THIS IS T Beg1nning of MR

0. 9

FEDERAL ELECTION COMMISSION

A%A S " %41 T A)% D)C I(4.

THIS IS T BEG1nning OF MR #

!ATE FI LWED J.CAW-RA NO.

CAMERAMAN Eym . Waach 300 South Pou17S&&*At. Site 17W. LAS V4 Nevada 89101

October 28, 1992

a, VA CERTIFIED MAIL

Mr. Lawrence Noble Office of the General Counsel Federal Election Commission 999 E Street, N.W. Washington, D.C. 20463 Dear Mr. Noble: CN I am writing this letter as a formal complaint to the FEC regarding the enclosed document, which was mailed to Nevada voters under United States Postal Service Bulk Mail Permit No. 517. As you can see, the document represents an apparent independent expenditure against United States Senator Harry Reid, who is currently campaigning for reelection. The document is deficient under FEC regulations because it fails, pursuant to 11 CFR §110.11 (i1), to "...clearly state that the communication has been paid for by [an identified person not connected with a registered committee]", or to identify the person or persons. In addition, I believe the mailer, which was received in the United States mail this date, represents a violation of 11 CFR 109.2(b) since it appears to represent what may be an expenditure in excess of $1000, and I can find no record that expenditure has been reported to the FEC within 24 hours. I have, this date, filed a Freedom of Information Act request with the United States Postal Service to identify the holder of Bulk Mail Permit No. 517. When that information is received I will supplement this complaint. I request, however, that the FEC not wait to take action but that it attempt to determine: Mr. Lawrence Noble October 28, 1992 Page 2

1. The identity of the person or persons holding Bulk Magi Permit No. 517; 2. The identity of the person or persons who paid for the production and/or mailing of the enclosed document; and 3. Whether that person or persons complied with the 24 hour reporting requirements for pieces mailed less than 20 days before a federal election. It may assist you in your investigation to know that one of

- the individuals listed in the list of persons in the enclosed sailer itself (but not listed as a person who paid for the mailer) * is Lucille Lusk, a former Republican candidate for the United States House of Representatives, and a present or former official of the Republican Party in Nevada. I believe that if Ms. Lusk was involved in the production, distribution or planning of the enclosed document, as a matter of law her involvement represents actual or imputed participation by the Republican Party of Nevada and may constitute a further violation by the Republican Party. I also believe that, given Ms. Lusk's prior involvement in federal election campaigns, if she participated in such activity, any violation represented herein would have had to be knowing and willful.

C Further evidence of knowing and willful violations of the law would be indicated if, as I believe, the Layne Rushforth listed in * the enclosed document is indeed the Layne T. Rushforth who is a member of the State Bar of Nevada, and who would presumably be familiar with the law governing such conduct. I would appreciate it if you would take whatever action you can to immediately pursue all available remedies to the fullest extent of the law. If I may provide any further information or be of any assistance in your investigation, please do not hesitate to contact me. Mr. Lawrence Noble October 28, 1992 Page 3

Would you be so kind as to send me a file-stamped copy of this complaint, with its MUR number, after it has been filed. Sincerely,

Evan J. Wallach

STATE OF NEVADA ) ss: COUNTY OF CLARK ) Evan Wallach, being first duly sworn, deposes and states that: 1. The above stated facts are made by him of his own personal knowledge, except for those matters stated upon information and belief, which he well and truly believes; and 2. That he is personally aware that the above-stated Complaint is made under penalty of perjury, and subject to the provisions of Section 1001 of Title 18, United States Code.

Evan J. Wad4ach

Subscribed and sworn to before me this 28th day of October, 1992.

"-ARY P~UB

NOTARY PUBLIC STATE OF NE VADA Counity of Clark BRETT SEARS al111111AIN~f 'uNM Ir. Rdjpo Inside ... A sampling of Harry's public record shows Wi-)USPA AJPOOM J3uhM RUl k3~m. U3VJ Why I Am NOT Supporting 4'DL au2lnff

u!nopag UUAk ilo Harry Reid ... uLIn 1. P"io 11)168 AN 'SI'A s.l qIJOASONtVOJIaqS OOLI#IS qat S (XK quo)ROV =A Ural pol

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khmle Caer Anna Marie Rovison Carol Paul Shelley Whittle Gary Ekis BE Rook Lou Ipso De" Anderson Jeff Whittle Linda Ekina Dianne Anderson DeCall Thomas Tim Fichtcr Offim We* am Dmw W hm Knrtia Hawn Betty Tyree Joe Jolley MON .Han Lionel Tyree Paul Clarke Backy Mo Joseph Thirko Dixie Clarke Dr. iMsta W Cl- IkI om ch~k So"t Raymond S. llertn Jim Turner Liab Smith Caroline Ouhler LARene Turner DeeHorne Darrel Oubler Leland Pace Kendel Jm Raesd Haao d Doa Baphaw Adele Dodge JoAnn Pace BSl L Smt Waen ShNpe BSvw C An Smith Bob LAmb DeVonme Meldon DJge Dennis Dni Dalton Tryn Paxton Fotherinlghm B. RVth Md1Ma OBatera Dalton Robert Paxton Rick Bailey Barry Ford Deanna Bryant Jean Cornwall Liy Robb Gene Bryant Mike Halvermon Joey Patns Gemp Md~es 3 een K(athy Robb Grace Cox Sandra Halverson V1 Owen Cox Danny lagrig Vickdn MeDavlet Pat Iowc Durel Lee Jim Muster Jack Lowe Grant Farrar Maspre Mhmtr Sandra Taylor Danielle Farm Owy Hdlmme LAaMBria Barneyawne Lavier Taylor Robert Baphlaw Vhwm sow Patricia Wilson Myrna -~b Kelly Thmar Barbie Banda Tye Halveron Greps 0. Bshait JoAn aney Lmeef Pedersn ie ThamaU Louie Banda Becky Halvermon Jann -N Craig Jame. Mary Lou io-" Bresds Govr Kristie Jensen Psed 6w byametnmd omwm Dr. Ge=al W. Jamse Hasy B1om Jan Webster Names continued on bc...

996 6~ 6 0 0 "6 THE CONGRESSIONAL QUARTERLY SHOWS ...

ABORTION & REL4TED F UNDING SU PREM E COURT NOMINATIONS RELIGIOUS I.IBERIY PLAVBOY

WMConfuaaia Repnn to auibona W2billmeni few Itwiit Omifirmalmaiiil0" 11 SetalerIII the 115S %trw n1(t A2, Amedadml Utscee the mena(if the Seisactehatlowh hlf 2MI Aiiiendiften i anl SIli li et ie iIii k ..i ,a and meole" 1NMM te exsinklreaewmupn wouald can..io Teailemmyia the SamatehoeRil laduesi bAMSoul- Sua4Wm (awa sbomaldtine it's earlier ruling. peiiing (linpena pitiprain fl tailk- relnldeeuiiuln%.4 itiagarinee fi.I lite picen hU* fii dw Vmh ~dIIIPapuistw am1udll1U os. blind (toi eliminate funding ftile Ifbahlk isu of I 6)Aait' matg.ilum I er, as a member of the board of Trustees of "tlAalmr acheu pt*riei liJv *4. isoi A no vote opposed &mi A yell vote supported iheag foe UNFPA, 1iuvia tw. A no vote allowed continued use of Concord I ospital, voted to Initiate a policy of voluntary school prayer. Rid vo.yiNO1±. which gives money to Cina with It's forced tax funds for Playboly performing abortions at that hospital. jaj)n In Braille. IIwjyKiti aherti..m and stesilimation policy. jiaM Kcjj l11115345 WMan k. suawnd liar rules and pass the hill I,. al m studentrelgtus pleimpsli "wet in publicsoeriindaiy teliii~a duiku is-n iihatiai tihesSof ieiis it) *in, iviii A ni) o 4ti ( ..enuamsix-t-a(( latriner iimI,iu , ie 11 S Suwiiie ( tuil lilt 5W Met... u, rtaagcmidthe Irdes and l a the tmit, denied student religious groups the use of atalitat 5%X~5 ii. laiill fisal 19&S#.7liw jx~jj lieslt TIhomas Is a "natural law" advocate, which school facilities. LhlyRcJid y led NQ lilt SS15h'.uiXiu A lielN 1-111,. ".14i li' ltaIN IIII wrA blesitumtol. Iadye plaisagsl and adi~eiltn lsiy life encompasses the inalienable right to life. aermrem,i"v or. itio41A yes vote supported this 1ialkkl vtAial AUAJNL1 Um'o~ia agi I ii alaiuN a I-J)) 1, .a#I ?I uii A y'ts vote approved fundinga much of which goes to Planned $548,637.431. mimj than the administration lParmnholod and similar clinics. jjuy I{(Lad requested. 1kujy~j

"He thereore is the truest friend of the liberty 1114 2907 PdIaea rt Ai the ill) I, lpiilI '.i li14 'iit 'MtntA 1. Ii mli hitelrvt )%-5.1 , Iia1Na Jl IAu 11 Vll ItI.ut TAX.PNID ABORTION COUNSELING of-his country who trifes most to promote its [IS 1'1t1l1' AInalr tidi lFuult fIuka I, I0 a,,, ,*,' A yes vote approtved $450,3"9,(M) nwrc-. than lter virtue, and who ... w 11 not suffer a man to president requested. Iirty Kid tiLkd~-Y A0 1111ismen budpurathewiy law the Ilair. IlI IS and I dwetmef tIll 46.17 Imaits)lW uilli)ji ')ii.u~iuA' 1,tlt~jflthe aditma.o be chosen into any Mie of power and trust I A'Ii. Ay c ate 'he -'ans 2 ~l4 o1 vite sup~ported $14,307,988,307 for fioltigil adyfi" tamily phiosmf haws, I'') oaw tit A yes who is not a wvise ma aid. [jLy-JZIi~iQ LY-)L. SIL vote supported the use of tax money for abortion counseling. Harly Rcid votcd Y E Misin0111:d to afmh V00, CON SIlU IONAI. ISSUES IIOMOSEXUALIIlY

hllo 2.;07 IhAveai 4 ilk hii)l I,.ui~iu ti/S md IN S1.141 lm..iif IheI, rrichitouiei a-m a %%ouing viid ,dbr S 1430 lioltuit lI, table (kilt) thec Kenniedyt ai ii , iiii k TAX FUNDED ART.-OBSCENI'IY Aitnsitiosg alsmcitldrlmntel the DU) tide toat.1m Lurlanaksilkatih. hauuJu&,. ban iat ie &.eau iaii rua, bineki ther fedeal 4-.i11 N.6ii1 iii)I amke- Inlitule aii li iat., Iung it..) Ilk wi lnaiiitiuk lwiat bar t iw r~t lerrinueals itim citthing. leaching III serving , 1 nniii deaith II inmate alieals authocirizfunds Iii hire the bill Vnun till the-ha qll teil., lilet Irdiiulair itut. S MRI574 Aaiedmewaito piuet the NIA treanuing litcia) role toiih 14)mettns (g" Lhargeelwith -)t etnid Ia 10i,000iner i a l .. ratioiei 41iien l. Q DI(,, ts i11 A Iioading tril., imue iua I l II,$) Iar nd'Atue.alui'i un ) 6 1Wti ) fi.hd toi presate. denbar. deitarita m jog4%k initabu that witual 41emir inmtbtit a inieu, ix if the Nureni of the man... defeCt u sefilie, I& a PSacalY.eeen, .ay. WXtUl.ii . 1i ILK-, yes lotel imptsed as%%aiting period for hand- A yes vote supported use of fetailtissue fronm ..rije~enlvu #e. tw4 A no vote allowed D.C. to fo~rce inducedl abortions. Il~~j r3( vlteJ I mamma or arom " en.iss "q A no vote allowed gun purchases and banned some semi-auto- organizations such as Big Brothers to accept ~ainuusa t)Str 1 A).. It 1. L.'n)W aYi~I- continued use of tax money for this type of matic weapons. Hany Reid voted YES. homosexuals as adult leaders, anev.iby haie been art. Har= Reid voted NO. Santdirlte: (1) JV241. ebianisde emailleadof mat iiah asrlvolving a emlik.rof the J991 S 12114 Miiii.k 1,. table (kill) the eniendiinere III ceetaat that i%. aji ii.) it filAIa 14ii t llie6(t r IIb I W)e * re kiiNIed hrV 1114 p.,* at t i..ail . Ifarry Reid voted NL). nul II ia til.0 #1iN 100i (0) -. 4(d aiiKi) p i iiitl io Iii miiitityliaitit %ith n iliadu ta earen the 5 Al i Vblte stttllI "it 307 ltiltas isotabor (kain) te ine udieIa nsna I O Iliiakt I And.l Miilli I., 1iltifflk the Ingf 4 winetern(ir III ihe, lIfil 5311 Weistiint.t tabtle (kill) the .,nwindini I,, ilh-n.t). stew na ib. -ii the ("eA IVA) latier lit-paliiceit eppeijutie 1 talatns in PV1 it) bar haitiiamenualand liaw-iaat nit..n lit t00.bill 01R V71) hi siawi us a Sena&*pIamod InIsame haiting onaise 14 li di ral Ii gi/alKy a 11.41ivIt "1uIvy A yes vote pmil-astil in preeijaanmnwAignnletwl. juitnder, Ilit o;:r0 Im theU iOf nil h 1111seari400Web deemed 4weene.4l u/s-it* allowed lte continuatin of rederal regula. Iij mut ir4ma A yes vote would have allowed D.C. li uoimeimm A yes v'ote allowed continued use of tins that may result in the taking of private tax funlds for obscene art. IRn &id Voted to force organizations such as Scouts too tax flunds lt lie used fiot ivedlirs alid syringvs l11ilty. 1 iiiy Roed Voted1YLS 'y; 11044itr - 4# a i1 I nd 5/ 4/, 1-1111 L... - , . ( ) #1 I l'iui S S

FEDERAL ELECTION COMMISSION

November 6, 1992

Evan J. Wallach 300 South Fourth Street, Suite 1700 Las Vegas, NV 89101

RE: MUR 3688

Dear Mr. Wallach: This letter acknowledges receipt on November 2, 1992, of your complaint alleging possible violations of the Federal Election Campaign Act of 1971, as amended ("the Act"), by the tf Nevada State Republican Campaign Committee and Bob Beers, as treasurer, Lucille Lusk, Layne T. Rushforth, and the Nevada Coalition of Conservative Citizens. The respondents will be notified of this complaint within five days.

0You will be notified as soon as the Federal Election Commission takes final action on your complaint. Should you 06 receive any additional information in this matter, please forward it to the Office of the General Counsel. Such O.1 information must be sworn to in the same manner as the original complaint. We have numbered this matter NUR 3688. Please refer to this number in all future correspondence. For your 'q- information, we have attached a brief description of the Commission's procedures for handling complaints. Sincerel

Jonathan A. Bernstein Assistant General Counsel

Enclosure Procedures FEDERAL ELECTION COMMISSION WASHINGTON 0( .N4h

November 6, 1992

Bob Beers, Treasurer Nevada State Republican Campaign Committee 7310 w. Smoke Ranch Road, STE S Las Vegas, NV 89128

RE: MUR 3688

Dear Mr. Beers: The Federal Election Commission received a complaint which indicates that the Nevada State Republican Campaign Committee 0("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 MM 3688. Please refer to this number in all future correspondence. Under the Act, you have the opportunity to demonstrate in 0C1 writing that no action should be taken against the Committee and you, as treasurer, in this matter. Please submit any factual or cN 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 C- 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 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. ~~1 R S S

Bob beers, Treasurer Nevada State Republican Campaign Committee Page 2

If you have any questions, please contact Holly Baker, the staff member assigned to this matter, at (202) 219-3400. For your information, we have enclosed a brief description of the Commission's procedures for handling complaints. Since rely,

""Tonathan A. Bernstein Assistant General Counsel Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement FEDERAL ELECTION COMMISSION WASHINCTON D( .!"4h

November 6, 1992

Lucille Lusk 6624 Celeste Ave. Las Vegas, NV 89107

RE: MUR 3688

Dear Ms. Lusk:

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 co complaint is enclosed. We have numbered this matter HUR 3688. Please refer to this number in all future correspondence.

Under the Act, you have the opportunity to demonstrate in 10 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 O1 matter. Where appropriate, statements should be submitted under oath. Your response, which should be addressed to the General 0 1 Counsel's Office, must be submitted within 15 days of receipt of this letter. If no response is received within 15 days, the oCommission may take further action based on the available information.

This matter vill remain confidential in accordance with 2 U.S.C. 5 437g(a)(4)(B) 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. S S

Lucille Lusk Page 2

Sincerely,

Jonathan A. Bernstein Assistant General Counsel Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement 'C FEDERAL ELECTION COMMISSION AASHINC TO) D( Zit4ol

November 8, 1992

Layne T. Rushforth 530 S. Las Vegas Blvd. Las Vegas, NV 89101

RE: MUR 3688

Dear Mr. Rushforth:

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 C) complaint is enclosed. We have numbered this matter HUR 3688. 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 CN matter. Please submit any factual or legal materials which you believe are relevant to the Commission's analysis of this 01 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 0. this letter. If no response is received within 15 days, the Commission may take further action based on the available "information.

CV This matter will remain confidential in accordance with 2 U.S.C. S 437g(a)(4)(B) 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 nano, address and telephone number of such counsel, and authorizing such counsel to receive any notifications and other communications from the Commission. Layne T. Rushforth Page 2

If you have any questions, please contact Holly Baker, the staff member assigned to this matter, at (202) 219-3400. ror your information, we have enclosed a brief description of the Commission's procedures for handling complaints. Sicrel,

Jonathan A. Bernstein Assistant General Counsel Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement

C\I FEDERAL ELECTION COMMISSION WASHI%(TO% D( November 6, 1992

Nevada Coalition of Conservative Citizens President c/o Lucille Lusk 6624 Celeste Avenue Las Vegas, NV 89107

RE: MUR 3688

Dear Sir: The Federal Election Commission received a complaint which indicates that the Nevada Coalition of Conservative Citizens may have violated the Federal Election Campaign Act of 1971, as 11 amended ("the Act"). A copy of the complaint is enclosed. We have numbered this matter NUR 3688. Please refer to this number NO in all future correspondence. CN Under the Act, you have the opportunity to demonstrate in writing that no action should be taken against the Nevada Coalition of Conservative Citizens in this matter. Please 0% submit any factual or legal materials which you believe are relevant to the Commissionts analysis of this matter. Where appropriate, statements should be submitted under oath. Your response, which should be addressed to the General Counsels 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 tinformation.

This matter will remain confidential in accordance with 2 U.S.C. 5 437g(a)(4)(5) 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. Nevada Coalition of Conservative Citizens President Page 2 If you have any questions, please contact Holly Baker, the staff member assigned to this matter, at (202) 219-3400. For your information, we have enclosed a brief description of the Commission's procedures for handling complaints. Sincerely,

Jonathan A. Bernstein Assistant General Counsel Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement NoS Coalition of CoDvaive Citzens 6624 Celeste Avenue Las Vegas, Nevada 89107 (702) 870-6858 FAX 878480

November 18, 1992

Jonathan A. Bernstein Assistant General Counsel Federal Election Commission Washington. D.C. 20463

Re: MUR 3688

Dear Mr. Bernstein: for a mailg NCCC gave permission to Chuck Home to utilize it's bulk mail permit disclosing information on Senator Harry Reid's voting record. It is our understanding tlt it was paid for by small contributions from the private citizens whose names were printed on it.

NCCC had no expenditure at all for the mailer (although one person erroneously sent a check for $35 to us, which we deposited and wrote a check to Mr. Home in that amount.) A check of our bank records would show that we did not pay for the postage, printing or any other expense related to the mailer.

Feel free to make any investigation of this matter public.

Yours truly,

Chairman F

C-> cc: Chuck Horne x II~ CONNISSION MAIN COPY Ao00 h23 It1It7 November 17, 1992

Jonathan A. Bernstein Assistant General Counsel Federal Election Commission Washington, D.C. 20463

Re: MUR 3688

Dear Mr. Bernstein: .. My husband and I each contributed $10 for our signature on the mailer referenced in MUR 3688, and later contributed an additional $50. It is our understanding that it was paid for by small contributions from private citizens. I have no connection of any kind with the Republican Party, and I doubt they even knew about this mailer.

04 Please do make your investigation of this matter public.

Yours tdy,

6624 Celeste Ave Las Vegas, NV 89107 1(702) 870-9557

cc: Chuck Home 53 Wilson, Beers & Ediud Business Computer Specialists 4 73 10 Smoke Ranch Road, Suite S Las Vegas, NV 89128 (702) 228-2983 November 22, 1992 XrT* ,n Holly Baker LIP, r'T Federal Election Commission 999 E. St., NW Washington, DC 20463 C)

Dear Ms. Baker:

On behalf of the Nevada State Republican Campaign CrI tteeI would like to requpest a fifteen day extension of the tine we have to respond to your letter of November 6, 1992, notifying us we have been named as a participant in MUR 3688.

The reason is that Brian McKay, our state party chairman, left for two weeks vacation on November 9, 1992, and will be unavailable to help prepare our formal response until his return.

I would like to make the following points to assist the

commission's early resolution of this MUR. -

We do not hold, nor do we know who holds, bulk mail permit ' number 517. We do not know the identity of the person or persons who paid for the production and/or mailing of the document enclosed with Mr. Wallach's complaint, nor did we pay for it.

Neither Lucille Lusk nor Layne Rushforth are officials of our committee. I have only been involved with the committee personally for the past two election cycles, and during that time, neither individual has even been active in the party.

I anticipate that upon Mr. McKay's return, you will receive a notarized copy of the above facts, but we would still like an extension granted.

Finally, we would like to request copies of the Nevada State Democrat Party's Form 3X for both the third quarter and the pre-general election short period be sent to us, care of our committee's address.

Sincerely,

WILSON, BEERS & EDWARDS Bob Beers, CPA

-tad Pq*W FEDERAL ELECTION COMMISSION INASHINGTON DC 2o.144 December 1, 1992

Bob Beers, Treasurer Nevada State Republican Campaign Committee 7310 W. Smoke Ranch Road, Suite S Las Vegas, NV 89128 RE: MUR 3688 Nevada State Republican Cmte

Dear Mr. Beers:

"- This is in response to your letter dated November 22, 1992, which we received on November 27, 1992, requesting an 'C extension of fifteen days to respond to the complaint in MUR 3688. After considering the circumstances presented in your letter, the Office of the General Counsel has granted the O.1 requested extension. Accordingly, your response is due by the close of business on December 9, 1992. If you have any questions, please contact me at (202) 219-3400. Sincerely,

rHolly Baker Attorney ONEL SAWYER 8 COLLI .J., [t.i , , ATTORNEYS AT LAW M ,-

SAM'.. ' S LIONrL EVAN J WALLACH 1700 VALLEY BANK PLAZA "', DF( UCC1 RORY J BrlD NPTfr GRAN- SAWYER pARVEY WHITTEMO RE 300 SOUTH FOURTH STREET MARCGAAR H RYUWOUHJNRUEI N MARK LEMMONS -CN 0 COLLINS TCDD TOUTON STEPHEN M SAN\,'LLI *Z) -" OS 0Av 0 WHITTEMORE PAUL C LARSEN SErVE MORRIS M PkR'STINA PICKE PING LkS VEGAS, NEVADA 89101.I PAT LUNDVALL _f rCY P ZUCKER CAM FERENBACH (702) 383-8888 LAUREL E DAVIS CRAIG S NEWMAN PA_ a EJMANOWSKI GREG L JENSEN GORDON H WARREN C EDWAR(I GER ES .)w R 3R( D FAISS NYNDAS MABRY LOUIS E GARFINKEL DAN R 01PEASER B. C..AD G CAMPBELL MARK H GOLDSTEI N FAX 1?02) 383 8045 DONALD L SODERBEPg CHRISTOP,4rp p " OOPEr CAV :. N FREDERICK AN'4ONY N CABOT DEBORAH L EARL SUVINDE..4 r, AHLUWALIA ANnQEdV S BRIGNONE -1 RY J SMITH CARL 0 SAVELY PAMELA 1i RO ERTS r ZEN. S L KENNEDY PA'L D BANCRCF LAYNE J BUTT T-4OMAS j REICH4 q CAPBD W HORTON 19 AN M KAY ELLEN WHITTEMORE MADELENt I AMENOCLA :AN - BOWEN CLEEN A DOLAN .. ABQES H N CREA _? E%N FER A SMA December 1, 1992 MAeI A SOLOMON - R BA.- EV BC,"ZNE. M JWEAN , , A-, SE-7 GOLDWATER

0F C "

(702) 383-8832

Jonathan A. Bernstein, Esq. Assistant General Counsel Federal Election Commission 999 E Street, N.W. Washington, D.C. 20463 RE: MUR 1688 Dear Mr. Bernstein: Enclosed please find a copy of a letter I received this date in response to the Freedom of Information Act request I filed wiox the United States Post Office on October 29, 1992. In your letter of November 6 you asked that if I received any additional information I forward it to the office of the General Counsel. Accordingly, I am enclosing this letter. It is not sworn because this is the form in which I received the response. I do believe, however, that it will lead you to admissible information relating to the person or persons responsible for the illegal mailing of which I initially complained. Please note that I have been orally informed that Ms. Lusk signed for Bulk Permit No. 517 on behalf of the Nevada Coalition of Concerned Citizens and that she is the individual holder of the bulk permit at issue. As I stated in my letter, which became MUR 3688, Ms. Lusk has been both a party official and a Federal candidate, and I believe she has more than sufficient knowledge of laws governing Federal elections to create scienter in relation to the conduct about which I complained.

RENO OFFICE IOO VALLEY BANK PLAZA. 5O WEST LIBERTY STREET I RENO, NEVADA 8 501

(702) 7a8-8666 * FAX (702) 786-86682 LIONEL SAWYER 8 COO& ATTORNEYS AT LAW 0

Jonathan A. Bernstein, Esq. December 1, 1992 Page 2

If you have any questions or comments, please feel free to contact me. Sincerely,

Evan J. Wallach

EJW:bas Enclosure November 29, 1992

Mr. Evan Wallach Lionel, Sawyer & Collins 300 S Fourth St Ste 1700 Las Vegas, NV 89101

Dear Mr. Wallach

The permit holder for permit imprint #517 has agreed to full disclosure of information pertaining to their bulk mailing activities. C) N Please contact Ms. Lucille Lusk at the following address:

Nevada Coalition of Conservative Citizens 6624 Celeste Avenue Las Vegas, NV. 89107

Ms. Lusk can be reached at 870-6858.

If I can be of any further assistance, please contact me at 361-9288.

Sincerely

Dee Terrano Manager, Mailing Requirements (Acting) U.S. Postal Service 0o 40

FEDERAL ELECTION COMMISSION

AASHIN(CTON DC 20463 December 8, 1992

Evan J. Wallach Lionel Sawyer & Collins 1700 Valley Bank Plaza 300 South Fourth Street Las Vegas, Nevada 89101

RE: MUR 3688 Dear Mr. Wallach:

This letter acknowledges receipt on of the December 4, 1992, supplement to the complaint you 1992, against filed on November 2, Lucille Lusk, the Nevada State Republican 'Campaign Committee, Layne Rushforth, and the Nevada Coalition of Conservative Citizens. The respondents will be sent copies of the supplement. You will be notified as soon as 011 the Federal Election Commission takes final action on your complaint.

Sincerely,

Holly Baker tn Attorney Uo FEDERAL'0 ELECTION COMMISSION WASHINGTON. D C 20463

December 8, 1992

Bob Beers, Treasurer Nevada State Republican Campaign Committee 7310 W. Smoke Ranch Road, STE S Las Vegas, NV 89128

RE: MUR 3688 State Republican Cmte Dear Mr. Beers:

On November 6, 1992, you were notified that the Federal Election Commission received a complaint from Evan Wallach alleging violations of certain sections of the Federal Election Campaign Act of 1971, as amended. At that time you CN were given a copy of the complaint and informed that a response to the complaint should be submitted within 15 days 0K of receipt of the notification.

04, On December 4, 1992, the Commission received additional information from the complainant pertaining to the allegations in the complaint. Enclosed is a copy of this additional information.

& If you have any questions, please contact so at- (202) 219-3400.

0*1 Sincerely,

Holly Baker Attorney Enclosure 0

FEDERAL ELECTION COMMISSION WASHINCTON DC 2046 December 8, 1992

Lucille Lusk 6624 Celeste Ave. Las Vegas, NV 89107

RE: MUR 3688 Lucille Lusk Dear Ms. Lusk: On November 6, 1992, you were notified that the Federal Election Commission received a complaint from Ivan Wallach alleging violations of certain sections of the Federal Election Campaign Act of 1971, as amended. At that time you were given a copy of the complaint and informed that a response to the complaint should be submitted within 15 days of receipt of the notification. 0O. on December 4, 1992, the Commission received additional information from the complainant pertaining to the allegations in the complaint. Enclosed is a copy of this additional information. If you have any questions, please contact me at (202) 219-3400. rSincerely,

Holly Baker Attorney

Enclosure 0 0

FEDERAL ELECTION COMMISSION WASHIN(;TON, D C 20463

December 8, 1992

Layne T. Rushforth 530 S. Las Vegas Blvd. Las Vegas, NV 89101

RE: MUR 3688 Layne Rushforth

Dear Mr. Rushforth: On November 6, 1992, you were notified that the Federal Election Commission received a complaint from Evan Wallach alleging violations of certain sections of the Federal Election Campaign Act of 1971, as amended. At that time you 04 were given a copy of the complaint and informed that a response to the complaint should be submitted within 15 days 0 of receipt of the notification. On December 4, 1992, the Commission received additional information from the complainant pertaining to the allegations in the complaint. Enclosed is a copy of this additional information.

If you have any questions, please contact me at (202) 219-3400.

Sincerely,

Holly Baker Attorney

Enclosure FEDERAL ELECTION COMMISSION WASHINGTON D C 2046)

December 8, 1992

Lucille Lusk, Chair Nevada Coalition of Conservative Citizens 6624 Celeste Ave. Las Vegas, NV 89107

RE: MUR 3688 Coalition Dear Ms. Lusk:

On November 6, 1992, you were notified that the Federal Election Commission received a complaint from Evan Wallach \0 alleging violations of certain sections of the Federal Election Campaign Act of 1971, as amended. At that time you 04. were given a copy of the complaint and informed that a response to the complaint should be submitted within 15 days 0%. of receipt of the notification. 0% on December 4, 1992, the Commission received additional 0 information from the complainant pertaining to the allegations in the complaint. Enclosed is a copy of this 1q, additional information. C If you have any questions, please contact me at (202) 219-3400. Sincerely,

Holly Baker Attorney Enclosure ___P 3LiI son, Beerst uEdwads Business Computer Speciolists 73 10 Smoke Ranch Rood, Suite S Las Vegas, NV 89 128 (702) 228-2983

Decerber (, 1992

Federal Election Commission 9 99 K. St. , N:w 4 Washington, DC 20463

Dear Ms. Baker:

[h:irn you for granting the Nevada State Republican Central - rquested extension regarding MUR 3688. We - S our comittee should be dropped as a respondent to

".. d no knowledge of this mailing prior to receiving a your office. I spoke to Lucille Lusk about copy.7this matter.oI it from She informed me that she is not, and has not n this just-past election cycle, been a member of the Nevada Republican Party. Additionally, Layne Rushforth was an Independent American candidate for county commission C\J during the last election. Accordingly, we can find no connection between our committee and Mr. Wallach's alleged 0% violations.

1ea~e~ Let me know if I can answer any further questions regarding this issue.

MI last letter's closing paragraph requested a copy of the Nevada Democrat Party's most recent Form 3X. I appreciate your rapid response, directing me to the appropriate section in your organization. I must confess that my request had alterior motives: the Nevada Democrats have not 1:i1Pd a 3X for the past several quarters, and I was attempting to subtly highlight our committment to coml)ance, particularly compared to those who instigated MUR 3W 8. I should probably bag the subtlety and stick ,.'it-y natural tactlessness in future correspondence.

jntact me should the Commission require additional o<,'-c> tion from us regarding this MUR.

' EFRS & EDWARDS

Regcile Pow' BECXY, SINGLETON, DE LANOY, JEMBON & LIST, CwD.

Z:Q&.kE DE LANOY A PROFESSIONAL LAW CORPORATION &.COt"SON K tC9 ',~w t:4SIj9@ QC8ERT L)ST RENC6C AC|M"( oII47-,90 "ARM C SCOTT JR 530 LAS VEGAS BOULEVARD SOUTH -- "CILLCo6.AGA K OGERM9ImK LAS VEGAS. NEVADA 8IO#01-G1 OF CCOUN6CL RC,,ECT P SAJt4-AUION WILLIAM Bwjc[ A LESL[E (702) 385-3373 SINGLETON RC,-ANO K- MAwTNmin RICHARD 0 CAMPBELL. JP 3A1. L.. P POILSENiERG ReGwr A AOd CALLAWAY FACSIMILE (7021 385-9447 JACK C CeRRv S-EP64cN S KENT :AaOL R DAVIS E ZAEtI- GO"P GONZALE.Z RENO OF'ICE A%CL.A OlS.AIZER P9 M IY4ANSON 100 WEST LI[ERTY STRE- SutTE ?OO E RU$ORTH"F % DA9r'C01, FLANAGAN aj RENO. NEVADA 89SO ;;OtGRT A- %ERSCSIAN4 (70Z) 323-8864 -- WAS HUGH PEILRSOIN - :-E.LsrE iI.CE rACSIMILE i-?W 323-5523 -EA L-KAALE ENETN CREIGHTON DO JENSEN A ACKER -Z-%cMCdSSCK Thmuan~d &sda Depwom~ . % S WILLIAMS NYAUACKYE S ZASAN P CLARK Layne T. Rushfw& .L%ES - EDARDS Direct Pbone: (702) 474-2629 N NELSON , .ORNRA WE NS-EE., Direct Fax: (702) 355-6742 A MUrLLER PARKER - - ZoE 4 SA EAPBERSON November 17, 1992 7% SENNION .R -- %- * a-GGAR

Federal EJection Commission Office of the General Counsel 999 E Street, N. W. Washington, D.C. 20463

RE: MUR 3688

Dear General Counsel:

I am sending this letter as a response to the former complaint filed by Evan J. Wallach in this matter. I respectfully state that:

1. I am neither a registered Republican or Democratic, but rather I am registMe in the State of Nevada as a member of the 'Independent American Party of Nevada'.

2. To my knowledge, the mailer was prepared and sponsored independent of any political party or any particular candidate's campaign.

3. It was asked that each person whose name was to appear on the ad contribute $10.00. I contributed a total of $20.00 on behalf of my wife and myself. On information and belief, each person whose name appeared in the mailer made a similar contribution. I am sure that these were others who may have made more significant contributions, but I know of no one who made a contribution whose name did not appear in the mailer itself.

4. I am an attorney and I practice primarily in the area of trusts and estates. No portion of my practice relates to compliance with the Federal election laws.

5. Lucille Lusk was a former candidate for the United States House of Representatives, and I personally conferred with her in regard to the preparation of the mailer. In her efforts to assist with the preparation of the mailer, she never 6* *0

L~ to Holly Baker Hber 17. 1992 P2

once indicated to me that she was acting in any capacity other than as an individual concerned citizen. There was never any reference to the Republican Party or to any organized political party with respect to this particular mailer.

6. No one that I know who was involved in the preparation of the mailer is familiar with the Federal Election laws, and no one knowingly or willfully violated any of those laws. All those who were involved, insofar as was known to me, were extremely concerned that everything in the mailer be completely true and accurate, and I was asked to review the Congressional Quarterly to verify that the votes represented in the mailer as having been made by Harry Reid were completely true and accurate.

7. I have no personal knowledge relating to the cost of the mailing or the source of its financing except as outlined herein. In fact, the only knowledge I have is that I paid $20.00. I have no knowledge with respect to contributions that may have been made by other persons, although I can only assume that the other persons whose names were on the mailer also made similar contributions.

I am more than happy to discuss this matter with anyone from your office. I have already spoken to Holly Baker, who was very informative and very helpful. I can assure you that any violation of the Federal Election laws was inadvertent and unintentional, that once apprised of the law it will never be violated again, and because no particular group or entity was involved, any further action on the part of the Commission would be really unnecessary.

Respectfully,

BBCKLEY, SINGLETON, DeLANOY, JEMISON & LIST. CHARTERED

LTR:pf

Law Ofce of BECKLEY, SINGLETON, DE LANOY. JWlSON & LIST. CHARTERED A Pmf.ssi Law Coqxontim 00

STATE OF NEVADA I ss. COUNTY OF CLARK

LAYNE T. RUSHFORTH, being first duly sworn, certifies and declares that:

I. The foregoing letter is hereby submitted as a response to a formal complaint filed by Evan J. Wallach, which has been designated as MUR 3688.

2. 1 am personally aware of the contents of the foregoing letter and I hereby declare under penalties of perjury that the facts contained therein to be true of my own knowledge except for those matters stated upon information and belief, which I believe to be true.

Subscribed and sworn to before mc this ( I day of 0ou l ( ,1992.

Nt ARY PUBLIC MUR # 3 6 1Y

ADDITIONAL DOCUMENTS WILL BE ADDED TO THIS FILE AS THEY BECOME AVAILABLE. PLEASE CHECK FOR ADDITIONAL MICROFILM LOCATIONS.

C FEDERAL ELECTION COMMISSION

) :0"

THSi Th ,dc m 1L1/t______

DATE FILMED CAMEA NO. Press

wim nmc o iw:ciim

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_ :.:• ,i ;ox ; i. i ...... • i • : L I

Y33l REDE IS RElFERREDI YO A DDI?!WWL RZCROFZXLN wctiis FOR TUlE FOLLOIING OCURUS PFERINUW TO T111S CaK

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

2. Memo, General Counsel to the Commission, dated April 14, 1993, Subject: Enforcement Priority System. See Reel 354, pages 1595-1620. 3. Certification of Commission vote, dated April 28, 1993. Seee Reel 354, pages 1621-22. 4. General Counsel's Report, In the Netter of 3nforea Priority, dated December 3, 1993. See Reel 354, pages 1623-1740. 5. Certification of Commission vote, dated Dear 9,1i3. See Rteel 354, pages 1741-1746. DEC G~~

3van 3. Wallsch 300 South Fourth Street Suite 1700 Las8 Vegas, MV 89101

RI: NUR 3688 er Mir. Wallach:

receivedOn youruloveebr lo 11at2, 1953, allegiag the Federal certain 3lection violations Coummssion of. the Federal Liec-tion Ceip .Act of l1 1, as amnded ('the Acte).

.. ,. " .: . se.ie- o | . 43Wg~, , ,4L

3o .1 Baker Attorney

AttachmentNarrative

Date the Commission voted to close the file- ilCCIS33 uwa smiler,crn"s in the foruaov avu This matter involvesamalrithfomfaltt signed by 165 individuals, expressly advocating the defe~t of Senator Harry Reid, and bearing the notice "Paid for by concerned citizens." Complainant alleges that the mailer involves violations of the disclaimer and independent expenditure reporting provisions. Complainant further alleges that because Lucille Lusk, Chairman of Nevada Coalition of Conservative Citizens, whose bulk permit was used to send the mailer, is a Republican, participation of the Republican Party in the mailer can be imputed. Lucille Lusk admits that the Nevada Coalition allowed a person to use its bulk mail permit to send the mailer, and denies that the Republican Party had any involvement with the mailer. The Nevada State Republican Campaign Committee denies any involvement with the mailer. It appears that the Nevada Coalition of Conservative Citizens may be responsible for the mailer and that the group may have made expenditures sufficient to trigger political committee status. The case involves no indication of any serious Latesta by Respondents to violate the PICA, and only a limited mdount of money is involved. : +LEW RAL ELECTION COMMISSION

SObl !lers, treasure r U da stte Rlepublican Campaign Committee 7310 W. Smoke Ranch Road, Suite S Las Vegas, NV 09128

RE: NUR 3688 Nevada State Republican Campaign Committee and bob beers, as treasurer Dear Hr. Beers: On November 6, 1992, the Federal Election Commission notified you of a complaint alleging certain violations of the Federal gloction Campaign Act of 19710 as amended. A ...colpy Lof*'Mtb omplaint wse enclosed with that notifiation. A te cosdering the circumstances of. ths matfe, the :' ha&m detemnend to exercse its poncoril * 4 0 and. to take no action against the WW s

++Wg!" ic t~rdfeaseit dovso ms o8

the ftomeplco,, the public record rm ptiot t red.

If you have any questions, please contact me at (202) 219-3400. Sincerely.

Bol113J*+ baker Attorney Attachment Narrative Date the Commission voted to close the tile: DEC 0 9 WSVADN3 3656 C~1ZIUOU OF CWWU3VAFIVS C1U55II This matter involves a mailer, in the form of a letter signed by 185 individuals, expressly advocating the d eet of Senator Marry Reid, and bearing the notice lPaid for by concerned citizens."W Complainant alleges that the mailer involves violations of the disclaimer and independent expenditure reporting provisions. Complainant further alleges that because Lucille Lusk, Chairman of Nevada Coalition of Conservative Citizens, whose bulk permit was used to send the mailer, is a Republican, participation of the Republican Party in the mailer can be imputed. Lucille Luak admits that the Nevada Coalition allowed a person to use its bulk mail permit to send the mailer, and denies that the Republican Party had any involvement with the mailer. The Nevada State Republican Campaign Committee denies any involvement with the mailer. It appears that the Nevada Coalition of Conservative Citizens may be responsible for the mailer and that the group may have made expenditures sufficient to trigger political committee status. The case involves no indication of any serious itult by Respondents to violate the FICAk, and only a limited ~mt of money is involved. i I. ;#WERAL ELECTION COMMISSION "

Lucille Lusk, Chairman Weaa C~elition of Conservative Citizens 6624 Celat. Ave. Las Vegas. NV 89107

RE: MUR 3688 Nevada Coalition of Conservative Citizens and Lucille Lusk, as chairman Dear Ms. Lusk: On November 6, 1992, the Federal Election Commission notifi~d youa of a complaint alleging certain violations of the Federal glection Campaign Act of 1971, as amended. A copy of the complaint was enclosed with that notification. Afte r coneidering the circumataaces of this neter, th "aeiIop ** ' determined to-ezercise its prosecutOral... ~ndo t ke n ac io i st e Nevad *6 :* in

*1 itznsadyoascaim! ~'~coordin , o the CnisiOn,clo it*e.

t~b:I smteapisd th puisin rord prirU*.C.6ip Of 4 ) not1 lnger aly,and ttpe msfle iM/s /

#iibe- teoacothe public record r iot~rmd.

If you have any questions, please contact me at (202) 219-3400.

Sincerely, /La It -

Holly J. Baker Attorney Attachment Narrative Date the Commission voted to close the file: O .o This matter involves a mailer. in the form of a lets~t signed by 185 individuals, expressly advocating the defeat of Senator Harry Reid, and bearing the notice "Paid for by concerned citizens." Complainant alleges that the maler involves violations of the disclaimer and independent expenditure reporting provisions. Complainant further alleges that because Lucille Lusk, Chairman of Nevada Coalition of Conservative Citizens, whose bulk permit was used to send the mailer, is a Republican, participation of the Republican Party in the mailer can be imputed. Lucille Lusk admits that the Nevada Coalition allowed a person to ue its bulk mail permit to send the mailer, and denies that the Republican Party had any involvement with the mailer. The Nevada State Republican Campaign Committee denies any involvement with the mailer. It appears that the Nevada Coalition of Conservative Citizens may be responsible for the mailer and that the group may have made expenditures sufficient to trigger political committee status. The case involves no indication of any serious intAuat by Respondents to violate the PICA, and only a limited aint of money is involved. Lucille Lusk 66.24 Celeste Ave. Las Vegas. NV 89107

RE: NIJE 3666 Lucille Luck Dear Hs. Lusk: On November 6, 1992, the Federal 3lection Comission notified you of a complaint alleging certain viL~atias .of the Federal Ilection Caupeig Act of 1971, as am ,md.A cOpy of the complaint was enclosed with that notiflition. After consideri~ng the circmmsteaoes .of this ...... he Commission bas* temined tO uri £ p, bt

vtW. b t*5u~.

'ifou hvean qusio. + " i19 t

219-3400. Sincerely,

Holly J. Baker Attorney Attachment Narrative

Date the Commission voted to close the tile: DEC 0 g J " stind by 165 individuals, expresly advocating the detect oE. Senator Harry Reid. and bearing the notice "Paid for by concerned citisens." Complainant alleges that the mailer involves violations of the disclaimer and independent expenditure reporting provisions. Complainant further alleges that because Lucille Lusk, Chairman of Nevada Coalition of Conservative Citizens, vhose bulk permit was used to send the mailer, is a Republican, participation of the Republican Party in the mailer can be imputed. Lucille Luek admits that the Nevada Coalition allowed a person to use its bulk mail permit to send the mailer, and denies that the Republican Party had any involvement with the mailer. The Nevada State Republican Campaign Committee denies any involvement with the mailer. It appears that the Nevada Coalition of Conservative Citizens may be responsible for the miuler and that the group may have made expenditures sufficient to trigger political comIlttee status. The case involves no indication of any serious hntot by Respondents to violate the PICA, and only a liited t of money is involved. •Las Vogas Slvd. LaS Vegas, NV S9101

XE : NU 3608 Layne T. Rtushforth Dear Nr. Rushforth: On November 6, 1992, the ?ederal Election CoIntsion notified you of a complaint alleging certain violations of the Federal election Calmain Act of 1971, :as amue. A 0 copy of th. complaint was enclosed with that notifgtiton. t After considering the civeumstaneos of thiitter, the Comision has detite4to ser~ise its pro* da I discrtion and to teh no stio ~t

rtife oo rdhaveay, ithe Cir' one ,@..{c

t~isnmatter.

tNerraivecd

toclethfi:DEs Date the Commission voted cloIe the file., C O I WL.XflOU OP €O3nVAKV CITlS3IS ,

This matter involves a mailer, in the form of a letter€ signed by iSS individuals, expressly advocating the defeat Of A Senator Harry Reid, and bearing the notice "Paid for by concerned citizens." Complainant alleges that the mailer involves violations of the disclaimer and independent expenditure reporting provisions. Complainant further alleges that because Lucille Lusk, Chairman of Nevada Coalition of Conservative Citizens, whose bulk permit was used to send the mailer, is a Republican, participation of the Republican Party in the mailer can be imputed. Lucille Lusk admits that the Nevada Coalition allowed a person to use its bulk mail permit to send the mailer, and denies that the Republican Party had any involvement with the mailer. The Nevada State Republican Campaign Committee denies any involvement with the mailer. It appears that the Nevada Coalition of Conservative Citizens may be responsible for the smiler and that the group may have made expenditures sufficient to trigger political committee status. The case involves no indication of any serious int~t by Respondents to violate the FECA, and only a limited aImt of money is involved.