw the Symms Committee file regular pre-election reports with the F.E.C. at the same time as the Kempthorne campaign to ensure that no further violations occur; 4. Require the Kempthorne campaign to refund no less than _NJ $16,470.00 to the Symms Committee to reflect the minimum value of the unreported in-kind contributions; 5. Impose any further res ictions or penalties as the CN circumstances may requir . DATED this i day of August, 1 2.
Daniel E. Wlliams STATE OF IDAHO ) ss: County of Ada ) On this J day of August, in the year 1992, before me, TAN! R.SolwijI, notary public, personally appeared Daniel E. Williams, known or identified to me to be the person who executed tho instrument, and acknowledged to me that he executed the same.
IN WITNESS WHEREOF, I have hereunto set my hand and affixed my official seal the day and year in this certificate first above written.
4aryubL.'c for Idaho Residing at LIA-LJDJAI My Commission Expires jqsq. ":ISSION
IBWEST 92 AUG 31 PM 3:bbt Post Register C Kempthorne, Symms accused of violating campaign laws Associated Pro called it "baseless and false." gresaman Richard Stallings, "This is to the BOISE - The campaigns of Re- truly much ado about scandals that have rocked Con- ublican Senate candidate Dirk nothing," Snider said, promising groe in recent years, 0 the Kempthorne emptorne and the man he wants campaign's full cooperation made no comments about political to succeed - retiring GOP Sen. wit any reuests from the federal ethics in his nationally televised Steve Symms - have been accused agency.But Kelly Beale, who oper- address. of conspiring to violate federal ates KRB Enterprises andprovide earlier, Republicans campaign finance laws. computer and federal financial charleA dayStallings with abusing his In a formal complaint filed compliance services to both Kemp- congressional r.mailiig priv- Tuesday with the Federal Election thorne and Symms, said most of ilep to bolster his campaign pros- Commission, Dan Williams, the at- the computer equipment in the Pct. Stallin. upportwe said the torney for the Idaho Democratic Kempthome operation came from w Wasaditoron. Party, claimed the Symms cam- either Symms' or GOP Son. Larry And Williams said his charges pain - with its 486,000 war Craig's campaigns. Beale also said were mush more serious. contributed equipment, ho sold the Ke orne camp a "What I'm takng about are se- ervice and staff to the Kemp- computer for $5001 ast spring. rios vksahlmt 1 Abdeal am- None thorne political operation in excess of that p or paign laws," WIIs said. "it's of legal limits, and that neither those tranmctions Sre ldsnlld In the Kempthorne GbMr we've got an =masratlonjpingopt campaign reported the subsidies as or Symms rt. that's w~~mtaking "I" required ports. But Beale said the equip- aivatq I te by federal law. ~nms~ulpsnt aidstaMf even The Symms ment in question has little value. campaign, in its "All the machines thIve current al status, ha, already down there belong to other peo-got slaily, the complaint al- contributed I the maximum $2,000 . ple," Beale F. allow under federal law, and said. "I don't know Wil- what they did; Symms Paid for the Komptorne campaign liam said all in-kind, or non-cash, either do- office mast SepW"Vbmmd 0tober. nated them or contributions through the alleged they bought them. But Snider sid the space the subsidies would Hut they have little value - maybe Kempthorne campaign occupied be illegal since 50 bucks." at they ED beyond that time was elsewhere that limit. The in the The allegations and complaint same building and being paid for by Kempthorne campaign, were which has been lodged against the Boise may- it. under criticism or less than three both inside and outside hours before The complaint also alleged that the Repub- K'mpthorne stood in lican Party for its less-than-subtle the national while the Kempthorne campaign spotlight, addressing the ties to Symms. had no comment Republi- has reported spending more than can National Convention in Hous- initially. ton. $1,500 on computer parts, supplies and repairs since last October, it But after reviewing the com- Although he has repeatedly plaint, spokesman Mark Snider has never reported buying, leasing linked his Democratic rival, Con- or being donated a computer.
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92 AUG31 PM3:5b
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to report.loan of computers. .L. . - A . I J Washingi. 7tis really makes their whole toward the overall maximum ctribxion *I- eatl a~a o-called i ssiden very hy- lowed" sa11*1id. Williams has allered that sinec Symn "a~bd~ ~ma the Democratic Party's has already donated the legal masimum of a 6iOthe FEC has prompted him to' $2,000 to Kempthourne's campaign in cash, sek a rutling-O the xtnmputcrsharing ar- any in-kind contributios such as th'com- puter system areover the liint. "rI' . n; to the FC and say, all But Rebcrger siys the useof the system fight, what am our "rtlrngrequirerent do not qualify as a Vift Kempthirne must ha'?" Rebhtersaid "ruday. pay for all naiferm.ince and repair work Dnocratic Party attorney Dan Williams. while he's using it and any iniprvmcnints lie who filedthe FIC complaint Tuetay, said makes stay with thr syten when iiles on there is no doub, Kempthorne has broken to the next user fedeal camMign laws "it'snot worth a het k of a lot in the mar- "I think fey'n admitting a violation," ketplac," Rebergcr said of the system, p" Wdlianumid. ie regulations are really of whin:h are 10 years old, prehLstonc in quite.'simple If you reive something of val- computa tcrms "But, there's certainly valuc ut you simily have to report it and it goes I'h.,. s".e KEMPT;ORNE: Al Bush attacks
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- d r, - FEDERAL ELECTION COMMISSION
WASHtNCION )( 20461
September 4, 1992
Daniel E. Williams Idaho State Democratic Party P.O. Box 445 Boise, ID 83701
RE: MUR 3584 Dear Mr. Williams: "0 This letter acknowledges receipt on August 31, 1992, of the c . supplement to the complaint you filed on August 18, 1992, against Dirk Kempthorne, Steve Symms, Dirk Kempthorne Senate '92 CN and Sharon L. Allen, as treasurer, Symms for Senate Committee and Richard L. Buxton, as treasurer, Julie Harwood, Peter C, Moloney, and Pat Nelson. The respondents will be sent copies of the supplement. You will be notified as soon as the Federal Election Commission takes final action on your complaint. Sincerely,
Richard M. Zanfardino Staff Member 00 00
FEDERAL ELECTION COMMISSION 0WASHIN,ON. 1I IV%,
September 4, 1992
Dirk Kempthorne Senate '92 Sharon L. Allen, treasurer P.O. Box 1866 Boise, ID 83701
RE: MUR 3584
Dear Ms. Allen: On August 25, 1992, you were notified that the Federal Election Commission received a complaint from Daniel Williams CN alleging violations of certain sections of the Federal Election Campaign Act of 1971, as amended. At that time you were given a copy of the complaint and informed that a response to the complaint should be submitted within 15 days of receipt of the notification. On August 31, 1992, the Commission received additional information from the complainant pertaining to the allegations in the complaint. Enclosed is a copy of this additional information. If you have any questions, please contact me at (202) 219-3690.
Richard M..4 Staff Member Enclosure FEDERAL ELECTION COMMISSION WASHNTON ("2M*J
September 4, 1992
Dirk Kempthorne 2211 Cornhusk Ct. Boise, ID 83706
RE: MUR 3584
Dear Mr. Kempthorne: On August 25, 1992, you were notified that the Federal Election Commission received a complaint from Daniel Williams alleging violations of certain sections of the Federal Election CN Campaign Act of 1971, as amended. At that time you were given a copy of the complaint and informed that a response to the complaint should be submitted within 15 3ays of receipt of the notification. 011 On August 31, 1992, the Commission received additional information from the complainant pertaining to the allegations in the complaint. Enclosed is a copy of this additional information. If you have any questions, please contact me at (202) 219-3690. IV) Sincerely,
R chard M. Zanfardino Staff Member
Enclosure FEDERAL ELECTION COMMISSION WASHINCION U( 044)
September 4, 1992
Symms for Senate Committee Richard L. Buxton, as treasurer P.O. Box 471 Boise, ID 83701
RE: MUR 3584
Dear Mr. Buxton:
On August 25, 1992, you were notified that the Federal Election Commission received a complaint from Daniel Williams C4 alleging violations of certain sections of the Federal Election Campaign Act of 1971, as amended. At that time you were given a copy of the complaint and informed that a response to the complaint should be submitted within 15 days of receipt of the notification. On August 31, 1992, the Commission received additional information from the complainant pertaining to the allegations in the complaint. Enclosed is a copy of this additional NT information.
0 If you have any questions, please contact me at (202) 219-3690.
rNSince ely. -
Richard M. Z nfardino Staff Member
Enclosure 00 0.
FEDERAL ELECTION COMMISSION WASHINCION 0( .'O*b
September 4, 1992
Hon. Steve Symms P.O. Box 471 Boise, ID 83701
RE: MUR 3584
Dear Senator Symms:
On August 25, 1992, you were notified that the Federal Election Commission received a complaint from Daniel Williams alleging violations of certain sections of the Federal Election Campaign Act of 1971, as amended. At that time you were given a copy of the complaint and informed that a response to the V_ complaint should be submitted within 15 days of receipt of the notification.
On August 31, 1992, the Commission received additional information from the complainant pertaining to the allegations in the complaint. Enclosed is a copy of this additional information. If you have any questions, please contact me at (202) C 219-3690. Sincerely,
0~\
Richard M. Zanfardino Staff Member
Enclosure 0. 0
FEDERAL ELECTION COMMISSION wAsH,-NCON DC 204,
September 4, 1992
Julie Harwood 8723 San Marino Dr. Boise, ID 83712
RE: MUR 3584
Dear Ms. Harwood: On August 25, 1992, you were notified that the Federal Election Commission received a complaint from Daniel Williams alleging violations of certain sections of the Federal Election -Campaign Act of 1971, as amended. At that time you were given a C, copy of the complaint and informed that a response to the complaint should be submitted within 15 days of receipt of the 01% notification. On August 31, 1992, the Commission received additional information from the complainant pertaining to the allegations in the complaint. Enclosed is a copy of this additional information. NX If you have any questions, please contact me at (202) (7 219-3690.
Sincerely
Richard M.dnfardino Staff Member
Enclosure FEDERAL ELECTION COMMISSION WASHINGTON 01C 204b)
September 4, 1992
Peter Moloney 4931 Sorrento Boise, ID 83704
RE: MUR 3584
Dear Mr. Moloney: 1714 On August 25, 1992, you were notified that the Federal Election Commission received a complaint from Daniel Williams alleging violations of certain sections of the Federal Election Campaign Act of 1971, as amended. At that time you were given a and informed that a response to the complaintcopy of the should complaint be submitted within 15 days of receipt of the O 1 notification. 1 On August 31, 1992, the Commission received additional information from the complainant pertaining to the allegations C) in the complaint. Enclosed is a copy of this additional information. If you have any questions, please contact me at (202) C219-3690. Sincerely,
Richard M. Zanfardino Staff Member
Enclosure FEDERAL ELECTION COMMISSION
September 4, 1992
Pat Nelson 3349 Chickory Way Boise, ID 83706
RE: MUR 3584
Dear Mr. Nelson: On August 25, 1992, you were notified that the Federal Election Commission received a complaint from Daniel Williams alleging violations of certain sections of the Federal Election In Campaign Act of 1971, as amended. At that time you were given a copy of the complaint and informed that a response to the C complaint should be submitted within 15 days of receipt of the notification.
CN On August 31, 1992, the Commission received additional information from the complainant pertaining to the allegations in the complaint. Enclosed is a copy of this additional information.
if you have any questions, please contact me at (202) C 219-3690.
Sincerely,
Richard M. Z Staff Member Enclosure 9EDRAI'//. ELp1
p / 3'IV/ 1418MW~
September 8, 1992
Mr. Jonathan A. Bernstein Assistant General Counsel Federal Election Commission 999 E Street, N.W. Washington, D.C. 20463
RE: NUR 548 Dear Mr. Bernstein: I vas employed by Symms for Senate until October 31, 1991, and began vorking for Dirk Kempthorne's campaign November 1, 1991. It was necessary to keep the Symms for Senate office open for business after Senator Symms announced that he had decided not to run for the U.S. Senate in order to complete thank you letters to contributors, refund contributions, pay creditors, prepare the 1upcoming FEC Report and conduct other necessary business before C closing the office. Anything done for Dirk =Vtone prior to aevber 1, 1991, was voluntary during my lunch hours, evenings and e s I, along with many other volunteers, gladly gave of our free time to promote Dirk's candidacy in space rented by the e camign at 802 W. Bannock, Room 804---ngotLjP_10, as e by Mr. Williams. C I hope this will clarify the allegations made by Mr. Daniel Williams. Sincerely,
Julie liarwood cc: Richard Zanfardino orOF DIGalCOF0 COE
NU 3548 art W. Harwood I 1s3 8723 San Marino Drive Boise, ID 83704
TILZVZ: 208-375-7411 (H) 208-336-0404
The above-named individual Is hereby designated as my
counsel and is author:zed tz receive any notifications and other communications from the Commissicn and to act on my behalf before the Commission.
C- 011 9/8/92 _ 44,rkUpT/I Date = ignacte
REPO 'S NAIM: Julie Harwood
-al= 8723 San Marino Dr. Boise, ID 83704
HWUM POit 208-375-7411
BusXN8l: 208-336-0092 FEDERA,I Ec,, ,
MAI! 1 09/09/92 15 5hi
Mr. Richard Zanfardino NJ Federal Election Commission N) Office of General Counsel Washington, D.C. 20463
Dear Mr. Zanfardino:
RE: MUR-3548 )-
This letter is in response to your notification of complaint I received August 29, 1992. I was an employee of the Symms for Senate campaign through 0: October 31, 1991. It was my responsibility to help in the closure of the campaign office, and all activities related to that task. I occasionally volunteered for the Kenpthorne campaign prior to C November 1, 1991. 0% Please feel free to contact s if any other information is needed. Very truly yours,
Peter D. Moloney %DIRM ELEU1I'' it 15 8 iN
September 10, 1992
Federal Election Cominission Jonathan A. Bernstein Assistant General Counsel Washington, DC 20463 RE:MUR 3584 Dear Mr. Bernstein:
I am responding to your letter received August 28, 1 9 92 a regarding a complaint filed by the Idaho Democratic Party against Dirk Kempthorne, Kempthorne for Senate, and Steve Symms, Symms for Ci Senate.
I was employed by the Symms for Senate campaign from May 1991 to October 31, 1991. Despite the fact that Senator Symms announced in August that he would not be running for re-election, the Sywms cy' campaign office remained open. At that time August thru October, I did computer entry, thank-you letters, and worked on the FEC report due during that period.
From the period that Dirk Kempthorne announced his candidacy until November 1991, I did do volunteer work for his campaign on my own time and did not charge the Kempthorne campaign for my C services. In November 1991, I was hired by the Kempthorne for Senate campaign and continue to work for the Kempthorne for Senate te campaign on a part-time basis. rI hope this will explain any misunderstanding about my employment during this time. S. ly,
Mrs. Pat Nelson *DE-AL -_-LUcr;.1
SE? 16 1 5P
September 14, 1992
Mr. Jonathan A. Bernstein General Counsel's Office Federal Election Commission Washington, D.C. 20463
Dear Mr. Bernstein:
This responds to your letter of August 25, 1992, which was received on August 31, 1992, regarding MtJR 3584.
The complaint alleges various in-kind contributions were not reported by this committee.
With regard to rent payments, all payments have been reported as outlined in the complaint. In September and October of 1991, this committee rented an office in the Hoff Building, Boise, Idaho, Room 804 and did not utilize Suite LP 102. In November, 1991, this committee rented Suite LP 102 when it became available. Some of the computer and printer equipment utilized by this committee came from the Symms for Senate committee with the understanding that it would need to be maintained and upgraded in lieu of rental or lease payments. This particular equipmient ranges in age from four to seven years -- considerably outdated by current computer standards. An outside vendor estimate (attached) of the current market value of this equipment totals $1950. This committee has already expended far in excess of the maximum estimated value on repair, maintenance, parts and upgrades to keep this equipment in functional status. This committee has reported monthly payments to Fisher's Office Equipment, Boise, Idaho, which includes a monthly lease payment for a telefax machine. The copier utilized by the committee is on a lease agreement (attached) with the Craig for Senate committee and the lease payments will be reflected in this committee's appropriate report filings. Telephone line 208 344-1776 was acquired in November, 1991, and has been rented from U.S. West and reported by this committee since that time.
P. 0. BOX 1866 BOISE. IDAHO 83 701 208 336-0092 FAX: 336-2154 es0
This campaign did not utilize paid staff members until November, 1991. What little campaign activity that took place prior to that time was accomplished with several volunteers. The candidate did not even formally announce and kick-off his campaign until January,, 1992, as the primary election was not held until May 26, 1992.
Please advise if you have any additional questions. Sincerely,/
Sharon L. Allen Dirk Kempthorn Treasurer Candidate ESTIMATED VALUES FOR COMPUTER EQUIPMENT: (3)- IBM PERSONAL COMPUTERS- $150.00
(1)- NEC POWERMATE 386-20- $800.00
(1)- IBM AT- $400.00
(l)- MEMORY UPGRADE- $300.00 C (I) - HP LASERJET- $150.00
(1)- NEC 5200/5300- $150.00
TOTAL: $1950.00
K" IA United States Senator@ Washington, D.C.
LAM~r r- or
LEASE AGREXMr
The Craig for Senate Committee agrees to provide the Kempthorne for Sezate Ccmmittee with various office equipment items (266 Hitech ecputer, Sharp copier, four chairs) for the duration of the 1992 election cycle (ending December 15, 1992) in return for monthly re~meration of $100.00, payable semi-annually upon receipt of invoice.
.l..ie Earwood Office Manager Chief of Staff Kempthorne for Senate Senator Larry Craig fltb~ttetao FEDERAI Ft F, ) A A: 'I 'I STEVE SYMMS seI nH~ IDAHO
September 14, 1992
Mr. Jonathan A. Bernstein Ass't General Council Federal Election Commission Washington, D.C. 20463 (Delivered via FAX to 219-3923) Dear Mr. Bernstein: This letter is in response to your letter of August 25, 1992 which enclosed a complaint by the Idaho State Democratic Party, and a letter dated September 4, 1992 from your associate, Mr. Richard M. Zanfardino, which enclosed an addendum to the complaint. Rather than respond separately to the complaint and the addendum, I am requesting a time extension of an additional 15 (days from date of receipt of the addendum to respond to both. The amended complaint was received at my Boise campaign Post COffice box on September 10, 1992.
In reviewing the addendum, I note the complainants have added new allegations to their complaint and have attached arbitrary dollar values to their accusations. It will take additional time to respond to the new and amended allegations. Please consider this request and let me know immediately if the time extension is not approved. Thank you for your consideration.
Steve Symms U.S. Senator
NOT PAID FOR AT GOVERNMENT EXPENSE FEDERAL ELECTION COMMISSION
September 15, 1992
The Honorable Steve Symms United States Senator 509 Senate Hart Office Building Washington, DC 20510
RE: MUR 3584
Dear Senator Symms:
This is in response to your facsimile dated September 14, 1992, which we received on that day, requesting an extension of 15 days to respond to the complaint in this matter. After considering the circumstances presented in your letter, the Office of the General Counsel has granted the requested -extension. Accordingly, your response is due by the close of business on September 25, 1992. If you have any questions, please contact me at (202) 219-3690.
Sincerel
Richard M. Zanfardino Staff Member & •-Ay ! , , ,
STEVE SYMMS ZS8 12 i I' t IDAHO
September 25, 1992
Mr. Jonathan A. Bernstein Ass't General Council Federal Election Commission Washington, D.C. 2n4f3 NO RE: MUR 3584 (Delivered via FAX to 219-3923) Dear Mr. Bernstein: This letter responds to your letter with attached complaint by Mr. Daniel E. Williams of August 25, 1992 and Mr. Richard M. Zanfardino's letter and attached complaint addendum, also by Br. Daniel E. Williams, dated September 4, 1992.
The complaint and addendum allege the syms for Senate (N Committee (Symms Committee) made several in-kind contributions to the Kempthorne for Senate Committee (Kempthorne Committee) during 1991 and early 1992. Regarding the allegation in paragraph 6 of the original complaint, the Symma Committee did not provide office space for the Kempthorne Committee. Activities in room LP 102 were Symms Committee activities until November when it was released. I understand the Kempthorne Committee subsequently rented the space. With regard to paragraph 7 of the original complaint, the Symms Committee has no knowledge of and denies any connection with the Kempthorne Committee's use of a telefax or copy machine. Certain computer and peripheral equipment was provided to the Kempthorne Campaign in exchange for servicing, maintenance and upgrades as necessary. It is my understanding the cost of those items exceeds the value of the equipment and that those costs have been reported appropriately as required by the FEC. As to the inference that Symms bumper stickers signify ownership, that logic would put the Symms Committee in possession of hundreds, if not thousands, of automobiles. Paragraph 9 alleges the Symms Committee provided the Kempthorne Committee with a telephone line. That is incorrect. The Symms Committee relinquished the line upon closure of the
NOT PAID FOR AT GOVERNMENT EXPENSE office. The telephone number appears on the fundraising letter because the Symms Committee had a large supply of letterhead, which included the former campaign number, on hand prior to my decision not to run. The Symms Committee continues to use that letterhead as needed. The allegations in paragraph 10, 11f 12, 13, 14, 15 and 16 suggest Symms Committee staff were performing work for the Kempthorne Committee while being compensated by the Symms Committee. That is incorrect. However, although I have no direct knowledge Of thisj i S possible and perfectly allowable for some Symms' Committee Staff to have agreed to volunteer on their own time to help the Kempthorne Committee. The addendum to the complaint attempts to attach dollar amounts to the prior allegations. I believe the above responses adequately address the additional allegations contained in the .0 addendum.
I trust this response will put to rest the false, and clearly politically motivated allegations from Mr. Williams Please let me know if you require any additional information. Sincerely 0%
Steve Syumms MUR # 3 5:FL]
ADDITIONAL DOCUMENTS WILL BE ADDED TO THIS FILE AS THEY BECOME AVAILABLE. PLEASE CHECK FOR ADDITIONAL MICROFILM LOCATIONS. FEDERAL ELECTION COMMISSION vhASHI%CTON DC 2046
THIS IS THE END OF UR # ,158ff<
DATE FI LfED CZE RA NO. 2- CAPERMN C
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703 TUl FOLLOF!GlI DOCWDINTS PERTIWEUT TO 5115 CASK
1. Memo, General Counsel to the Commission, dated September 22, 1992. Subject: Priority Systen Report. See Reel 354, pages 1.590-94.
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. 4. General Counsel's Report, In the Rlatter of-Daf-. t
Friont 1 , dated December 3. 1993. Soeet~ 354, pages 1423--!740. 5. Cetification of C 8mi'eioa vote, daeod Pe Uf 9, 1*3- See leal 354, pages l741-174. DeaielIdaho State3. williams, Demeratic 3.q. Party P.O. Box 445 Boise, ID 63701
RE: NUN 3584 Dear Hr. Williams:
On August 19, 1992, the Federal Election Comission received your complaint alleging certain violations of the Federal Election Campaign Act of 1971,* as inndeid ( "the Act 3 ).
the @iroteos .5 4 ~* S*~OE £t~ n~
m the ~ 4~a3~ ~ ~ ~ I 437.~..
BOlIBk.r Attorney
Attachment Narrative
Date the Commission voted to close the file: pEC09 tbwt m Zt. tb. .... 'p ze ...ab. 5te o oin1 t • m | tne am tte. s uo of the ly, c ter Sstem, bt~u nitain thaet the computer system was of minimal value. The case involves no significant issue relative to the other issues pending before the Coumission, there is no indication of any serious intent by Respondents to violate the VICA, and no substantial amounts of money are involved. ': L FEDERAL ELECTION COMMISSION -
Ybe Honorable Stove Symas P.O. Box 471 Boise, ID 63701 RE: NUR 3564 Steve snms
Dear Senator Syas: On August 25, 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 matter, the Commission has determined to exercise its prosecutorial discretion and to take no action against you. lee atta r narrative. Accordingly, the Commission closed it fleoin this matter. Yhe confidentiality provisions of 2 U.S.C. : S437gla)(12) no longer apply and this matter is nov# ! rIn addition, although the complete file mast be li ! public record within 30 days, this could occur ata i. ~fllowin certification of the Comiioa'e vote. Z / ~~ihe slmIt any factual or legal maertilS to tbpublic record, please do so as sootatepossible~ji Be rt.file my b placed on the public record rio t l pt of your additional mterials, any pemiesoible sub ~ v~ill be added to the public record wthen received. * If you have any questions, please contact me at 4302) 219-3400. Sincerely,
~ o~~Baker Attorney
Attachment Narrative
Date the Comission voted to close the file: DEc r. ba~be .. tt.* u. of the pu , e pter . but maintain that the computer system ves of sinTal vs~e The case involves no significant issue relative to the 0ther issues peadin, before the Coinigilon, there is no indication of any serious intent by Respondents to violate the FECP0 anid no substantial amounts of money are involved. ' .' ....;. FEDERAL ELECTION COMMISSION " ... :! °"
'he Honorakble Dirk Rempthorne 2211 Cornhusk Ct. Boise, ID 83706
RE: MUR 3584 Dear Senator Kempthorne: On August 25, 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 vith that notification. After considering the circumstances of this matter, the P3 Commission has determined to exercise its prosecutorial discretion and to take no action against you. See atta e Wr narrative. Accordingly, the Commission closed 1T file in D this matter. ~The confidentiality provisions of 2 U.S.C. . l-S437g(a)}(12 } no longer apply and this matter is nov p*4. Z~n addition, although the complete file ,ast be pl "s# , public record within 30 days. this could occur at folloving crtification of the Cmltsion's vote. ~~wish to submit any factual or legal materials to .!,. r the public record. please do so as soon as possible ., ....- ~~the tile may be placed on the public record prior-to, ~~of your additional materials, any permissible dubi~i, :/ / C) viii be added to the public record when received..: :,," .: I', If you have any questions, please contact ma at 4( 3 219-3400. Sincerely.
Holly Baker Attorney
Attachment Narrative
Date the Commission voted to close the file: ~ec ~ I 'ti iipt tie ,o tteel a age0 Of the jiys compter 8yter, bum ntithat the computer sysemo vas of miniml vele. The case involves no significant issue relative to the other iuues pendin before the Comission0 there is no indicotion of any serious intent by Respondents to violet. the FECA, and no substantial amounts of money are involved. .... irk Keaptborne Senate '92DE
Slharon L. Allen, Treasurer P.O0 Box 186 Boise, ID 03701 RE: HUH 3564 Dirk Kempthorne Senate '92 and Sharon L. Allen, as treasurer Dear Mts. Allen: On August 25, 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. pAfter considering the circumstances of this .matter, the Comilssion has determned to exercise its prosecutOriel r" discretion and to take no action against Dirk Ieaptboru. Senate '92 and you, as treasurer.Seatchdnrtl. Accordingly, the Comission closed T flei ttahisnmrate .
~The cosfidesan1litp provisions of 2 U.S.C.
will be added +to the pbice record whn rceoived. F, If you have any questions, please contact me at (3fl). ~219-3400.
Sincerely,
Holly Baker Attorney
Attachment Mar rat ive DEC Date the Commission voted to close the file: muteutin that the~ ciomptr systml was of sin l ~e Theo case invlves no significant isoue relative to the Othr tiOOIt penlel beOOrO the Comiesono, tbeote is- m indication of any serious intent by Respondents to violeto the PICA, and no substantial amounts of money are involved. SWASIrNGITON. DC 20*1~ ' '" * "
": for lSenate:Ceinttee SP.o. Sot 471. mSoi, I ZD 63701 RE:l NUR 3564 iSyms for Senate Committee and Richard L. Buxton, as treasurer Dear Hr. Buxton: On August 25, 1992, the Federal Election Commission notified you of a complaint alleging certain violations of the tederal Election Campaign Act of 1971, as amended. A copy of the complaint yas enclosed vith that notification. After considering the circmsltnces of this mater, the Camiseeion has determined to exercise its prosecutetial. Seretion and to take no action against the 9 m fo is Gmtt,+eoe and you,* as treasuarer. 8Se attached Ua~4 .... dingly, the Coiniseion closedits file in thiC . b @onidetility propvision, of 3 U.S.C. .,-+:+.+:.. +:4 121U,nolm ir pply and h+enettr +s atb tb ale t. rbe ist i+3a..w i# tt i...... ,he,C . mt .te.+ ~U.ubLs,~ t'd, s do...sm
..ll+___,1jaddd h to the ublic record whtc ewed. +.+++. .: Kf you have any questions, please contact ma at 4) 31940.
sincerely,
"HolyBke Attorney
Attachment Nar rativye
Date the Commission voted to close the file: D ! ! , : i ;' ,/;'i 'i ;'i
tbeobej ta. oomtt.'~ es*of thb ay eom~t.r a 8ta, but mtala that the eoaputer 8yetea ws of atnlusi value. the case involves no significant issue relative to the other issues pending before the Ceiiios, there is no indication of any serious intent by 3espondents to violate the F3CA, and no substantial amounts of money are involved. FEDRALELECTION COMMISSION :"i::: .... " 'HINCGTON. DC 2G114b], !: lert . larwood, Esq. f~' 0723 San Narino Drive Boise, ID 83712 RE: MUR 3584 Julie Hartwood Dear Mr. Harvood: On August 25, 1992, the Federal Election Commission notified your client of a complaint alleging certain violations of the Federal Election Campaign Act of 1971, as amended. A copy of the complaint vas enclosed vith that notification. After considering the circumstances of this mtter, the Commission has determined to exercise its prosecuatorial discretion and to take no action against your client. o a4tached narrative. Accordingly, the Commission cel lt file in this matter.
The confidentiality provisions of 2 U.8.C. . £ 437gra) (12) no longer apply and this statter is me" Imb~arcor vi h 30dyPs. this could occur at! i relio c rvif t hein of the Cinieaion's vote. , wish t@ eaheit any factul or legal smtorials toe ~ the public record, please do so a.s on as .ossb.. ? the file may be placed on the public record prior t "1 of your addtional mterials, any prmissible s .. ' viibe added to the public record when received. *
If you have any questions, please contact me at (2012) 219-3400.
Sincerely,
Holly Baker Attorney
Attachment Narrative DEC 09~ Date the Commission voted to close the file: um1~1 tatthe cmpuer syta w8 of ala el vs ?he case involves no significant issue relative to the other issues pending before the Comisesion, there is no iadicstion of any serious intent by lespondents to violate the F3C, and no substantial amounts of money are involved...... i W ASHINGTON. DC 2O44 . - ,i... •i: "FEDERAL. ! .! :I ' ELECTION COMMISSION. i.. ,iiii.!
1stt Nelson DE 0U 3349 Chickory Way noise, ID 63706 RE: anU3584 Pat Nelson Dear PNs. Nelson:
On August 25, 1992, the Federal Election Comission 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 discretion and to take no action against you. See attace narrative. Accordingly, the Commission closed T file La i this matte r. The confidentiality provisions of 2 U.S.C. ,, S 437g(a)(12) no longer apply and this matter is now i public record within 30 days, this Sould occur at 0 i following oettification of the Omeion's vote. |: is topubit aonrd, factual orlga tril o p th ulcrcrpsedo so as seon as possible. th ail b lce nthe public record prior to-...1 of your additional mterials, any permissible subi.1~i '" Wi will be added to the public record when received. , If you have any questions, please contact me at 42*1 : 219-3400.
'' Sincere , ,
Hollyt Baker Attorney
Attachment Narrative
Date the Commission voted to close the file: 9 S ++.. t..--Sr+aS* 'Ot- 2b 39 tsr++ rg+ m
lbs e involves no significant issue relative to the otb~ec lms8 pending before the Comeson, there is no indication of any serious intent by Respondents to violate the PIBCA 9 and no substantial amounts of money are involved. $ ' .. .- :: * '' ; .. :"° -. FEDERAL ELECTION COMMISSION
. : ~ ~~~WASHItqCTON .D C .1) . "- . ,. ' DEC ilv Peter Noloney 4931 Sor rento Doise, ID 63704 RE: NUR 3564 Peter Holoney Dear Mir. Moloney: On August 25, 1992, the Federal Election Commission notified you of a complaint alleging certain violations the of Federal Election Campaign Act of 1971, as amended. A copy of the complaint vms enclosed vith that notification. After considering the circumstances of this matter, the pe ComiSSiOn has determined to ezerctie its prosecuteoril dicretion and to take no action against yOU. See ) narrative. atteobed Accordingly, the Comissioon closed TE fiile in i : this matter. Thbe confidentiality provisions of S 437y(o) (l2) 2 U.S.C. a no longez apply and this matter is now ld = I. ditoa, althlough the co~slate til e ait be '1*& *
-~~ws to, uba.ie amo faecpuli rord U na tbetsd. :...
15 If you have any questions, please contact m at (*02)" S219-3400.
Sincerely,
Attorney
Attachment Narrative
Date the Commission voted to close the file: €' ::. i i~ n thbat the mpate tJyastes wi of Fae
'toe case involves no significant ismie relative to the other isanes pending before the Comision, there is no indication of any serious intent by epondonts to violeo the FEICA, and no substantial amounts of money are involved.
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