THIS IS TIE BEGIMIC of MJR # (O 4E

FEDERAL ELECTION COMMISSION ~A44sI%-T2C)% D( :.%'ti

THIS IS TIE BEGIMIC OF MJR # (o 4e

DATE FILMED / 9/:9 CAMERA NO.

CAMERAMAN NOW -NJ

NATIONAL ORGANIZATION FOR WOMEN OF NEW JERSEY

August 21, 1992

Office of General Counsel FEC 99 E Street, NW Washington, DC 20463

To Whom It May Concern, Enclosed is a piece of campaign literature from a New Jersey Congressional candidate which does not state who " paid for its production. Additionally, this flyer was distributed as an extra insert in the August 9, 1992 regular church bulletin of St. Rose of Lima Church in Haddon Heights, NJ. This bulletin and flyer were given to everyone attending service, including those who are not official members of St. Rose but who simply worshipped there that day. ', Since I believe these acts are in violation of federal election laws, I hereby file this complaint regarding the use of this literature and the method of its distribution. I ask for an FEC investigation into this matter, and if possible to be notified of the findings of any C*, investigation. Thank you for your attention.

Sincerely,

,~<3JA4* Donna Puluka, President

AYAJ

r BARBARA E. b,9/ NOTARY PUBLIC OF NEW JES C= WY COMMISS1ON EXPIRES NOV. 1. 4

e 114 W. State Street, Trenton, New Jersey 08608 * (609) 393-0156 0 FAX: (609) 393-8123 0 A Atteanion PRO=LIFIS

You can help get video-tapes showing aborted babies and the truh abou nboctgn broadcast on TV and cable during Prime Time! Despite the Liberal media's pro-abort bias, the networks rai censor or prevent it thanks to a ruling by the Federal Election Commission! -AND- You can help elect Pro-Life candidate KEN LOWNDES to Congress in NJCD #1! (C-v Florio's olw seati." Item: These "famous" 30-second pro-life political ads were used by pro-lifer Michael Bailey in his primary campaign in Indiana earlier this year. Candidate Bailey won his race with 60% of the vote and is challenging pro-abort Democrat Congressman Lee Hamilton. [YOU probably heard about these effective pro-life TV commercials as reported by pro-family media such as Family News in Focus, 700 Club CBN News, and USA Radio Network News as well as the major networks and newspapers.) Item: The pro-life political campaign ads use excerpts from the video "The Hard Truth" and shows the grisly ibut recognizably humani remains of aborted babies. They show the victims. Item: The TV and cable stations in Indiana refused to run the ads at first... but were fored I& broadcast the pr-ife videos by the Federal Election Commission. ', Item: Since the ads were broadcast, business at Indiana's abortion mills has dropped sharply! These j ads save babies' lives! They change hearts and minds! They show the TRUTH! l,Ne: Pro-abort Democrat Rob Andrews {incumbent) & pro-abort Republican Lee Solomon are running for Congress i Ne s WX Congressional District 1 IGov. Florio's old mti Good News: fe c KEN LOWNDES is also on the ball as an independent pro-life candidate against both pro-abortion candidates thus giving pro-lifers a viable option.

YY=u can contribute to the LOWND fLS fo C Q2camnsign (even if you don't live in New Jersey). The ads will be broadc at in the GreaterPlal a r loftd in the center of the New Yorlk.to-Washington Nordt Corridor. The ads will be seen by millions of people in parts of New Jersey, Pennsylvania, Delaware, and MarylavA Please contribute financially to this grass roots campaign for Life! No contribution is "too small". All contributions are welcomed and needed. Individual contributions may not exceed $1,000 in accordance with federal election laws. With sufficient funding, we could air the entire 10-minute Hard Truth video as a campaign ad

~ Yes! I want to help elect pro-life candidate Ken Lowndes to Congress and get the "Hard Truth" video pro-life political ad broadcast on TV and cable stations.

My name is: Phone: ( ) -i My address is: -- Zip:-...- Mys adr e i:o-- ;------Zp []I also want to help in other ways iex: literature distribution, phone calls, etcl. Please contact me.

e r to Dolltlca Enclosed is my contribution of $ _4-_. S r !-AVo. ,e Make checks payable to: Lowndes for Life for Congress '92 Deiwyn Amerine, Treasurer PO Box 121 Haddonfield, NJ 08033 (609) 4861405

Please DO return this coupon with your contribution. Antn D" Enu. Key co LAX FEDERAL ELECTION COMMISSION .%ASHINCTON UC 204431

900- September 21, 1992 Donna Puluka, President NOW- NJ 114 W. State Street Trenton, NJ 08608 Dear Ms. Puluka: This is to acknowledge receipt on September 17, 1992, of your letter dated August 21, 1992. The Federal Election Campaign Act of 1971, as amended ("the Act") and Commission Regulations require that the contents of a complaint meet certain specific requirements. One of these requirements is that a complaint be sworn to and signed in the presence of a notary public and notarized. Your letter was not properly N-. sworn to. In order to file a legally sufficient complaint, you must swear before a notary that the contents of your complaint are true to the best of your knowledge and the notary must represent __ as part of the jurat that such swearing occurred. The preferred form is "Subscribed and sworn to before me on this -- day of was 0 , 19 2" A statement by the notary that the complaint sworn to and subscribed before her also will be sufficient. We are sorry for the inconvenience that these requirements may cause you, but we are not statutorily empowered to proceed with the handling of a compliance action unless all the statutory INT requirements are fulfilled. See 2 U.S.C. 5 437g. C- Enclosed is a Commission brochure entitled "Filing a Complaint." I hope this material will be helpful to you should you wish to file a legally sufficient complaint with the Commission. The file regarding this correspondence will remain confidential for a 15 day time period during which you may file an amended complaint as specified above. If the defects are not cured and the allegations are not refiled, no additional notification will be provided and the file will be closed. If you have any questions concerning this matter, please contact me at (202) 219-3410. Sincerely,

Retha Dixon Docket Chief

Enclosure cc: Lowndes for Life Congress'92 St. Rose of Lima Church h NOW - NI NATIONAL ORGANIZATION FOR WOMEN OF NEW JEI

-- 4

September 24, A92 rmta~ 3.e CX Office of General Council FEC 99 E Street, NW Washington, DC 20463

To Whom It May Concern,

Enclosed is a piece of campaign literature from a New tin Jersey Congressional Candidate which does not state who paid for its production. Additionally, this flyer was 0, distributed as an extra insert in the August 9, 1992 regular I church bulletin of St. Rose of Lima Church in Haddon Heights,:."i NJ. This bulletin and flyer were given to everyone attending service, including those who are not official members of St. - Rose but who simply worshipped there that day. Since I believe these acts are in violation of federal election laws, I hereby file this complaint regarding the use of this literature and the method of its distribution. I ask for an FEC investigation into this matter, and if possible to be notified of the findings of any investigation. Thank you for your attention.

Sincerely,

-7- Myra Terry President

ComnlubiE*pf*s 10 -29v,1996 *114 W. State Street, Trenton, New Jersey 08608 *(609) 393-0156 9 FAX: (609) 393-8123. AAttention PRO-LIFf t!

You can help get video-tapes showing aborted babies. and the trut abwut abign broadcast on TV and cable during Prime Time! l)eqpite the Liberal media's pro-abort bias, the networks oarj censor or prevent it thanks to a ruling by the Federal Election Commission! -AND-

in NJ-CD #1!I' You can help elect Pro-Life candidate KEN LOWNDES to CongresqIr. j,tf%!,%' p li Spat

Item: These "famous" 30-second pro-life political ads were used by pro-lifer Michael Bailey in with 6010 his primary campaign in Indiana earlier this year. Candidate Bailey won his race ()f the vote and is challenging pro-abort Democrat Congressman Lee Hamilton. IYOU probably medin a FamlY New. in horIrd ni)nijt thpee effectivp pro-life TV commercialn aq reported by pro family ttich and * ,w,,papers.i FO,,,'q. 700 Club RNNNews. nnd USA Radio Network New.s as well ar the major networks. "The Truth" and Item: The pro-life political campaign ads use excerpts from the video IHard the victims. qhows the grisly Ibut recognizably human) remains. of aborted babies. They s how f Item: The TV and cable stations in Indiana refu.sed to run the ads at first... but were force Wohdc1 the prohlf |idmb the Federal Election Commission.

Since the ads were broadcast, business at Indiana', abortion mills has dropped sharply! Item:Thse p a s b "v.g! They change hearts and minds! They show the TRUTH!

Ba News: Pro-abort Democrat Rob Andrews lincumbentl & pro-abort Republican Lee Solomon old set.I are running for Congress in INigw Jsegy Congressional District 1 IC'ov. Florio's GLood Nes: Pro-L& ondsa te KEN LOWNDES is also on the ballot as an independent pro-life candidate against both pro-abortion candidates thus giving pro-lifers a viable option. CONG M 12 campaign.. c 10 , -You can contribute to the LWND I forLIIE for (even if you don't live in New Jersey). The ads wifl be broadcast in the Greater Philadephia ads wifl be area located in the center of the New York-to-Washington Northast Corridor. The wLen by millions of people in parts of New Jersey, Pennsylvania, Delaware, and Maryland. Please contribute financially to this grass roots campaign for Life! No contribution is "too small". All contributions are welcomed and needed. laws. Individual contributions may not exceed $1,000 in accordance with federal election c,. ad. With sufficient funding, we could air the entire 10-minute Hard Truth video as a campaign ------Yes! I want to help elect pro-life candidate Ken lowndes to Congress and get the "Hard Truth" video pro-life political ad broadcast on TV and cable stations.

N y name is: ------Phone: ( ____) - My address is: ------Zip _ Please contact me. I IIqlo want to help in other ways ex- literature distribution, phone calls, etc). Enclosed is my contribution of $ ,,..,-.

Make checks payable to: Lowndes for Life for Congress '92

Deiwyn Arnerine,"Treasurer PO Box 121 lladdonfield, NJ 08033 • (609) 4861405

Att(n Dats Euitiy *K'V CO& LUM-41I21 Plen, DO return this coupon with vour contribution. FEDERAL ELECTION COMMISSION WASHI%CTON. DC 204tb October 7, 1992

Myra Terry, President National Organization for Women of New Jersey 114 W. State Street Trenton, New Jersey 08608

RE: MUR 3642

Dear Ms. Terry: This letter acknowledges receipt on October 5, 1992, of your complaint alleging possible violations of the Federal Election Campaign Act of 1971, as amended ("the Act"), by C:) Lowndes for Congress '92 and Delwyn Anerine, as treasurer, and the St. Rose of Lima Church. The respondents will be notified of this complaint within five days. A

'C 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 0 forward it to the Office of the General Counsel. Such information must be sworn to in the same manner as the original complaint. We have numbered this matter MUR 3642. Please refer to this number in all future iCorrespondence. For your information, we have attached a brief description of the VT Commission's procedures for handling complaints. c Sincerely,

Lisa E. Klein Assistant General Counsel

Enclosure Procedures FEDERAL ELECTION COMMISSION WASHINCTON DC 2'0 5 October 7, 1992

Delwyn Amerine, Treasurer Lowndes for Congress '92 P.O. Box 121 Haddonfield, NJ 08033 RE: MUR 3642

Dear Mr. Amerine: The Federal Election Commission received a complaint which indicates that Lowndes for Congress '92 ("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 3642. Please refer 'to this number in all future correspondence. CUnder the Act, you have the opportunity to demonstrate in writing that no action should be taken against the Comittee and you, as treasurer, in this matter. Please submit any factual or O. legal materials which you believe are relevant to the Comission's analysis of this matter. Where appropriate, 0% statements should be submitted under oath. Your response, which should be addressed to the Gezieral Counsel's Office, must be submitted within 15 days of receipt of this letter. If no response is received within 15 days, the Comission may take further action based on the available information. C This matter will remain confidential in accordance with 2 U.S.C. S 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 Comission 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. Delwyn Amerine, Treasurer Lowndeu for Congress '92 Page 2 If you have any questions, please contact Craig D. Reffner, the attorney 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,

Lisa E. Klein Assistant General Counsel Enclosures 1. Complaint 2. Procedures CN 3. Designation of Counsel Statement

Ncc: Kenneth Louis Lowndes NO

C: FEDERAL ELECTION COMMISSION ASHIGTO% DC 2046

October 7, 1992 St. Rose of Lima Church 4th & Kings Highway Haddon Heights, NJ 08035

RE: MUR 3642

Dear Sir or Madam: The Federal Election Commission received a complaint which indicates that the St. Rose of Lima Church ("Church") 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 3642. 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 Church in - this matter. Please submit any factual or legal materials which a. you believe are relevant to the Cossission'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 subbitted within 15 days of receipt of CD this letter. If no response is received within 15 days, the Commission may take further action based on the available information. C, This matter will remain confidential in accordance with 2 U.S.C. 5 437g(a)(4)(B) and 5 437g(a)(12)(A) unless you notify the Commission in writing that you wish the matter to be made public. If you intend to be represented by counsel in this matter, please advise the Commission by completing the enclosed form stating the name, address and telephone number of such counsel, and authorizing such counsel to receive any notifications and other communications from the Commission. St. Rose of Lima Church Page 2 If you have any questions, please contact Craig D. Reffner, the attorney 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,

Lisa E. Klein Assistant General Counsel Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement

rN ***-LOWNDtS FOR CONGhSS '92***

@vwwdthmrv~wrembk~dwwc~ywoo 10I *dk. wM&Ak arm hm h shepuvauds ujitrdimdhime4ok wtun 40"C -,-mat Umf a Gdb owd ba,& Am God k Gd " -manu L L~dm At,e meflpOt aJm IV O T E F-- 0 DS 0O LI F E A P . B O 1 21: -e O FIE L N 0 8 0 3 3 ( 6 0 9 ) -4 8 6 1 4 1

20 October 1992

Federal Election Comission Washington DC 20463 Attn: Lisa E. Klein Assistant General Coumsel RE: NUR 3642

DIear Ms. Klein: C..i

Then flier that is the siihect nf this cnmniaint Wli itr cm from this arynittee. It was not asked for by this xrr-nittee, was not sutunitted to us for cousel, was not reproduced by this committee, nor was it put out anywhere by,- this cowmittee. CA

With regard specifically to S.Rose of Lima Catholic Church in Haddon Heights, tn New Jersey, where according to the complaint the flier was found inserted in a Sunday leaflet, neither this ccrnittee nor any individual known to us either contacted or was in so much as a position to contact anyone there about any such insertion or any involwvent of the church at all.

0Weare glad to cooperate with you in any way you need for enforceent of the federal election laws.

Sincerely yours,

rea or Congress '92

' ..

.2 - l7z2 I**

LAw Opvicas MCKERNAN, MCKERNAN & GODINO j io , 113 NORTH SIXTH STREET i ''

CAMDEN, NEW JF.RSET 08102-1269

MARTIN F. MCKERNAN TELEPHqONE (6O) 004-7759 IN REPLY PLEASE REFER TO MAirTInP F. MCKERNAN. JR. AX (600) 0.4-0620 TAMES J. Gowno.,JR. October 29, 1992 #2084

Lisa E. Klein, Esquire Assistant General Counsel c- N) Federal Election Commission Washington, D.C. 20463 %S

Re: MUR 3642

Dear Ms. Klein:

Please be advised that this office represents St. Rose of Lima Catholic Church in Haddon Heights, New Jersey. Your letter of October 7, 1992, to the Church was referred to me and I wish to apologize for not having responded earlier but I was away when it arrived.

I enclose herewith an affidavit of Monsignor Richard J. Callahan who is the pastor of the Church in which he notes that no such insert was ever placed in the parish bulletin as alleged. Monsignor has advised me that the first time that he saw the flyer - and indeed the first time that he heard of Ken Lowndes - was when he was advised of the complaint which had been filed with your office.

I am also enclosing a completed Designation of Counsel form.

I trust that you will not hesitate to contact me if you have any further questions or comments in this regard.

With thanks for your attention to this matter, please allow me to remain

ery truly your ,

MARTIN F. McKERNAN,

encls.

(VIA FEDERAL EXPRESS) ~4w - 6~

STATEMENT OF DESIGNATION OF COUNSEL

MUR 3642

NAME OF COUNSEL: Martin F. McKernan, Jr.

ADDRESS: McKernan, rcKernan & Godino, Esquires 113 North Sixth Street

Camden, New Jersey 08102-1269

TELEPHONE:(6 0 9 ) 964-7-759

The above-named individual is hereby designated as my

counsel and is authorized to receive ant notifications and other

communications from the Commission and to act on my behalf

before the Commission.

Oct.29. 1992 Date Signature Richard J. Callahan Pastor

St. Rose of Lima Church RESPONDENT'S NAME:

Highway ADDRESS: Fourth Avenue and Kings Haddon Heights, New Jersey 08035

TELEPHONE: HOME(609 547-0564

BUSINESS( IsareI STATE OF NEW JERSEY ) as: COUNTY OF CAMDEN )

Monsignor Richard J. Callahan, of full age, being duly sworn according to law, upon his oath deposes and says: 1. I am the pastor of St. Rose of Lima Catholic Church in Haddon Heights, New Jersey. 2. I have served in this capacity sinco 1979 and I am completely familiar with the operations and activities of the parish and with the facts and matters contained herein. 3. I have reviewed the letter to the Federal Elect 7 Zonr~ssion from the National Organization for women of New Jerse wherein it is alleged that "the August 9, '992 regular cnur:r tuletin of St. Rose of Lima Church in Haddon Heights, N.'." !:nta.ned an insert encouraging individuals to vote for one Ken Lowndes who I now understand is seeking election to t.7e Un~ted States Congress.

4. The regular church bulletins of St. Rose of l:a Th.rc contain special inserts approximately forty times a ,-ear. However there has never been an insert encouraging persons to vote for Mr. Lowndes and, indeed, there was no insert of any CC) kind in the church bulletin of August 9, 1992. 5. I had never even heard of Mr. Lovndes until I 'C received the letter from the Federal Election Comission advising 0me that a complaint had been filed in this regard.

RICHARD J. CALLAHAN

CK Sworn to and subscribed before me an attorney-at-law of the State of C . New Jersey, on October 29, 1992

JAMES J. GODINO; JA. MUR # 3 46

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

Oa FEDERAL ELECTION COMMISSION VASHf%CTO% DC .'04b3

THIS IS THE END OF UR #

DATE FILMED IRL2114--aCAWRA ,NO. 0 CAMERAMAN -¢ wi,: ,,ii'

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

2. Memo, General Counsel to the Commission, dated April 14, 1993. Subject: Kuforcement Priority System. See Reel 354, pages 1595-1620. 3. Certification of Comtission vote, dated April 26,* 1ff3. See Reel 354, pages 1621-22. 4. Geueral Counsel's Report, In the Mattter of lkftoeu t Priority[, dated December 3,-l993. . Seeflel 354, pages 1623-1740..

5.C.ieino m . oe ae '%D.f ?; .k;, See Usel 34, p"ge 1741.1746...... Z*3~."'

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~etmslOtaisetion for Women of Rlev Jersey Trenton, BJ 0608

33: NUR 3642 Doer Us. Terry:

oe Ootor s,* l~, * te ted. cal 3l to C~omeoe receivd Jct of 9-, as ammied (-tbe~ I }t~.

.. .. , 4: .

Craiy D. 3o~ftmr 2' Attorney

AttacintUsmrtative

Date the Cemi/msion voted to close the file: DEC 0, , 9 vom csinlss

,. . , OtganisatlonThis matter of Womenarose of by New a complaintJersy alleging filed bythat the aNational flyer isn : support of Ken Lovndes' 1992 Congressional campaign / was distributed during the August 9, 1992 service at the iii ina St. loes of church. The bulletin does not met the FICA's disclaimr ~requirements. The Comittee has denied any involvement preparing in or distributing the flyer. Zn a signed affidavit, the Ronsignor of St. Rose of Lima has denied ~question that the flyer in was distributed during the church's August 9, 1992 se rv ice.

This case involves inexperienced players, amount no substantial of money, had little or no impact on the process and does not present any significant issues relative to the other issues pending before the Commission.

p 4~ j ~z4~ -~ :i!i! : : :,:,iii.

'WAS#4INCTO& 0 C ~

Relernan,Naftin F. Nc~ltonam,Mlclternan e Jr.,Godino, 35g. IsJquirtes 113 Worth Sixth Street Camen, NJ 00102-1269

lRt: WUR 3642 St. Rose of Line Church

Dekar Hr. Rlernan:

Fyourederal clientsOn SlectionOctober of a7, complaint1992, the allegingFederal certainSlection violationsCommission ofnotified the campaign Act @f 197 * s emended. A cop of the complaint ws. enclooed vith that notification.

pp~g W3~Ik WW #4 the S1E ~ If you hews aip ~ ~l~se ~~sct ~ *t 4~~) 21).34~.

Sincerelyr,

Craig D. Reffner -~ Attorney Attachment Narrative

Date the Comeission voted to close the file: ~ ii i This mtter arose by a complaint filed by the National Oryanisatlon of Women of Bow Jersey alleging that a flyer in support of Ken Lovndes' 1992 congressional campaign was distributed during the August 9. 1992 service at the St. Rose of Lisa church. The bulletin does not meet the PSCA's disclaimer requirements. The Committee has denied any involvement in preparing or distributing the flyer. In a signed affidavit, the Nonsignor of St. Rose of Lisa has denied that the flyer in question vas distributed during the church's Auqust 9, 1992 se rvice. This case involves inexperienced players, no substantial amount of money, had little or no impact on the process and does not present any significant issues relative to the other issues pending before the Commission. * A"i i ! / i *: :

i . forCongress ,93 t, 0 Sox 131 Saddonfield, NJ 06033

RB: NURq 3642 Dear Hr. Amerine: On October 7, 1992, the Federal Lovades Election Commission notified for Congress '92 and you, as treasurer, of a complaint alleging certain violations of the Federal Election of 1971, Campaign Act as amended. A copy of the complaint vas enclosed with that notification. , . " After canasderin the cireumjtoese of this matter, th ... ".. t e4 t e .m its prect i M4to

~ otk oattma...... fr...r~s U ~w~a

'Sraig" D. Re"ner tttorne

Ifyotta ay utins leseCntttm N19rat00.

DateComissin he votd Snclerte ley, - susllmus tom conumas .... This mtter arose by a compLaint filed by Organization the National of Woenh *of tiev Jersey alleging that a flyer in support of Ken Lovndes, 1992 congressional campaign was distributed during the August 9, 1992 service at the Lima St. Robe of church. The bulletin does not meet the FECA's disclaimer requirements. The Committee has denied preparing any involvement in or distributing the flyer. In a signed affidavit, the Ronhignor of St. Rose of Lima has denied that the question flyer in vas distributed during the church's August 9, 1992 service. This case involves inexperienced players, amount no substantial of money, had little or no impact on the process and does not present any significant issues relative to the other issues pending before the Commission.