FEDERAL ELECTION COMMISSION WASHINCTON, 0 C 0463

THIS IS a}E BEGINI(,3 OF MM # ___A 92

DATE FILMED ,,,IJ C',ERA NO.

-mw n 5 FFWW -WWI

Pl(Wn

a' Mary Lou Cl ... --- wuw • • m" 300 Escondido Ave. Vista, Ca. 92084 1 -619-724-7541

Re: Congressman Ron Packard, Unfair Political Practices Dear Sir, The following information is submitted to fulfil the require- ments to file a formal written complaint with the Federal Election1 Co-n'iiss ion. This formal complaint is to identify Congressman Ron Packard

- from California as the respondent. lI unfair political practices, by receiving services and mailings that should be a matter of campaign records as contributions. The enclosed article is a like accusation on a State level. Many people in ths Congressional District received N.R.A. letters in Congressman Ron Packard's behalf. I am challenging as to wheth er this was acknowledged as a comapign contribution. A copy of two diffenent mailings should be ovtaineI by you from the 17'.%., because they are not available to me. Respondents address: Rep. Ron Packard

2162 Rayburn House Office Bldg.

Washington, D.C. 20515 1-202-2253906 48th. District Rep.. Sincerely,

.PW? 1A-K Mary oU Clift ,,&W" € ,"JAC - 0. 3on Esconjido Ave. \aNFO COMrv Vista, Ca. 92084 WCnm G 1971 -61 9-724-7541

Subscribed and Sworn to before me.74r on this 8th div of 1ANUARY, 199t.

P.- EIWIhL_ - wmiaip_ _'ak.

State takes aim at NRA's contributions to Morrow The Fair Political Practices Commission will consider week whether to fine the Na- tional Rifle Association orS33,000 tardiness for failure to disclose in disclosing con- tributions to Assembly candi- dates, induding Assemblyman Bill Morrow, R-Oceanside. An FPPC spokeswoman said the NRA failed to report spending SS,143 on campaign mailers that mentioned Mor- row on April 27 and May S, 1992. The mailers went out in the weeks leading up to Mor- row's victory in a bruising eight-way Republican primary for the 73rd District Assembly seat. The mailers were done inde- pendent of the Morrow cam- paign, and the commission has not accused Morrow of any im- proprieties in the matter. The commission will also consider whether to levy fines on the NRA for $11,600 for a mailer on behalf of three can- didates on May 5, 1990, includ- ing former Assemblywoman SLMny Mojonnier, R-Encinitas. FEDERAL ELECTION COMMISSION lopWLI1 Washington. DC 20463 January 22. 1996

Mary Lou Clift 300 Escondido Avenue Vista, CA 92084

RE: MUR 4292

Dear Ms. Clift:

This letter acknowledges receipt on January 16, 1996, of your complaint alleging possible violations of the Federal Election Campaign Act of 1971, as amended ("the Act"). The respondent(s) will be notified of this complaint within five days.

You will be notified as soon as the Federal Election Commission takes final action on your complaint. Should you receive any additional information in this matter, please forward it to the Office of the General Counsel. Such information must be sworn to in the amne manner as the original complaint We have numbered this matter MUR 4292. Please refer to this number in all future communications. For your information, we have attached a brief description of the Commission's procedures for handling complaints.

Sincerely.

P~r.kI x 3 1" -

Mar> L. Taksar. Attorney Central Enforcement Docket

Enclosure Procedures FEDERAL ELECTION COMMISSION W~hgOw. DC 2048

January 22, 1996

Maryrose Jennison, Treasurer NRA Political Victory Fund 11250 Waples Mil Road Fairfax, VA 22030

RE: MUR 4292

Dear Ms. Jennison:

The Federal Election Commission received a complaint which indicates that the NRA Political Victory Fund and you, as treasurer, may have violated the Federal Election Campaign Act of 197 1, as amnended ("the Act"). A copy of the complaint is enclosed. We have numbered this matter MUR 4292. 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 the NRA Political Victory Fund and you, as treasurer, in this matter. Please submit any factual or legal materials which you believe are relevant to the Commission's analysis of this matter. Where appropriate, statements should be submitted under oath. Your response, which should be addressed to the General Counsel's Office, must be 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 %ith 2 U.S.C. § 437g(aX4)B) and § 437g(aX 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 anyv notifications and other communications from the Commission. If you haveinyquetions please contact Alva E. Smith at (202) 219-3400. For your information, we have enclosed a brief description of the Commission's procedures for handling complaints.

Sincerely,

Mary L. Taksar, Attorney Central Enforcement Docket

Enclosures I. Complaint 2. Procedure 3. Designation of Counsel Statement F0 I

FEDERAL ELEClION COMMISSION WQnWo DC 2048

January 22, 1996

William L. Hardy, Treafu Friends of Ron Packard P.O. Box 1549 Carlesbad, CA 92018

RE: MUR 4292

Dear Mr. Hardy:

The Federal Election Commission received a complaint which indicates that Friends of Ron Packard ("Committee") and you, as treasurer, may have violated the Federal Election Campaign Act of 1971, as amended ("the Act"). A copy of the complaint is enclosed. We have numbered this matter MUR 4292. 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 the Committee and you, as treasurer, in this matter. Please submit any factual or legal materials which you believe are relevant to the Commission's analysis of this matter. Where appropriate, statements should be submitted under oath. Your response, which should be addressed to the General Counsel's Office, must be submitted within 15 days of receipt of this letter. If no response is received within 15 days, the Commission may take further action based on the available information.

This matter will remain confidential in accordance with 2 U.S.C. § 437g(a)(4)(B) and § 437 g(aX I 2)(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 namne, address and telephone number of -such counsel, and authorizing such counsel to receive an% notifications and other cornmuiications from the Commission. " - .T, .. .! "/ - "'

If you have my question please contact Alva E. Smith at (202) 219-3400. For your information, we have enclosed a brief description of the Commission's procedre for hundling compaints.

Sincerely,

Mary L. Taksar, Attoney Central Enforcement Docket

Enclosures 1. Complaint 2. Prcedur :* 3. Designation of Counsel Statement FEDERAL ELECTION COMMISSION wain=gon DC 2048

January 22, 1996 The Honorable Ronald C. Packard 2162 Raybum Hose Office Building Washington, DC 20515

RE: MUR 4292

Dear Representative Packard: 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 4292. Please refer to this number in all future conespondence.

Under the Act, you have the opportunity to demonstrate in writing that no action should 'Le 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 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 2 U.S.C. § 437g(aX4)B) and § 437g(aX12XA) 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 numbeKr of such counsel, and authorizing such counsel to receive any notifications and other communications from the Commission. If you have any queson, pleas contact Alva E. Smith at (202) 219-3400. F(r your information, we have eloed a brief descr ption of the Commission's procedures for handling complaints.

Sincerely,

Mary L. Taksar, Attorney Central Enforcement Docket

Enclosures 1.Complaint 2. Procedures 3. Designation of Counsel Statement FEDERAL ELECTION COMMISSION Washhnton. DC 20463

January 22, 1996 The Honorable Ronald C. Packard 3746 Center Way Fairfax, VA 22033

RE: MUR 4292

Dear Representative Packard:

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 4292. Please refer to this number in all future corespondence.

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 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 resonse 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. § 437g(a)(4)B) and § 437g(a( I 2)(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. Ifyou have any quution, pleme contact Alva E. Smith at (202) 219-3400. For your inforation, we have enclosed a brief description of the Commission's procedures for handling complaints. Sincerely.

j

Mary L. Taksar, Attorney Central Enforcement Docket

Enclose 1. Complaint 2. Prcedues 3. Designation of Counel Statement Febru 2, 1996

Federal Election Commission 999 E Street, NW V T.. Washington, DC 20463

ATTN GCneral Coumss Office

RE MUR 4292 -

Dear Sirs.

I am in receipt of. ou letter dated Jummay 22,1996 nofiFyin nm that a complain has been filed against me or my campaign. You have nmbeed the matte MUR 4292.

It appear the complai allees nm cy aign failed to rep" a in kind cpu p contribution in the form of a letter with an re of myself by the National Rifle Association (NRA). Until Ireceived the complaint I had no knowledge of the letter. To this date I have nemv see the letter aigedl.- endorsing me The letter was not sene with my Fc - wit my Pionitom in m A ionWii eor at the request or suggestion of myself, my agats, or my r- cougnte nor was the rsmeCt solicited or applied for b%-me,

It is n u rndig that the NRA does send letters to their m,edorsing lists of canidates. and they make such endorsements based on voting records, and those el areMatirdv of the NRA's o wn volition.

As a result there was no in kind contribution I was aware of. and therefore, nothing to report Consequenth the complaint against me is not valid, and the Commission should iake no action ot-er thai, action dismissing the complaint

Sinccrc %

R n Packard \lcmber of Congress -' 17 Sncad Dn c (ceansidc, (A 92)5

Friends of Ron Packard

PBox~ 15414 CAJ12'y-k v NATIONAL RIFLE ASSOCIATION OF AMERICA * 11250 WAPS MILL ROAD FAMPAZ, VA mao ormA or T= ChULCo"M February 7. 1996 TZMoN:Fsxr (M0)(708) 2671250U74.M

Ms. Mary L. Tacker. Attorney Federal Election Commission Central Enforcement Docket 999 E Street, N.W. Washington. IX 20463

RE: MUR 4292

Dear Ms. Tacker:

As an Assistant General Counsel for the National Rifle Association. I represent both Mary Rose Jennison in her capaciti as Treasurer of the NRA Political Victory Fund (NRA-PVF) and the NRA-PVF itself. I have enclosed a Statement of Designation of Counsel executed by Ms. Jennison to that effect.

Insofar as the complaint of Mary Lou Clift giving rise to this action is so completely devoid of any specific facts or circumstances upon which to deduce or find a prohibited act. I regret that my clients are. at this time. unable to supply the Commission with a reasoned response other than to deny any violation of the applicable statute and regulations. Specifically. Ms. Clift has not even set forth a time period or a particular election in which the unspecified prohibited act is alleged to have occurred.

While the NRA Political Victory Fund has supported Congressman Ron Packard in \arving degrees in the past. this support has been dutifully characterized and reported to the Comnission on the apprpriate reporting forms. At no time has the Poiticai , ictor% t-und made an%- contribution to. or expenditure on behalf of. Congressman Packard which would be prohibited under the Federal Election Campaign Act or its implementing regulations adopted b\ the Commission.

I \kould. ihcret;re. urge the 'omnission to dismiss this frivolous and untounded ,o)mplaint\ \ th preiudi.C Please feel free to contact me if I can be of further assistance to vou /

Ke\ in \I (unn'Ll ,hal \', istilt (vL'l'cral] . ll,'

r n1Li ).urc STCATFp : 11OF 2i, ]R.qONATa 1 161 to *4cOU,1 I_

MUR 4292

NAME OF COUNSEL: Kevin Michael Cunningham

FIRM: National Kifle Association of America ;I I I ice of the General Counsel ag ADDRESS: £3 1120 Waples Mill Road

Fairfax, Virginia 22030

TELEPHONE:(703 ) 267-1257

FAX:(iL0-) 267-3985

The above-named individual ishereby designated as my counsel and isauthorized to receive any notifications and other communications from the Commission and to wt on my behalf before the Commission.

Z. Date S itwre

RESPONDENI'S NAME: , arv R,,-e ,TenTsi(-n, Treasurer

ADDRESS. ..~m- LdiU.~ili!LLct.' rx Fu~ ____

~: .t' >1

. .. ' ..

ft! .',IN |Iq FEL ,; '. BEFORE THE FEDERAL ELECTION COMMISSION:.. u Ifk i'45t'V In the Matter of . ) ) Enforcement Priority )

GENERAL COUNSEL'S REPORT

I. IN1TRODUCTION

In accordance with the objectives of the Enforcement Priority System ("EPS") adopted b% the Commission in May 1993. the Office of the General Counsel has

periodicall. recommended that the Commission not pursue cases that are stale or that. in comparison to other pending matters, do not appear to w,-arrant the use of the

Commission's limited resources. This General Counsel's Report recommends the

Commission not pursue 43 cases that fall %%)thinthese categories.

II. CASES RECOMMENDED FOR CLOSING

A. (a,,c' Not Warranting Further Pursuit Relative to Other Cases Pending Bcfore the Commission

\ critical comvnent of the Priorit% S%stem is identifying those pending cases that

,j,To! \\ ir.nt thc turther c\1penditur, of 'Crnmission resources Each incoming matter

1,C. jtu.!icd us,.n' (,Coiniision-appro\ ed criteria and cases that. based on their rating. do

r'ot kNi'.,nt puriit rclatic to other rvndin case,. arc placed in this categor' . 3v closing

,,uch ,ac, thc (ommisson is able to use its limited resources to focus on more Having evaluated incoming matters, this Office has identified 24 cases which do not warrant further pursuit relative to othe pending matters.' A short description of each case and the factors leading to assignment of a relatively low priority and consequent recommendation not to pursue each case is attached to this Report. Attachments 1-24.

As the Commission has previously requested, we have also attached responses and referral materials where that information has not been circulated previously to the

Commission. Attachment 25.

B. Stale Cases

Investigations are severely impeded and require relatively greater resources when

the activity. and the evidence of the actrit. are old. Accordingly. the Office of the

General Counsel recommends that the Commission focus its efforts on cases involving

more recent activity. Such efforts will also generate more impact on the current electoral

process and are a more cfficicnt allocation of our limited resources. To this end, this

Office has identified 19 cases that

this Office believes are

no%% too old i %vjrrant the u,,c ol the ('ommisslon's resources

Thcw mutters are MLR 4227 (,€llstone for Senate) (Attachment I). MUR 4273 (Jesse Wineberm) i .Machmcnt 2 . %IL'R 42QO (L.incoln Club of Riersidc Count') (Anachment 3): MUR 4292 (Convrcsman Ron Packard) (Attachmen 4I. ML R 4293 (Willie Colon for Congress) (Anachment 5): M't.R 4424 iklan Kr'es for President *%I(Attachment 6). MUR 4299 (UAW-V-CAP) (Attachment 7). NIt R 4 112 (onorna Count% Repubhlicans) (Attachment 8I. MLIR 4316 (Ross Perot) (Anachment 9). MUR 4' , P81Pai k Cocbs I'mto rignr-ss) i Attachment 10). NMIR 4324 (Buchanan for President) (Attachment I 1). SIt k 4 32, Man (jarmecki fof Congress '961 Attachment 12). MUR 4329 (Golden Door) iAttachment 13 ). MIR 4330 (Trice llarve,) (Atachment 14). MUR 4333 (WSB-TV) (Anachment 15). .( 'R 4 .4 (Cc%\ Communications) 4 Attachment 16). MUR 4336 (WSB-TV) (Attachment 17). MUR 4339 SS13- TVi tt achn i1t M R 4%48 iSoejin for Congress) (Anachment 19). MUR 4359 (Francis Thompson for ( onress.i Attachment 201. MIL 'R 4360 (A es cand Commitnee) (Artachment 21). MUR 4.6 f A S11 T\ ii Attachment 2>-'') LR 4364 tFriends of Jimm\ Blake) (Atachment 23) and Pre-MUR 28 )cp tirmcnt ot the Interior i Attachment 24) Because out reommendation not to pursue these cases is based on their stalenes, this Office has not pre e separate narratives for these cases. we have attached responses and referral materials in those instances where the information was not previously circulated. Attachments 26-45.

This Office recommends the Commission exercise its prosecutorial discretion and no longer pursue the cases listed below effective September 3, 1996. By closing the cases efTective that day. CED and the Legal Rev-c%' Team each will have the necessary time to prepare closing letters and case files for the public record. I!I. RECOMMENDATIONS

A. Decline to open a MUM, close the file effective September 3, 1996, and approve the appropriate letters in the following matters:

I) Pre-MUR 293 2) Pre-MUR 311 3) Pre-MUR 328 4) RAD Referral 95L-03 5) RAD Referral 95L-1 6) RAD Referral 95L-16 7) RAD Referral 95L-22 8) RAD Referral 95NF-21

B. Take no action, close the file effective September 3, 1996, and approve the appropriate letters in the following matters:

1) NIUR 4061 2) MUR 4074 3) MUR 4101 4) MUR 4146 5) MUR 4151 6) MUR 4175 7) NIUR 4180 8) MUR 4184 9) NII'R 4198 10) IL'R 4201 11 1MR4__'? 1_' \lIiR 4232 I \11R 4273 14 \L'R 4290 1 ; MUR429" 16) MUR 4293 17) MIR 4294 Ig) \IR 429Q 19) M 'R 4312 2M \1t'R 4316 21 M'R 4318 N2W",LR 4324 23 NILR4325 24) NIL R 4329 25 i L'R 4330 2t)) ML R 43" .7) 'IVR4334 OWN.~~U

28) MUR 4336 29) MUR 4339 30) MUR 4348 31) MUR 4359 32) MUR 4360 33) MUR 4363 34) MUR 4364

C. Take no frther action, close the file effective September 3, 1996, and approve the appropriate letters in MUR 3826.

q~z4L General Counsel r

BEFORE THE FEDERAL ELECTION COSU(I8XON

In the Natter of ) ) Enforcement Priority. )

CERTIFICATION

I, Marjorie W. Emmons. Secretary of the Federal Election

Commission, do hereby certify that on August 21, 1996, the

Cozmission took the following actions on the General Counsel.s

August 14, 1996 report on the above-captioned matter:

I. Decided by a vote of 5-0:

A. Decline to open a MUR, close the file effective September 3, 1996, and approve the appropriate letters in each of the following matters:

1) Pre-MUR 293 2) Pre-MUR 311 3) Pre-MUR 328 4) RAD Referral 95L-03 5) RAD Referral 95L-11 6) RAD Referral 95L-16 7) RAD Referral 95L-22 8) RAD Referral 95NF-21

B. Take no action, close the file effective September 3, 1996, and approve the appropriate letters in each of the following matters:

MUR 406" 2 MP 4 C74 3 MJR 41C: 4) MUR 414E 5) M'JR 4151 6) MJP 41"t W.TR 418 8 MJR 4184 9 M 7 4198

(continued) k .uetm qWv -

Pederal Election Commission Page 2 Certification for Enforcement Priority Auquut 23, 1996

10) MU 4227 11) MUR 4232 12) MUR 4273 1.3) MUR 4290 14) MUR 4292 15) MUER 4293 16) MUR 4294 17) MUR 4299 18) MUR 4312 19) MU 4316 20) MUR 4318 21) MUR 4324 22) MUR 4325 23) MUR 4329 24) MUR 4330 25) HUR 4333 26) IUE 4334 27 ) MUR 4336 28) HUR 4339 29) MUR 4348 30) MUR 4359 31) MUR 4360 32) HUR 4363 33) MUR 4364 Coz=issiooners Aikens. Elliott, McDonald, McGar-y. and Thomas voted affirmatively with respect to each of the above-noted matters.

Attest:

Date ,-Parjorie W. Seci tary of the Comisaion Received in I.I.e Secretariat: Wed., Aug. 14, 1996 4:56 Circulated p.m. t.e Co..ission: Fri., Aug. 16, 1996 12:00 p.m. Deadl ne ±- vzte: Wed., Aug. 21, 1996 4:00 p.m.

br w~. 0 S

FEDERAL ELECTIO\ COMMISSION

SEP 0 i99 CERTIFIED MAIT RETURN RECEIPT REOUESTED

Mary Lou Clift 300 Escondido Aenue Vista. CA 92084

RE MUR 4292

Dear Ms Clift

On Januar% 16. 1996. the Federal Election Commission received your complaint alleging certain %iolations of the Federal Election Campaign Act of 1971. as amended ("the Act"

After considerine the circumstances of this matter, the Commission has determined to c\%*rciw. its prosecuiorial discretion and to take no action auainst the respondents. See attached narrate'e Accordinul. the Commission clo,.-d its file in this matter on September 3, 1996. Thi. matter ,,ll become pan of the public record %-ithmn30 dais

The Act allo,,s a complainant to seek judicial re\ le\e,of the Commission's dismissal of this action Se: - 1 S C 4.37p a8,1

Si nctxel\.

Colleen 1 Sealander. Anome\ Central Enforcement Docket

..\lla hmicni \arrati\ c MUR 4292 CONGRESSMAN RON PACKARD

Man Lou Clift filed a complaint alleging that the National Rifle Association ("NR.A") failed to disclose contnbuiions made on behalf of Congressman Ron Packard. She alleges that the NRA made contnbutions to Ron Packard by sending "mailings" to individuals on his behalf This complaint is based on an article which indicates that the NRA was fined for failure to disclose or tardiness in disclosing contributions to Califormia state candidates

In response. the NRA states that at this time it is unable io supply the Commission %,itha reasoned response other than to den% an% %iolation It points out that no time penod is set forth by the complainant and complainant has not specified any particular act The NRA states that all of its past suppor for Congressman Packard has been reported to the Commission and that at no time has the NRA Political Victory' Fund made an% contribution to. or expenditure or behalf of. Congressman Packard which would be prohibited under the FECA

In response Congressman Packard states that he has never seen the letter allevedl\ endorsing him Hie states that the letter %%as not sent w.ith his cooperation, or v. ith hi, prior consent, or in con ,ultai on vith him or at the request or suggestion of him,,elf hi, agents. or hi,- campaign committee nor %-.as the endorsement solicited or applied for b\ him

I herc i, no indication that the acti\ it\ had a significant impact on the process and thcr. i', no indication of an% ,eroou, intent to \ iolate the FECA This maner is less ,,jin.fic-nt relative to other matter,, pendinV hd'orc the Commission FEDERAL ELECTION COMMPISSION

Kevin Michael Cunningham National Rifle Association of America Office of the General Counsel 11250 Waples Mill Raod Farfax, VA 22030

RE MUR 4292 NRA Political Victorv Fund and Mar%Rose Jennsion, Treasurer

Dear Mr Cunnineham

On Januar%22. 1996. the Federal Election Commission notified your clients, NRA Political Victor%Fund. and Man Ross Jennsion. as treasurer. of a complaint alleging certain %iolat Pons of the Federal Election Campaign Act of 1971. as amended. A copy of the complaint %%asenclosed with that notificaaion

4C) After considering the circumstances of this matter. the Commission has determined to -r \ercise its prosecutonal discretion and to take no action against your clients. See attached narratie Accordinul.. the Commission closed its file in this matter on September 3, 1996.

The confidentialit%pro% isions o1"2 U S C . 4371gas 12no longer apply and this maner i. no%% public In addition. although the complete file must be placed on the public record %ithin 30O da . this could occur at an% time followine certification of the Commission's vote. C ltifou 'wish o, submit an% factual or legal materials to appear on the public record, please do so a, .oon a,, o ,ible While the file ma be. placed on the public record prior to receipt of your additional maicrtals. an%permissible submisions %%illbe added to the public record when rcccl%ed

1f' ou ha, c an\ questions. please contact Al a F Smith at (202) 219-3400

Sincrrel-

Colleen T Sealander. Atome\ Central Fnforcement Docket

- m in 3rT T3,11 MUR 4292 CONGRESSMAN RON PACKARD

Mary Lou Clift filed a complaint alleging that the National Rifle Association ("NRA") failed tu disclose contnbutions made on behalf of Congressman Ron Packard She alleges that the NRA made contributions to Ron Packard by sending "mailings" to individuals on his behalf This complaint is based on an article which indicates that the NRA was fined for failure to disclose or tardiness in disclosing contributions to California state candidates

In respor.se. the NRA states that at this time it is unable to supply the Commission %%Itha reasoned response other than to den%an% violation It points out that no time period is set forth b%the complainant and complainant has not specified any particular act The NRA states that all of its past suppon for Congressman Packard has been reported to the Commission and that at no time has the NRA Political Victory Fund made an% conlTibution to. or expenditure on behalf of. Congressman Packard which would be prohibited under the FECA

Inresponse. Congressman Packard states that he has never seen the leter allevedl% endorsing him He states that the lener %%asnot sent with his cooperation, or moith his pnor consent, or in consultation with him or at the request or suggestion of himself, his aLents. or his campaigln committee. nor vas the endorsement solicited or applied for h% him

Ther-C is no indication that the acti, it%had a significant impact on the process and thcr : .,no indicaton of an% scnou, intent to \iolate the FECA This maner is less ,icnificant rclaitie to other matters ending before the Commission ~-

FEDERAL ELECTION COMMISSION

SEP 0 6 1996 The Honorable Ronald C Packard U.S House of Representati es 2162 Rayburn House Office Building Washington, D C 205 15

RE MUR 4292

Dear Represntatje Packard

On Januar' 22. 1996. the Federal Election Commission notified you of a complaint alleging certain Violations of the Federal Election Campaign Act of 1971. as amended. A cop. of the complaint was enclosed with that notification

After considenng the circumstances of this maner. the Commission has determined to exercise its prosecutonal discretion and to take no action against you. See attached narrative. Accordinel%. the Commission closed its file in this matter on September 3. 1996

The confidentialr'. provisions of 2 US C § 437Sg(aX 12) no longer apply and this mailer is no%% public In addition, although the complete file must be placed on the public record %ithirn 30 da%s. this could occur at any time following certification of the Commission's vote. If ou %%ishto submit an% factual or legal materials to appear on the public record, please do so a' soon as possible While the file ma% be placed on the public record prior to receipt of your additional materials, an% permissible submissions %%illbe added to the public record when "-7 receied

lfou ha'c an% quctions. pleas contact AlIa E Smith at (202) 219-3400

Sinc-rel --

/ollecnT Sealander. Atiome\

Central Enforcement Docket

V\ ac ht ni \jr "ill \.-, MUR 4292 CONGRESSIAN RON PACKARD

Mary Lou Clift filed a complaint alleging that the National Rifle Association ("'NRA") failed to disclose contributions made on behalf of Congressman Ron Packard She alleges that the NRA made contnbutions to Ron Packard by sending "mailings" to indiiduals on his behalf This complaint is based on an article which indicates that the NRA was fined for failure to disclose or tardiness in disclosing contributions to California state candidates

In response. the NRA states that it this time it is unable to supply the Commission %,itha reasoned response other than to den% an% ,iolaton It points out that no lime peinod is set forth by the complair.ant and complainant has not specified any particular act The NRA states that all of its past support for Congressman Packard has been reported to the Commission and that a: no time has the NRA Political Victory Fund made an% contribution to. or expenditure on behalf of. Congressman Packard which would be prohibited under the FECA

In response. Congressman Packard states that he has never seen the letter alleedl' endorsine him fie states that the letter vas not sent '%ith his cooperation, or with his pnor consent, or in consultation with him or at the request or suggestion of himself, his agents. or his campaign committec. nor %%as the endorsement solicited or applied for b%, him

There isno indication that the acti%it had a significant impact on the process and thvr i,.no indication of an\ serous intent to -,iolai the FECA This matter is less s Lnficant relat .to other matters pcnding before the Commission FEDERAL ELECTION COMMISSION , SEP 0 6 196

William L. Hardy, Treasurer Friends of Ron Packard PO Box 1549 Carlesbad. CA 92018

RE MUR 4292

Dear Mr Hardy

On Januan 22, 1996, the Federal Election Commission notified you of a complaint alleging certain %tolationsof the Federal Election Campaign Act of 1971. as amended A cop_ of the complaint -as enclosed i%%ith that notification

Afier considenng the circumstances of this matter. the Commission has determined to cwrcise its prosecutonal discretion and to take no action against Friends of Ron Packard and \ou. as treasurer See attached narratie Accordingi\. the Commission closed its file in this matter on September 3. 1996

[he confidentiali. pro%isions of? 1: SC 437iqa X1-2) no longer apply and this matter i,. no%% public In addition. although the complete file must be placed on the public record \%ithin 30( da s. this could occur at an\ time following certification of the Commission's vote. It \ ou %-.ish to submit an\ factual or legal materials to appear on the public record, please do so as soon as possible While the file ma, he placed on the public record prior to receipt of your additional material. an\ permissible submi,,,ions \%ill he added to the public record \%hen rcccix cdi

It \ou ha'c an\ questions. please contact Al~a E Smith at (202O 19-3400

Sin~re l\

Colleen T Sealander. Artorne, (cniral Fnforceren )ocket

.\ ilwah mc ni \Jrrat\ t: MUR 4292 CONGRESSMAN RON PACKARD

Mary Lou Clift filed a complaint alleging that the National Rifle Association ("NRA'") failed to disclose contributions made on behalf of Cong,'essman Ron Packard. She alleges that the NRA made contributions to Ron Packard by sending -mailings" to indr'iduals on his behalf This complaint is based on an article which indicates that the NRA %%as fined for failure to disclose or tardiness in disclosing contributions to California state candidates

In response, the NRA states that at this time itis unable to supply the. Commission vith a reasoned response other than to den% an% iolation Itpoints out that no time p-riod is set forth by the complainant and complainant has not specified any particular act The NRA states that all of its past support fo, Congressman Packard has been reported to the Commission and that at no time has the NRA Political Victory Fund made an,, contribution to. or expenditure on behalf of. Conilressman Packard which would be prohibited under the FECA

In response. Congressman Packard states that he has never seen the letter alleeedl' endorsing him He state, that the le tier vas not sent w'ith his cooperation, or %lth his prior consent. or in consultation w'ath him or at the request or suggestion of him,,clf. hi% avecnt. or his campaign committee, nor 4as the endorsement solicited or applied for b' him

Thre i,no indication that the actis it%had a significant impact on the process and th.rc. i,,no indication of an% s-eriou,, intent to tolai, the FECA This matter is less ,.nifcjni relai; . to other matters p'nding before the Commission - w w

FEDERAL ELECTION COMMISSION WASHICTON, D C 2463

TH ISISTHE END F MJR # _ I__A

DATE FILED & - CAM~ERA ND. s - 41? 4L