THIS IS. Th E GIINW OFPMURN

FEDERAL ELECTION COMMISSION

NOW WtoksIMC10% or 20f4

THIS IS.Th E GIINW OFPMURN# _ _

DATE F II MNIf

-*PMA y-~ or "M UNITED STATZS OF AICA

Communist Party (USA) 0 Gus Hall, National Chairman : Communist Party (USA) Judith LeBlanc, National Organization Secretary Communist Party (USA) Treasurer, Communist Party (USA) Angela Davis, Presidential candidate Nikhail Gorbachev, N Former President Union of Soviet Socialist Republics 00 D Communist Party of the Soviet Union or its successor

Defendants

Grover G. Norquist of 718 North Carolina Avenue Southeast, Washington, D.C. 20003, hereby files this formal Oseplaint against the Communist Party (USA), having a smailing address of 235 W. 23rd Street, 7th Floor, New York, NY 10011; Gus Hall, National Chairman, Communist Party (USA), having a mailing address of 235 W. 23rd Street, 7th Floor, New York, NY 10011; Judith LeBlanc, National Organization Secretary, Catmiet Party (USA) having a mailing address of 235 W. 23rd Street, 7th Floor, New York, NY 10011; Treasurer, Cnnunist Party (USA) having a mailing address of 235 W. 23rd Street, 7th Floor, Nev York, NY 10011; Angela Davis, presidential candidate, address unknown; Nikhail Gorbachev, address unknown; and the Communist Party of the Soviet Union or its successor, address unknown. Page 2

This Complaint is filed pursuant to the provisions of the United States Code based upon information and belief that the defendants have conspired to violate and have violated provisions of the Federal Election Campaign Act of 1971. as amended. This Complaint is prompted by a Washinaton Post article of March 1, 1992 (Exhibit A) and articles in the New York Post of December 19, 1991 (Exhibit B), February 13, 1992 (Exhibit C), and March 5, 1992 (Exhibit D), which reported the Communist Party (USA) received over $2 million per year in cash from the government of the former Soviet Union. The article describes activities which apparently comprise regular and wholesale violations of federal election law. The defendants appear to have knowingly solicited and accepted contributions vastly in excess of the contribution limits. Defendants appear to have knowingly solicited and accepted cash contributions in excess of the legal limitations on cash contributions. Defendants appear to have violated the prohibition on contributions from a foreign government or interest. V4 Further, defendants apparently failed to report these V) contributions as required by the Federal Elections Campaign Act, 40 as amended. This arrangement appears all the more curious in light of the fact that numerous published reports during the years in 0 question contain repeated and strenuous denials by defanet ams Hall and other officials of the Comunist Party (USA) that the party received financial support from the Communist Party of the Soviet Union and/or the government of the Soviet Union. It has been reported in the ffaa3 n Postu that a receipt for $2 million, signed by Gus Hall, was found in the personal C' files of Mikhail Gorbachev. This receipt suggests that Mikhail Gorbachev,, then president of the Soviet Union and head of the Soviet Communist Party,, conspired to violate and has violated FEC laws by contributing money to Gus Hall and to the Communist Party (USA). Complainant requests that the Federal Election Commission undertake a full investigation of these activities, including a complete audit of all financial records, both known and secret, of the Communist Party (USA), for the years in question, or at least for the years for which the Commission has statutory authority to seek such an audit. The Commission is asked to utilize its power of subpoena, if necessary, to obtain and examine such records. Page 3

Complainant further requests that the Commission seek amended disclosure reports for the years in question from the Comunist Party (USA) detailing all contributions, both legal etd illegal, which are subject to the disclosure requirements of the Federal Election Campaign Act, as amended. Finally, Complainant asks the Commission to fully investigate the financial relationship of the Communist Party (USA) to Communist Party (USA) candidates for federal office, including its candidates for President. Did candidates of the Communist Party (USA) knowingly seek and/or accept funds from the aforementioned foreign source(s), either directly or indirectly? The Commission has an obligation to find out. Complainant asks the Commission to seek an audit of the financial records of the Communist Party (USA) candidates for president and other federal offices for the years in question. NO Complainant requests the Commission to compel disclosure of all such contributions subject to the disclosure requirements of federal law.

C04

By: ______Grover G. Nor ist

Subscribed and sworn before me this 2O -day of March, 1992.

Notary Public

W Commission Expires December 14, 15lj3 oAUAuMu Cur.;'

-1 hr Cal wearm canftrw hoder am Nd ito h h iodk t SNO an W&W- a y 1967N.1 .Hdshn rhe tociu to don go i as "l e

tOw unindu a do&~ soed MWm -es to iamh- ting tie*1 e

lpieri semin, deconut hum kawsf baders ar-eundth wudi M up an the do&h of then4Sm to Fbi and dohuienpuar Communwu party didf 000muOok m001w dor tNM A M i New T.. MUM Corbuck, A Pftiaero a warlwideane Commist Ocenpr- mumming was belld to discuss the CINMXtMM A24. C*L I Documents Show How Gus Hall Got-Millions COMMUMM IFei.sm Al 1990. the year after the acy' readl did eu tfor drumamic much of the e00 Ps seven decades. with the Kirem- 7Communism rtlbomiEast FE secretly fund cea parties fomnlad to El S0radir. Bus they rPo rame the uNSIn of A ?C ThAe C m AmP y A the tem of moum of doi set :A~ide by Monoaw ery ywhfr the pomusism if aM inu were nymomre11 Fewl he the "Nos by intrninte - 3~agm m oea~nnnc sspromotion

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3C." wratle Hd in InJsa.z:._.iI vie glfthau vrug make cumase asdifficult to buid a ona.______lesisqcaanmebu. the ac of chan nw ar GCo - doisW seke" as@&mued hNabeguge tIr and o"Cer former Pkhuro has re sdtwas fo&adeato A polaf. irau ibers.But the fact mbelo frm Mot.- that anw tl s . a former amtoe cow. He warned tat pur-y leders flu byKNCR rmwm ne ib A_-_-.. fsm ohcalt er agam the for- to Cmm es Party a r Sovet sectary i homes or sell theIr New York ead- leade. wh s reported chargeo bnuermt.oM l rela ns qa0rter unlenmore have asked Russ rnaIon aI- 9 7 n Preadenit The cumnents shwe that Do- sastance was fortheatg. 8 forS$2n dleon by French ler as eltsin for a blket Immnt y brynan m ied Party leader read em .prosecuion thrt, before he mnthe advsesubsa aganstto the any American inrase boureoesanit"What we spend inm parso M"RECEdae two rioffice last December.Kacording a peanMusto packets of pa- rUw| Connunis Party, sayigm $o m to the average campMMi '."followed by aM illegble sin. t wltsi aides, the reute was re- millon a year wa, quite "fficant." ds iPa expen e for a U.S.. snator, whichis te ,,, o ents to client parties ceased nowHa $20 a ndin.Hall wrote. ti IN~ W E

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.. . arxist. hero ' a-imoal he when be ded in L... may* 2864 is aamt tn his cn Vt. =3%u CAM&i Xwpoftn a be WO* vlCoM Iba the dash of -a g~ pavy .111Wimary. nTo. t frlo to Now To* gmdw rfomi the am w m't a cYWn s y. -M to bajlwjw dw to the bash Mbowo LOR LMM7ar or Pwatt.%&A GMwa -ses Is notg to )ose a&y abwA -j Rome (Aatmo od amd filakcg fth fimaomu ty - kt 4" w'9l W-91-ow In the Im-. w 'anMM fPat.) &As kmdl in... tI ,,,,na,,,, -aed w to 7 tha a -the woof loved on t,, tmn RiAInM m o Dy ard to 0mmn their yoa toward ud, lk M& ta tha ,phukm t ]laflathe mam m dumhan of bb fhllowanIal- w~ n mn, man, -watI-ar1ed -- so Togiuami toAr aafte m Win~ w a-1w the ot~ h save IIE wteft oua Mo CMIo1 lae l I-.- Mhedy hemlin o A ,wn in how Ilvme Blw at Ut aw hoaw t -- wIa a xd c9 sup. a"Nm49lbnaval InM toCdy od theto a a~ 11A a -m atnwot tbL Bnlf~hlm lun-hods.by wwll. dlm c ome 2Oa iwonw: Amuys theCr.hmw sU ft i fIm L At a* mo. Th'ls how do the RhIm t'o of l b toMo 01 -Iokmn= Is in the W cme MAthe &a tw TfM Togliatti *pown Ineadou* akmd Ithf aunswrd plea POWftew memtft beWd the s a to help saver (Gmm~njamd mea addIem i10~WAin in fta- -a to -on - 1=12 GUfaj WaM__Iian POWs only~ to Vreo - fte wu&.L*.t - to Al t rft~ tdi aeb 1 held by Stalin f*Inte ~aea at mum PMIJOWs wa capird [,Ubtd mofn MZamds at tMe BMW= Flog "be MMMU affetdthe tWh Mimldia had sea Owm to ftio of hlgogiam to Uftww SMuccWhert ININat myagn Ag& A~mg the Wehr- to ih4y the dteocn ton the atbuw at &wow* CONga -as an [tUaW MUMUa~rhud:= 0OIis-nm kHtindbug A Mm hm 'GMsouraw Iyep(s Tain theWarcb of the flIgw Italiasn COMZtmti .W ta* Iet is zwt ambohega' =mois aomis mast qem~ that TogliaWt tozu- Mwe rumaw of the -tla eYm.1t= -w WU Wth SUain bbhl Of coonng maVccM baa tae Itaum ion Togliawt b=da~t a poliJ dat Wbya y *a lk Uoo. la- awl Staln oujoye tmuzay Nlow by the m om crn darWIMUM& fhs~M Io WiM iOwdei na c i Mmisi pcofc= flabWW~ &AgItlY's leading conmu- 'It doaIi~ m pomage tha the archive diieorod a 1Wi nixt who was herakded a3 a TOOgLart could have wriumz t~waa ai*b~ ~i4. ~POST THURSDAY. MARCH S, i Why Moscow funde 0Gus Hall I Co by. v* btha

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FEDERAL ELECTION COMMISSION WASHINCTON. 0 C 204&3

April 6, 1992

Grover G. Norquist 718 North Carolina Avenue, S.E. Washington, D.C. 20003 RE: MUR 3493 Dear Mr. Norquist:

This letter acknowledges receipt on March 30, 1992 of your complaint alleging possible violations of the Federal Election Campaign Act of 1971, as amended (*the Act), by Gus Hall, the -- Communist Party (USA), Mikhail Gorbachev, Judith LeBlanc and Angela Davis. These respondents will be notified of this complaint within five days. Although your complaint els alleged C4 violations of the Act by the Communist Party of the Soviet Union, our information is that that entity is banned and not lonatable. Accordingly, we are not notifying them of your complaint. If you have information that will allow us to notify this 61", please forward it to us at your earliest convenience. You will be notified as soon as the Federal Eleotios o Commission takes f inal action 016 your complaint. Shoul4 lou receive any additional intormatio, in this satter, Plenge ftvard it to the office of the General Counsel. Such Informata 41at be sworn to in the same manner as the original complaint. W have numbered this matter RUR 3493. Please refer to this 06 i4 all future correspondence. rot your information, we have attoted a brief description of the Commission's procedures for kanIltg complaints. Sincerelk2

Jonathan Bernstein Assistant General Counsel znclosure Procedures "AY

FEDERAL FLECTION COMMISSION WASN ICION. OC n3 April 3, 1992

Communist Party (USA) and its Treasurer 235 w. 23rd Street Now York, NY 10011 RE: NUR 3493

To whom It Ray Concern: The Federal Election Commission received a complaint which alleges that the Commnist Party (USA) and you, as treasurer, may have violated the Federal Election Campaign Act of 1971, as amended (*the Act'). A copy of the complaint is enclosed, we have numbered this matter MIR 3493. Please refer to this nuber in all future correspondence. Under the Act, you have the opportunity to de0metrate in writing that no action should be take Aaist tbo CMist Party USA)and you, as treaurer, in tbis atter. Pl---e submit any factual or legal materials which you belim ate relevant to the Criesion's analysis of this matter. Uere appropriate, statments should be submitted under oath. tour response, which Should be addressed to the General dsowl's Office, must be subaitted within IS 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. This matter will remain confidential in accordance with 2 U.S.C. S 437g(a)(4)(B) and 5 437g(a)(12)(A) unless you notify the Commission in writing that you wish the matter to be made public. If you intend to be represented by counsel in this matter, please advise the Commission by completing the enclosed form stating the name, address and telephone number of such counsel, and authorizing such counsel to receive any notifications and other communications from the Commission. at if You have any questions, IVtc1I~V*~ the attorney assi"ed Of 21- asvetothis matter, t aa l- tyu Infornalion, we hav enclosed a btief utitOO ot the Coimisson s proceduces for handling %MoVuprlikts. Sincerem

nathan Betnstein Assistant General Counsel Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement * FEDERAL ELECTION COMMISSION WA$1NING | ON. I) C 30*l3l

April 3, 1992

Gus Hall 235 W. 23rd Street New York, NY 10011

RE: HUR 3493

Dear Mr. Hall: ,q- The Federal Election Commission received a complaint which alleges that you may have violated the Federal Election Campaign Act of 1971, as amended ("the Act'). A copy of the complaint is 4enclosed. We have numbered this matter MUR 3493. Please refer to this number in all future correspondence. Under the Act, you have the opportunity to dmonstrate in vriting that no action should be taken against you in tbis matter. Pleas submit an factual or legal materials tlch you believe are relevant to tie Commission's analysis of this o matter. Where appropriate, statements should be submitted under oath. Your response, which should be addressed to the GW~rel Counselts Office, must be submitted within l days of reei-pt of this letter. If no response is received within S da , the C Commission may take further action based on the available information. This matter will remain confidential in accordance with 2 U.S.C. S 437g(a)(4)(8) 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 stating the name, address and telephone number of such counsel, and authorizing such counsel to receive any notifications and other communications from the Commission. if you hay any questionst, plSO eouitt 00"'4 .th. attorney assigned to this matter, at (202) 2194M. " ! ymar information, we have enclosed a brief dcsripti on of , Commissionos procedures for handling Cmplaints.

onahanBernstein Assistant General Counsel Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement F'

FEDERAL ELECTION COMMISSION WASHWTOn. 0 C 20*3 S April 3, 1992 Judith LeBlanc, National Organization Secretary Communist Party (USA) 235 W. 23rd Street New York, NY 10011 RE: NUR 3493

Dear Ms. LeBlanc: The Federal Election Commission received a complaint which alleges 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 NUR 3493. 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. Plese submit any factual or legal materials which you believe are relevant to the Commission's analysis of this matter. Where appropriate, statements shomid be submitted under oath. Your response, which should be addressed to the General receipt of Counselos Office# must be submitted within IS1 das of this letter. If no response is received within S days, the Commission may take further action based on the available i.frm*ion.

This matter will remain confidential in accordance with 2 u.S.C. i 437g(a)(4)(B) and S 437g(a)(12)(A) u.-'.ass you notify the Commission in writing that you wish the matter to be m public. if you intend to be represented by counsel in this matter, please advise the Commission by completing the enclosed form stating the nane, address and telephone number of such counsel, and authorizing such counsel to receive any notifications and other communications from the Commission. if you have any questions, pl, attorney assigned to this matter, at (202 1*-4 .rO information, we have enclosed a bnri ttiOTa "ofthe Commissiones procedures for handling .80'aits.

Jonathan Bornstein Assistant General Counsel Enclosures1. Complaint 2. Procedures 3. Designation of Counsel Statement FEDERAL ELECTION COMMISSION WASHINCTON. D C 2O3

April 3, 1992

Angela Y. Davis 10463 Royal Oak Road Oakland, CA 94605

RE: MUR 3493

Dear Ms. Davis: The Federal Election Commission received a complaint which alleges that ,-u may have violated the Federal Election Campaign of the complaint is GAct of 1971, as amended ("the Act"). A copy enclosed. We have numbered this matter HIJR 3493. Please refer W to this number in all future correspondence. C4 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 analysis of this _believe are relevant to the Commission's matter. Where appropriate, statements should be subsitted wader which should be addressed to th *e"ral oath. Your response, of Counsel's Office, must be submitted within 1S days of receipt within 1S days. the 0 this letter. If no response is received C.omilssion may take further action based on the available information. C This matter will remain confidential in accordance with 5 4!7g(a)(4)(B) and S 437g(a)(12)(A) unless you notify 2 U.S.C. made the Commission in writing that you wish the matter to be 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. xf you have any questions, pleae ontaC t 't sler, he attorney assigned to this matter, at (202),219-34W. Fot r information, we have enclosed a brief deciption of the Com ssiones procedures for handling complaints. sincerely

athan Bernstein Assistant General Counsel Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement FEDERAL ELECTION COMMISSION WASHINGTON. 0 C 20M3

April 3, 1992

Mikhail Gorbachev Leningradskiy Prospekt No. 49 MOSCOw, Russia 125468 USSR

RE: MUR 3493

Dear Mr. Gorbachev: The Federal Election Commission received a complaint which Campai n you may have violated the Federal Election Actalleges of 1971.that as amended ('the Act'). A copy of the complaint ?s enclosed. We have numbered this matter MUR 3493. 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 -V0 believe are relevant to the Commission's analss of this matter. Where appropriate, statements should-be submitted uaier oath. Your response, which should be addreseed to the General o OicerfCounsel must be submitted within IS dois of receipt of this letter. If no response is received within days the qW Commission may take further action based on the available information. This matter will remain confidential in accordance with 2 U.S.C. S 437g(a)(4)(9) and S 437g(a)(12)(A) unless you notify the Commission in writing that you wish the matter to be made public. If you intend to be represented by counsel in this matter, please advise the Commission by completing the enclosed form stating the name, address and telephone number of such counsel, and authorizing such counsel to receive any notifications and other communications from the Commission. if you have any questions, plee. Contact a* ft Your attorney assigned to this matter# at (32) 23"4 . infornation, we have enclosed a brief description of the Comission's procedures for handling comlaints. Stcrel

§nathan Bernstein Assistant General Counsel Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement FEDERAL ELECTION COMMISSION WASHINCTON, 0 C 30403 April 3. 1992

Boris Yeltsin Commonwealth of Independent States The Kremlin Moscow, Russia USSR RE: MUR 3493 Commonwealth of Independent States (FKA Union of Soviet Socialist Republics)

Dear Mr. Yeltsin: tn The Federal Election Commission received a complaint which CM alleges that the Convealth of Independent States, as successor to the Union of Soviet Socialist Republics, may have •') fvviolated the Federal Election Campaign Act of 1971, as amded ("the Act"). A copy of the complaint is enclosed. We hove mtbered this matter NOR 3493. Please refer to this number in all future correspondence. o Under the Act, you have the opportunity to demonstrate in :riting that no action should be taken against the Conwmm alth of Indepondent States in this matter. Please submit any factual or legal materials which you believe are relevant to the 0 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 0 subwitted within 15 days of receipt of this letter. If no response is received within 15 days, the Commission may take further action based on the available information.

This matter will remain confidential in accordance with 2 U.S.C. 5 437g(a)4)(B) and 5 437g(a)(12)(A) unless you notify the Commission in writing that you wish the matter to be made public. If you intend to be represented by counsel in this matter, please advise the Commission by completing the enclosed form stating the name, address and telephone number of such counsel, and authorizing such counsel to receive any notifications and other communications from the Commission. Niv* 2 If you have any questions, please contact Tony Buckley, the attorney 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. Sincere-

Jonathan Bernstein Assistant General Counsel enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement ROY M1. KAUJFMAN AToaON4V AT LAW 745 LEA UGUILU4 *0 UIUPMI AYUL %A? CLEIN.ADS. OHIO 44114 or - April 8, 1992

Federal Election Commission

Office of the General Counsel - xc 1325 K St. 7- Washington, D.C. 20463 ATTN: Jonathan Bernstein, Asst. General Counsel Re: MUR 3493 Dear Mr. Bernstein: tn The Communist Party (USA), Gus Hall, Judith LaBlanc and - the Treasurer of the Communist Party submit the following C4 response to the Complaint filed by Grover G. Norquist. "Q I. The Complaint cites no specific article of the US Code which has been violated. The election coittees for preidential candidates for the CPUSA have always filed their reports. No I 0 criticism has been received from the PIC.

•q II. The allegation sugg eted by the Washington Time* C) isthat groundless OMr. Hall andmy pure be inficture. violation of 11 CPR 102.15"

CPUSA Political Comittees have never couingled 0 their funds with personal funds of officers, member of the committees, or any other inividuals.

III. The charge that Gus Hall received millions of dollars from Michael Gorbachev in violation of the US Code pertaining to the FEC is also groundless. The FEC has received the reports from the CPUSA political committees which are accurate accounts of the money received and spent for the election campaigns of CPUSA Presidential candidates. The last records being for 1984. ll MUR 3493 April 8, 1992 Page 2

The CPUSA has run no presidential candidates since the Hall-Davis campaign in 1984 prior to Gorbachev taking office. There is no probable cause to believe that the charges alleged are true. There are no affidavits filed, but only hearsay from some of the media which is pure speculation and not based on fact. The FEC has all relevant data in its files, and has already reviewed the CPUSA Political Committee reports and has not found them wanting. It appears that the Liberty Lobby and its supporters are trying to slam the FEC because it has initiated an investigation of the Liberty Lobby for US Code violations and is accusing it of being *soft' on Communists as a ploy to divert the investigation from it to the CPUSA.

be dismissed. Lt) The charges should t n Very truly yours,

C4d Roy M. Kau an Attorney fo CPUSA & LaBlanc & Hall

RMK: IMC 3493 no or AD82 - 4"11A CLEVELAND. OHIO 8 -o 216 861-5542

as my ,he above-ne in-dividua i.s .ecoy designated and othec counsel and is aut.o=zed to recetive any notifications ccmunications frc t. Coimssion and to act on my behalf before the Cowlssion.

mOUallow SNMU

lo t

S-: -5 (d urnsm IMM ______Lcx.L aw15 p Witi

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216 861-5542

The above-named individual .s 'ereoy designaced as my otbet counsel and is authorized to receive any notifications and cmunicactons f"= the Commissicn and to act on my bhalf before t.e COmmIssion.

ArloOwfk.%

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il i | I i i i I ui n M swims 133S a 28, 1992

TODY Di&ioC- 20463

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go*" IOD] iIo ma UlndMW woo"m ,lMz .giULo . f-"l fa~" imw kami FEDERAL ELECTION COMMISSION WASHINGTON. D.C 2063

May 4, 1992

Angela Y. Davis 10463 Royal Oak Road Oakland, CA 94605

RE: MUR 3493 Dear Ms. Davis:

This is in response to your letter dated April 28, 1992, which we received on that same date, requesting an extension of time to retain counsel and respond to the complaint filed against you by Grover G. Iorquist. After considering the circumstances presented in your letter, the Office of the General Counsel has granted an extension of 20 days. Accordingly, your response is due by the close of business on may 26, 1992. if you have any questions, please contact me at (202) 219-3690. Sincerely,

AttTon Buckleyney( Nay 11, 1992 "

Jonathan Bernstein, Esq. Assistant General Counsel Federal Election Commission o Washington, DC 20463 -

Re: NUR 3493 Dear Mr. Bernstein: %0 I have been retained by one of the r xeit in this matter, Angela Y. Davis, to W-e--_mt.hervith wo _t to the complaint of Grover G. Morquift iimte 1be 30 1902. CO Aside from the 9inEWaly Vae and -- tU_-e3, of the oK charges, I wish to call certain t-ers-to ya eMtm"ion. 0 1. Ms. Davis was United States at the 190a an *al 4 e*1i .. .- ft thethe 1984 campaign, her principal 14-t~e WIi a Etiaml Hall-Davis Campaign 84 (he "), it frm11Wi110 the complaint whether a-- - .- i11ol acta ae baim made against Ms. Davis bee ororte. tte S W event, Ms. Davis unequivocally dmies I- -la in or L of any o. illegalities.

2. It is apparent from the frae of the m lantt that the real intention is not to call possible violations of the act to the attention of the Comission, but to air the o lainant's personal grievances. The complainant lacks any personlI knowledge of illegal contributions. Apparently the sole predicate for the complaint is a series of naper articles which refer to alleged payments to the Commist Party. To the best of our knowledge, the articles raised no question regarding the financing of the Comittee, and nothing in the Comittee' reports gives any indication of iropriety. The iieston should also take note in this regard of the relatvely amall amounts received and expended by the Ciittee. Contrary to the complainant's assertion, nothing in the newspper articles wJonathan 3ernste4in, seq. may 11, 1992 pae. two

sthat either Ns. Davis or any of the other resp.A- "conspired to violate... FCC lavs." 3. As noted previously, Ms. Davis was last a candidate IS the 1984 election. Upon information and belief, no contribftiM were received by the Committee subsequent to September 30, I". The relevant statute, 2 U.S.C. S455(a), provides in pertinent part that 0(n]o person shall be prosecuted, tried, or punished for any violation of subchapter I of this chapter, unless the indictment is found or the information is instituted vithin 3 years after the date of the violation." Obviously, even if, arguendo, any illegal contributions were made, the statute of limitations has long since run and no prosecution could ensue. It necessarily follows that there is no basis for an investigation by the Commission.

It is clear from the foregoing that the complainant ham no real interest in the investigation of violations of the F3OM. Not only is there no shred of evidence indicating violations of Cthe Act by my client, but no reasonable inference of such violations can be drawn from the information provided by the complainant.

Based upon the foregoing, I respectfully request that W Office of the General Counsel recommend that the Comwislen t that there is no reason to believe that a violation has been coMmitted, and that the Commission dismiss the complaint in thi matter.

Very truly yours,

Jeffrey Schwartz

JS:eg May 12, 1992

Mrs. Joan Aikens 7, chairwoman --3v' Federal Election Comission 999 R Street, N.W. U Washington, DC 20463 Re: FEC Coinlaint dMUR-3493 Dear Mrs. Aikens:

We are anxious to see the pending FC oamplaint against the Communist Party USA prosected vigorously.

Would you be so kind as to proviAsO esc of the u wemdWith a narrative sumary of (a) the intitim atof the Ve v*it . ,t"ct to this complaint, and (b) the sttus of any &Oti= y we currently taking? We also urge to make yaw f indiqm p le oa e as and appreciate your efftet- on thls nette. Sim~wely

Q11 J oi-I.A. as.

Ars, Sk.IqVWW KIMOrt, Ir I Alo-- S

MU 4 q3'=q

FEDERAL ELEV nFc

DAE 7-7-72 v 0 S--mwM APb k 10 I 56 1A ° 'AW P.O. am m a MILPrrAS. CALIFORNIA 9 C42 AMMM FEC

(408) 2MUI W.*Cr Norquist vs Hall irt .4 Federal Election Commission

999 E St., N.W.

IV Washington D.C. 20463

I urge you to act qsily and decisively on the Norquist vs Hall case. Te CPUSA is riptte7W .ei with and filamolilly Iupp eed many cur- •r7 r,=9 org-ni_- oi---_= N OR la CS- "M- . m--- a . t -_y. suc Information mst be " M to--tbe AMticaf people. Pleaca

C0 Sncereiy,

j~v\ iI~ C.oMMISSioNkE3T3ON', I OZRALD OXDWXTZ 00S N0313U WLLO O 00310 CNICA0O, ILLINO18 60610

July 7, 1992 tr The Federal Election Commission 999 E Street, N.W. Washington, DC 20463 Gentlemen: I understand that information from Moscow discloses that the Communist Party of the USA has received funding through Gus Hall and Nikhail Gorbachev in violation of U. S. election laws. This matter is of sufficient interest, particularly in view of the political campaign now going on that the matter be handled expeditiously.

I would appreciate it if you would respond quickly to the Morquist v. Hall, Gorbachev and the CPUSA lawsuit. Sincerely,

GG/Arf MAlII fAOQ r X -13 1 97. tL

Re: Eorquast vu,, , o vormA t" CPU"

SWe titi g to =60 the laO to miad quAekl :In the abm am& 0se. oPovew It, f t of w1o for '0 fe fe is acts"g aw bel1*of wwwOwv~ity of Amelms8 In C#4 ~ n a .. aat 4eo~f *

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WA . CAN" v tCe 9

The Federal Election Commission 999 3 Street NW* WashingtonDC 20463

July 9,1992

Dear FEC representative,

I understand that Grover Norquist, president of Americans _ for Tax Reform, has filed a complaint to you against the Comm- unist Party - US.A.,Gus Hall and Mikhail Gorbachev, for conspir- ing to violate U.S. election laws. As a concerned taxpayer and informed citizen of this r%- country, I would urge you to respond as quickly as possible on this matter. %0 More information coming out of the(now open to us)Soviet N4 Union's archives are revealing more names, organizations and dollars spent against this country during the Cold War. Thank you for your urgent co-operation. CO

0%. Sincerely 0 1,A Cc; C!57/ 'S C *Al 3#? ~A4.

St is 9i

M TU.C

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fit~ ADDITIONAL DOCUMENTS WILL 9g ADDED TO THIS FILE AS THEY DICONE AVAILABLE. PLEASE CHECK FOR ADDITIONAL MICROFILM LOCATIONS. FEDERAL ELECTION COMMISSION wASHI TONT',DC X063

THIS ISTH EM OF U #

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FORt YE1 FOLLWIlIUG DOCWSE ,,PIWU,, TO Y5nE CASE

1. Memo, General Counsel to the Comission, dated September 22, 1992, Subject: Priority System Report. See Reel 354, pages 1590-94.

2. Memo, General Counsel to the Commission, dated A~pril 14, 1993, Subject: Enforcement Priority System. See Reel 354, pages 1595-1620. 25. N1 3. Certification of comissaion vote, dated April 1193. O See Reel 354. pages 1621-22. 4.GeealCune'sRpot.I teUte o o ~ ft~r~y. atd Dcebe 3. 93 ; ii i Dm135 4, pqes 16234740. i

5. ttgimo ~ 1avt t Grover 0. oqiat 716 Worth Carolines Awenue, 3.3. Washington, D.C. 20003

RE: RUN 3493 Dleer Hr. Nlotquist: os Etcb 30, 1092. th ftiersl Ulecti.. u~oa 1ed m

Date the Comission voted to clos, the tile: DC~ IauinYaskiy ?rospokt no. 49 MSOSCow, Russia 123468

33: RU!. 3493 Deer Mr. Gorbachev: On April 3, 1992, the Federal Election Commission notified you of a complaint alleging certain violations of the Fedral 3lectioa Campaign Act of 1971,* am amended. A oopy of h €ouplaint yWs enclosed with that notification.

Afr cmeid~riag th €ircmtanoe* of this lattg, .the

,i+.&WleI m wit . A~1Iy

*!ine~lly,

Tony: luckley Attorney

Date the Commission voted to close the file: DEf.eo kreg~yassy Chetveof the rikov Russian Federation 11214~hStreet, N.M. Wshington, D.C. 20036

RE: RUR 3493 Dear Nr. Chetverikov: On April 3, 1992, the Federal Election th Co-o-.lt .of la,.od t Sta.. ofa CoComa-isloo .tt. notified

219-3y90. hove any qtaetons, p1.... otct me at 4(2)

Sincerely.

Attoney -

Date the Commission voted to close the file: DE J Jeffrey Schvartu, Lsq. 21-36 33rd Road Long Island City, NY 11106

RE: NUN 3493 Dear Kr. Schwartz: On April 3, 1992, the Federal Election Commission notified your client, Angela Y. Davis, of a complaint alleging certain amended. A copy of the complaint was enced with that notification.

Afe ogdr h imtm. of the

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RE: IWN 3493 Dear Rrt. Kaufmn: Os April 3, 193, the Pederal Ilection CooIalsmoa nqtlfie 7 es@)[email protected] btelecad h .mwitWa"tW I "u,. It.

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RE : NUN 3493 Dlet Hr. Nail:

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Date the Comissiou votd to close the file: O c*9 m