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************************************************************* Kathy Sullivan, Chair September 23,2004 - Lawrence Norton, Esquire General Counsel Federal Election Commission 999 E Street, N.W. Washington, D.C. 20463 C RE: Complaint of the New Hampshire Democratic Party Against Nader for Choices for America, and Norway Hill Associates, Inc., MUR 55 13 Dear Mr. Norton: r- On August 10, 2004, the New Hampshire Democratic Party filed the above-referenced complaint with respect to activities of Norway Hill Associates, Inc. in collecting signatures to get Ralph Nader on the ballot as a candidate for President in the State of New Hampshire. Based upon additional information that has come to our attention, including the FEC filing made by the Nader Campaign this past week, we would like to s’upplementthe complaint filed August 10,2004. We believe that this FEC filing establishes coordination betweenSNorwayHil1and the Nader Campaign. We also believe it shows Norway Hill and the Nader Campaign are now working in concert to “cure” impermissible in-kind corporate donations by attributing these donations to individuals after the fact. As stated in our August 10,2004 complaint, Norway Hill Associates, Inc., a New Hampshire for profit corporation, undertook a signature drive to get Ralph Nader on the ballot in New Hampshire. According to published press reports on August 10, 2004 (see Portsmouth HeraZd, August 10,2004, attached as Exhibit A), aNader spokesman denied knowledge of the petition effort. Earlier press reports raised questions of whether Republican signature gatherers were making in-kind donations to the Nader campaign. (See Union Leader, August 8, 2004, attached as Exhibit B.) . When asked on August 9th about whether Norway Hill had made an in-kind donation, the company’s principal, David Carney, said he hadn’t yet figured out what it was.
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