CREW’S TOP TEN ETHICS SCANDALS 2010

1400 EYE STREET NW, SUITE 450 WASHINGTON DC 20005 www.citizensforethics.org CREW’S TOP TEN SCANDALS OF 2010 Laugh ‘Til It Hurts Tickle fights are no laughing matter when they involve a congressman and his staff. Rep. Eric Massa (D-NY) resigned from Congress on March 8, 2010, following allegations of sexual harassment and bizarre behavior. His ever-shifting reasons for stepping down included his resurgent cancer, the toxic atmosphere of Washington, a pending ethics investigation, and, most colorfully, threats from a naked .1 The laundry list of allegations against him paint a picture of a lawmaker out of control, whose crude comments and unpredictable actions had his staff on edge for almost a year.2 Rep. Massa, who lived with some of his staffers, was accused of a host of potential violations of House ethics rules, including groping staff members and using inappropriate language in his office.3 But it wasn’t until an anonymous online comment accused Rep. Massa of soliciting sex from a bartender that Rep. Massa’s staff contacted the office of House Majority Leader about the congressman’s behavior.4 When told about the allegations the week of February 8, 2010, Rep. Hoyer gave Rep. Massa and his staff 48 hours to report the matter to the ethics committee or he would do so himself.5 The ethics committee publicly confirmed the investigation into Rep. Massa on March 4, and the congressman announced his resignation on March 5.6 After Rep. Massa’s resignation, Republicans pushed for an investigation into when House Democratic leaders first learned of the allegations against Rep. Massa and whether they acted appropriately.7 The full House recommended the ethics committee continue its investigation into the allegations of misconduct, despite Rep. Massa’s resignation.8 On April 21, 2010, the ethics committee described the allegations against Rep. Massa as “serious,” and said it would look into the conduct of other House members and staff in the matter.9 Meanwhile, in the three days between his resignation announcement and actual departure, Rep. Massa’s campaign paid his chief of staff $40,000 and spent $32,000 to renew a lease on a car, prompting a separate federal investigation.10 Both investigations appear ongoing.

1 David Saltonstall and Michael McAuliff, Departing Rep. Eric Massa Goes Down Swinging: Rahm Emanuel Threatened Me – In the Nude!, Daily News, March 8, 2010; John Bresnahan, Hoyer Knew of Massa Allegations, Politico, March 3, 2010; John Bresnahan and Glenn Thrush, Rep. Eric Massa to Resign, Politico, March 5, 2010. 2 Carol D. Leonnig, Staffers’ Accounts Paint More Detailed, Troubling Picture of Massa’s Office, The Washington Post, April 13, 2010. 3 Jonathan Allen, Massa Aide Opens Door to Lawsuit, Politico, April 13, 2010. 4 Leonnig, The Washington Post, Apr. 13, 2010. 5 Id.; Bresnahan, Politico, Mar. 3, 2010. 6 Press Release, House Committee on Standards of Official Conduct, 111th Congress, Statement of the Chair and Ranking Republican Member of the Committee on Standards of Official Conduct Regarding the Investigation of Allegations Involving Representative Eric Massa, March 4, 2010; David M. Halbfinger and Raymond Hernandez, Congressman Accused of Harassment Resigns, The New York Times, March 5, 2010. 7 Leonnig, The Washington Post, Apr. 13, 2010. 8 John Bresnahan and Jonathan Allen, House Keeps Massa Probe Open, Politico, March 11, 2010. 9 Press Release, House Committee on Standards of Official Conduct, 111th Congress, Statement of the Chair and Ranking Republican Member of the Committee on Standards of Official Conduct, April 21, 2010. 10 Carol D. Leonnig, Payments by Former Congressman Massa Investigated, The Washington Post, April 22, 2010.

Sins of the Senator Apparently, Sen. David Vitter’s (R-LA) prostitution scandal made him a little more forgiving of others’ misdeeds. At least, that’s one possible explanation for why Sen. Vitter kept on an aide accused of assaulting his girlfriend, and even used public money to pay the staffer’s travel expenses when he returned to Louisiana for two court dates in a DWI case. Other possibilities are less benign. Brent Furer, a legislative assistant who handled women’s issues, among other topics, was arrested in January 2008 for attacking his ex-girlfriend with a knife after he held the woman against her will, cut her, and threatened to kill her.11 Although Sen. Vitter’s office said the senator took “significant disciplinary action” against Mr. Furer after the arrest, records show Mr. Furer’s pay was suspended for only five days.12 Mr. Furer’s assault arrest was the most recent in a long criminal record, including at least three arrests for driving under the influence and one for cocaine possession.13 Taxpayers footed the bill for Mr. Furer to travel to Louisiana on two separate occasions – dates that coincided with scheduled court appearances for drunk driving charges.14 Sen. Vitter’s spokesman said the senator was unaware of the DWI arrest until it was reported publicly and it was standard procedure for staff to attend meetings in Louisiana.15 Mr. Furer finally resigned in June 2010, days after CREW and ABC News publicly revealed his assault charge and criminal record.16 Voters overlooked the scandal and elected Sen. Vitter to a second term in November. Ready, Fire, Aim! The carefully edited video posted by conservative blogger Andrew Breitbart made USDA official Shirley Sherrod look like a racist.17 Ms. Sherrod, who is black, seemed to say she had failed to help a white couple save their farm because of race.18 Within hours after the video was posted, she was pilloried by everyone from the NAACP to commentator Bill O’Reilly, and her bosses pressured her to resign.19 Just as quickly, though, the news cycle turned around. The full video surfaced, making it clear Ms. Sherrod had been telling an anecdote about overcoming her own prejudice. The couple in the story said they counted Ms. Sherrod as a good friend.20 Agriculture Secretary Tom Vilsack offered to resign, and held a press conference to apologize to Ms. Sherrod and offer her a new

11 Matthew Mosk and Brian Ross, Vitter Aide Resigns After ABC News Disclosures About Past, ABC News, June 23, 2010. 12 Id. 13 Id. 14 Marsha Shuler, Records Link Aide’s La. Trips, DWI Case, 2TheAdvocate.com, August 19, 2010. 15 Id. 16 Mosk and Ross, ABC News, June 23, 2010. 17 Karen Tumulty and Krissah Thompson, Firing of USDA Official Shirley Sherrod Now Under Review, The Washington Post, July 21, 2010. 18 Id. 19 Howard Kurtz, Finger-pointing at Fox in Shirley Sherrod Firing, The Washington Post, July 22, 2010; Tumulty and Thompson, The Washington Post, July 21, 2010. 20 Tumulty and Thompson, The Washington Post, July 21, 2010.

2 job with the department.21 President Obama, meanwhile, apologized through his spokesman, and personally called Ms. Sherrod.22 Nevertheless, she declined the position.23 Greasy Palms The explosion of BP’s Deepwater Horizon also blew up the too-cozy relationship between the Minerals Management Service (MMS) and the energy companies it regulated. The problems with MMS were deep and longstanding. The agency had a built-in conflict of interest: it collected billions of dollars in royalties from the same companies it was responsible for policing.24 In November 2008, a former regional supervisor for MMS pleaded guilty to failing to report gifts from oil companies. An Interior Department investigation into the agency’s Lake Charles, Louisiana office, released shortly after the oil spill, found “that a culture of accepting gifts from oil and gas companies was prevalent” throughout the district office.25 The Interior Department report revealed a deep network of relationships between industry and government personnel, including long friendships. Larry Williamson, the Lake Charles district manager for the agency, went so far as to tell investigators, “Obviously, we’re all oil industry.”26 The report also found workers using illegal drugs, and hundreds of instances of employees circulating pornography on work computers. In one case, an MMS inspector conducted four inspections of a company’s oil platforms while discussing a job with the same company. As oil spilled into the Gulf of Mexico, the Obama administration dissolved MMS and replaced it with three separate regulatory agencies, dividing up enforcement, energy development and revenue collection.27 A December 2010 Interior Department report on the Bureau of Ocean Energy Management, Regulation and Enforcement, the agency now responsible for regulating the safety of offshore drilling, found continued problems with staffing, training, and pressure from the oil industry, though the report noted that the agency has already begun addressing many of its recommendations.28 As the spill recedes from public view, let’s hope regulators remember their job is to police oil companies. Junk Dealer Georgia voters overlooked an impressive array of red flags in choosing former Rep. Nathan Deal (R-GA) as their next governor: a federal probe, ethics investigations, and murky personal

21 Sheryl Gay Stolberg, Shaila Dewan and Brian Stelter, For Fired Agriculture Official, Flurry of Apologies and Job Offer, The New York Times, July 22, 2010; Roger Simon, Tom Vilsack Offered to Resign Over Shirley Sherrod, Politico, August 25, 2010. 22 Jake Tapper, Huma Khan and Karen Travers, President Obama Speaks Via Phone With Shirley Sherrod, ABC News, July 22, 2010. 23 Mary Clare Jalonick, Ousted Worker Sherrod Rejects Return to Ag Agency, Associated Press, August 24, 2010. 24 Patrik Jonsson, Obama to Sever Ties Between Drilling Cops and Big Oil, The Christian Science Monitor, May 11, 2010. 25 U.S. Department of the Interior, Office of Inspector General, Report of Investigation – Island Operating Company et al, Case No. PI-GA-09-0102-I, March 31, 2010. 26 Id. 27 Ken Salazar, Secretary of the Interior, Order No. 3299, May 19, 2010. 28 U.S. Department of the Interior, Office of Inspector General, A New Horizon: Looking to the Future of the Bureau of Ocean Energy Management, Regulation and Enforcement, Report No. CR-EV-MMS-0015-2010, December 2010.

3 finances.29 Rep. Deal resigned from Congress on March 21, 2010, ostensibly to concentrate on his gubernatorial bid but just before the House ethics committee’s deadline to act in his case.30 The quasi-independent Office of Congressional Ethics (OCE) made its report on Rep. Deal public anyway, and it wasn’t flattering.31 OCE found Rep. Deal appeared to have improperly used his position as a member of Congress, as well as House resources, to preserve a state vehicle inspection program that financially benefitted him and his business partner.32 Rep. Deal also omitted his role as a corporate officer of the company from his financial disclosure forms in 2008, and the $75,000 he earned from the position was a violation of House rules limiting outside income.33 Since Rep. Deal left Congress, new information about his finances reveals he has more than $5 million in outstanding debt and faces possible bankruptcy.34 He initially failed to disclose his debt in pre-election financial disclosure forms, the subject of a complaint filed with the Georgia State Ethics Commission. He amended the forms only after the debt was reported in the press.35 Another state ethics complaint questions expenditures of more than $135,000 in campaign funds on airplane and helicopter flights through a company he co-owns. The company, North Georgia Aviation, leases aircraft from two companies managed by his congressional chief of staff, Chris Riley, and headquartered at Mr. Riley’s home address.36 Despite Rep. Deal’s litany of ethics issues, he won the governorship of Georgia with 52.9% of the vote.37 Scandalous Scholarships When Rep. Eddie Bernice Johnson (D-TX) explained why she ignored anti-nepotism rules and doled out thousands of dollars in Congressional Black Caucus Foundation (CBCF) scholarships to her relatives and the children of a staff member, she made it sound as if she had almost no choice.38 There were not enough “very worthy applicants” in her district, she explained - even though the only academic criterion for the scholarship was a 2.5-grade-point average. The congresswoman denied knowingly violating the rules, despite having previously served on the CBCF board, and claimed scholarship decisions were made by her aides.39 Undermining Rep. Johnson’s protestations of innocence were two letters she signed asking the CBCF to issue

29 Jeremy Redmon, Georgia Election: Deal Defeats Barnes to Take Governor’s Mansion, The Atlanta Journal- Constitution, November 3, 2010. 30 Eric Lipton, Ethics Report Faults Ex-Congressman, The New York Times, March 29, 2010. 31 Office of Congressional Ethics, 111th Congress, Report and Findings Related to Rep. Nathan Deal, Review No. 09-1022, February 5, 2010. 32 Id. 33 Id. 34 Alan Judd, Deal Could Face Financial Insolvency After Backing Family Business, The Atlanta Journal- Constitution, September 15, 2010; Shannon McCaffrey, Report: Nathan Deal Didn’t Disclose Loans to Ethics Panel, Blames ‘Oversight’, Associated Press, September 16, 2010. 35 Aaron Gould Sheinin, Deal Responds to Ethics Complaint Over Debt, Aircraft Use, The Atlanta Journal- Constitution, November 2, 2010. 36 Id.; Aaron Gould Sheinin, Campaign Paid $135K to Lease Aircraft from Company Nathan Deal Co-Owns, The Atlanta Journal-Constitution, September 27, 2010. 37 http://elections.nytimes.com/2010/results/governor. 38 Todd Gillman and Christy Hoppe, Rep. Eddie Bernice Johnson Violated Rules by Steering Black Caucus Foundation Scholarships to Relatives, The Dallas Morning News, August 29, 2010. 39 Id.

4 scholarship checks directly to her grandchildren and great-nephews rather than to the colleges they were attending, which would have violated the foundation’s policy.40 Following public outcry, Rep. Johnson repaid the foundation $31,000.41 The scandal prompted Rep. Donald Payne (D-NJ), chair of the CBCF, to launch an “extensive audit of the scholarship program.”42 The audit is much needed: Rep. Johnson wasn’t the only one handing out scholarships to loved ones. Rep. Sanford Bishop (D-GA) awarded CBCF scholarships to relatives and other recipients with connections to him and his wife.43 Rep. Bishop’s staff argued the anti-nepotism rules were not in place when he awarded the scholarships to relatives, and therefore, no rules were broken.44 Nevertheless, the congressman repaid the CBCF for at least some of the scholarships.45 Dumb and Dumber Some stunts work better than others. On January 25, 2010, conservative filmmaker-activist James O’Keefe and three other men were arrested for tampering with the telephones at Sen. Mary Landrieu’s (D-LA) district office in while passing as telephone company employees.46 Mr. O’Keefe said he was trying to record embarrassing video of Sen. Landrieu’s staff ignoring calls from constituents.47 It wasn’t his first undercover sting. Mr. O’Keefe rose to prominence last year by posing as a pimp, and recording video of ACORN employees appearing to offer advice on tax evasion and prostitution.48 Soon afterwards, Congress voted to cut federal funding for ACORN, and the group eventually shut down.49 At Sen. Landrieu’s office, two of Mr. O’Keefe’s partners – including the son of an acting U.S. attorney – dressed as telephone company employees and gained access to the senator’s office by telling a staff member they were there to fix a problem with the phones.50 Meanwhile, Mr. O’Keefe filmed the encounter using a cell phone camera.51 A fourth accomplice waited with a listening device in a nearby car.52 The four men were arrested after they were unable to provide proper credentials.53 Mr. O’Keefe later said in a statement that the “sole intent of our

40 Todd Gillman and Christy Hoppe, Letters Suggest Dallas Lawmaker had Direct Role in Scholarships for Relatives, The Dallas Morning News, September 8, 2010. 41 Todd Gillman, Johnson Reimburses Black Caucus Foundation for Scholarships Given to Her Relatives, Aide’s Kids, The Dallas Morning News, September 2, 2010. 42 Press Release, Congressman Donald M. Payne, Chairman, Congressional Black Caucus Foundation, Statement on CBCF Scholarship Programs, August 31, 2010. 43 John Bresnahan, Sanford Bishop Steered Scholarships to Family, Politico, September 9, 2010. 44 Id. 45 John Bresnahan, Bishop to Repay Scholarship Money, Politico, September 10, 2010. 46 v. Robert Flanagan, et al, 2:10-mj-00012-LM, Affidavit of Steven Rayes in support of the Criminal Complaint (E.D. La. 2010). 47 Michael Kunzelman and Brett Blackledge, Lawyer: Phone Scheme Meant to Embarrass Senator, Associated Press, January 28, 2010. 48 Darryl Fears and Carol D. Leonnig, The $1,300 Mission to Fell ACORN, The Washington Post, September 18, 2009; http://www.youtube.com/watch?v=LtTnizEnC1U&feature=player_embedded. 49 Congress Votes to Strip ACORN of Federal Funding, Fox News, September 17, 2009; ACORN to Shut Down in Wake of Scandal, Fox News, March 23, 2010. 50 David Hammer, ACORN ‘Gotcha’ Man Arrested in Attempt to Tamper With Mary Landrieu’s Office Phones, The Times-Picayune, January 26, 2010; United States v. Robert Flanagan, et al, Affidavit of Steven Rayes. 51 Id. 52 Hammer, The Times-Picayune, Jan. 26, 2010. 53 Id.

5 investigation was to determine whether or not Sen. Landrieu was purposely trying to avoid constituents who were calling to register their views,” and admitted he “could have used a different approach.”54 Mr. O’Keefe and his three partners were originally charged with entering federal property under false pretenses for the purpose of committing a felony.55 The four pleaded guilty in May to the lesser charge of entering real property of the United States under false pretenses.56 While trying to embarrass Sen. Landrieu, they embarrassed themselves. Pay to Play, and Get Away On September 24, 2010, Paul Magliocchetti, founder of lobbying firm PMA Group, pleaded guilty to making false statements, making illegal conduit campaign contributions, and making illegal corporate campaign contributions.57 The Office of Congressional Ethics (OCE), which investigated whether PMA Group lobbyists traded campaign contributions for earmarks from defense appropriators, found evidence that “certain persons and companies saw their campaign donations as affecting decisions about earmarks.”58 On February 26, 2010, the House ethics committee cleared seven lawmakers – all of whom had accepted donations from Mr. Magliocchetti and his associates – of wrongdoing, even though OCE thought at least two lawmakers, Reps. Pete Visclosky (D-IN) and Todd Tiahrt (R-KS), deserved further scrutiny.59 In May, after the ethics committee closed its investigation, OCE referred the matter to the Department of Justice (DOJ).60 Thus far, all of the lawmakers who accepted Mr. Magliocchetti’s money have gone unpunished. Mr. Magliocchetti’s plea agreement with DOJ included a highly unusual waiver of his rights under the Freedom of Information Act (FOIA) and the Privacy Act.61 He’s also not required to cooperate further with the government.62 These provisions suggest DOJ may not want the public to learn about Mr. Magliocchetti’s relationships with members of Congress. As a result, CREW has filed FOIA requests with DOJ’s criminal division and Executive Office of U.S. Attorneys for documents related to the Magliocchetti case.63 The department has refused to provide the requested records and CREW is continuing to press its case. 64

54 Carol D. Leonnig, Conservative Activist Admits to Plot in Landrieu’s Office, The Washington Post, January 30, 2010. 55 United States v. Robert Flanagan, et al, Affidavit of Steven Rayes. 56 Campbell Robertson, Guilty Pleas in Landrieu Incident, The New York Times, May 26, 2010. 57 United States v. Paul Magliocchetti, 1:10-cr-00286-TSE, Plea Agreement (E.D. Va. 2010); John Bresnahan, Ex- PMA Lobbyist Pleads Guilty, Politico, September 24, 2010. 58 Press Release, Office of Congressional Ethics, 111th Congress, Statement of the Office of Congressional Ethics Regarding Evidence Collected in OCE’s PMA Investigation, May 27, 2010. 59 Roxana Tiron, Ethics Clears Seven Lawmakers in Probe of PMA Group, The Hill, February 26, 2010; House Committee on Standards of Official Conduct, 111th Congress, In the Matter of Allegations Relating to the Lobbying Activities of Paul Magliocchetti and Associates Group, Inc. (PMA), February 26, 2010. 60 Press Release, Office of Congressional Ethics, May 27, 2010. 61 United States v. Paul Magliocchetti, Plea Agreement. 62 Id. 63 http://www.citizensforethics.org/node/45737. 64 http://www.citizensforethics.org/node/45737.

6 Say it Ain’t So, Jo(hn) The Office of Congressional Ethics (OCE) has come under attack for living up to its mandate by investigating House members’ misconduct. Some members of Congress are pushing to shut down or gut the ethics office, which would return the House to the dark days of the ethics truce, when even outrageous misconduct went unchallenged. Members of the Congressional Black Caucus (CBC) have been some of the OCE’s most outspoken critics, and have voiced concerns about the OCE’s investigations into several African- American members.65 Many CBC members supported a resolution proposed in May 2010 by Rep. Marcia Fudge (D-OH) intended to eviscerate the OCE.66 The CBC is not alone in its criticism. Speaker-elect John Boehner (R-OH) fought and voted against the OCE’s creation, saying “we don’t need a new layer of bureaucracy to stand between those who break the rules and those who must enforce them.”67 Rep. Boehner has since suggested he might dismantle the office, despite its strong track record, though in December 2010, a spokesman for Rep. Boehner said no final decision had been made, and some Republican lawmakers said the OCE seemed likely to survive.68 If the OCE is eliminated, the House ethics committee will once again be the sole enforcer of House rules. Despite the recent high-profile censure of Rep. Charlie Rangel (D-NY), the committee rarely is moved to act. The OCE, on the other hand, has so far used its limited powers to refer 21 cases to the committee for further review.69 According to OCE Communications Director Jon Steinman, “Before there were maybe one or two published ethics reports every decade, and we’ve published twelve” so far this Congress.70 Hopefully, the OCE’s commitment to enforcing ethical standards won’t turn out to be a capital offense. Magic Money Delaware Republican Senate candidate Christine O’Donnell spent the 2010 campaign responding to nearly endless questions about her integrity, including allegations she had treated her campaign account like her personal piggy bank.71 Her former campaign manager, David Keegan, provided a sworn affidavit stating that in 2009, Ms. O’Donnell had used campaign donations for rent, meals and gas, and even a bowling outing.72 Nevertheless, on Federal Election Commission (FEC) forms, she mischaracterized those rent payments as “expense reimbursements.”73 In 2010, Ms. O'Donnell acknowledged paying half her rent with campaign money, but justified those payments by claiming her townhouse was also her campaign

65 Susan Crabtree, Watchdog Comes Back to Bite Democrats, The Hill, October 13, 2009. 66 Jay Bookman, Black Caucus Wants to Gut Key Ethics Reform, The Atlanta Journal-Constitution, June 4, 2010. 67 Id. 68 Jennifer Yachnin, Castle, Platts Propose Tougher Ethics Measures, Roll Call, August 11, 2010; Susan Crabtree, Watchdogs Team Up With Tea Party to Defend Ethics Office From Calls to Close, The Hill, December 2, 2010; Ben Pershing, Despite Critics, Hill Ethics Office Likely to Survive, The Washington Post, December 6, 2010. 69 http://oce.house.gov/reports.html. 70 Sherisse Pham, Are GOP Leaders Quietly Trying to Axe Office of Congressional Ethics?, ABC News, November 17, 2010. 71 Ginger Gibson, Senate Primary Hinges on Character, The News Journal (Wilmington), September 11, 2010. 72 Federal Election Commission, Complaint: MUR No. 6380, Affidavit of David C. Keegan, September 20, 2010. 73 Friends of Christine O’Donnell 08, FEC Form 3, April Quarterly Report 2009, April 21, 2009, p. 20.

7 headquarters.74 In addition, the FEC cited her on multiple occasions between 2008 and 2009 for failure to report campaign contributions.75 CREW filed complaints against Ms. O’Donnell with the FEC and is calling for a Delaware U.S. Attorney’s office investigation into whether Ms. O’Donnell committed criminal campaign finance law violations.76 Ms. O’Donnell’s personal finances are equally disastrous. Records show Ms. O'Donnell has no steady income and earned only $5,800 between March 2009 and July 2010.77 The IRS filed a lien against her in March 2010, citing more than $11,000 in unpaid income taxes and fees.78 Though she called the lien “questionable” and blamed technical errors, she has since paid an undisclosed amount to settle the matter.79 In 2008, Ms. O’Donnell was sued by her mortgage company for failing to make payments.80 While the house was in foreclosure, she sold it to her then-boyfriend and campaign staffer, Brent Vasher. She said she sold the house in order to run for office and claimed she was unaware of the lawsuit and had not received a notice of foreclosure.81

Ms. O’Donnell’s educational background also is irregular. During her 2006 and 2008 Senate campaigns, she claimed to have a Bachelor of Arts degree from Fairleigh Dickinson University (which sued her in 1994 over $4,823 in unpaid student loans).82 The debt was settled in 2003 and Ms. O’Donnell received a degree from the university in 2010 after completing additional coursework.83

Ms. O’Donnell, who won the primary with 53% of the vote but lost the general election by 16.6 points, spun her financial troubles as a key part of her appeal.84 “I think the fact that I have struggled financially is what makes me so sympathetic,” she said during the primary campaign.85 General election voters didn’t agree.

74 Ginger Gibson, O’Donnell Faces Campaign Debt, Back-Tax Issues, The News Journal (Wilmington), March 21, 2010. 75 Federal Election Commission to Friends of Christine O’Donnell, Notice of Failure to File, August 29, 2008; FEC to O’Donnell, Notice of Failure to File, July 31, 2009; FEC to O’Donnell, Notice of Failure to File, October 30, 2009. 76 Federal Election Commission, Complaint: MUR No. 6380, September 20, 2010; Letter from CREW Executive Director Melanie Sloan to Delaware U.S. Attorney David C. Weiss, September 20, 2010. 77 Russell Goldman, Checkered Financial Past Dogs Tea Party’s Christine O’Donnell in Senate Bid, ABC News, September 15, 2010. 78 Gibson, The News Journal (Wilmington), Mar. 21, 2010. 79 Gibson, The News Journal (Wilmington), Sept. 11, 2010. 80 Gibson, The News Journal (Wilmington), Mar. 21, 2010. 81 Id. 82 Id.; David Catanese, 17 Years Later, O’Donnell Earns Degree, Politico, September 3, 2010. 83 Id. 84 http://elections.nytimes.com/2010/results/primaries/delaware; http://elections.nytimes.com/2010/results/delaware. 85 Gibson, The News Journal (Wilmington), Mar. 21, 2010.

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