BEFORE the FEDERAL ELECTION COMMISSION in the Matter of MUR

BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of 1 ) MUR 4885 1

RESPONSE OF THE REPUBLICAN NATIONAL COMMITTEE TO THE SUBPOENA TO PRODUCE DOCUMENTS AND ORDER TO SUBMIT WRITTEN ANSWERS

The FLepublican National Committee ("RNC") hereby responds to the Subpoena to Produce Documents and Order to Subinit Written Answers issued by the Federal Election Conimission ("Commission") in the above-referenced matter. I'ursuant to the Commission's Instructions and Document Requests and Interrogatories. thc discovery request is limited to documents and information from February I, 1995 to present, relating to the April 3, 1995 combined $1 5,000 contribution inadc to the RNC by Mr. Gary G. Jacobs and his wife.

It should also be noted that the RNC has redacted certain non-responsive portions of document,s that i: is submitting to the Commission. The RNC nssures the Commission that these redacted areas do not include information requested by the Commission in the above-referenced matter.

Furthermore, although the Commission's Subpoena and Order refercncc an attachment of "March 27, I998 Correspondence from I Ialcy R. Barbour (1 pagc)," the RNC did not receive the referenced attachinent. Since the RNC could not take into account said attachment when foriiiulating its response, the RNC hereby rcservcs the right to supplement its response after receiving the attachment in question from the Commission.

WRITTEN ANSWERS

A. C'onc.e,ning the solicircrriot?qf'the conrr.ihirtion:

1. The solicitation was made by Mr. Wayne Bemian, a member of tlilc 1995 RNC Gala Committee. during a .Innirary, 199s "plionc day" pledgc drivc at tlie Willard Hotel in Washington, D.C. Mr. Berman telephoned Mr. Jacobs to ask him for a contribution to thc Gala.

2. Mr. Berman appears to have received ftindraising credit for the April. 1995 contribution from Mr. Jacobs.

3. The RNC has no responsive documents in regard to this rcqucst. However, the RNC is providing a copy ol'a 1995 RNC Gala invitation to tlie Commission. The RNC is not aware of whether Mr. Jacobs was sent such an invitation

1. A $IS,OOO coinniitnieiit was iiiadc by Mr. Jacobs to Mr. I3eriiimi iii January. 1995.

2. The RNC is not certain wlictlicr the contribution \V;IS transmittcd or lorwarded by mail or by hand, allhough il believes the contribution ivould have been transmitted or forwarded by iii:iil, The contributicin from Mr Jacobs was received in April, 1995, in response to an earlicr fundraising drive for the 1995 RNC Gala. The 1995 RNC Gala was hcid on February 9, 1995 at the Washington Convention Center, 900 9th Street, N.W.. Washington, D.C. The contribution was neither solicited nor received at the Gala event.

3. llic RNC is not aware of who actually tr:msmitted or forwarded the contribution, and it is not aware of who actually received thc contribution at the RNC.

4. Included in the responsive documents arc ;I daily deposit summary sheet. ;I deposit ticket, a source document containing a copy of Mr. .I~cobs'check, a thaiik you lettcr for the contribution, a documcnt listing Laredo National t3ank under the name Wayne Bernman, and general donor intimiation records pcrtaining to Mr. Jacobs. A copy ofa 1995 RNC Ciala invitation is also included.

C. ldetiti,$ till pr.sot~.swho provided myi+rttitttio)I or ri.s.si.sliince risecl i)?!kc prepiir~i~imofthc responses to these qiiestiotw rind tiocirtiieti/ reqiie.s/.s. If'ot erich pe~w)iitleii/$eti. .s/rrtefi,r which qirestioti or tiociitmtit ret/ires/ /lie infiirt~~trtiotior ri.ssi.sttince 1wr.s itseti.

For the Commission's requests pertaining to this matter, the RNC Counsel's Office: coordinated with the following individuals to organize responsive information and to respond to each of the Cominission's questioiis: Ms. I'atly

3 Luther (Director of Membership Services), Ms. Lauric Prysock (Director of Republican Eagles), Ms. Beverly Shea (Deputy Director of Finance), fvls. Jnnicc Knopp (Deputy Director of Finance), Mr. Waync Berman (Republican fundraiser), Ms. Paige Lance (Southern Representative of Republican Eagles), and Mr. Steve Ellis (Director of Computer Services). Each of these individuals can be contacted through the Counsel's Office of the RNC.

Respectfully Submitted,

Counsel for the Republican N2tional Committee

April 22, I999 A

SWORN TO AND SUBSCRIBED before me this '' day of April, 1999. n

My Commission Expires 1. i"',,

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Mr. Gary G. Jacobs President and CEO Laredo Natioml Bank Post offica Box 59 LaridO'TX 78042

AS M Eade you we recog&& nationwide as a member of one oftbe most disPineyidid and celebrated pupof Republicans. The fb%~cislwppart and ldcrsbip you khge0 OW entire Pf@' at d kvsls of government display a ran levei of commitment for wbich we we &ply indebted.

lo addition, continuing your Esgles mern%Pership gives you dque opprtunities 10 old tie mnd develop new friendships with o&ep Republican leaders hmthe politid sbd business coi%munitim Who share your exeordjonry commitment to our Party and ~\lrn&n9S futUn3.

Yaw Eagles membership is effective foe B AtU twelve months and atitbyou to all tho benefirs we have designed s~ficallyto honor individuals of youp caliber, and offers ~QUa full mge of smial and business activities with your fellow members and the leaders of out Party.

I look foward to seeing you at ow next nafiond meeting or wgiooal &$es event, and tRanking you personally for your continuing generosity to the Eagle program. I On behalf of&eentire P&y, ptwknow how much 1 spprcche yow commitmen?to the Republican Eagles. We are honored to have you join us 85 we continue to &eng&ea QUIPeply the 1996 presidential election cycle.

. EAGLE 1 ;)::a744 LA2E;IO NA?IGhbL SANK I Siz-7L3-115 1 PRij23ENT t CEO 04/13/1996 5 12- 7 23 - 115 1 MR. GARY c. ~llCa3S POST OFFICE CQAtrER 59 LAREDO TX 7E042

~PRNLNG This list is the property of the Republican National &omsittee any unauthoraxcd use is st~ic21yPRilHP3ITED lhis list contains eecoy names to monitor list USBgQ. LAREDO NATIONAL BANK $1 5,000

TOTAL: Add- Typo: Delivery (Primary) Addri: Post ORFca Box 59 Add& Cky: Laredo Stab: ‘IX ZIP: 780426059

~o~~j~u~on~: _.-Data: statuo: Amount: % Projaran: Accaun% sm; U17fBS Fua SlS,OCO.CQ Remval UIObE REIU: EWiW

’! ’!

U2lW 12:03:04 PM PAC ID I

PfdX Flwt Name MN east Mame SMffIX Mr. Gary G. Ja&

Add@) Post Ofcce Box 59 Add@) Strwt City Laredo state Tx ZIP 70042-0059 PmLAddr B - Doric; Typo I MayLOWO E Caunmcnb

Wshld Rag Cong Diet

\ I I I014A 04/17/1995 22262669 015,000.00 UWRM 04117,11865 I k

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. .I ! 104th Congress .~ ...... " i., IPJAWGW GAkA Geoqette Mos

p. HONORARY IN

CHWRPAAN,WEPUBLlCAN NATIONAL CO Haley Barbur cmm,REPeWLICrn NATIONa FINPNCE GO E John A. Moran CORPORKrE ClcPAIRMApIl Craig E. Fuller

Jmv And 'I%orne 6. Awbter Roger v. &dl Donald B. Mamn er Richand M&pwic& WilbJ. Mhue w Bm Betty %auhniMulphg David M. Brewer Naacy BrhkeP Edgar Branhnan Arcadio Cadk Lodwrick FA. 6hk Jack L CopW Mr. & MS. &le M. Craig, 1. Sugar Rautbod RdKn Day James D. Robinson, IHI Juanita Duggan Linda Gosden W&wn Melvyn 1. Estrin Rockwell Sch~kl Julie FMey Stephen Schwanmn Stephen Friedman Theirse Shaheen Walter J. Ganzi, Jr. Saul Steinberg Harvey Golub Ftaink D. Stella MR. Greenberg Peter Terpeluk, I. Patricia S. Harrison Constance E. Tipton John M. Hennessy Donald 1. Trump Jon Huntsman, Jr. Wob(ea Van Dine Gary G. Jacobs / Dirk Van Dongen Robert W. Johnson, 1V Elliott H. Vernon James H. Lake George Votis Kenneth L. Lay Linda L. Wacbner Howard H. Leach Leslie H. Werner Drew Lewis Stephen Wynn

'\ (List as of 12/28/94 .Complete Leadership lut to bc printed UI Inaugural Gala Program.) \ ...... -.-- __..... - , : .1;

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...... ) '.' :: i...... ,A *e":. . I... . . ': With Special Guests

'. Thursday, the Nin Nineteen hundred and ninety-five?

Washington ~QnventiQarCenter 900 Ninth Street, N.W.

638 p.m. Cocktail Recepticcrs Black Tie 238 p.m. Gala Dinner anand Program eply Enclosed

Tickets will not be mailed The ticket "WiD Cd" DwkJor individual ticket and table buyers will be open from %'UO am. to 8:ODp.m. a! the Coonventzh Center on Thursday, Febq9, 1'995. ..

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9-3 c/o The Republican National Committee 310 First Street, SE, Washington, DC 200103

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CREDIT CARD INFORMATION

L_ You may make your contribution to the RNC by credit card if you choose by completing the information below. b Q Peisonal D Corporate 0 Mastercard 0 VISA a American Express

Credit Card Number: / I-______- -__ Expiration Date: - _-______c- Name as it appears on Card: ...... - x___ Signature: -

Amount of Conmiution: $ -

Paid for by the Republican National committee and the Republican National State Elections Committee. Only those contniutions which do not fall under the limitations and prohibitions of the Federal Campaign Act will be used by the Republican National State Elections Committee. Federal election law requires us to report the following information:

Occupation:- Employer: 0 Check here if self-employed

To compile your membership profile, please complete the following and make any corrections to your name listed on the reverse side of this R.S.V.P. form. Name Salutation:

Home- Telephone: c_---_

___Offce Telephone: __ I , Fax Number:__

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John A. Moran, Republican National Committee FinanceChairman Max M.Fisher, Honorary Inaugural Chairman Georgette Mosbacher, Inaugural Chairman e Craig L. IbUer, Corporate Chairman FA @#4/99.5 si+W.&m Yd BEWEFITS FOR INAUGURAL LEADERSHIP

The 1995 Republican i'naugural win be one of our their fiand business associates to increme Party's truly historic events. As in the past, for events partinparion in this historic event. In recognirion of of this nature, indimduals within the business and your deeper wmmimnt by sening indimdual tickets political communities win be toorking together to make or tables>each member of our Inaugural Leadership this the greatest euent euer held A rare opportunity will receive :;penal mognition and enjoy the forrowing mists for a few indiuiduals to play an imponant role in benefits: ensuring this event's success by actively reaching out to

$150,000 Fundraising Goal sen o 1. Dals Seating at the Inaugural Dinner 2. Private Reception and Photo Opportunity with U. P 01' Inaugural - 3. 'Salute to Rpublican Governom' Luncheon -.-. 4. Speaker of the H.ouse VIP Reception 5. Breakfast in the US. Capitol with Senate Majority Leadeq Bob Dole and Speaker of the House, Newt Gingrich. Friday. Ekbnuzry 10, 1995) , 6.Wo (2) Priority Tickets to the 1996 Republican National Convention . ':.' ..- 'Rrpfi&* mlp and add ro of& Dinmrprogmm. -. we nu k inouhcccd be pmr imugwad .- .. : . -...... ~- . _. . .. %i52&7&m . .. $100,000 Fundraising God scllarFurduue?twn JWIhl~hP,EogleMonbidtijnmLhnwr~h .~..,. '.'. . I. Preferential Seating at the Inaugural Dinner I . .. 2. Briefing with U.!j. Senate and House Committee Chairmen .Ii !' .. .<.... . 3. 'Salute to Republican Governors' Luncheon ..--.. 4. Speaker of &e House VIP Reception Q 5. Breakfast and Photo Opportunity in the U.S. Capitoi with Senate Majority Leader, Bob Dole and Speaker of the House, Newt Gingrich (?+day, February 10, 1995) d +i Tz& %&a&tm. $45,000 Fundraising Goal SJI or Purchaw 3 OlgL U'cmbcrships or 3 fhnnn n~h I. Preferential Sea,ting at the Inaugural Dinner *' 2. Briefing with U.S. Senate and House Committee Chairmen 3. "Salute to Republican Governors' Luncheon 4. Private Pre-Dinner Reception with U.S. Senate and House Leadership 9* iz%w&& $15,000 Fundraising Goal senor ~unhrreI zhnu mmble 1. Preferential Bble of Ten (10) ** 2. Pre-Dinner VIP Reception with members of the Majority Party in the U.S. House and Senate . . __...' --. . .* You d have the option to requun a Governor, SCM~or MePnber of the Houac of Repnsentativa and hidher pest tr----- complete your table of ten. AU invited guests are peaper scheduling mnflrmation. Formal invitations are available for -. you to send to your prospear. For funher information, please contact Elizabeth Montgomely at (202) '8638720. . '. .. .

.. TEN TAT I V E AG; EN DA

Y;&d.==,&C,N, 8 r~ $-t Eagles' Inaugural Registration and Hospitality Suite 7~"k. 3.- Eagles' National Leadership Team Dinner ZJ&& i The Honorable Haley Barbour, RNC Chairman

YAui;y, srG,my 9 8- I. Eagles' Inaugural Registration 8:OO- B. 9:30- Celebeation Bwikfast

Willard InterContinental , '

&*/ifThe onorable: Haley B&ur Chainnan, Republican National Committee

A&zdgd I.. .. -. . -.. The Honorable [email protected] .. -

~. . ~,@e&zrofthe v.& ~OI+ of Representatives .-.. I-. ~ IO- L. I 2~mUS. Senat; and ~o&~eade&*p 13riefing Willard Inter6ontinental &u&9-& Senator Rent Lon (Mississippi) .~_ U.S. stnnte Majoriy Whip Senator Don :Nic!des (Oklahoma) Chairman, Repubihn Poky Committee Congressmm Dick Amey pxas - 26th) ...... Majority Leader of the US.House ... Congressman John Kasich (Ohio - 12th) .. , jr .*,.:. .. i. . _._. Chai7mn. HowBu&i Committee . .. Congressman Thomas J. Blfiey. Jr. (ViMnia - 7th) Chairman, House Energy and Commerce Committee

12:OhB. 2:09- "Salute to Republican Goveenors" Reception and Luncheon Willard InterContinental &V*d2&vr4/ &A: Republican Governors zyY/dF $/

Thc Willard InterCantinental Hotel. 1401 Pennsylvania Avenue. N.W., Wrshinjpfi. D.C..will sewc a8 the host hotel for the Eagles during the 1995 Rcpublion Inaugural. Special mom rates of $190 for single or double accomnodations have been secured exclusively for our memkn. Rcsewations may be made dtrectly with the hotel by calling (202) 626-9100. Please identie yciunelf as a membcr of the Wpub11c;m Eagles when calling.

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7LJentyyears ago, Predent Gerald R. Ford and the National Republican Parry created an entirely new way for individuals to participatr! in the political process. As the first and most p,restigiouspolilicnl support organization of its hnd, the Republican Eagles sustained the Pa'arty through its most dificulr yenrs and laid the foundntiom ujhich led to Ronald &;$an's landslide victory in 1980. From the begnning, Republican Eagles have remained steadfast in their commitment to the principles and uienk of our Party and our candidates at aN levels throughout America. The Republican Pang gatefilb achnouiledges a tremendous debt of gratitude for the crucial role the Republican Eagles played in the dramatic resuqence of the Republican Party thu year and the largest mid-term election majority suieep of this century. No membership organization uithin the Republican Paq enjoys a greater tradition of excellence and a more '.? prominent position of honor and respect than the Republican Eagles.

'I Befitnng its unequaled stature uthin our Party, erclusive ClChVlheS are nseserved solely for the Republican Eagles.

National Meetings - Each year Eagles receive International 'hdeMissions - In the past seven invitations to four national meetings. At least two of years, the Eagles have participated in three these meetings take place in Washington, D.C. and economic and trade missions in Europe and Asia. feature strategy sessions with prominent elected The Eagles have been welcomed enthusiastically by Party !eades From the U.S. Senate and House. Other heads of state, including heniier ILi Peng of the participants have included Republican Presidents, People's Republic of China and King Carl XVI Gustaf Governors and former Administration officials. of Sweden, high-ranking government and business officials in London, Paris, Budapest, Vienna, Beijing, 111 dinon ro the hutonc Republican Inaugural in Bipei and Hang Kong. In each c,ity, members Febncanj. upcoming a'ents in I995 include the Annual participated in political and econ,omic briefings, diplomatic events and national celebrations and Eagles' Cup golf adfennls clnssic in Palm Spnngs in were introduced to the historical and cultural riches Apnl, n '96 elecnon yenr stratepy mccnng in Washington of some of the most exciting and beautiful cities in 111 luly and rhc Eagles 20th rtnnir~ersaqBlnck-tie Cola the world. in k'mhl~~gullIll Oct0b:v W'C Updates - Eagles receive regular updates From Regional hleetings and Special Events - Regional the RNC Chairman offering talki.ng points and evenfs arid meetings are held across the country that briefing materials on Congressional and allow Eagles to introduce Friends and prospective ./&Idministrationlegislative initiatives. The Eagles' members to the Republican Eagles program in a newsletter, the RNC's Rising 'Rde publication and a more private setting. Recently, Eagle members have broadcast fax system keep members abreast of participated in many special GOP events including political and campaign activities. the 1994 RNC Annual Gala with President Ronald Reagan and Lady Maqzaret Thatcher, a live broadcast Republican Eagles are assigned tht17 own Regioraral of GOP/TV's Rlsing ride at Paramount Studios and a Representative In Washington, wh:, may be contacted Foreign Policy Forum with Henry Kissinget James unth questions regarding Eagles membership, additumal Baker, Jeane Kirkpatrick and Dick Cheney. \, benefits and upwming activilies at (202) 863-8720, ..

I+& 1:3% Luncheon Strategy luncheon with RNC Chairman Haley Barbour .. .-. .. .. , ._ ~~ ...... ---. ._ --~ k. 7:3+4 General Will-&dl ...: :.: ;,. : .. - (For members amving h'the;afternoon) .-...... -, . Washington Convention Center ..- 2:3+b3:3+ Afternoon Briefiqg U.S.Capitol 3&Yy&.- Senator Bob Packwood (Oregon) ~~ - Senate Finance Chainnnn Congressman Bill &her (%ms) _.. .: - House Ways and Means Chairman . -....- .. '; . I - . .'.I.-..-. ,-.. . ..-__.. . + VIP Cocktail kelption ._- ., . Speaker's Office, U.S. Capitol

7:3+ Gala Dinner Washington Convention Center

Aidy .%&my IC 8 30- c 9.30-, Leadership Breaklast and Photo OppNortunity U.S. Capitol with !$enate and House Republican Lea de rsh ip

- :...... ~...... --. .. -. .. . _-... \ .. .&fit&&& r+/ ..%& jfOO Since its inccprioii in 1988, Pam 100 has been the premier findraising ann of the Republican Party Its membcrs fomi a spe

9*18& $#z-iK/l 180 /&ntJcp.yfi Zmri 100 members twjoy a fill package of membership benefits ELents throughbut the United States and abroad are planned and designed to gwe Rum 100 members the greatest opportunity possible to meet and talk informally umh 1996 I?esuienhal candidates, PamJ leaders. forelgn dignitanes and spectal guests Membership

. : . includes: National and Regional Meetings - These International Business Meetings - In recent meetings feature working business sessions, years, Team 100 members have enjoyed a variety of strategy sessions, and fundraising updates. Past exclusive lousiness missions abroad. The 1994 East meeting participants have included: Gerald R Asia Ttade Mission included meetings in 'bipei, Ford, Bob Dole, Phil Grdmm, Jack Kernp, Dick Hong Kong, Guilin, Shanghai, Xian and Beijing. Cheney, Margaret Thatcher, Lamar Alexander, Steve Other meetings have been held in Rome, Paris, Memll, Pete Wilson. Bill Weld, John Engler, and Moscow, St. Petenburg, Prague, Vienna, Warsaw other Republican leaders. and Madrid. >am 100's stature enables us to meet with some: of the highest rank.ing government and 'Ram 100's upcoming events in I995 are: business officials while traveling internationally. Aspen Sln Dip, Aspc:n. Colorado (February 17-20); Nahonn! Spring h.leehng. Washington. D.C. (May 2)

J&z&dyz .%U&&.Cd Ram 100 membership requires a Sl00.000 commifment upon joining and every four years theraper A $25.000 conrnbuhon IS re4iciil.d in each of the intervening three years. 2am 100 members may contribute with a persoiinl or corporute chcck or a combination ofthe tuba.

Quesnons repriiiiig Rmn 100 rnembershrp or upcoming aChL'lheS may be directed to the 'Ram 100 ofice nr (202) 863-8720

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