FEDERAL ELECTION COMMISSION WASHING TON, 0 C 20463

THIS ISRhE BG1U10% OF M1JR #

DATE FILMED ff/ CAW-RA NO$ A

CAERA if14 4, - 4 93 DEC 21 Oft 10: 9

December 20, 1993 Federal Elections Commission office of General Counsel 999 E. Street, N.W. Washington D.C., 20463 Dear Gentlemen: I wish to file a complaint against Assemblywoman Andrea Seastrand for use of State Campaign funds to finance advertising potentially benefitting her federal campaign efforts. On or about September 12, 1993 Ns. Seastrand, a California State Assemblywoman,, announced her intentions to seek the office of United States Representative to the 22nd Congressional District of California.

on or about September 10, 1993 Assemblywoman Seastrand began running radio advertisements urging constituents to register to vote and later to get out and vote in the upcoming elections. In ) the commercial (copy provided) she identifies herself as "Assemblywoman Andrea Seastrandw and closes by stating "Paid for by Friends of Assemblywoman Andrea Seastrand." The commercial makes no reference to No. Seastrand's intentions to seek the Congressional seat. The commercial however,, was heavily run on radio stations throughout San Lisi Obispo and Northern Santa Barbara Counties well after she announced her intentions to run for Congress and could potentially benefit her federal race, all being paid for with state campaign funds. on approximately October 10, 1993 the Stoker for Congress Campaign Manager, Tim Staffel, asked Ms. Seastrand to "cease and desist" running these advertisements as his reading of the applicable law, as codified in the Code of Federal Regulations, seemed to suggest that it is unlawful to use moneys deposited into a campaign account earmarked specifically as a state office holder on any activities which could benefit efforts to win the congressional seat. Ms. Seastrand refused and the commercials continued to run through the November election.

The ads ran from September through the first week of November 1993 on stations in San Luis Obispo County and Northern Santa Barbara County which featured the Rush Limbaugh show (KUJHL, KPRL, KGLO). Ms. Seastrand's used Suggs and Lombardi as the advertising agent to purchase the ads and all ads were paid for by Friends of Assemblywoman Andrea Seastrand. The commercial clearly identifies Assemblywoman Seastrand urging constituents to vote and clearly states that the commercial was paid for by Friends of Assemblywoman. This appears to be in violation of the Federal Elections Commission's rules against using state campaign funds to finance or benefit a federal election. These statements are based upon personal knowledge and from speaking with members of the Stoker for Congress campaign (candidate, campaign manager and campaign coordinator) who share my same concern that Ms. Seastrand is using state funds to benefit her federal efforts. It is my hope that the Federal Election commission will look into these expenditures and resolve the situation as expeditiously as possible.

I, Stephen Anderson, residing at 1094 Old Mill Road, Santa Maria, CA, 93455 swear under the penalty of perjury, these statements to be true and correct except as to those things stated on information and belief as to those things I believe them to be true. Executed this 20th day of December, 1993 at Santa Maria, California.

k ~ 'irelf) I

S, hen Anderson FEDERAL ELECTION COMMISSION

pAHNIN M DECEMBER 23, 1993

Stephen Anderson 1094 Old Hill Road Santa Maria, CA 93455

Dear Mr. Anderson: This is to acknowledge receipt on December 21, 1993, of your letter dated December 20, 1993. 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 not&rizeT. Your letter did not contain a notarization on your signature. 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 a* on this ___day of 0 19 .0 A statement by the notary that the comlaint was sworn to Wi-d subscribed beforehim/her also will be sufi cient. 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 requirements are fulfilled. See 2 U.S.C. 5 437g. Enclosed is a Commission brochure entitled 'Piling a Complaint.' I hope this material will be helpful to you should you wish to file a legally sufficient complaint with the Commission. If you have any questions concerning this matter, please contact me at (202) 219-3410. Si cerely,

Retha Dixon Docket Chief

Enclosure cc: Friends of Assemblywoman Andrea Seastrand FEDERAL@ OcI O73 LAW OFFICES OF 40~441SS N~ om STEPHEN P ANDERSONMA" A PNOFEH9IONAL CORtPORATION ,

201 SOUTH MILLER STREET SITF 107 (805) 349-20g SANTA MARIA. CALIFORNIA 93454 FACSIMILE (805) 340-2003

January 5, 1994 Federal Elections Commission Office of General Counsel

999 E. Street, N.W. - Washington D.C., 20463 C Dear Gentlemen: I wish to file a complaint against Assemblywoman Andrea Seastrand for use of State Campaign funds to finance advertising potentially benefitting her federal campaign efforts.

on or about September 12, 1993 Ms. Seastrand,, a California State C Assemblywoman,, announced her intentions to seek the office of 7 United States Representative to the 22nd Congressional District of California. on or about September 10,, 1993 Assemblywoman Seastrand began running radio advertisements urging constituents to register to vote and later to get out and vote in the upcoming elections. In the commercial (copy provided) she identifies herself as "Assemblywoman Andrea Seastrand" and closes by stating "Paid for by Friends of Assemblywoman Andrea Seastrand."

The commercial makes no reference to Ms. Seastrand's intentions to seek the Congressional seat. The commercial however, was heavily run on radio stations throughout San Luis Obispo and Northern Santa Barbara Counties well after she announced her intentions to run for Congress and could potentially benefit her federal race, all being paid for with state campaign funds. on approximately October 10, 1993 the Stoker for Congress Campaign Manager, Tim Staf fel, asked Ms. Seastrand to "cease and desist" running these advertisements as his reading of the applicable law, as codified in the Code of Federal Regulations,, seemed to suggest that it is unlawful to use moneys deposited into a campaign account earmarked specifically as a state office holder on any activities which could benefit efforts to win the congressional seat. Ms. Seastrand refused and the commercials continued to run through the November election. The ads ran from September through the first week of November 1993 on stations in San Luis Obispo County and Northern Santa Barbara County which featured the Rush Limbaugh show (KUHL, KPRL, KGLO). Ms. Seastrand Is used Suggs and Lombardi as the advertising agent to purchase the ads and all ads were paid for by Friends of Assemblywoman Andrea Seastrand. The commercial clearly identifies Assemblywoman Seastrand urging constituents to vote and clearly states that the commercial was paid for by Friends of Assemblywoman. This appears to be in violation of the Federal Elections Commission's rules against using state campaign funds to finance or benefit a federal election. Those statements are based upon personal knowledge and from speaking with members of the Stoker for Congress campaign (candidate, campaign manager and campaign coordinator) who share my same concern that Ms. Seastrand is using state funds to benefit her federal efforts. It is my hope that the Federal Election Coimmission will look into these expenditures and resolve the situation as expeditiously as possible. ON., I, Stephen Anderson, residing at 1094 Old Mill Road, Santa Maria, C', CA, 93455 swear under the penalty of perjury, these statements to be true and correct except as to those things stated on information C' and belief as to those things I believe them to be true. o Executed this 5th day of January, 1994 at Santa Maria, California.

C)

'-Stephen Anderson

CERTIFICATE OF ACKNOWLEDGMENT

:state of California U:1. ______- h orme Pamela______R._____Haas ____

~~Sant Barbara -/ RIa pct!Stephen P. Anderson

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: -tin% S hdind and of ficial seal.

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FEDERAL ELECTION COMMISSION WASHING TON. D C 2M*3

JANUARY 10. 19q4

Stephen P. Anderson 201 South Miller Street Suite 107 Santa Maria, CA 93454 Dear Mr. Anderson: This is in response to your letter dated January 5, 1994t concerning Assemblywoman Andrea Seastrand. Although your letter is now notarized and states that it vas sworn to under penalty of perjury, it still fails to meet the requirements for a legally sufficient complaint. As we explained to you in a letter dated December 23, 1993, you must swear before a notary that the contents of your complaint are true to the best of your knowledge, and you must sign the complaint in the presence of a notary. The notary must alslo indicate as part of the lurat that the complaint was signed and sworn to in her presence. For tHis reason, the preferred torn is: wSubscribed and sworn-to before se on this day of 1 1994.0 Although a statement by the notary thatE-Me complal-hE was sworn to and subscribed before her is also sufficient, there is no indication in your letter or the Acknowledgment that the complaint was sworn to and signed in the presence of the notary. We regret any 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 requirements are fulfilled. See 2 U.S.C. 5 437g. if you have any questions, please contact Naura, Callaway, Special Assistant, at 202-219-3690.

Sincerely, Lawrence M. Noble General Counsel

,-L~ BY: Lois G. /Lerner Associate General Counsel LAW OFFICES OF STEPHEN P ANDERSOIjI 94'~9JAV 2,-j o A PROFESSIONAL Cori4S()ATION 3T

20)1 SouTH MILLHHU STREET SUITE 107 (805) 349-2009 SANTA MARIA. C;ALIFORNIA 93454 FACSIMILE (805) 340-2093

January 20, 1994 mriu 55 j Federal Elections Commission office of General Counsel 999 E. Street, N.W. Washington D.C., 20463 Dear Gentlemen: I wish to file a complaint against Assemblywoman Andrea Seastrand 'N for use of State Campaign funds to finance advertising potentially benefitting her federal campaign efforts. on or about September 12, 1993 Ms. Seastrand, a California State Assemblywoman,, announced her intentions to seek the office of United States Representative to the 22nd Congressional District of California. on or about September 10, 1993 Assemblywoman Seastrand began running radio advertisements urging constituents to register to vote and later to get out and vote in the upcoming elections. in the commercial (copy provided) she identifies herself as "Assemblywoman Andrea Seastrand" and closes by stating "Paid .'Por by Friends of Assemblywoman Andrea Seastrand." The commercial makes no reference to Ms. Seastrand's intentions to seek the Congressional seat. The commrcial however, was heavily run on radio stations throughout San Luais Obispo and Northern Santa Barbara Counties well after she announced her intentions to run for Congress and could potentially benefit her federal race, all being paid for with state campaign funds. on approximately October 10, 1993 the Stoker for Congress Campaign Manager, Tim Staffel, asked Ms. Seastrand to "cease and desist" running these advertisements as his reading of the applicable law, as codified in the Code of Federal Regulations, seemed to suggest that it is unlawful to use moneys deposited into a campaign account earmarked specifically as a state office holder on any activities which could benefit efforts to win the congressional seat. Ms. Seastrand refused and the commercials continued to run through the November election. The ads ran from September through the first week of November 1993 on stations in San Luis Obispo County and Northern Santa Barbara County which featured the Rush Limbaugh show (KUHL, KPRL, KGLO). Ms. Seastrand'Is used Suggs and Lombardi as the advertising agent to purchase the ads and all ads were paid for by Friends of Assemblywoman Andrea Seastrand.

The commercial clearly identifies Assemblywoman Seastrand urging constituents to vote and clearly states that the commercial was paid for by Friends of Assemblywoman. This appears to be in violation of the Federal Elections Commission's rules against using state campaign funds to finance or benefit a federal election. These statements are based upon personal knowledge and from speaking with members of the Stoker for Congress campaign (candidate, campaign manager and campaign coordinator) who share my same concern that Ms.- Seastrand is using state funds to benef it her federal efforts. It is my hope that the Federal Election Commission will look into these expenditures and resolve the situation as expeditiously as possible. I, Stephen Anderson, residing at 1094 Old Mill Road, Santa Maria, CA, 93455 swear under the penalty of perjury, these statements to be true and correct except as to those things stated on information and belief as to those things I believe them to be true. Executed this 20th day of January, 1994 at Santa Maria, California.

S~nc rel

Lbscribed and sworn to before me on this 20th day of January, 1994.

MtLA R. HAAS )tary Public 4 -4 J 6 0 r) I I

0

CERTIFICATE OF ACKNOWLEDGMENT

Stale of California n dat)borm, Pmea(oa)- Co~~in01BararofZ94 before Pamela2094__R. Haas CS oa nu t na t yB a or bf a r a I o a l y a p p e air e d__ - _~n -- _ _

I D~eaLI~iI&*~ x~rsonaIly * r Comm known to me (or proved to Com . 9604394HAA roe on the basis of' satisfaictory: evidence) to be the person(s) whose ~O TARY PUF1IC CALIFORNIA name(s) is/are subscribed to instrument and acknowledged go me the within: a. Sat, arbva that he/she/they executed the same in: CommE~,gsCuunlryul 51 g6 3 ~ his/hter/their authorized capacity(ies). and that by his/her/their signature(s) on the instrument the person(s), or the entity uo eafo hc h person(s) aced execute the whitrumtht my hand andofficial s-- l

* 's Signature FEEA ELECTION COMMISSION A~ASHINC0% DC 20-%1

JANUARY 31,. 1994

Stephen P. Anderson 1094 old Hill Road Santa Mlaria, CA 93455

RE: MUR 3855

Dear Mr. Anderson: This letter acknowledges receipt on January 21, 1994, of your complaint alleging possible violations of the Federal Election Campaign Act Of 1971, as amended ("the Act"), by Andrea Seastrand, Friends of Andrea Seastrand for Congress and Pete Agalos as treasurer, Friends of Assemblywoman Andrea Seastrand and Charles Storm, as treasurer, and Suggs and Lombardi. The respondents will be notified of this complaint within five days. You will be notified as soon as the Federal Election Commission takes final action on your complaint. Should you receive any additional information in this matter, please forvard it to the Office of the General Counsel. Such information must be sworn to in the ese manner as the original complaint. we have numbered this matter MUR 3855. Please refer to this number in all future communications. For your information, we have attached a brief description of the Commission's procedures for handling complaints. Sincerely,

Mary L. Taksar, Attorney Central Enforcement Docket Enclosure Procedures 0"0

FEDERAL ELECTION COMMISSION

JANUARY 31, 1994

Andrea Seastrand c/o Friends of Andrea Seastrand for Congress 626 Evans Road San Luis Obispo, CA 93401 RE: SlUR 3855

Dear Ms. Seastrand: The Federal Election Commission received a complaint which indicates that you may have violated the Federal Election Campaign Act of 1971, as amended ('the Act'). A copy of the complaint is enclosed. We have numbered this matter SlUR 3855. 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 matter. Please, submit any factual or legal materials which you believe are relevant to the Commission's analysis of this matter. Where appropriate, statements should be submitted under oath. Your response, which should be addressed to the General Counsiells, Office, must be submitted within 15 days of receipt of this letter. If no response is received within 15 days, the Commission may take further action based on the available information. This matter will remain confidential in accordance with 2 U.S.C. 5 437g(a)(4)(8) and I 4379(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. Andrea Beastrand Page 2

If you have any questions, please contact Joan McEnery at (202) 219-3400. For your information, we have enclosed a brief description of the Commission's procedures for handling complaints. Sincerely,

Mary L. Taksar, Attorney Central Enforcement Docket Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement ~ FEDERAL ELECTION COMMISSION

JANUARY 31, 19'94

Charles Storm, Treasurer Friends of Assemblywoman Andrea Seastrand c/o Friends of Andrea Seastrand for Congress Comitte 626 Evans Road San Luis Obispo, CA 93401 RE: HUR 3855

Dear Mr. Storm: The Federal Election Comission received a complaint vhich CD indicates that Friends of Assemblywoman Andrea Seastrand ("Committee") and you, as treasurer, may have violated the Federal Election Campaign Act of 1971, as amended ("the Act"). C:) A copy of the complaint is enclosed. We have numbered this matter HR 3655. Please refer to this number in all future correspondence. Under the Act, you have the opportunity to demonstrate in writing that no action should be taken against the Committee and you, as treasurer, in this matter. Please submit any factual or legal materials which you believe are relevant to the Commission's analysis of this matter. Where appropriate, statements should be submitted under oath. Your response, which should be addressed to the General Counsel's office, must be submitted within 15 days of receipt of this letter. If no response is received within 15 days, the Comission 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 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. Charles Storm, Treasurer rriends of Assemblyvoal Andrea Seastrand Page 2

if you have any questions, please contact Joan Enery at (202) 219-3400. For your information, we have enclosed a brief description of the Commission's procedures for handling complaints. Sincerely,

Nary L. Taksar, Attorney Central Enforcement Docket

Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement -TM FEDERAL Ft -FCTION COMMISSION

Wn JANUARY 31. 1994

President Suggs and Lombardi 520 Higuera Street San Luis Obispo, CA 93401 RE: MUR 3855

Dear Sir or Mladam: The Federal Election Commission received a complaint which Indicates that Suggs and Lombardi 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 11UR 3855. 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 Suggs and Lombardi in this matter. Please submit any factual or legal materials which you believe are relevant to the Commissionvs analysis of this matter. where appropriate, statements should be submitted under oath. Your response,, which should be addressed to the General Counsel's Office, must be submitted within 15 days of receipt of this letter. If no response is received vithin 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)(9) and 5 437g(a)(12)(A) unless you notify the Commission in writing that you wish t.- 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. president Suggs and Lombardi wpage 2

if you have any questions, please contact Joan McEnery at (202) 219-3400. For your infornation, we have enclosed a brief description of the Comaissionls procedures for handling complaints. Sincerely,

Mary L. Taksar, Attorney CO Central Enforcement Docket

Enclosures c 1. Complaint 2. Procedures 0 3. Designation of Counsel Statement FEDFRAL ELECTION COMMISSION

AASH\ ION. DC .104W

11wo)oI JANIJARY 31,. 1994 Pete Agalos, Treasurer Friends of Andrea Seastrand for Congress 626 Evans Road San Luis Obispo# CA 93401

RE: NUR 3855

Dear Mr. Agalos: The Federal Election Commission received a complaint which indicates that Friends of Andrea Seastrand for Congress (*Comittee*) and you, an 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 3855. Please refer to this number in all future correspondence. Under the Act, you have the opportunity to demonstrate in writing that no action should be taken against The Committee and you, as treasurer, in this matter. Please submit any factual or legal materials which you believe are relevant to the Comission's analysis of this matter. Where appropriate, statements should be submitted under oath. Your response, which should be addressed to the General Counsel's office, must be submitted within 15 days of receipt of this letter. if no response is received within 15 days, the Commission may take further action based on the available information. This matter will remain confidential in accordance with 2 U.S.C. 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 fromi the Commission. Maq 0 0

Pete Agalos, Treasurer Friends of Andrea Seastrand for Congress Page 2

If you have any questions, please contact Joan Nctnery at (202) 219-3400. For your information, we have enclosed a brief description of the Commissionl's procedures for handling complaints. Since rely,

Mary L. Taksar, Attorney Central Enforcement Docket

Enclosures 1. Complaint 2. Procedures 3. Designationl of Counsel Statement LAW OFFICES OF .E )EnAp LLI Ctm " S s' STEPHEN P. ANDERSON A'A1 i(t %0 A PR()PS89IONA1. rORPORATIONI

201 SOUTH MILLER STIREET Fa ZZ 3Q01 1II SU1ITX 107 " ' (805) 349-2099

.SANTA MARIA. GA*LYFORNIA 93454 FACSIMILE (805) 340-289:3

February 9, 1994 Federal Elections Commission Office of General Counsel 999 E Street. N.W. Washington D.C., 20463 RE: Complaint # MVR3855 Dear Sir: I have recently spoken with Congressional candidate Michael Stoker of the 22nd Congressional District in California concerning the

- complaint I have filed with your office against Andrea Seastrand et al. During that discussion,, Mr. Stoker expressed appreciation to me for being willing to speak out in favor of fair election practices and acting to ensure all candidates conform their conduct to the appropriate elections laws. However, Mr. Stoker also noted that campaigns should be based upon issues and then asked if I would be willing to withdraw my complaint. I told him that I would do so. I therefore,, am formally requesting that the Federal Elections Commission withdraw my complaint from further consideration or investigation at this time. I will, of course, reserve the right to ref ile it or another suitable complaint against any candidate as I believe very strongly in fair election practices and in the work your agency does to enforce those rules. Executed this 10th day of February,, 1994 at Santa Maria, California.

Sipcerely yours,

k.I' / jJ St~phen P. Anderson

Subscribed and sworn to before me on this 10th day of February, 1994.

F4AY[LAR.11AAS6 PAMELA R. HAAS '040 a NOTARY PUBLI C-CAbFONNA Santa &BiairaCx-IJ VyNCwm. Expres 1 E O)P-c- /Y? 0]

SUGGS. LOMBARDI ADVERTISING 520 HIGUERA. SAN LUIS O845M,~ CA 93401 P-4E 805(544-9220 - FAX 805544-5627 4?4?

Federal Election Commission Washington, D.C. 20463 Attention: Ms. Mary L. Taskar, Attorney, Central Enforcement Docket

Februarv 14, 1994 C"' In response to your 1/31/94 letter, Suggs, Lombardi Advertising was hired by the Friends of Assemblywoman Andrea Seastrand to produce radio commercials that encouraged voter registration and voter participation at the polls.

There were no references what so ever regarding Mrs. Seastrand's potential congressional bid in the commercials. The commercials were designed to educate listeners about the upcoming November 2,1993 special election and specifically address issues of interest on the ballot.

Suggs, Lombardi Advertisiilg produced the commercials and purchased! the air time. This was the sole involvement of my agency.

Attached are copies of the scripts for the spots that aired. If you have any further questions, please don't hesitate to communicate them.

Sin r,1

Stephen Lomnbardi Owner, Sg, Lconibardi Advertizin S S F LAW OPWICES OPr , P1 BAGATELOS & FADEM Af 4 THE INTERNATIONAL BUILDING -Wa*HONE BARRY FAOEIM 601 CALI1FORNIA STREET (415) 962-7100

PETER A. SAGATE LOS SUITE lot S? tow SAN FRANCISCO. CA4 :rORNIA 94100 (415) 2 5 February 15, 1994

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

Attn: Joan McEnery

Re: MUR 3855

Dear Ms. McEnery:

Pursuant to our conversation of February 14, 1994, this is a request for a twenty (20) day extension of time in which to file a response to the Commission's RTB finding in the abovementioned matter for the reasons set forth below. You advised that this letter and the Designation of Counsel Form could be sent by fax to you.

First, our firm was retained by the r-p-let Andrea Seastrand and her committees on February 12, 1994. T-he RTB response is due to the Commission by February 20, 1994. This does not permit sufficient time to be able to gather all the relevant facts and materials from my client and review such materials, research applicable legal authorities and draft an adequate response to the alleged violations.

Secondly, there are multiple related parties which have been asked to respond to the Commission under this MUR. I need additional time to confer with said parties and confirm their approval in writing that this firm may represent all parties in the interest of time and cost efficiencies. Based on these very reasonable reasons, I respectfully request a twenty (20) day extension of time, to March 12, 1994 in which to make a response to the Commission's RTB fmidings.

Thank you for your cooperation on this issue.

Very truly yours,

Peter A. Bagatelos PAB:bz cc: Hon. Andrea Seastrand weastran .215fec h~r

I B 0

STATEMENT 0r DESIGNATION Or COUNSEL

HU 3.s NAME OF COUNSEL: Peter A. Bagatelos

ADDRESS: Blaaatelon ~ 601 California Street, Suite 1801

San Francisco, CA 94108

TrELEPHONE:( 415 ) 982-7100

designated as my The above-flamed individual is hereby any notifications and other counsel and is authorized to receive to act on my behalf communications from the Commissionl and before the commissioni. K 2-11-94 Signature ( Date signature

Andrea H. Seastrand RESPONDENTOS NAME:

P.O. Box 14004 ADDRESS: San Luis-Obispo, CA 93406

TELEPHONE: HOME

BUSINESS( 80 549-3381 STATEMENT Of DESIGNATION or COUNSEL

MURa5j.A C; NAME or COUNSEL:* Pete A.:)~t1s

ADDRESS: Bagatelos & Fadeni

601 California Street, Suite 1801

San Francisco, CA 94108

TELEPHONE: (4159 qEl-7 1 QQ

designated as my The above-named individual is hereby notifications and other counsel and is authorized to rieceive any to act on my behalf communications frcom the Commission and before the Commission.e

Signature Date

Mi-ldred Dostalek RESPONDENT'S NAMiE:

2375 Del Camnpo- ADDRESS: San Luis Obispo, CA 93401

TELEPHONE: HOME BUSINESS( n/a STATEMHENT OT-DESIGNATION 0F COUNSEL

MR 3855

MAKE OF COUNSEL.' Peter A. Bagatelos

-Ci ~Z.~ ADDRESS: Bagatelos Fde 1801 601 California Street, Suite

San Francisco, CA 94108

TELEPHONE:( 4.1s5 R-1f

designated as my The above-named Individual is hereby any notifications and other counsel and is authorised to receive and to act an my behalf communications from the Commission before the Commissiont. 4 e) 2-11-94 s IgVftue ,q- oate

te Agalos RESPONDENTPS NAME: Pe

626 Evans Road ADDRESS: San Luis Obispo, CA 93401

TELEPHONE: HOME BUSINESS( fl/a STATEIEXT CF CESIONATION OF COUNSEL

MUR 3855 C.tA - NAME OF COUNSEL6-' Peter A. Baggiatelos

ADDRESS: Baciatelps & Fadern 601LCalifri Stet Suite 1801

San FrancCO C 9408

TELEPHONE:( 415.. 92-7100

as my The above-na'd individual is hereby designated notifications and other counsel and is autiorized to receive any to act on my behalf communications fr".2 the Ccz.zSisof and before the Comis~iofl.

3'1 na ture Date

IRESPCN:E-4T;ENA**S M .-res E. Storm,~

-- ; .*ar .ner, Point Way ADDRESS: rernto, CA 95831

TELEPHONE: HOME

BU2SINESS( 4 4-32 60 FEDEFRAL ELECTION COMMISSION

Stephen P. Anderson MA4RCH 11, 199'4 201 South Miller Street Suite 107 Santa Maria, CA 93454 RE: MUR 3855

Dear Mr. Anderson: This is in reference to your letter dated February 9, 1994, requesting that the complaint you filed against Andrea Seastrand and others be withdrawn. Under 2 U.S.C. 5 437g, the Federal Election Commission is empowered to review a complaint properly filed with it and to take action which it deems appropriate under the Federal Election Campaign Act of 1971, as amended ("the Act"). A request for withdrawal of a complaint will not prevent the Commission from taking appropriate action under the Act. Your request will become part of the public record within 30 days after the entire file is closed. If you have any further questions about this procedure, please contact me at (202) 219-3400. Sincerely,

9frInp 8. -M0

Mary L. Taksar Attorney THE~~~~BULON IN6"AICA

LAW OFFICES Or BAGATELOS &FADEM 41ON TEL

BARRY FADEM 601 CALIFORNIA STREET DmId R il e (415) Se1-7100 PETER A. BAGATELOS SUITE 16801 ' FAX SAN FRANCISCO. CALIFORNI1A 94100 (415) 962108O5

March 11, 1994

BY FDRLEPRESS

Lawrence M. Noble, Esq. - General Counsel Federal Election Commission 999 E Street, N.W. Washington, D.C. 10463

RE: MUR 3855

Dear Mr. Noble:

Enclosed please find the Response of Andrea Seastrand; Friends of Assemblywoman Andrea Seastrand and Charles Storm, Treasurer, and Friends of Andrea Seastrand for Congress and Pete Agalos, Treasurer, to your letters to the several respondents, dated January 31, 1994, in the above referenced matter.

Very truly yours,

Peter A. Bagatelos

PAB/mlq Encl. ,castad3 11fec. Itr

cc: Chairman Potter Vice Chairman McDonald Commissioner Aikens Commissioner Elliott Commissioner McGarry Commissioner Thomas BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of )MUR 3855 ANDREA SEASTRAND; )- FRIENDS OF ASSEMBLYWOMAN ) ANDREA SEASTRAND AND) CHARLES STORM, TREASURER; Z FRIENDS OF ANDREA SEASTRAND ) Response To Federal Election Commission FOR CONGRESS AND PETE ) Letters dated January 31, 1994. AGALOS, TREASURER& RESPONDENTS

INTlRODUCTION

This response is submitted on behalf of Andrea Seastrand, Friends of Assemblywoman

Andrea Seastrand and Charles Storm Treasurer ("FAAS"), Friends of Andrea Scastrand for

Congress and Pete Agalos, Treasurer ("FASC"), (hereinafter "Respondents") in response to letters, dated January 31, 1994, from the Federal Election Commission ("FEC" or

"Commission") to the aforementioned parties containing a complaint filed with the Commission by Stephen Anderson, an attorney in Santa Maria, California. A copy of the complaint was received by the Respondents on February 5, 1994. The opportunity to provide information demonstrating that no action should be taken against the Respondents was made available for

15 days, or until February 20, 1994. Based on a request for additional information contained in our letter of February 15, 1994 to the Commission, it is our understanding the Commission granted Respondents a 20 day extension to respond to the Commission's findings. This document is filed in accordance with that extension of time and in accordance with

2 U.S.C.§437g(a)(l). Mr. Anderson, who apparently filed his complaint letter at least three times before it was accepted by the FEC (see letters of December 20, 1993, January 5, 1993, and January 20,

1994), attempts to allege violations of the Federal Election Campaign Act of 1971, as amended

("FECA") by an elected state official who expended state campaign committee funds for radio ads containing a request to register to vote and to vote in a special statewide election in 1993.

There was no reference to, let alone no "express advocacy" of, any federal candidate for any federal election. On behalf of Respondents, we deny all allegations in this complaint in their entirety, on the bases that the complainant has not met his burden of showing facts sufficient under the law to establish that any contribution or expenditure was made by FAAS to influence

FASC. In addition, no facts whatsoever have been tendered to demonstrate the ads expressly advocated the election of Seastrand for Congress, (i.e., the complainant in effect has tendered allegations of wrong-doing under the FECA which basically constitute wishful thinking). it will also be shown that the complainant's filing of the complaint appears to be politically motivated to benefit a third party candidate for Congress. These reasons are explained in more detail in this response. Based on the information provided herein, we respectfully ask that the

FEC make a finding of "tNo Reason To Believe" and close this matter.

1'

DESCRIPTION OF PARTIES

I. Andrea Seastrand is a member of the California State Assembly. She has represented the 33rd Assembly District for the past three years, winning the seat after her husband,, Eric Seastrand, who was the former Assemblyman, passed away. She declared her candidacy for the 22nd Congressional District from California on September 14, 1993, a day after the one-term incumbent, Congressman Michael Huffington, announced that he was giving up his seat to run for the U.S. Senate. (See Declaration of Andrea Seastrand attached hereto as Exhibit A).

2. The Friends of Assemblywoman Andrea Seastrand is officially known as the

Friends of Assemblywoman Andrea Seastrand 33 Club. This is a political committee, organized under the California Political Reform Act of 1974, as amended ("PRA"), and registered with the California Secretary of State's office. Its treasurer as of August 20, 1993 has been Mildred Dostalek, and not Charles Storm. Mr. Storm, a previous treasurer of the committee several years ago, has not served in such capacity during the period under review herein. Under California law, this committee, which originally was created to support the election bid of Seastrand for the State Assembly, has been used to raise and expend funds in support of Seastrand's officeholder functions during her current term of office. Such committees are commonly used by elected officials in California to pay for various items, including communications with constituents on topical issues. Such expenses are permitted under the PRA. (See Declarations of Charles Storm and Mildred Dostalek attached hereto respectively as Exhibits B and C).

3. The Friends of Andrea Seastrand for Congress is a principal campaign committee of Andrea Seastrand. The committee was organized and sent its Statement of Organization.

-3- (FEC Form 1), dated September 14, 1993, to the FEC, which acknowledged receipt of the form

on September 23, 19931 Its FEC identification number is C00284083. Pete Agalos is the

treasurer of this committee. (See Declaration of Pete Agalos attached hereto as Exhibit D).

4. Stephen Anderson is the complainant in this matter. He is an attorney who

maintains offices at 201 South Miller Street, Suite 107, Santa Maria, California 93454.

5. Mike Stoker ("Stoker") is a County Supervisor for the 5th district in the County

of Santa Barbara, State of California. Mr. Stoker is a declared candidate for the 22nd

Congressional District from. California. His principal competition for this seat is Andrea

C~sScastrand. Mr. Stoker maintains offices at 201 South Miller Street, Suite 107, Santa Maria

California, the same office as Stephen Anderson.

N30

FACTUAL SUNMMARY

1. Assemblywoman Andrea Seastrand ("Seastrand") was elected in 1990 to

represent California Assembly District 33. This district encompasses all of San Luis Obispo

County, and the northern third of Santa Barbara County. She is a registered Republican.

2. A special statewide election was called in 1993 by Governor Pete Wilson to be

held on November 2, 1993. There were no federal candidate elections on that ballot. There

-4- W 0 were a number of very important and controversial issues on the statewide ballot that drew substantial attention by the press and interest by the public. These included Propositions 170 and 171, dealing with property taxation, Proposition 172, dealing with extending a half-cent sales tax and earmarking the proceeds for law enforcement, and Proposition 174, a school voucher initiative that would have severely altered the economic underpinnings of public and

pivate education. These measures involved complex issues and substantial public discussion as to their merits and short-comings. Many political leaders and elected officials spoke out with their views as to the effects that these measures would have and whether they should be supported or opposed. This is a commonplace practice for officials to provide leadership to the constituents, who look to them for guidance.

3. Seastrand is a very active assemblywoman, who takes particular interest in providing service to her constituents. She has particular views regarding issues affecting those constituents. Seastrand supports the concept of the free exchange of ideas and voter participation at the polls. As anm elected official, she felt an obligation to provide leadership to her constituents on these controversial statewide measures by expressing her views and encouraging her constituents, through radio ads, to register to vote and to actually vote on those issues.

4. Seastrand retained the services of Suggs, Lombardi Advertising ("Suggs") to produce and place two radio ads. Suggs is an advertising firm which provides such services.

Ad number one, which was made on August 30, 1993, included a description of Assemblywoman Seastrand as the speaker, explained the important issues on the ballot, and encouraged listeners to register to vote so they would have the opportunity to decide the important statewide issues.

Ad number two, which was produced on October 20, 1993, similarly identified

Assemblywoman Seastrand as the speaker, described the important statewide issues facing the voters, and encouraged listeners to vote no matter how they felt on those particular issues.

Transcripts of these ads are attached hereto with the Declaration of Stephen Lombardi under

Exhibit E.

5. The ads made no reference to Andrea Seastrand as a candidate for Congress or to any other candidate or any federal election. They were purely issue oriented, provided in a non-federal election year, and related solely to issues of importance to the citizens on a special statewide election ballot.

6. Suggs was retained to produce the spots and to select the stations and amount of time to purchase. The ads were run on the Rush Limbaugh radio talk show, carried on four different radio stations which have a broadcast area that reaches Seastrand's 33rd Assembly

District. The ads were run on stations KPRL. KUHL, KGLO, and KTMS. Ad number one ran from September I through September 30, 1993. Ad number two ran from October 25 through November 1, 1993. (Copies of the invoices for these advertisements are included herewvith as Exhibit F.) The cost of ad number one was $3,992. The cost of ad number two was $ 1,068. These costs were paid in full by the Friends of Assemblywoman Andrea

Seastrand 33 Club (i.e. the California officeholder committee).

7. Radio station KPRL is located in Paso Robles, California; radio station KUHL

is located in Santa Maria, California; radio station KGLO is located in Arroyo Grande,

California. The foregoing cities are located within the 33rd Assembly District. Radio station

KTMS is located in Santa Barbara, California. This city is not within the 33rd Assembly

District, however based on the recommendation of Suggs, time was purchased on KTMS

because of its audience rating and its programming area reaches well into the Assembly

District. Seastrand attempted to reach her constituents, based on the stations that they were

most likely to listen to, as determined by their location within her Assembly District. Suggs

recommendation was based upon constituents in the southern portion of her Assembly District

being more likely to listen to the Santa Barbara station than to the other stations located more to the north and farther away. The geographic location of the station is irrelevant - its broadcast range, which included the Assembly district, is the much more relevant aspect.

8. The complaint filed by Mr. Anderson. while attempting to allege violations of the FECA, nevertheless acknowledges that: "The commercial makes no reference to Mrs.

Seastrand's intentions to seek the Congressional seat." On that fact alone this case fails to meet the requisite thresholds of a complaint, and should be dismissed. Instead, the complaint, based on some arbitrary standard, attempts to infer that Mrs. Seastrand's protected free speech activities, which are totally unrelated to any federal candidacy or federal election, fall within

the restrictions and prohibitions of FECA and regulations promulgated thereunder.

Mr. Anderson further acknowledges in his complaint that his sworn statements are based

upon personal knowledge and . - . from speaking wkith members of the Stoker for Congress

campaign (candidate, campaign manager and campaign coordinator) who share my same

concern that Mrs. Seastrand is using state funds to benefit her federal efforts." Mr. Anderson

thus is acting on a coordinated basis with Mike Stoker, his campaign representatives, and

others who are promoting Mr. Stoker as a candidate for the 22nd Congressional District seat

from California.

Iv

LEGAL STANDARDS

The issue succinctly framed is whether the text of ad one or ad two constituted an in- kind contribution by FAAS to FASC; the result being an excessive contribution (2 U.S.C.

§441a) and a prohibited contribution (2 U.S.C. §441b) in light of the fact FAAS was a state committee which collected permissible corporate funds.

The general definition of "contribution" is essentially any gift, advance or anything of value for purposes of influencing any election to federal office (2 U.S.C. §431(8)(A).

Corporations are prohibited from making such contributions in connection with any federal

-8- 0 election (2 U.S.C. §441b(a)). A review of the Commission's intepetton of these two statutory provisions in attempts to articulate a standard for review has been ever evolving and currently is viewed as narrowing the specific language eligible to meet the §441lb standard.

(See: FEC February 8, 1994 Agenda Item; MCFL Rulemaking Summar of Comments and

1ffihtinl Rules. The courts clearly are holding that absent express advocacy, there exists no communication which is made in connection with a federal election, thus no violation of

§441lb.

Respondents argue, and the facts clearly reflect, that since there was no reference whatsoever to a federal election, a federal candidate, or generically to a get out to vote in a federal election, there is not a scintilla of evidence proffered to support the express advocacy standard. However, the facts in this matter would not support a violation of §44 l b or

§43 1(SXA) disregarding an express advocacy standard and employing the broadest means test previously applied by the Commission. Without iny reference whatsoever to a federal candidate, or to vote in a federal election, this case lacks even the basics of an innuendo to influence a federal election, and it must fall.

The complainant would have the FEC utilize a standard which would not allow any non-federal officeholder, who might become or does become a candidate for federal office, to engage in any speech or conduct paid for with any funds, not merely a state political committee account, if there is any possibility of exposure by the officeholder to the voters. Complainant would prohibit appearances for such things as charities, business or public office related

-9- matters. This is a very restrictive standard that would be totally at odds with the First

Amendment to the Constitution and with standards established by the courts in a series of preeminent case decisions, discussed below. The Commission has never subscribed to such a standard.

Thus, the legal standard to be applied herein requires very clearly that, for expenditures to fall under the restrictions and prohibitions of the FECA, there must be express advocacy of a candidate for federal office. Vague connections, as the complainant has offered, simply do not meet the test.

This standard was wellI addressed in the case of Federal Election Commission v.

Furgatch 807 F.2d 857 (9th Cir. 1987), in which the court stated:

We conclude that speech need not include any of the words listed in Buckley to be

express advocacy under the Act, but it must, when read as a whole, and with limited

reference to external events, be susceptible of no other reasonable interpretation but as

an exhortation to vote for or against a specific candidate. This standard can be broken

into three main components. First, even if it is not presented in the clearest, most

explicit language, speech is "express" for present purposes if its message is

unmistakable and unambiguous, suggestive of only one plausible meaning. Second,

speech may only be termed "advocacy" if it presents a clear plea for action, and thus

speech that is merely informative is not covered by the Act. Finally, it must be clear

-10- w S

what action is advocated. Speech cannot be "express advocacy of the election or defeat

of a clearly identified candidate" when reasonable minds could differ as to whether it

encourages a vote for or against a candidate or encourages the reader to take some other

kind of action. We emphasize that if any reasonable alternative reading of speech can

be suggested, it cannot be express advocacy subject to the Act's disclosure

requirements.

Furgath. 807 F.2d at 863.

The above standard has been carried forward and strongly reaffirmed in subsequent cases, including Federal Election Commission v. National OMrizan for Woe 713 F.

Supp. 428 (D.D.C. 1989); Faucher and Maine Right to Life Commite Inc. v. Federa Election

Commissio. 928 F. 2d 468 (USCA, First Circuit, 1991), cert. denied, ___U.S.

112 S. Ct. 79 (1991); and FEC v. Survival Education Fund. Inc., 89 Civ. 0347 (TPG) (USDC,

SDNY, 1994).

The Court in Faucher was adamant in its affirmation of the standard when it stated:

Express advocacy is language which "in express terms advocate~sJ the election or defeat

of a clearly identified candidate" ... . This express advocacy test was again embraced

by the Supreme Court in the more recent case of Massachusetts Citizens for Life. See

Massachusetts Citizens for Life, 479 U.S. at 249. The FEC, however, maintains that

the language relied upon in Massachusetts Citizens for Life was mere dictum and

-11- therefore not binding on this court. We do not agree. All nine Justices assented to that

portion of the opinion which states: "We therefore hold that an expenditure must

constitute 'express advocacy' in order to be subject to the prohibition of §441b." Idj

at 249 (emphasis added). We cannot accept that in resolving constitutional issues such

as the one presented in Massachusetts Citizens for Life the Supreme Court proclaim

the law lightly .... In further support of this position, we note that the second and the

ninth circuits have both likewise recognized the express advocacy test. See Fedal

Election Commission v. Central Long Island Tax Reform 616 F.2d 45, 53 (2d Cir.

1980) (section 441d "clearly establish[es] that, contrary to the position of the FEC, the

words 'expressly advocating,' mean exactly what they say"); Federal Election

Commission v. Fugatcb 807 F.2d 857, 860 (9th Cir.), cet den 484 U.S. 850

(1987) ("We must apply [the FECA] consistently with the constitutional requirements

set out in Buckdey').

Fau at 469.

The instant set of facts clearly do not fall within the above applicable standards. The text of the ads did not discuss a federal election, but rather a state election. The purpose was to provide leadership as to certain controversial state ballot issues, to encourage participation by citizens in our democratic voting process, and to encourage particular results as to important statewide issues affecting citizens and taxpayers in Seastrand's Assembly Distnict. These purposes were pursued as to state issues in a purely state election in a non-federal election year for a ballot on which no federal candidates were included.

- I 2- ARGUMENTS

I. COMPLAINANT HAS FAILED HIS BURDEN TO SHOW SUFFICIENT

FACTS UNDER THE LAW TO SUPPORT AN ACTIONABLE COMPLAINT.

Complainant has the burden to present a clear set of facts to the Commission which

demonstrate that a respondent has violated the FECA (11I CFR §Il I.I4(d)(3)). In this case, the

complainant has failed to do so. He offers only rhetoric and innuendo. The complainant acknowledges that Seastrand, a California State Assemblywoman, ... began rnnming radio advertisements urging constituents to register to vote and later to get out and vote in the upcoming elections." In fact, there was only one upcoming election which Seastrand referenced. The complainant conveniently does not mention in Is complaint that the election was purely for statewide issues, involving no federal candidates or elections, and that thee was no solicitation of funds or any advocacy whatsoever for federal candidates in federal elections.

The complainant further acknowledges that Seastrand identified herself as

"Assemblywoman Andrea Seastrand" and that the ads further stated that they were "Paid for by the Friends of Assemblywoman Andrea Seastrand." He further acknowledges that: "The commercial makes no reference to Mrs. Seastrand's intention to seek the Congressional seat."

These are not facts on which a viable complaint can be based. They clearly demonstrate that

Assemblywoman Seastrand was discharging her duties as an officeholder to communicate with

-13- her constituents about issues affecting them as citizens, taxpayers, parents of school children, and property owners and renters, which she and they cared about. Her advocacy was issue oriented and exhorted people to register to vote, to actually vote, to send a message to elected state officials about certain issues, and to influence the manner in which government operated.

This does not come even close to meeting any standard articulated by the Commission, let alone the strict standards for express advocacy described above.

The fact of this complaint being filed at all is unfortunate because it demonstrates how anyone, especiay those who may have personal agendas, may mail a 290 letter and cause

Respondents, as here, to incur substantial expenses to protect their rights. Funds used to conduct research, obtain documents, collect thorough information, and provide this response are funds which are difficult to raise under campaign laws, and which otherwise cannot be used for campaigning. We believe that complainant and his communicants, including Stoker, are well aware of this fact.

Under facts which demonstrate that Stoker is a candidate for Congress for the same seat as Seastrand, that Mr. Stoker is communicating and coordinating with the complainant regarding this matter, and that the two gentlemen share offices in the same building, it is unseemly that the FEC should entertain seriousiy a complaint which very well could have been filed to harass Respondents herein and to force them to allocate precious time and money to address these proceedings, rather than to go about their legally permitted business in an

-14- unfettered manner. The FEC should not allow its enforcement process to be manipulated or

abused in such manner, if indeed this is the case.

Based on this argument alone, we request that the FEC take no further action on the

complaint.

2. THIS CASE DOES NOT MEET THE FEC'S NEW ENFORCEMENT

CRITERIA AND THEREFORE SHOULD BE DISMISSED.

In the January, 1994 edition of the Federal Election Commission Record, the new FEC prioritization system was explained. The various factors by which the Commission prioritizes cases as higher or lower priorities is helpful here. Based on our argument 1 above, and the facts laid out heretofore, we strenuously assert that this is, and should be treated as, a very low priority case not worthy of wasting any of the FEC's time and resources.

The facts clearly demonstrate that there is no wilful or knowing intent to violate the

FECA; in fact, there is no violation inasmuch as there has been no reference to a federal election or candidate, nor any express advocacy. There has been no apparent impact of a violation on the electoral process, inasmuch as there has both been no violation and no federal electoral process to be impacted. The particular legal area involved, i.e. that of express advocacy, has already been addressed fully by various courts. Respondent has failed to proffer any facts to support his allegation and merely encourages the Commission to undertake a

-15- needless fishing expedition. Any further action by the FEC in this area should be taken under

a rule making, and not an enforcement approach. (See argument number 3 below).

Based on these factors, this MUR should be ranked as having no priority at all, and the

file should be closed.

3. THE FEC SHOULD NOT PURSUE RULE MAKING THROUGH

ENFORCEMENT ACTION.

The court cases cited above (NOW.~ MCF Face a pra and Survival,

gp)have substantially altered various provisions of the FECA, as applied, and regulations promulgated thereunder. While the cases very clearly lay out the applicable standard, the regulations of the FEC have been in a state of flux. On March 9, 1994, the FEC considered draft final rules, prepared by the Office of the General Counsel, seeking to establish firm guidelines and rules for what constitutes express advocacy. Promulgation of these proposed rules is a direct response to various court cases which have seriously challenged the previous broad interpretation of the FEC as to what constitutes the appropriate standard of review for

§441lb and §431 (8)(A) violations. The expressed advocacy standard is much more restrictive and limited; thus decisions to pursue enforcement become much more severely curtailed. Since the proposed regulations will be under review and discussion for the immediate future, it would be imprudent, unfair, and inequitable if the FEC were to pursue action against Respondents herein, based at best on flimsy factual allegations and very strong case law that favors

-16- I E _199 a 0

Respondents herein, while the precise regulations are yet to be promulgated by the

Commission.

Based on this argument, we respectfully request that the filing on this matter be closed.

4. NOTWITHSTANDING THE FEC'S NEW ENFORCEMENT PRIORITY.

THERE SHOULD BE CONSISTENCY IN ENFORCEMENT DECISIONS

AND ADVISORY OPINIONS OVER TIME.

In 1986, the FEC considered, in MiUR 2161, involving Assemblyman Mike Antonovich in California, facts almost identical to those herein. Mr. Antonovich, a declared candidate for the U.S. Senate, was the spokesman for a series of T.V. advertisements advocating a No vote for then California Supreme Court Justice Rose Bird. Mr. Antonovich never identified himself as a federal candidate, nor was there any reference to any federal election. The complaint alleged that the mere appearance in the commercial by Mr. Antonovich constituted a prohibited in-kind contribution.

In that case, the FEC voted to find no reason to believe and close the MUR. This instant MUR is on all fours with that previous matter and similarly the Commission should find no reason to believe and close this matter.

-17- M- MM a 0

The FEC has issued a strong list of various Advisory Opinions over time, albeit involving different fact patterns, essentially concluding that activities not involving federal candidates or federal election years do not fall under the FECA. Some of such Advisory

Opinion conclusions include:

(a) A federal candidate raising money for debt retirement, currently a state senator,

who wanted to make public service announcements on television to raise funds for

diabetes research, was advised that since the purpose of the announcements was not his

nomination or election to federal office, no reference would be made to his candidacy

for Congress, and no appeal would be made for fuinds for his federal campaign, the

activity would not be subject to the FECA. (AO 1978 - 88).

(b) Radio and television ads paid by a union encouraging their members to vote were

found to be outside the scope of the FECA where the ads supported specifically state

candidates, and no federal candidates for office were mentioned. (AO 1978 - 102).

(c) Congressman Gephardt could moderate a public discussion program, held both in

and adjacent to the Congressional district he represented, and discuss topical issues

without falling under the constrictions of the FECA. The FEC stated: "Where the

purpose of the activity is not to influence a nomination or election of a candidate for

federal office but rather in connection with the duties of a federal officeholder, the

Commission has consistently held that no contribution or expenditure results under the

-18- Act." The FEC further stated: "Although it is possible that your involvement in the public affairs programs may indirectly benefit future campaigns, the Commisson concludes that the major purpose of the activity contemplated by the above proposed agreement would not be the nomination or election of you or any other candidate to

Federal office ... . This opinion is conditioned, however, on (i) the absence of any communication expressly advocating your nomination or election or the defeat of any other candidate, and (ii) the avoidance of any solicitation, making or acceptance of campaign contributions in connection with this activity.' (AO 1981 - 37).

(d) Expenditures of a political party for the purpose of identifying and motivating persons to support the party's gubernatorial nominee were considered to be for the additional purpose of influencing the election of persons to federal office, but only because a combined federal and state election ballot existed. (AO 1978 - 50).

(e) Even the appearance by a federal officeholder in another candidate's commnercial does not result in an in-kind contribution to the Congressman, even where he was identified as being a Congressman in the advertisement, since the ad contained no mention of the Congressmans candidacy, did not advocate his election or defeat of his opponent, and contained no solicitation of fuinds to his campaign. (AO 1982 - 56).

Similarly, a federal candidate's newsletter was deemed not to be a campaign expenditure subject to limitation since the newsletter did not refer to the candidate's views or to her campaign. (AO 1990 - 5).

-19- 0 0

In all of these authorities, the main theme is that expenditures which do not involve the promotion of a federal candidate, an impact upon federal candidates in federal elections, or solicitation of funds for the benefit of federal candidates, do not fall under the proscriptions of the FECA. Instead, they are outside the purview of the FECA.

Based on this argument, the file in this MUR should be closed.

5. THERE IS NO EXPRESS ADVOCACY AND THE FECA IS NOT

APPLICABLE HEREIN.

In the event that the foregoing arguments, individually or collectively, do not constitute sufficient grounds to stop this MUR in its tracks now, then the MUR should be foreclosed based on the single argument that there is no express advocacy under applicable legal standards.

In Federal Election Commission v. National Oraiainfor Woe.(NOW) the United States Court of Appeals for the District of Columbia considered three letters sent to the general public, which were paid with NOW's corporate flmids. In those letters, there were references to politicians and elected officials, messages about the ability of citizens to help elect or defeat such politicians, implied exhortations to the reader to take action as

November elections loomed close, and other references. Despite these clear references to

Federal Elections, and the ability of voters to take certain actions, the court nevertheless found

-20- there was no express advocacy. The court noted the clear distinction that must be made between "issue discussion," which strongly ties in with the First Amendment, and candidate oriented speech that is regulated by the FECA. The court concluded that, under the EIKS#M test, there was no express advocacy since the central message of the three letters was to expand

NOW's organization. The court noted that reasonable minds could dispute what NOW's letters urged the readers to do., since they did call for action, but the letters did not expressly tell the readers to vote at the polls against particular candidates in the 1984 election. The court felt that because the letters were suggestive of different meanings, and that there were different pleas for action, and the types of actions were unclear and varied, the express advocacy test of Furgatch was not met. The letters did not go beyond issue discussion to express electoral advocacy.

This was similar to a decision in Federal Election Commission v. Central Lon Island

Tax Reform -immediately. 616 F.2d 45 (2d Cir. 1980), where the court concluded that a leaflet which contained a group's economic views, which criticized the voting record of a

Congressman and included the Congressman's picture, was not express advocacy. This conclusion was reached even though the leaflet exhorted the reader to let the Congiressman, know how the reader felt about his vote and to thank the Congressman when he votes for lower taxes and less government. Since there was no reference anywhere to the

Congressman's party, to whether he was up for re-election, whether there was any election pending, or how the reader should vote at any election, the court held that the FECA did not apply since there was no express advocacy of the election or defeat of the Congressman.

-21- M ___ M I

In Fauch[r s the U.S. Court of Appeals for the I1st Circuit considered voter guides distributed by a non-profit membership corporation. The voter guides contained candidate positions on pro-life issues. The court, in determining that the guides were protected as fr-ee speech under the broad category of issue advocacy instead of regulated by the narrower standard of express advocacy, stated:

In Buckley. the Court quoted Thomas V. Collins 323 U.S. 516 (1945), approvingly, on

the difficulty of interpreting the meaning and effects of words:

[W]hether words intended and designed to fall short of invitation would miss

that mark is aquestion both of intent and of effect. No speaker, in such

circumstances, safely could assume that anything he might say upon the general

subject would not be understood by some as an invitation. In short, the

supposedly clear-cut distinction between discussion, laudation, general advocacy,

and solicitation puts the speaker in these circumstances wholly at the mercy of

the varied understanding of Is hearers and consequently of whatever inferences

may be drawn to his intent and meaning.

Such a distinction offers no security for free discussion. In these conditions it

blankets with uncertainty whatever may be said. It compels the speaker to

hedge and trim.

-22- Bucley424 U.S. at 43 (quoting Collins 323 U.S. at 535). In our view, trying to

discern when issue advocacy in a voter guide crosses the threshold and becomes express

advocacy invites just the sort of constitutional questions the Court sought to avoid in

adopting the bright-line express advocacy test in Buckley.

Face at 470.

Also in accord with this line of cases is a recent decision of the U.S. District Court for the Southern District of New York, Federal Election Commission against Survival Education

Fund. Inc. et. al 1/12/94). The court cited the "express advocacy" standard as not being applicable to expenditures for letters that were issue oriented and, though they referred to a specific candidate and a specific election and implied that an official should not be re-elected, were not found to have violated or come under the jurisdiction of the FECA.

If the above cases did not find express advocacy based on even stronger facts than here, then surely the facts of this MUR must be found not to constitute express advocacy.

Therefore, the activity complained of herein cannot come under the FECA's jurisdiction.

Under this conclusion, this MUR file should be closed without delay.

-23- CONCLUSION

Respondents herein have clearly established that the flimsy facts submitted by complainant, which were supplemented by Respondents herein for the benefit of the FEC, do not invoke violations of the FECA. Respondents have engaged in issue advocacy, which is pure free speech protected by the U.S. Constitution and as interpreted by the courts of the land.

The conclusion is inescapable that the messages in the radio ads were "content neutral" as to any candidate promotion. To undertake further proceedings against these Respondents would be oppressive, would have a chilling effect upon their First amendment activities, would be a major denial of applicable legal standards, and would harm the integrity of the Federal Election

Commission.

On behalf of Respondents herein, we request that the file for MUR. 3855 be closed forthwith.

Respectively Submitted,

Peter A. Bagatelos

Dated: ______Counsel for Respondents

-24- LIST OF EHBITS

DESRITON

A Declaration of Andrea Seastrand

B Declaration of Charles Storm

C Declaration of Mildred Dostalek

D Declaration of Pete Agalos

E Declaration of Stephen Lombardi and Transcripts of 2 Radfio Ads

F Invoices from Suggs, Lombardi Advertising

wsm ksu.bt EXHIBIT A

IMQ BEFORE THE FEDERAL ELECTION COMMISSION

DECLARATION OF ANDREA SEASTRAND

MUR 3855

1, Andrea Seastrand, declare as follows:

1. My mailing address is 320 Ebb Tide Way, Shell Beach, California 93449. I am the Assemblywoman for the 33rd Assembly District in the State of California. I was elected to this seat in November 1990 and reelected in November, 1992 for respective two year terms. I am a registered Republican.

2. As an elected official, I have a great interest in all matters affect my constituents as citizens, taxpayers, parents, property owners and renters,. and people in general. It is one of my highest priorities to provide direct constituent services, to be accessible to my constituents, and to communicate with them regarding issues of concern. One of the ways that I provide such services is through leadership and setting an example.

3. During 1993, Governor Pete Wilson called a special statewide election for November 2,1993. The purpose of this election was to have the electorate vote on a number of statewide ballot measures which would have a dramatic impact on the economic and social fabric of California. These included statewide Propositions 170 and 171, relating to property taxation. Proposition 172, relating to the extension of a one-half cent sales tax earmarked for law enforcement purposes, and Proposition 174, relating to a school voucher proposal that would have taken funds from the public school budget and made them available to students attending any public or private school for elementary and secondary education. These measures held dramatic and complex repercussions for the State of California, if enacted. It was incumbent upon me, as an officeholder to express my views, and to encourage people to register and vote, thereby expressing their views on these measures.

4. In order to accomplish this goal,. I had the idea of preparing radio advertisements for these purposes. The idea and the follow-up activity to prepare these advertisements was commenced on and before August 30, 1993. At that time, I utilized the advertising firm of Suggs, Lombardi Advertising through my controlled committee, the Friends of Assemblywoman Seastrand 33 Club. The Committee is registered with the California Secretary of State's office under the California Political Reform Act of 1974, as amended. Its purpose is to support me in my officeholder activities, including communications with my constituents. 5. 1 prepared a first advertisement on August 30,.1993, the purpose of which was to express my views and information to my constituents and to encourage them to register to vote so that they would have the opportunity to vote at the ensuing statewide election.

6. 1 decided during August, 1993 to prepare a second advertisement, encouraging people to vote, but delayed preparation of the advertisement until October 20,,1993. The reason for the delay was because I did not want the second advertisement to run until just before the November 2, 1993 statewide election date, so that people would be reminded that they should vote on that date in the few days just prior to the election. Otherwise, I was concerned that voters might otherwise overlook their opportunity to vote on that date. 7. The advertisements were placed for radio stations which carried the Rush L baugh radio talk show and aired at stations within my constituents' listening area. The messages were geared for more conservative constituents that are more likely to listen to the Limbaugh Show. Three of the stations physically are located within my assembly district; one is physically outside of the district, but broadcasts to areas that include constituents within my district, including specifically the cities of Varxeaterg Vilage, Santa IAria Lompoc. andi The three stations within the district are KPRL, KUHL and KGLO. The station outside the district, but which serves constituents within my district,. is KTrMS.

8. 1 represent an assembly districted comprised of San Luis Obispo County and the northern area of Santa Barbara County. This area is a very large area and radio reception can vary from area to area, and the broadcast station choices among constituents can vary as well. For these reasons, the four stations which carry the Rush Limbaugh show, targeted as the media vehicle for carrying my radio ads were selected. 9. On September 13, 1993, Congressman Michael Htiffington, who represents the 22nd Congressional District from California, advised that he would not run for re-election. I decided on that date to declare my intention to be a candidate for that congressional seat. On September 14, 1993, 1 established principal a campaign committee, selected a treasurer(namely, Pete Agalos) and instructed my representatives to prepareand file the necessary FEC Forms 1 and 2 with the FEC and House of Representatives. Until that date, had I not formulated any definite plan to run for Congress. I did not engage any in activities involving express advocacy of being a candidate for Congress

2 S 0

nor did I solicit any funds for such purposes until Mr. Huffington declared his intention to leave his Congressional office.

10. The radio ads were prepared and broadcast solely as part of my activities as an elected official and leader within my assembly district. The advertisements did not promote me or anyone else as a federal candidate,, nor did I refer to any federal election or process, nor did I solicit any funds for a federal candidate or committee, or in any way affect any federal election. The activity was aimed solely at expressing views and encouraging voter participation and exchange of ideas about statewide issues of importance to my constituents. The advertisements were an unrelated activity, related to my issue advocacy, from my subsequent decision to become a candidate for Congress. The advertisement did not involve any candidate promotion activities but encouraged constituents listening to the Rush Limbaugh Show to register and to vote.

11. Mike Stoker is a County Supervisor, from the Fifth District, for the County of Santa Barbara. He has declared himself to be a candidate for the 22nd Congressional District from California. He and I are competing for the same seat. Mr. Stoker maintains offices at 201 South Miller, Suite 107, Santa Maria, California 93454.

1 declare under penalty of perjury that the foregoing is true and c ect to the best of my knowledge.

D ate d:O "Z IflY

3 01

EXHIIT B BEFORE THE FEDERAL ELECTION COMMISSION

DECLARATION OF CHARLES STORM MUR 3855

1, Charles Storm, declare as follows:

1.

2. During the period from approximately June, 1990, through approximately June, 1991, I served as Treasurer of the Friends of Assemblywoman Andrea Seastrand Committee. This committee was registered with the California Secretary of State's office under the California Political Reform Act of 1974, as Amended.

3. On or about February 3. 1994, I r eceived a letter, dated January 31,, 1994, from the Federal Election Commission. This letter advised me that a complaint had been filed, indicating that the Friends of Assemblywoman Andrea Seastrand, and me as Treasurer, may have violated the Federal Election Campaign Act of 1974, as Amended. The letter offered me the opportunity to dmntate in writing that no action should be taken against the Committee and me, as Treasurer.

4. Since I am not the Treasurer of the aforementioned Committee, and have not been the Treasurer of the Committee during the time period in which the alleged violation occurred. I did not have any control over the affairs of the Committee or responsibilty legll for the activities of the Committee. I have no other independent knowledge of the activities complained of.

5. it is my understanding that the current Treasurer of the Friends of Assemblywoman Andrea Scastrand 33 Club Committee is Mildred Dostalek. I declare under penalty of peijur) that the foregoing is true and correct to the best of my knowledge.

Date d: _ _ __:_ _ _ _ _ CHARLES STORM sasrnswnf d=c EXHIIT C BEFORE THE FEDERAL ELECTION COMMISSION 1% DECLARATION OF MILDRED DOSTALEK

MUR 3855

1, Mildred Dostalek, declare as follows:

I.

2. 1 became the Treasurer of the Friends of Assemblywoman Andrea Seastrand 33 Club on August 20, 1993. On this date an amended Statement of Organization was signed and sent to the Secretary of State's office. I replaced Pete Agalos as Treasurer of this Committee. This Committee is a controlled committee, as defined by the California Political Reform Act of 1974, as Amended. It is controlled by Assemblywoman Andrea Seastrand. The purpose of the Committee is to support Assemblywoman Seastrand in her officeholder activities.

3. During the period that I have been Treasurer, the Committee made expenditures of $3,992, $ 1,008, and $60 respectively, for radio ads prepared and placed by Suggs Lombardi Advertising, located at 520 Higuera Street, San Luis Obispo, California 93401.

4. The purpose of the advertisements was to express Assemblywoman Seastrand's views on various statewide measures, which were to be voted upon at the November 2, 1993 statewide special election called by Governor Pete Wilson, and to encourage voters to register and to vote on such measures. To my knowledge and belief, there was no attempt to influence any federal election or to support or oppose the candidacy of any candidate for federal office.

5. The expenditures for the radio advertisements are permitted by the California Political Reform Act, as specified in California Government Code §89512, because the expenditures relate to a legitimate political, legislative, or governmental purposes. These purposes include the right of the Assemblywoman to communicate with her constituents on current affairs and issues affecting them as taxpayers and citizens, as well as to promote a government interest of encouraging participation in the democratic process through voting and the free exchange of ideas.

I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge.

Dated: ?L(C C,/, -(7L &tie &d6Lc MILDRED DOSTALEK amumndoaI&Je d= EXHIRIT D BEFORE THE FEDERAL ELECTION COMMSSION 0".. DECLARATION OF PETE AGALOS

MUR 3855

1, Pete Agalos, declare as follows:

I .

2. 1 served as Treasurer of the Friends of Assemblywoman Andrea Seastrand 33 Club from January, 1992 until August 20, 1993. On the latter date, Mildred Dostalek officially took over as Treasurer for the Committee.

3. On September 14, 1993, Andrea Seastrand declared her intention to be a candidate for Congress for the 22nd Congressional District in California. She asked me on September 13, 1993 if I would serve as Treasurer of her Committee. I agreed to do so and thereupon signed a Statement of Organization (FEC Form 1) on September 14, 1993 and submitted it to the Clerk of the House of Representatives to register the principal campaign committee for Mrs. Seastrand. The name of the Committee is Friends of Andrea Seastrand for Congress. Its FEC identification number is C00284083.

4. As Treasurer of the Friends of Assemblywoman Andrea Seastrand 33 Club, I was aware of Mrs. Seastrand's intention to prepare radio advertisements expressing her views as an elected official to her constituents regarding statewide ballot measure issuies, and to encourage her constituents to register and vote on such measures. I became aware of this intention on or about August 20, 1993. At no time did Mrs. Seastrand indicate any intention of preparing these advertisements to promote any candidacy for federal office, including herself, or any other federal committee or election process. Her sole stated purpose was to communicate her views to her constituents and encourage them to participate in the democratic process of voting and the exchange of ideas.

5. To my best knowledge. the Friends of Assemblywoman Andrea Seastrand 33 Club Committee paid for the radio advertisements. The Friends of Andrea Seastrand for Congress Committee, of which I have been the continuous Treasurer since its inception, did not pay for the two radio advertisement referenced above. The Committee has not paid for any other advertisements or items except those having a direct relation to Mrs. Seastrand's campaign for federal office.

I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge.

Dated: ______IfETE AGALOS smumnga- d=c EXIRBIT E BEFORE THE FEDERAL ELECTION COMMISSION

DECLARATION OF STEPHEN LOMBARDI

MUR 3855

1, Stephen Lombardi, declare as follows:

1. I am the owner of Suggs, Lombardi Advertising, located at 520 Higuera Street, San Luis Obispo, California 93401. My firm provides services that include producing radio commercials and placing commercials on broadcast stations.

2. In August, 1993, the Friends of Assemblywoman Andrea Seastrand 33 Club Committee asked my firm to produce radio commercials that encouraged voter registration and voter participation at the polls with respect to statewide issues of importance on the November 3, 1993 special statewide election ballot.

3. Two different advertisements were prepared for the Committee. One, encouraging voter registration, was produced on August 30, 1993. The second ad, encouraging voter participation at the polls, was produced on October 20, 1993. The ad copies for both ads were written prior to the foregoing production dates. Prior to when the first advertisement was produced on August 30, 1993, it was discussed and contemplated that the second advertisement would be prepared subsequently.

4. Mrs. Seastrand requested that these ads be run on the Rush Limbaugh radio broadcast to her assembly constituents. There are four radio stations which carry this show, i.e., KPRL, KUHL, KGLO, and KTMS. KTMS. while physically located outside the boundary lines of the assembly district, nevertheless reaches the homes of persons in the cities of Lompoc, Vandenberg Village and Santa Maria, all of which are within the district, where many residents listen to this station. We recommended these stations to the Committee and Mrs. Seastrand.

5. This firm's fee agreement with the Committee was based on fair market rates consistent with industry standards. There were no discounts. The Committee has paid all invoices we have submitted.

6. In preparing the advertisements for the aforementioned committee, I dealt with Assemblywoman Andrea Seastrand. During the course of our discussions, there was no mention of the ads being produced to influence any federal election, to support or oppose any federal candidate for office, to solicit funds for any federal candidate, committee, or election, to influence any federal election process, or even specifically to promote Mrs. Seastrand as a possible federal candidate. The discussions were exclusively aimed at promoting Assemblywoman Seastrand's purpose of communicating with her constituents and encouraging thenm to participate in the election process on statewide ballot measure issues in an election at which there were no federal candidates on the ballot.

7. Copies of the scripts of the ads are attached hereto, and/or submitted separately by letter, dated February 14, 1994, from me to the Federal Election Commission.

I declare under penalty of peijury that the foregoing is true and correct to the best of my knowledge.

Dated:______

,easvaPAEN' LOMARD

-2 - I COPY

c~lont' A"DREA SEASTRAND- Oate: 10/23/93 SUGGS. LOMBARDI ADVERTISG 520 HWGUERA. SAN LUIS OBISPO. CA 93401 Tle:* SPECIAL ELECTION-RUJSH"1 PHONE B05W44-9220 FAX 80654/58P27

Lengt: 10 30 60 stat~on

Co-op: Vkdgo/ Production Aids

(ANDREA) - HELLO FELLOW DIFITO HEADS! I 'M ASSEMBLY0A

ANDREA SEASTRAND, A REPUBLICAN IN THE STATE LEGIS TUBE

REPRESENTING YOUR INTERESTS BY FIGHTING AGAINST

HIGHER TAXES, FEE INCREASES AND THE CONSTANT 10 sec. GRO~flH OF BIG GOVERNMENT. NOW, YOU TOO CAN DO

SOM4ETHING FOR OUR STATE ANTD FOR YOURSELF. THERE

IS A SPECIAL ELECTION ON NOVEMBER SECOND. MANY

IMPORTANT ISSUES REQUIRE YOUR INPUT. ISSUES 20 see. SUCH AS THE-ISCHOOL WAJCrlEP, THE PERMAN'ENT EXTE01SI T

OF THE STATE SALES TAX AN]) PROPERTY TAXES. Y(,,J

CAN BE SURE TH-AT THE SPECIAL INTERESTS WILL BE

GETTING THEIR SUPPORTERS TO THE POLLS... HOW 3soc. ABOUT YOU AND ME AND THE REST OF US COM~MON FOLK

AND TAXPAYERS? NO 'MA TEFR HOW YOU FEEL ON THESE

ISSUES, THE ONLY WAY TO INFLUENCE YOUR GOVERNMENT

IS TO VOTE! THE SPECIAL ELECTION IS TUE SDAY, 40 sec. NOVEMBER 2nd. PE SURE YOUR VOICE IS HEARD LOUD

AND CLEAR! RUSH WOULD WArNT IT THJAT WvAY! "1DIFI'Oll

(ANNOUNCER)- PAID FOR FY FRIENDS OF A]NDEPA

50 soc.SEASTPAN\D.

I min. - . Cet:ANDREA SEASTRAND

Dot*: O 8/20/93 SUGGS. LOMSAUMI SAN LtSOB61M. CAP'0' Th~e:520 HIGUERA. jj4g20*FX855452 uREGISTER AND VOTE"CHN 0 Langtti: 10 30 60 station

Co~p:Video/ Production Aids

(ANDREA) - HELLO FEU"~ DITTO HEADS! I 'M ASSEMBLYA

ANDREA SEASTRAND# A REPUBICAN IN THE STATE LEGISLATR

REPRESENTING YOUR INTRESTS BY FIGHTING HIC-FER TAXES,

FEE IN\CREASES AND BURDENSOME REGULATIONS. NOW 10 sec. YOU TOO CAN Do SaqMnING FOR OUR STATE! 7--E DEJADLINE

TO REGISTER TO VOTE IN THIS NOVEMIBER' 5 STATEW-IDE C', ELECTION IS OCTOBER FIRST. IF YOU AREN'T REGISTMERED

To VOTE, YOU WON'T HAVE HAVE A SAY REGARDING THE r--20 s~c. VARIOUS MEASURES ON THE BALLOT. THEY DEA;L WlITH

EVERYTHING FROM SCHOOL VOUCHERS, EXTENDTING TKE

STATE SALES TAX To THE TAXES YOU PAY ON YOUR PROPERTY!

C'SIGNING Up IS EASY! JUST STOP BY ANY PUBLIC LIBRARYl 30 soc. POST OFFICE OR OTHER COUNTY GOVERNMENT BUILDING-

OR MY OFFICE AND FILL OUT A CARD. IF YOU'VEr MOVED

SINCE THE LAST ELECTION, YOU MUST RE-REGISTER WNITH

YOUR \rEW ADDRESS. IF YOU'RE FED UP WITH TXAX INCREASES 4.0 sec. AND POLITICIANS WHO ARE DOING THINGS THEIR WAY,

THEN ITS TINE TO SEND A MESSAGE! REGISTER BY OCTOBER

FIRST!! FOR MORE INFORMATION ON HOW YOU CAN REGISTER

kEPUBLICAN CALL 546-9533 IN SAN LUIS OBISPO OR 966- 50 sec. 3392 IN SANTA MARIA. PAID FOR BY FRIENDS OF ANDREA

5EASTRAND COMITTEE.

i min. EXHIIT AJ

SUGGS, LOMBARD I ADVERTISING INVOICE 520 HIGUERA page 1 SAN LUIS OBISPO, CA 93401 FAX 805-544-5627 805-544-9220

Transact ion Date: 03-30-93 Sale Invoice Du~e Date: 11-04-93 Terms: Net 15 Invoice # 4B13

Sh ip To:., Sol d To: ANDREA SEASTRAND ANDREA SEASTRAND ATTN: ERIC DANIELS DANIELS ATTN: ERIC 523 HIGUERA 523 HIGUERA SAN LUIS OE4ISPOCA 93401 SAN LUIS OBISPOCA 93401 ot y UM Pr ice Extension Item ID Descr ipt ion

KPRL 1 . 00 504.00 504. 00 __RADIO RUSH 1 .00 792.00 792.00 SRADIO KUHL 1 .00 19,980. 00 1,V980. 00 RADIO0 KTMS 1 .00 616.00 616.00 SRADIO KGLO 1 .00H 100. 00 100.00 RADIO PRODUCTION REGISTER SLO REGISTER SM

Subto:t al1 39192.00 Total Invoice PLEASE REMIT WITHIN 15 DAYS OF RECEIPT. An interest charge of 1 1/2.::' per mo:nth will be added tco over due accounts. You alsco will be charged for any attorney's fees, C:ourt costs and collect ion costs, 3,992.00 if necessary. Net Due L1r AWIDAVIT OF SERVIC ENE et cobids LuaObbopo d VM I Be:

FAX (805) 238-5332 (805) 238-1230 ...... I...... 32ndi & Oak St *PO Box 7 * paso bies * CA 93447 F'aoe 1 INVOICE AND STATEMENT Subwlbtd aWWSwaW S10BOO

...... I...... NOTARY PUBLIC SEA0'01 SUGGS. LOMBARDI ADVERTISG 520 HIGUERA STREET My CommnWion Exvsm ...... SAN LUIS OE4ISPO. CA 93401

BILLINGODATE 1 ~c 1 = Ic y-ertiser: ANDREAi SEA23TRANE

1.) P.AI.fArCE FROMI LAST STAITEMENT

C -:r 1T R,AC T 2G7- / RJSH LIMDA1 ULi--

SHOW" l2.iIK~ 4.7 THE LIMPgIUGH 12.OC~ LIMBAgUGH SHOW" 17 ~ 12 I "~ T HEC- 6C) SHOW" -. 1)1 4; THE LIMBAUGH " RUSH .L~. 1~' THE LIME4AUG3H SHOW" 60~ 1 2 . "RPUSH SHOW" 12.00 4-.--- - I9' THE LIMBAUGH "RUSH 9:7 LIME4AUGH SHOW" 1 2 . 4; THE " RUSH LIMBAUfGH SHOW" IL THE "RUSH SHOiW. T H E LIMPAUG"-i 9 :46a "RUSH LIMF4AUGH SHOW " 1,'-1 12 TH E "RUSH -- ; - - c THE LIMBAUGH SHOW " "RUSH 12 THE LIMEUAUGH SHOW'' "PRUSH SHOW' I T. THE "RUS H L IMBA~CUGH SHOWQ T HE RUSH LIMBAUGH SH20-i. Li MEAUGH -HAC R U.S 1'3 i f7 L T 1 r-,~ L. I F,~

L I LM UClv

is an ANNUAL PERCENTAGE is computed by a PERIODIC RATE OF 1,/2%e PER MONTH, which A"Finance Charge following date of purchase. RATE OF 18%, added to the unpaid balance at the end of the next month

THIS NYOSCE WAS PREPARED FROM OFFICIAL STATION PROGRAM LOGS PLEASE PAY THIS AMOUNT-. TMWESSHOWN MOVE ARE ACCURATE PLUS OR MINUS 0 IN. AFFIDAVI OF SERVICEI

,spthcr I}se: E9 EOsini ThImi1n 11% IVBm~snRbly ~ im KPAL-AM In Aceonemnc.WN~ he sw nu 1n ame (805) 238-1230 * FAX (805) 238-5332 By ...... I...... I.... 32nd & Oak St * PO Box 7 * Paso Robles * CA 93447 04 C F-"L2 INVOICE AND STATEMENT Subscribed and Sworn to Bo Me this ...... day of ...... t19......

SUGGC3. LOMBRiEDI ADVERTIS6 ...... NOTARY PUBLIC 520 HIGL[ERA STREET CA 934K')t SAN LUIS OPISPO. 1 My C.mmiuuion Expvss ......

7/ .- J. BILLING DATE Im. ,Cice i 155 -vertiser: 5ANDREAt SE4STRAN D

>'> CONT INUATrON FR'M F.EYIOUD

IHOW' .~, THE LIMBAUGH "R US H SHOW" LIMBAUGH 9 (.~ THE SHOW" 4. THE "F.US H LIMEIAUGH ~ 1 2 THE LIMBAgUGH TH E LIMBAgUGH SHOW" THE LIMSAUGH SHOW" A-.'. "RUSH LIMBAUGH f-s - THE S HO0W 9 4 THE LIMBAUGH SHOW" Li IEgAUGH C-; i~j .1~, THE rSHO0W "RUSH L INBAUC-H ~ 4.i93 THE SHOW :11 T HE Li MBAUGH "RUSH LIMEBsUGH /-i ''-7-, THE 4. ~- '-.5/';: THE LIMEAUGH 1~ 9 USH "R SIH C!W' i.2 THE LIMBAUGH 4..4 ~.- £4:.- - 9/29/93 THE "RUSH L I M E4 'U C S H DI. -2H CDV. 53 THE L I MB AUO 4~ f~;;-, " PUSH 4. C ~5/3C. 9C THE LIME4AUGH- S H v

SUB~TOTA~L

Total Sales---- 5. Discount orn Sales Net Sales 425. 4

- . DENIS E .WmN b. A -~ ~ COMM. #996128 Z WUS CAISOCOJf .1o xva A 119

A Finance Charge Is computed by a PERIODIC RATE OF 1'/z PER MONTH, which is an ANNUAL PERCENTAGE RATE OF 16%, added to the unpaid balance at the end of the next month following date of purchase

*60DAS,0.AD VE C U..RETe3gg.

4L~' . 4298. 40 0. 00 00v4- I THIS INVOICE WAS PREPRD FROM OPFICIAL STATION PROOGRAMLOGS HSA O N~~ TIONS SHOWN ABOVE AREACCURATE PLUS OR MINUS8SMIN.PES PLEASE PAYA THIS AMOUNT KUHL/KXFN RADIO .. (805) 822-7727 INVOI& NUmER: 18592 - P.O. BOX 1964 SANTA NARIAv CA 93456 INVOICE DATE: 9/301/93 . PAGE I TYPE. Complete ACCOUNT: 58966 CONTRACT: 0001703 PRODUCT- biLYL flurtLII :1alesman:~aJ.esman: bTLYL "Urr 11

ANDREA SEASTRAND SUOGSt LOMBARDI ADVERTISING 520 SOUTH HIGUERA SAN LUIS OBISPOp CA 93401

All times shown are approximate within 7 minutes. Date Number KUHL Times Wed 9/1/93: 9: 30a 10: 41a Thu 9/2/93: 10: 17a 11: 17a Fri 9/3/93: 9:51a 11:30a 9/6/93: 9: 17a 10: 17a 9/7/93: 10: 17a 11 :51a 9/8/93: 9: 17a 11: 17a !on 9/9/93: 9:41a 10: 51la re 9/10/93: 9:51a 11:51la Vd 9/13/93: 10: 41 a 11: 59a Thu 9/14 /93: 10: 17a 11: 17a rr i 9/15/93: 10: 17a 11: 17a Hon 9 /16/93: 9:30a 10: 51la Tue 9/17/93: 10: 17a 11: 30a 9/20/93: 9:59a 10: 59a 10: 17a 11:51la fri 9/21/93: 9/22/93: 9:31a 11: 17a Ron 9/23/93: 10: 17a 11: 30a Te 9/24/93: 10: 17a 11: 17. 9/27/93: 9:59a 11:51la 9/28/93: 10: 17a 11:51la Wed 9/29/93: 9:51a 11::59a Thu 9/30/93: 10: 51 a 11 :51a

Contract #0001703 9/1/93 to 9/30/93 9/30 44 60's @ $18.00 $792.00

k I 5-2-b

Karen L. Brooks ~~NTARY PUBLIC CAUFORW~ SANTA BARBARA COUNTY 0 ~rI C~rnn ExpamS AVIJ 21. 97.

I affirm that the announcements were broadcast as indicated above. i~~K IN g NWnbur12101l-j Uf40OE DAf / 3 0/9a PA~~~~~ 1UmiU UI 0 ACCOUNT: 1.320/ CONETRACT:' 13.W20 PRIOCUCT. 1 ~ni~n: WHM I LL 'r .ItI p sm An : WHA I L.L- Y

ANDREA SEASTRANO SUmW.S., L.Ot'IARI)1 ADVERTISING3 520 Hf GUERA sr. SON L.UIS CJEISFPO, CA 93401

.16

V J-PI %J-ft 9 KTIlS TiaLc 3 U C.1V 10: 41 a 10: 1.. 11: 1L~ -' 100: b"; i I1L: ~/35/',3: 1 0: 4 1 --a 10: 1 8,A 10C:41 a 110: 1 83A 9/6/93: 2 10 : 5-3a 10:5,3a u S- 10 :4 1 a 1 1 :4ia 2 10: 41a 11t:41a. 9/15,/93: 2 r i 10 : 1 < 11 :41 / . /9.: 2 10: 41a 9/1i 7/93: 2 10 : 1 6a 11 :53a 9/20/93: 2 93/2 11/93: 10: 41a 1: 41 C Ue 10: 18a 9/22?/93: 2 9/23 /93: 9: 18a 11: Er 9/P4/93: 10: 32aE 10: 18a 10:- 53a Wedi '3/29/93: 10 :53a~ 30/93: 10 : 1 6'a Th;-# 'J/

tc~e ?H71~ 9~./~1~ .§/~ $1.1 98E0. 00

fi~J . f. I

* * .&-.-~\ * * w~e~i-J * 1i~,UiE'Y~ S 0 * PAy

I affirm that the announcements were broadcast as indicated above.

!A A01 - - '02 Od ':~ / ~ /c, "53L0-1 - , A"T§ - \. My cxmnnuaiuu, iiwToo 0-1 J ROCGLO COMMUNICATIONS ------P.O. Box 170 I7(4I1 AM. 34O 0 Date :Invoice: Arroyo Grande Ca ,93421 rI j9 ~ ------1Oct 93 :1346 +------+------

ARROYO GR A 1P. CA 93421

Bill Andrea Seastrand To: C/o Suggs And Lombardi 520 Higuera San Luis Obispo, CA 93401

------4------+ :PO Number : Terms Project +------4------+ on reciept ------+----+------.------+ 'Quantity: Description : Rate :Amount: ------+------+------44: :60 second commercial announcements 14.00 : 616.00: 9: :60 second commercial announcements 0.00 0.00o

a ------a ------a-- 4 a a a TO A : r 4. - --a------H;LNC. -u DUE &Jf All times shown are appro . te within 7 minutes Times are preceeded by thsn designators A-J

6 a.m -lO&m. 10 a.mn.-3 p.m. 3 p-.-S p.m., I Will I 3 /0: 0-, . I~2 X

Date.- 8IC 2C, IA I. 3c ______

Contract Run Date. -Zq-30 10 ,:' .5u_ __ _ _ Co-Op Source. 13 14 j. . ,.q______

15~ 'SIC C. 31______

16 ______'%.Total Number of ads, ran. 5 17 ___ __._ Ic Lc'i t. 5x. _ _ __ _ CGross Sales. r"

,-Total paid commercials ran: Hq 21 C,3C 4C '. I51, ______22 q. , j ______NO-ital no charge commercials ran 9 23 1______q 24 ______Trade Dollar Amount:______25. i: q______26

27 3_____: C5, 11,.54 _ _ _ _

29 cl a-3_____5

30 ~ 2 ______

31 ______

Station Doctiinentations Approved by the Co-Operative Advertising Committee of The Association of National Advertisers

This announcem-ert %kas broad _.:______tmes, as entered in the stations program log The tim.es t,.is dnnuncmcn~s boadas c tlld O ~:~ !tI~n cet on our invic(s) number/dated_____ a: the earned rate of S______"-)fo announcements, for a total of5

S______h for announcements, for a total of'S S______-h foIr announcements, for a total of$S

(Notarize above) Siuniiure of station official Typed name and title Stat ion I '~~1 SUGGS, LOMBARDI VERTISING I NVOICE 520 HIGUERA Pag 1 SA1N LUIS OBISPd#,CA 93401 FAX 805-544-5627 805-544-922C0

Transact irn Date: 10-31-93 Sale Invoice Due Date: 12-09-93 Terms: Net 15 Invo~ice # 4910

Ship To': Sr- T-:,: 1d FR:IENDS OF ASSEMB4LYWOMAN OF ASSEMBLYWOMAN FRIENDS ANDR:EA SEASTRAND ANDREA SEASTF:AND P.O. BOX 14004 BOX 14004 P.O. SAN LUIS OBISPO, CA~ 93406 SAN LUIS OBISPO, CA~930 Pr ice Ex~t ens ion Item ID Descr ipt ion Ot y UM

FF'L - 10)/93.: RAD I10 180. 00) 180. 00 RADIO fhUHL -10/93 1 .00 168. 00 168. 00 RADIO0 Ki3LO 10!25 -11/1/9'%3 1 . -- C-) 450. 00 450.00 VTMS -10/'K3 RADIO 1 C)C 90. 00 90. 00 NRADIO KTMS -11/1/93

-A5

S~btc'-t-al

1 , oo~ . Total Irvc'-:ic:e FILEA-E FErIITF WITHIN 15 DAItYS OF FE!---F'T. An interest c:harge cif 1 1/"--% per mocnth will L-z- added tocoy:.ef'dUe accounts. '"CLU also: will be c:harged for any at t clrn e-y' fees, co:urt co:sts and colilect icn coasts, 1 , UI)~5 . ('C if necessary. Net DUe

* I AFFIDAVIT OF SERVICE RENDERED I& OfC400ffft 1 SS: Cox"t of Son Lut Obapo A LsnCOAMOefff 906rOn The Undetuignd Having See Dul Sworn .Deposss end Says That Broadcasting Service Has Bee Rendered by Raft Station ICPRL-AM inAccoroenc Wih ft AccanVpenTri Statementd: ~5s- I By ...... I...... (805) 238-1230 * FAX (805) 238-5332 32nd & Oak St * PC Box 7 * Paso Robtles * CA 934U7 Subecribed and Sworn lo Before INVOICE AND STATEMENT IMUe s...... dayof ...... 19..... LCtIE4SADI ADkYEPTISG SEA00I SUGO , ...... NOTARY PUBLIC 520 HIGUER-A STREET' SA~N LIJIC__ OEISF'O. CA 974kC1 My Commision Expwes......

BIUNODATE 1r./c et~ # 1 4'S A-dvert i - :Z ANDPEA SE'3TRAkNED

-T _' r_ . '?'.' HLHUU~. F 0 M L A:: ' If -;I -

r ONTR : 7-T 2,6 / PUSH LIMPAUG3H

I - as -, 25 9 THE LIMSBIUGH SHOW " I"IF., U SH SHOW' 7HE LIMBA'UVGH I ~ LIMBUGH SHOW" THE i 5)a3 LIMEIAUGH SHOW " 1 1.'Ic THE "RUSH I tsi 11_% 27' f THE LIMBAULGH3 SHOW" 7. "RUSGH THE LIMBAUGH SHOW' 0'Z). 6 I I- . THE LIMS"IUGH SHOW' "PUSH i.*.~ -I-', 3 LIMBA~UGH SHOW'" -a% - 53', 7z. "RUSH LIMEBiUGH SHOW'" :1a31 "RUSH LIMBAUGH SHOW'4

SUPsTOTA~L

:*otaR Sales - - - - Dis~counrt ons S_:zaes is. l4et Sales I I'2 . ''K

SA Finance Charge is computed by a PERIODIC RATE OF I%% PER MONTH, which is an ANNUAL PERCENTAGE RATE OF 18%, added to the unpaid balance at the end of the next month following date of purchase.

_i . 4!-t THISENIN30 WAS .. 0 6L~tUFfDAYS~ PLAS cPAYJ TlO UNT

TWAS SHOWN MMOVARE A=MRTE PLUS OA MINUJS SMIN. 'WHLj(KXFM RADIO 0)9e2-7727 NUMBER: 18777 *P.O. BOX 1964 INVO CA 996 KUHL, a Maria, California SANTA MARIA, INVOiCEDATE: 10/31/93 PAGE: I TYPE: Complete ACCOUNT 58966 CONTRACT: 0001785 PRODUCT Salesman: STEVE MOFFITT

ANDREA SEASTRAND SUGGS, LOMBARDI ADVERTISING 520 SOUTH HIGUERA SAN LUIS OBISPO, CA 93401 PAY ThIS AMOUNT: : $ 180.0ee 11/21/93 All times shown are approximate within 7 minutes. Date Number KUHL Times Mon 10/25/93: 2 9:05~a 9:59a Tue 10/26/93: 2 9:05a 9:59 a Wed 10/27/93: 2 9 :05a 9:59a Th u 10/28/93: 2 9:05a 9 :59a 7f ri 10/29/93: 2 9:51a 10:51a

Contract #0001785 10/25/93 to 10/29/93 10/29 10 60"s @ $18.00 $180.00

I affirm that the announcements were broadcast as indicated above.

MY obmissinxie All Limes shown are appr ate Within 7 minutes Times are preceeded by tam designators A-J 10 a.m.-3 p.m. 3 m. p. AM 68-M.-IOLM.

2 3 4 5 ToSafwot L1-L

D~t 9

10 4, Cop Sx: ______13 1 + 15

16 _ _ _ _ Tota! N'umber of ads ran: 17 19 Gross S3iecs 109_____00

'20__ _ ~irv' . 1ninerc,3S a

23 ____

Do!!.t; ______V rAic Amount 24 __ _ _ _

27 q5!5 ______28 IC.5qA f1.415 29 1C C)'. 1 30 31

/\/.Ai. I I 1i 'J 1,e3-& L , :i'. 75 Station Documcntations Approved by the Co-OperativQ Advertising0 Committee of TeAssociation of National Adx ectisers

* -. s dnilou-icerent % iis b-,oadcast ______timecs, as enitered in the stations~ programn- 1;D: ' t~ this

-~~. :-~c:c wsboaid-ast wvcre billed to -,his station's clicnton our invoice(s) nurnbcr/daecd______2' t earnd rate of

5 ______ach for______announcements, for a tots, :$ ______S ______CaCtM fo ______announcecments, for a total uCS______S ______ach f r______announcemnents, for a'101.a1 of'S______

Simon c'~fficial ~YI)Cd n~inc .iiid Lilk (\'ot.tr!:,.c'C -Ia~ovc) X)ve) SinnattireStgn3ture oo~ st:i:!'o.,.st:i:io.~ oft"icial Typed name ind m1c S I..,., On INVQMNumbw. 147F 4

ib 123 P 1 banta Ba ba a GO PAG ivM Complete ACCOUNT: 13207 CONTRACT: 1320730 PRODUCT: Mesman:.I.e s ni a n: WI-Il II I..1.1

ANDREA SIEA*3 fRAND SUGGS, L-OMPARDI ADVERTISING 520 HIG'JFRA ST. SAN LUIS or-ir0, cA 93401

f-i. I tmres shownl are approx imate wit i. n 5, M Iu

9:16a. 11:3 10/,26/ 33: 9:18-1- 11:5 3a 10/27/9-73: 3 9:41a 10:3 Oa 10/28/93: 2 93:41, 10:5 10/29/93: 2 11:31a 11:- 3a

Con trac't 0t13P0730 101/25/93 to 10/29/93 I10/29C 10 60's @ $45.00 $450. 00 10/3 Agenc y Commrission Cre dit -$E67.50 H17CITLDIU $ 38 2 . C-0

*~ ~ c~~~~ % S.-.-. L *

SAI.A BANA4 -f *My Cc-r-mrEN) S-:)t 19. 5

as indicated above. " I t~a nmuSflflO bodcs ffi~ \. Mv r~nmmi~inn arnirm c~'~ / ~ c. ,' ~ qJ N I Iutr ~ 12669 W40MW~1 1/11 / 93 PAM 1 TYPE Complete PA0UN: 13 20 7 CONTRACT:- 1320730 PROCUCT: alesman: WHA I LEY

* ' ANDREA SEASTRAND _-SUOGS,9 LOMBDARDI ADVERTISING 520 HIGLJERA STS -SAN LUIS ODISPO, CA 93401

All times shown are approximate within 5 minutes. Times Date Number KTMS Mon 11/1/93: 2 9:31a 11:41a

Contract #1320730 11/1/93 to 11/1/93 11/01 2 60's @ $45.00 $90.00 -$13.50 11/01 Agency Commission Credit NET DUE: $76.50

uq~ dcast as indicated above.

r% rr jr v8% LA, wvimmI..frnnw~r , "11Jt. '

I - , - "~U~'~- -~ ~:-'~ - ~ -' - U

-- a

SUGGS, .LOMBA:DI 9 DVEPT IS ING INVOICE 52C- HIGULEPA Page 1 SAN LUIS OE4ISPOy CA 93401 FAX 805-544-5627 805 -54 4-92'20., -

Transac~tionl Date: 11-30-93 Sale Invoice Terms: Net 15 Due Date: 01-13-94 -4-A 694 Invoice # 4997

Ship To: So I d T:: FRIENDS OF ASSEMBLYWOMAN FR:IEND'S OF ASSEMBLYWOMAN ANDR:EA ANDREA SEA~STF'ND SEASTRAND P.O0. B~OX 14004 P.O. BOX 14004 SAN OBISPO, CA 93406 SAN LUIS OBISPO, CA 93406 LUIS Ot y UM Pr i ce Ext ens ion: Item ID Descr ipt ion

. 00 1 . 36 RADIO I'UHL 00 I . 17- FDIO 1:[PF:'L

Subtotal 6''.

T,--.t a1 Invoic e uU F-LEASE REMIT WITHIN 15 DAYS OF F:ECEIFT. An interest c:harge c'f 1 1/2%. per mo:nth will be added t': o:verdue accounts. You also will be charged for any attorney's fees, :C'Lrt costs and collection costs, if necessary. Net Due 6b6: . 0 ( 0 suggs, lombardi invoice prep form

flff month DO-10, 3010 radio

3020 television

3030 print ad

3040 agency service fee

3100 billboards

3110 art

3120 printing

3030 radio production

3320 other

TOTAL

KAL"1I', 2-4- AFFIDAVIT OF SERVICE RENDERED

o(ICaoinl SS &l San Luis ObpoJ A Lfl~S4SOV Slohovi ThUdaresWHa*Vg _an~Imwr Deposes W~dSaP That Seodcasting 8ervfte Has Seen edsdby *ot~aK~AMinAccordmnce

(805) 238-1230 - FAX( (805) 238-5332 32n~d & Oak St . PC Box 7 - Paso Robles * CA 934"7 S uscrib rdSworn lo 19 INVOICE AND STATEMENT me ft .. (MOf...... 9f4

SEA i:'K, SUGS LOMBA~RDI ADVERTISGC 20HIGUERA2 STREET SAN LUI S 0 BEUSFG'. C A -.4 k)

Invoice # 147 Advertiser: ANDREA E3FN SlUNG DATE

BLANCE FF.UI1 LRbl TA1TE

11./3/9 PA~f'MENTE CHECK' #~53

C 0N T R-C T 6 &' /' FU S:H L I MIE AUG H I /937 THE ,Fu-H LIMPAUGH "HOW" 60I 12 . /93 THE "RFUSH LIMBAUGH S,-HOWI' _11: -"%1a

SUSPTO0T~i -924

Total S-A-es ------

Net !2ed-es - - -- -

2 -ie S FeR ,: JOE

PERCENTAGE A Finance Charge is computed by a PERIODIC RATE OF 1li% PER MONTH, which is an ANNUAL of purchase. RATE OF 18%, added to the unpaid balance at the end of the next month following date

60DY'0AtDOE CUREN 3 DAY 1224 102 .0C 00 I 0I

ms iNVOICE WAS PREPARED FIqMO ICIAJ. SATION PROGRAM LO LAEPAGSSAOUT...... t TIMES SHOwN ABOVE ARE ACCURATE PLUS OR MINUS a MI.PLAEAYTIAMUT K.UNL/ KXFh ,RADIO (805)0:922-7727 INVO -umE * P.D. BOX 1964 * SANTA MARIA, CA 9* INv QHL~TIEDT-11/28/93 Wnta Maria, Californiia PAGE. 1 .lYPE. Complete ACCOUNT. 58966 CONTRACT 0001785 PRODUCT.

Sal esm an: STEVE MOFFIT'T.

ANDREA SEASTRAND SUGGS, LOMBARDI ADVERTISING 520 SOUTH HIGUERA SAN LUIS OBISPO, CA 93401

All times shown are approximate within 7 minutes. Times Date Numb er KUHL Mon j1/1/93: 2 9:05a 11:30a

Contract #0001765 11/1/93 to 11/1/93 11/01 2 60"s @ $18.00 $36.00

I affirm that the announcements were broadcast as indicated above.

MW c mission expire 4/1/97 0c 713

SUGGS. LOWM DAOVERTBIG RdauZ9 I3 52 i1 15 520 W-UA. SAN LUIS OBWSO, CA 9340 PHON 806/544-922= FAX 06/544-567

Federal Election Commission

999E Street, NW Washington, D.C. 20463 Attention: Ms. Mary L Taskar, Attorney, Central Enforcement Docket

Mardh 24, 1994

Re: MUR 3937C

Dear Ms. Taskar:

We are responding to your March 7,1994, letter. That letter is similar to another letter dated January 31, 194 that we received from you previously. The two letters contain different MUR numbers. The first letter referred toMUR 3U5. Your March 7 letter refers to MUR 3937.

The complaint letter included with your March 7, 194, letter raised several issues affect Assenblywoman Andrea Seastrand and her comnme. I have no knowledge about any of the issues raised -in the complakint letter except the ones dealing with the radio ads and the expenditures in the Federal report for artwork and design. The radio ad issue was the samle issue that was in the January 31, 194 letter on MUR 3855.

Ipreviously sent you a letter, dated February 14,1994, which responded to th radio ads issue. 1 have enclosed another copy of that letter. Also, I provided a signed declaration to Mrs. Seastrand's attorney that I understand he sent to you separately. I am including a copy of that declaration with letter also.

*The artwork and design costs of $380 as shown in the Federal report were for a brochure fbr the Federal committee, It wa- a tontallv -zemrafe trans~cticon fr~nrn the radio ads.

These materials constitute my response to your miost recent March 7,1994 letter regarding MUR 3937, and specifically the issue of the radio ads. As I said before, I have no other knowledge as to the other issues raised in the complaint.

Sincerely,

S Lom U -nr-,'uggs, Lombardi Adverti:ing

Enclosures rr LAS-..)

1I(N(; 1-014 M

Statemnent **we"l pod" too Trpe or Pew Si k. ADFILED

w Mit~i S~It ~-Long Form 31 DEC 9 3 lpag~e o -45 A FcaOlhsel oiho OflY Date of 51e61le0 being Mte& Check em of She gSnwhr boxes t.oel as he typo of soaeenSo I pplieables lMenU, Days Yowal n/a _ k4 Sosewvall Skoanogm 1*MWM al QMrAftI'd Q II lomunongafng mt(Aach sci1o)IoW isI415 k)UlOt~i flolo~)_ I In iks Statemefnh List woy other 1S Other CHeltS o Included cownte d by you and any 4 viffees not inclakdd ian this cosolefatd stetenard! that are primaiyarwd to rUeWcv contribiWIu or mad CasimNed Ceasmitte caOIfflitteeSqAofwih s de Aiwkudgt that are Isuduied In Odas SItnnt ____ t a. apendtures ean beh4fu your candidacy. Andrea H. Seastrand

AssemblX~ywoman, 33rd Assemly~jI1L- . WiIVIS 1-1110 320 Ebb Tide Way___ anStAll IWca Pismo Beach, CA 93449 to mama 45"M Za' Friends of Assemblywoman 910281 1-0lU-11I8Da Andrea Seastrand 33 Club gccumatli uuain 00 U114114111 00"WMI)IJME#a P.O. Box 14004___ SIM :rCo A~c hI&~ San 4biis Obispo, CA 93406 (805) 546-9533

Mildred Dostalek __ 111"M Qu 15SS -40 i~h

-eu - &vli kyid~ 5, AnwhI addatwewI aewWWwc duprltely kalarled comiuartion sheets

OlXcalrnokd at CAnddide: a VOIIsetla, I have stied all iss*WAI diligence and totihe best of my knowlge tile uteasurer hias Twemma: dilogeuce on IIICIIuvin tis ssaocel. I have geviewed live state- ddmigcmce Wrpucpwing Ois sstalscimen to14tile best1 (I m~y used all eaounaile I have used all reasonabe Wd toh hese of nay knwledge tile mlnisimuIu contained heiein and in the ifummiom comemued herewn aWd in the aesadeed Kliedales isim tuild wcill thle kunwlede the d schedules is trule awli awnple I certify muklr penahy of perjury under Icelfify wale penaly (it pcrjury "Okie the laws of Ole State 4'f cahikWuitt wiast Imp~ laws of lite 3S of Cahilornia that tile fiwgo"n is hue and CorIKCL. foregifg i m cofect doi IsS Ajis Obispo, CA -~ ~ AN 94 28 J 4 ~ A San Luis Obispo, CA

CilIt"AitiAI - KUAOIOV IIWASIOIR M~~~i~ Lift 'AIAleuj1.ItU:iiLltJVIKA1aLS tilt glI1.giLAt lIii (lMAI-t lIIf I"go 1 11411'llAOL4 I1, 4U4111I-. 9 '41 $eA fig~., "11 g f #lif* Afflo1MV' OfI' Yt 11ogqgg'lIII 5ilJMMARY i'A(;l Camspaign Disclosure Statement Two.orpoPIhInk. Slatemeed cevers peeled S~yPawe Aemeime mail be reied to whole deooms. ft 01 JUL 93_ SEENGHAIKMONAEARS 31DEC 9 3 IPage-el-614 5 W~AW 6OsEH inciununc6axiEi4A &MicW-itDocouMIIm li Friends of Assemblywoman Andrea Seastrand 33 Club 910281 ~

Contributions Received Columno A Column C C02o0l umU3lEnM MANVIAl 1AOD46EIXS, INEENDOFEUEIOW) tAIX) CAXUJAN5 A 91 I Monetary CaudnhtioNIS ..... SchIakdeA Iume3 S 39944. 7.0- s 96100.90 Men eceived ...... StlmexAe Ii, L1re I 0 $56156.20 0_ W "M13l1lAL CASH CONTRIBUTIONS, Add I mes f # 2 S 39944.70 9610.90 4 Nonotielary Conitribution Schlmado C. Line 3 3310.56 4304.70_ 761 5.26 5 SUBI10O1At CON I 1HUUIONS I cvkki[d :uvcoableot l'nurtis) Add i ares 3#.4 S 43255.26 $60460.90 $103716.16 0 6 Enforceable Pronuses (ExcludeLoan Guaranlees, Lure 18 below)Scliedule V. Line 1 0 0

7, TOTAL CONTIRIBUTIIONS RECEIVED . -. Add~anes 5 .6 S 43255.26 . 60460..90 $103716. 16 Expendtures Made 8 Cash Payrneits (Ot11wtOwtoans Made)I SdeleeE. Line5 $ 4 47 39 . 83 S 54.421 $---99161_.00

9 Loans Made ...... Sc/uekrllH.Lkle 0 _0 0 10OSUJBTOTA[CASI IPAYMEN IS ...Addcinues 8.#9 $ 44739.83 $ .,,54421 .17 996 Oo

11. Accrued Expenises (Unpaid 8ills) Scliedule F brie 5 _ 0 0 0 12. TOTAL EXPENDITURES MADE ...... Add Lans 10.1# S_44739.83 S 54421 .17 $ 99161 .00 Wrent"Cash statenent 13. Beginnin Cash Balance ...... ewous Surnirwy P'age. LiW 11 6141.77 *Frn pxevious Statemnent Sufnrary Page. Coumint C Howmever. Iif1,5is the first report lied for thea calendar 14. Cash Receipts - ...... - ColurmiA.Lkne3above 39944.70 yeaw. Cokarnn 13sho~uld be bManrexcept fir Loams Received (Line 2). Fikwceable Proises (Line 6). 1oanS 15 Mwiisc meukicreases in Cash . Scihdol I. 1erie 4 1413.38_ Made (Line 9). ndwAccitued [xienses (1 ie 1) 1O. Casil Payments ...... Colimnit A. ne 10 above 44739.83 17. ENSING CASH BALANC.E.... Add bees 1. 14# 15. Owen subtract Line 16 $ 2760.02 Sumry for Candidates TSWrmnefn StaWmui1 Lmn 17 mnust be zero c(1440Mc11A mAMII)NK In Both June if~0*i a NOI VFANeOAIIINAM01141 and Novemrber Elections

18. MOAN GUAIIAN lEES RECEIVEDL )...... Sclhdle BLPtvf . COhN? V (b) $ 0 III Ilhns 6/30 1/1 C 0).110

GO^ Kqeivaseets MWd Outstanding Debts Ilecoived S 60400.90 4 3 21'). 26

19 Casli I (PalV810OC15 S~te ofh Iswu'hs (ill Frivol so V22I Xpomi inl~t ofu')' 1.1 21) Outsteusdiu1tI D)14 Add I it *I nots I I in (rIiiii,i ( itew 44 / 3,. 11 (q~ r - Mido $ )41.I

-j SCIIEDULJF A 11ohdiule A TWOe or PybtSIn k. Staenwnt covers period Mom.ter Contributions Received Ameusre may be rounded to vibeS. dollors. Iro 01 JUL_93_

3 1 SEE 94INCUI(tK N (*fWnS Iheg DEC 93 Pego. 3 si 45 kC&fndFFE E .R cUA AIE AMICUNERIIIEE) cCMMi1 ar Friends of Assemblywoman Andrea Seastrand 33 Club 910281

RAL NAME AN) A(IWSS OF CON111tI1 11011 D3AIE 10 COWM1:,ISSEE.H MI 4 )("@IIt( StA# AM)NUUUIISS. OCCINWA I KO AND EwkoYtR AM0JNI nFVF.05 CISN ATIVE 10 DAJE CI*AAAlIVE IMAlE 1ItIE NMFRI0.Of NOSE10 U4111101111AS WIN ASSIGiN0. ofU witl E&N11OilNSI4 tIIS FIE1100 CAI.EPA)AI YEA1 0151I ENSFRINIASCMSEIIS N AME£MA SS) NMEINWNESS (JANJI - 1*C 31) (IF Mil't SCAREF) .AUG 9 3 Lola Eide Owner 133.00 133.00 609 22nd Street Glazing Contractc Paso Robles, CA 93446

08 AUG 93 Ted Mamno Sel1f 33.00 232.00 100 country Club Drive Investmientis San Luis Obispo, CA 93401

07 JUL 93 Vicki Melville Curriculum Analyst 66.00 132.00 6015 Quail Court Allan Hancock Coillege Santa Maria, CA 93455

09 OCT 93 Peggy Miller self 165.00 264.00 P.O. Box 98 Developer /Real Nipomo, CA 93444 Estate

27 JUL 93 David Mooklar Vice Pr es ident 133.00 133.00 780 Highland Drive First I nterstate Los osos, CA 93402 Bank

SUBTOTAL S 530.00 Memitv Conkdw Summaty 1. Amin teceived " pedW - coutrubuemma i $10StNLv nue. (hchdeaN SdW~eA uNOiAL...... $ 29130.00 2. Amoouu mm'ived this period - cwsuibuwnms 4i Icss than $14K). (DO wiitemr~c.) ...... $ 10814.70 I TWA itnctay amrnrituekrns acccived this( jiima 3994 4.7 (AWk hmns I wid 2. linscr hcrc andl avn 11w Stittsmmy I lage, (owaij A. 146c 1')I.... }~ TL $ 4i-- thedaie A (Continuation Shoot) TIp.~ of Pellet fill I#*k. Slateoeid cover* period gg Monetary Contributions Received Aewne udo fa1mjurle I

lo.,,sl 31 I)i.:(. 9 Pagle 4 .9 4 NAME If TEEIW~(tIIt~l('.AMUMIE AtN)Ctt EIwou0MlRU ff ~----- IiDI Friends of Assemblywoman Andrea Seasiraiid 33 Club 91 0211 Fitt OAEM) AtIENFSSI. cJmutWiii3ilioft W~E u0CnOL"I It.N 0u A1111010 IkW taisV II'SNMA AMI) A11111SS. lIECE WED I N1I D IAMSOn. 0 MN) 11MU1 IA~N N NASWON 1. 1,1111 IIVAP SIXIOM AI NII SSI

09T 93 Eugene Moon 8348 Northvale Way Citrus Heights, CA

04 OCT 93 Sylvia Bolander Muscia 4737 Jespersen Road San Luis Obispo, CA 93401

04 OCT 93 Florence Noia 840 Stratford Pismo Beach, CA 93449

09 OCT 93 1Jesse Norris 2047 Wilding Lane San Luis Obispo, CA 93401 0T9 Elinor Reeves 4431 Doral Drive Lompoc, CA 93436 04 OCT 93

Fred Reichman 125 Whitecap Street Pidmo Beach, CA 93449

SUSTOTAL S 447.00 Shoot) Type or Print In Ink. Schedule A (Continuation Amoeunts m&V be rounded CAI H ORNIA 1991 WRINII Monetary Contributions Received to whole dollars. JUT,covers 93 period 490_ Lstaleernnfrm1 lereugis 3 1 DEC: 9 3 Pago 5 .o 4 iNi&L Cfa 6(1f~bOi ErEIKUICA A)AIE N4C)oN I KtI)E_6 OMI I IlF_ 10 A)I~ Friends of Assemblywoman Andrea Seastrand 33 Club 910281

______I 1~ T flit NAMEF AFI)A1%SFSS*(V CONl1t1llIf01 DAlf INovMMtiit NIINVW14l4(MAMIlt'SHAA& AP*IMUWWNSS, MAIl U'AIIOIJ AWI EAI 411 ADMA *411 43lIVU1) (.119441AIIVI- MO)IAK Im) CAI I WIt I All IIINII)1RWOn.W If #)I I) N IIf"AININASNIII. in 511 lbI~Not41f 1 to 111%1Ii1114 ( i ll11If.A I I (NIIII II*A~tNW o$~ ~w AD N SSI M4AIMfi419f~ 1155 s) (IAll 1(4 i)

10w,93 Dick Reynolds retired 66.00 165.00 339 Bakke Way Solvang, CA

10 SEP 93 Ethel Roberts retired 33.00 232.00 3938 Mesa circle Drive -LomocCA 93436 10 SEP 93 Bonnie Royster Owner 132.00 381 .00 326 St. Andrews Way Par Excellence Santa Maria, CA 93455

04 OCT 931 Orlando Severo, Jr. President/CEO 66.00 199.00 129 Hercules Avenue California Lompoc, CA 93436 Commerical Spacepoi Inc.

07 JUL 93 Jeff Sharer Owner/Self 330.00 330.00 585 Foxen Canyon Road Farmer Santa Maria, CA 93454

04 OCT 93 Donald Smith IExecutive 66.00 265.00 3938A Mesa Circle Drive Western Cmeia Lompoc, CA 93436 jSpace Center

____ SUBTOTAL S 693.00

£( CG 0 9 ~ Ut 1-1 -,1 -

CA lI i IA (L ,l Type or Ptine 11"ink. A (Continuation Sheet) slatenvent covers period Schedule Ameunie mway be reided 191 R 490 Monetary Contributions Received to whele donlate. grto1 JUiti ()I 6 313iol Di:' ")3 Pae of 4 ji1)#A IMF Hi iNitE .w jiE[EiKxL*RnCANMEi~~ioswow F Friends of Assemblywoman Andrea Seastraiid 33 Club) 910281 U ~ YI TI -- TI Fill HAWE. )U WS(IIIIIIIf IIVI' f.1*A AAIIVI If)IlA 11 P.111 AIMV 1In 1 i, 1 I )AIC IN( *44WS1110AINUIRWd il£eht4SAL MN U'I?; (MII'Allf VI A111II.1 flYIIt AMIIXINilot 10 1111(41'i I AI I WNAI 11 ll INSI)MSIM1114411WSUCIII IU lIASNhAJI IWO~ (iAl 11 I #1 UINI-Mil I ( lAtIIII 144 111 I toll 114 AA 1011it9MA&V AAlMN .5

1 ECP George C. Smith retired 33.00 118.00 623 E. Central Santa Maria, CA 93454

10 SEP 93 Mark Smith self 10 0.00 100.00 1136 W. McCoy Lane Mark J. Smith Santa Maria, CA 93454 Construction

04 OCT 93 Patricia Sparks retired 66.00 132.00 256 Santa Fe Shell Beach, CA 93449

07 JUL 93 Kae Spencer retired 66.00 132.00 5255 Jack Creek Road 0 Templeton, CA 93465 04 OCT 931 Hugh Staton Self Employed 99.00 1 6 .00 2455 Jacaranda Land Los Osos, CA 93402

04 OCT 93 Nancy Stewar Owner6 6.00 198.00 614 East Ros Stewart Olds Santa Maria, CA 93455

SUBTOTAL 4:~0.00

(U U 0 9~ ~~ M -- --q

S(:II1iI)U.ii A (cili Shoot) Tw..rPriuliwlusk. Stae3.seist cove period Schedule A (Continuation UL9 Monetary Contributions Received AnswuhuuII m .

Ihru~h~ 1 DEC9 3

CFctssm oRcviCMIAANCONIMMOLLWOMMI lE wAMEoF 910281 Friends of Assemblywoman Andrea Seastrand 33 Club a______a I FtLNAME )MXVVSS0F(*8,4IlI1lIW1 EIMNA1IVE 100~AII (El tUAiINAMNImEn AA I I lI W1II 1vii 0lNINF lVEIOAIE IDAlf to COlNkIIII.WMUUINM oil(AWbI I 4 MN NOWNOUW" SS, C:AII- tAI I Y AlJI 011011I 0 all IIIIo"hI)INfsOI UlatEI I ()MI I 1*C 311 III AM~ It Ali II 16NIN IIWAM N MW AANNUU PQS M" toCm ttei " 93 Evelyn Teixeira housewi fe 132. 00 132.00 1V* 408 S. Marian Santa Maria, CA 93454

16 AUG 931 Dena VanNorman teacher 99.00 132.00 991 Taft Street Santa Maria/Bonita Pismo Beach, CA 93449 School District

66.00 165.00 04 OCT 93 Calvan Venable ret ired 4131 Oakwood Road Lompoc, CA 93436

04 OCT 931 RalphVohs retired 66.00 132.00 242 Del Mar Court 0 San Luis Obispo, CA 93401 132.00 16 AUG 9 Ted Waddell retired 66 551 Highland Drive San Luis Obispo, CA 93401

25 AUG 93 Granite Construction David Watts, Inteit 250.00 750.00 P.O. Box 900 mediary Watsonville, CA same address

-- -~ __ SUTOTAL S 679.00_ _

( G9( 9 L 11h~k1110101"6411 covers period Schedule A (Continuation Sheet) Type or priMII Monetary Contributions Received toWWI. *

31 t[M-;C 9 3 oF~EIXA ORcimiGnctsJImE ANDcuNi"Lxiot;l*AmM icIe Friends of Assemblywoman Andrea Seastrand 33 Club MUl N"M AN) AhWVSSOU rIUIII4U1001 (JISSAI)I A11 DAIE If 11VAIII M IVV* I IMC M" If I StdM* PN)NIU FICE40INN LOWf U1 II NOSS)000AIIIIIIdSNSNASW0,11I) 10 4411104 11 5~CEU) MII I IW9ASINIIINAL41 A£NVIISS) fA 01

2*JG 93 Leonard Wheeler ret. W 1332 Cavalier Lane San Luis Obispo, CA 93401

04 OCT 93 Steve Will Pres idi P.O. Box 5050 CoastI Santa Maria, CA 93456

16 AUG 93 Art Anthony retirei 261 Coral Court Pismo Beach, CA 93449

25 AUG 93 Winfield Arata retir 4414 Countrywood Drive Santa Maria, CA 93455

04 OCT 93 Dick Armstrong self 511 E. Main StreetRelE Santa Maria, CA 93454RelE

10 SEP 93 Everett Baker retir 1944 Coralitos Avenue San Luis Obispo, CA 93401

9 )0 C)0 9 £ u ( 1111111 EVEnE Typme or POW1.lot NAe. CAI Schedule A (Continuation Shoot)3 Ameunle may be ,mmwdd il 04YA dQ 1991 1:0RM- 01 Mionetary Contributions Received to WIWI* dolls"e. [Staeentecovers peried 31eell 1)1.:(' 3I Pago 1i) Is #All 11 9 10 28 1 Friends of Assemblywoman Andrea Seastrand 33 Club I I -I FIRU NAK* AMIAi11 rotW clBINill114)11 Il I AI N AIIVI It II iI AMIN11111IN11-1 lvii1 I AtIII $All ifAll I 11111siiMEN~i(N, 1110)MIll111UIA SI l AISM;Id I (it Au111It ANlI I IN lllfI#U 5j 1111lNOWASINWISNA AI£MWU %1; HAM1 290. 50 ~CT 9]3 Milton Barnette Owner 66.00 340 Townsend Lane Barnette Realty Santa Maria, CA 93455

1 33.00 1 33.00 07 JUL 93 Cheryl Bedford Owner 1300 North H Street Sunset Auto Center Lompoc, CA 93436

33.00 265.00 10 SEP 93 Vennie Lee Brown retired 137 Meadowbrook Drive Santa Maria, CA 93455

66.00 1 32.00 10 SEP 93 Harry Clark retired 2360 Lake Marie Drive Santa Maria, CA 93454

1 66.00 10 SEP 93 Anthony Cossa insurance Agent 33.00 P.O. Box 7070 Pollard & Cossa Santa Maria, CA 93456 Insurance

66.00 232.00 25 AUG 93 Sjany DeGroot Owner 1015 Buchon Street DeGroot' s San Luis Obispo, CA 93401 Nursing Home

SUNTOTAL S 397.00

/ (i G C0 9 $ SCIIN111 I A (tom'l

Schedule A (Continuation Sheel)TI*oPliots$. Staleenesal covers peried Monetary Contributions Received eftnlybrofd K A

through . 31 PIC 1pgP 10g o 4

III 0.411 i Friends of Assemblywoman Andrea Seas~rand 33 Club I 9)10 2 81

-fl i tt A A i IIt' T11Nii0111%111 11 i)AIE 1g W A Of~II1.04A11111EW4 1l4*001111 011%AWU MW 0kill" 3% (XIIAIWWI0A"AI 01 1yi A#*AllMII 94 .1IVI 1 1I111ANA99II 01AII 4A#A IIAIIVI 9449i il IWU&WE) 1N919S1411111AU a 11WI11H9SAA9UNPAS SOWN*1). 11i ll lOI9e19it le iUSlilIIi CAlI II~W'i YMAl 4)1i If IWIFA IOWASIONOi64 W 11 AIXW RS) m&A fit lootN3 RI (PAuli 9)f4:1)

2EP 9 3 Grace Dillon retired 132.00 198. 00 W P.O. Box 3060 Pismo Beach, CA 93448

25 AUG 93 Margaret Duf lock retired 100.00 150.00 P.O. Box 82 San Ardo, CA

04 OCT 93 Cecilia Fitz-Gerald retired 123.00 156.00 P.O. Box 37 Nipomo, CA 93444

10 SEP 93 James Gates Pharmacist 199.00 365.00 125 Serrano Heights Sierra Vista San Luis Obispo, CA 934C15 Hospital

16 AUG 93 Claire Goedinghaus Self employed 99.00 124.00 13106 Neff Road investments LaMirada, CA

10 SEP 93 Homer Hayward Owner 33.00 166.00 6 Miramonte road Hayward' s Carmel Valley, CA 93423 San Luis Mill & Lumber suuyoyAa S 686.00

(~ U 0)9~ '~ SC;(Il11)l 11.1 A (t owe Schedule A (Continuations Sheet) TyPO or PGUn In,ink. Aunne sney berounded S1aloesent cevece porled Monetary Contributions Received So wheoee . Irem I 11t, 913

[lwh3 1 DEC' 9 3 Paof11 45 N4i 6F&Fzil 11 ORCt4E) A ANSh NSI 1(1-1EMOMM I IfF fl~eiN1111.411 Friends of Assemblywoman Andrea Seastirand 33 Ciubl 1)10(128 1 Fitt IMM APA)ANVUS eortCtWN5WNlI 10COASO FoigIN IlEk 1l) COSAeeIfl1 HeAAA04A1NO IRS, AMw(A #i itI111%411 l.IIIN AIIVF lOI)AIF 4l.IJIR AIIVI 11,1)A II 0A~WI (MA W lANDIS 1111%11101) e:AtI UAIIUYlAll ()Il Iit £MNU S ~IA UNCIIIN 141110SML JAIlI liref 1I III Alle eeAeeeI

*UG Wilma Hermreck retired 66.00 396. 00 P.O. Box 217 Nipomo, CA 93444

10 AUG 91 Dewayne Holmdahl self 33.00 165.50 P.O. Box 462 consultant Lompoc,'CA 93436

10 SEP 9. Robert Honnors Sel f 33.00 266.00 70 Paseo Hermoso Optometrist Salinas, CA 93901

06 AUG 921 Saburo Ikeda Farmer 33.00 166.00 230 Larchmont Drive Ikeda Bros. @1 Arroyo Grande, CA 93420

10 SEP 93 Gordon Klemm Engineer 99.00 132.00 1008 Acorn Drive Arroyo Grande, CA 93420

i U3 EdeKnight retired 66.00 132.00 3995 Colima Road Atascadero, CA 93422

SUNTOTAL S 330.00

6~' U C; ) Schedule A (Continuations Sheet) Typo.ofb, k~o i u.S11019991096 ciiv.,e porled ~.R, Armounle mway be g- Monetary Contributions Received to *wel "e from~ 1 JUL 93 191rR4 0

*wrougl, .31 DFEC *93 pg 12 6, 45 OF OFF M~t~nn A*JIE M*iuCuelnotEtu,*IFE Friends of Assemblywoman Andrea Seastrand 33 Club 910281 Rh.L HAW AWJA(E1FSSOFCNlflffw #to" D)AN Its r0*lIIFF INAIUUIIM oPIIUMI IfI *I ALO NWNOON%%. (W~AIII 114AW N- W I oyt n AA III IN 1.1 IVI I I IJIMINAIIVI lollAir (A *At,4iI A IIVI, I() I )A I I FICPOI Nitil1 MOM" O.Of W) MIMN ItIIKS INWIN ASW 1). In sill SII "Ifl 1Hiit 11UIS 11101 (Al I IAJAI 'iiAll (illIL. 11 IN I5INF I.11SNAWuSAINIISSI MAAN(N 101W* SSl (IAIII (JfC 31) (Ir AIVI ' AIII f 070L 93 Doris Lahr ret:ired 66.00 132.00 W 353 Machado Santa Maria, CA 93455

10 SEP 93 Harry Rex Land ret ired 99.00 132.00 633 Ramona Avenue, 34 Los Osos, CA 93402

04 OCT 93 Boyd Larson ret :ired 33.00 166.00 224 South J Street Lompoc, CA 93436

25 AUG 93 Don Lewis retired 66.00 199.00 P.O. Box 457 0 Lompoc, CA 93437

04 OCT 93 Gladys Loomis retired 66.00 1 32.00 950 Huasna Road, 38 Arroyo Grande, CA 93420

25 AUG 93 Victoria Lowrey housewife---- 1--33-.00, 222.00 P.O. Box 1266 Morro Bay, CA 93442

SUNTOTAL S 363.00 TWpO or PliIn k*hu. Stateent eovoie period Schedule A (Continuation Sheol) Amuusli may be roundled Monetary Contributions Received to frwe defe.

31 DEC:( 93 page_ - 3of4 (XOFEI K01ti*lon CANIiIiE AM) CIN* 11 1 E(1 C MI II F 910281 Friends of Assemblywoman Andrea Seastrand 33 Club

nfl NAME AM) AlIUffS O NIIIII l AllVF 10lI)Alf- CA"I AAlIIV[ SNAOI ANI)NUUN1111S MCINAIift 9iA"I) t K1 Wt 1 AA NJ I IN4.1 IVI 1) cl *AN I1 to UnkAIIIIANAiU11li(1WIOUMAWASIII CIIi111Al F)fSAil I All 0 il4 iN %W IN %ottNI)SiIlhUI offl HN6im i ~ ~litI fIEIVI~o llNlliiiI NLAilkR01 I NOIW1111 M*NI~IilkINIA JIlAIO ING1i ii (11 Al4' i1eW I HtIill IASQI Of5M M4*I AlIXUNSSI MAm (If 1119544WSSj

330.00 10*6P 93 Coast County Pharmacy Assoc. 330.00 1245 Broad Street San Luis Obispo, CA 93401 Western Agricultural Chemicals ssoc. PAC 50.0500 500 27 OCT 93 P.O. Box 22323 Intermed ary: Gary Pemberton500 Sacramento, CA 94822 Ciba- eigy Corp. ID 800897 5510 lirdcage, 110 CA ______~-______-it Lr i hts 95610 2000.00 27 OCT 93 California Restaurant Assoc. PAC 1000.00 1600 K Street, 100 Sacramento, CA 95814 ID 890231 500.00 27 OCT 93 California Mortgage Bankers Assoc. PAC Two 500.00 980 Ninth Street, 1450 O Sacramento, CA 95814 ID 890152 ___ 27 OCT 93 Texaco Inc. Intermediary: 500.00 500.00 Voucher Account Gavin K. McHugh Beacon, NY 12508 Texaco Iic. 1201 K S reet, 1140 K S~-~ re e t14, ~-- - _ _ _~0 27 OCT 93 The_ _ _ Tobacco Institute Intermedi ry: Bob Pruett 500.00 500.00 18751 L Street, Northwest The Tobacco Intitute Washington, DC 1225 8th St., 50 Sacramento, CA

3330.00 ______- ___ -SUBTOTAL

LC, G 0 9 i '~ Schedule A lContinuation Sheet) Typo of~ln104dof Ink~. ISlaterne., cover* reted ml Amount-may 60 Montary Contributions Received Wowhole delliWe. frm1 Jul., 93

Shrougls 3 1 D I C 93. page_1 4 e.4 NAE 6 FFCi6EE I*F5(J6WA(IE -AI4)cuifioLLEkiiC-AMkI IfE Friends of Assemblywoman Andrea Seastrarid 33 Club 910281 n&1t NAME AN MNSS(W CON111UU*11Wtl DAlIE luuHAW 10rC411AAt. SNA AMIA.s0.I %S,)MNtaW.l ( IU'Alk4 AMELfI.I 0Y~Fl AMON I I 'iflVII, CIlMtN AIIVF IIIIAIF IAM AIIVI 1i DIAll I~CEWEO ENI(l100 MD.WROA.WNOI 10 14h It1IIASIXIN AL960MI QN gotIhIvl~uouINIISPl CA1I F#AI ThAII 011 IFI m"ill InAm11141111M A&NWW ssl MN ()I .nf~fual IJAI (IFAF41 hAHlf r SEC 91 Anheuser-Busch Companies 500.00 1000.00 1451 River Park Drive, 126 Sacramento, CA 95814

17 DEC 93 California Motor Car Dealers A soc. PAC 500.00 500.00 555 Capitol Mall, 530 Sacramento, CA 95814 741623 15 NOV 93 California Credit Union League PAC Intermediary: 500.00 500.00 2350 South Garey Avenue Richard Mersereau Pomona, CA 91766 CA Credit Union Le gue 760225 1121 L Street, 410 ______mmmntf PVA RA 9 NOV 93 Miller Brewing Company Int rmediary: ~500.00 500.00 Milwaukee, WI 53201-0482 Par e D. Terry Liv ngston & Mattesich 1201 K Street 110 ______Sac. amento. CA 95814 9 NOV 93 Hunt Wesson, Inc. 500.00 500.00 1645 West Valencia Drive Fullerton, CA 92633-3899

4 OCT 93 California Hygienists PAC 500.00 500.00 300 Capitol Mall, 350 Sacramento, CA 95814 ID 830002 -1. 7:: SUBTOTAL * 3000.00

UI(~ 0 9 t/'~.~ Schedule A (Continuation Shoet) TWOe or 1111hob Ink. A..n. weaybe usd 610a01106111 towels peried Monetary Contributions Received to whole delta.. reen 1 Jul, 93

Shogs31 DEC 93 Pae-15 of,45 (* oriiu o-6-6iEWt4iDAE A4-C'uwI~K [-1tw~i - AI r Friends of Assemblywoman Andrea St-astrand 33 Club 91 0281 RILL MW AW)AIMWSS* LVC01411*011 fitCOMAIIU.0AINVOI0ESOMUShIASW~ AMNiON1 I%& (NIUAIS NJ All)Ek1oYEn AMOIN III 1:1 NlV1) I-AN AIV IODAIF (AEM1N AIIVt lWIoAt( I NMn1 NUKI1.'nwuno0 01 M"IIfAWS 1IN ASSK;0al) to Soft lW4)VII)IfkiIS CAI EWIJf YEAII Mti If1 INI(fN NVA5UWIStNA ANNN SS) tow~ EN IIIDwau.S J~Il lAfsC 1) 1WFAflI IA1M1F

.T93 California Ambulance Assoc. PAC 500. 00 500.00 1127 11th Street, 300 Sacramento, CA 95814 ID 890111

4 OCT 9 3 Western Mobile Home Assoc. PAC 500.00 500.00 1127 11th Street, 300 Sacramento, CA 95814 742422 Intermediary: 4 OCT 9 3 Mine Reclamation Corporation 500.00 500.00 980 Tahquitz Canyon Way, 204 Eagle Mountain Palm Springs, CA 92262 Landfill A Recyclirn Center same address 4 OCT 9 3 --Kisociatibn -of -Cal if ornia-Tnsuf Anc? e C6mffnL-9 915 Street, 1160 500.00 500.00 Sacramento, CA 95814 ID 830078 4 oc 9 Pacific Racing Association Intermediary: 500.00 1 000.00 P.O. Box 6047 Peter W. Tunney Albany, CA 94706 Ladbroke Racing 4 OCT 9 3 1100 Eastshore High, ay Albany-, -CA 9A 7 Of California Grape & Tree Fruit 1eague Intermediary: 1540 E. Shaw, 120 PAC liff Sadoian 500.00 500.00 Fresno, CA 93710 ruit PAC ID 800697 ame address

SUBTOTAL 8 3000.00

I~IU 09 2but S( I III )I ii A (L4. 'Ii Typo or 1%1#0 In Ink. stlonent covoe pesled Schedule A lContInuation Sheet) Asnowuse mayv be soend Monetary Contributions Received Sc w3.I. deoloae. 3rnt11U[ )I( 3 Pago. 16 of 45

~JAA~4Wtlt rin 1 11 *AkMMjAiE AMN) (AWIIl I M (I* W I I Assembi vwoman Anidrea Seast ranld 33 (C1 III) 9)10281 Friends of AMINEJI IN' IIVII) V~ I 4IAIi-f ______I.*IAII 1111.4111AII'/L lUIMI nu1 ~AN A4If V ~I*4('*dIIUIII MO] AMSNII I* fEI 41) IMIAE IN t6sWALegO.INW.NVuIN 14441* E I 1 I SH4AMAH A N4Nl SS, MCIIIIll10 IJvI)lI4 IV[ 1 CAI I IN II VI-All 1)11IjI) iltc-EKI) I INSIII MIMOMWN M)41) HINIOIISASININASS54(08111 NALU III lltIlS1l (JAIl I (*U II) 1000.00 Western United Dairymen PAC 500.00 49& 1315 K Street Modesto, CA 95354 ID 771500 500 .00 500.00 19 SEP 93 California Cable Television Asboc. P.O. Box 11080 Oakland, CA 94611 ID 745932 500.00 500.00 10 SEP 93 Pacific Agribusiness Council 1715 Capitol Avenue Sacramento, CA 95814 810430 500.00 500.00 10 SEP 93 California Forestry Associatio 1127 11th Street, 300 Sacramento, CA 95814 761244

10 SEP 93 California Financial Services Association PAC 250.00 250.00 1010 11th Street, 210 Sacramento, CA 95814 881022 500.00 10 SEP 93 Southern Pacific Transportatia n Company 500.00 Southern Pacific Building One Market Plaza San Francisco, CA 94105

GUSTOTAL 2750.00

&w' 11)?~ SC111-.'1AJ1.1; A (Ioml) Schedule A (Continuation Shoot) twop :r PtmUsIn 1". 914101100111 covers poriod Monetary Contributions Received *0weo eae htem I J UT. 9 3

1trouvg .3 1 DIC 9 3

Friends of Assemblywomait Aindre--a Seastraiid 33 Clubi

FiLL P4A AWA43NW~SS0( CoN1lllW,41Ilfl W)AE iNIImsIUNhNVNkI PIPt.MAW111 StdAMI AMPNIN55S. M't213AII4V1ADI)8U16115V11 AWANMJI 1EO14I Ii) 1IAIIAI1IVlPiAgI IN11111U M4A11011V W111IMI4ASNNS~t#I 141S1l41(mll"Iml I I IS IIt Io CAI I,MoAI V1AllI 0114 I NO#Of IMAS 0 ItS NAAM &ADO111 SS) HAW (it lNAPPO911 IJAN I -iD G 1) (III AM 1ILJ111 F 106P~ 93 Political Action by Pest ContrpA Operators 3031 Beacon Blvd. 500.00 500.00 West Sacramento, CA 95691 ID 790454

10 SEP 93 Delta Dental Plan PAC 500 .00 500.00 1127 11th Street, 300 Sacramento, CA 95814 ID 790780

10 SEP 93 California Horsemen' s Benevolent & Protective 500.00 500.00 Association, Inc. P.O. Box 3747 Arcadia,_CA 91066-3744 10 SEP 93 CA Correctional Peace 01,--AOficr Asso'c.- PAC 500.00 600.00 770 L Street, 800 Sacramento, CA 95814 830349

10 SEP 93 California Fertilizer Associat ion PAC .-....-- - - 1 50 0. 0 0 500.00 1127 11th, 300 Sacramento, CA 95814 ID 850321 10 SEP 93 Unocal Corporation 1201 West 5th Street 500.00 500.00 Los Angeles, CA 90051

I _ SUBTOTAL * 3000.00

I (; C) 9 ? V ~ C Schedule A (Continuation Sheot) Kypee*r Pe#saU a leak.Stalessin covetse peeled Mo.,elary Contributions Received l ~l e firem 1 JU-L-93 --

truh-3 1- ) EC . 93

Friends of Assemblywoman Andrea Seas trand 33 Club

Fitt.NAAK AND A(IffSS OF CONIIUIU (11011 DAVE (* If W4MU3itSNS1111WIHOLMUhSI H SHAWUArnN) WNSS. (l'A(NIAI NA n~EENo IM 10 U M OMROfW) 10 ME*WI lIASUN NASSGMU. forSml II.4 FNIE11IWASINVOWHAW 1ANNWOSSI MAUI (Alit

10P93 California League of Savings Institutions 9800 S. Sepulveda Blvd, 500 T--os Angeles, CA 90045 ID 890572 10 SEP 93 California Optometric PAC P.O. Box 2591 Sacramento, CA 95812 ID 745825

10 SEP 93 California Rice Industry Assoc PAC 701 University Avenue, 205 Sacramento, CA 95825

25 AUG 93 Wine Institute Fund 425 Market Street, 1000 O San Francisco,'CA 94105 ID 743161

6 AUG 93 Avco Financial Services 3349 Michelson Drive Irvine, CA 92713

6 AUG 93 E&J Gallo Winery P.O. Box 1130 Modesto, CA 95353

SUBTOTAL * 3000UU ______

9&~I U C) 9 ;: ' . Shoet) TIypo or Pont In I$*k. Statement covers period Schedule A (Continuation Anwowinto may be reoded Monetary Contributions Received 10 whole dellars. frem 1-JUL . .-.-

1 9 3 1iDEC 9 3 Page, of34 NAM 0OFFCEEIMKUEfl 0171CAMMIJIE AI) CONI fl1tiED)CO MMI1 K[ Friends of Assemblywoman Andrea Seastrand 33 Club 910281 1y nINAME AND AIXVWUSS 01'eC01IUWINDI1PUM W~E IN COASOff, INUA l) (OA,oII a tIft I SNwlM A4 AINIUS! 01CiIN'A114 JM) I9A OYE AAINI 1I 1' IVI 1) (AIINAIIVF I()II)AIU Il4A J1 AIIVIL ii I ) I FECEL)E ItI JB)NM8UA(MI.IIF N)0I1) Nl5UW II OAS IIN 4Si(M . p1 oile kl 4~)Whh)ommh CAI I tJL)AII Y1All 011IF11 INIIJI11vAStIOVIS#MAW AAMIWSSj WNA&(a n OfhWNSRI (JANJI Df 4; ii1 93 Farmers Insurance Group of Comp~nies 161V 1000.00 Farmers Group, Inc. 500.00 4680 Wilshire Blvd Los Angeles, CA 90010 16 AUG 93 Association for Los Angeles Dep~iy -Sheriffs, -Inc. P+tC 828 West Washingron Blvd. 500. 00 500.00 Los Angeles, CA 90015 ID 822506

16 AUG 93 West Propane PAC Intl rmediary: 300.00 300.00 7844 Madison Avenue, 150 Ron Id Myron Fair Oaks, CA 95628 Wes em Liquid Gas Assoc ID 801434 address sam 16 AUG 93 Association of Physical Fitnes Centers PAC 500.00 500.00 600 East Jefferson, 203 Inter ediary: Nick Medei Rockville, MD 20852 1127 11th Street, 940 0- -ID 841317 -Sac-r mento,_CA951 First Interstate of California Intermediary: 250.00 250.00 16 AUG 93 1200 West Seventh Street Betsy Graves Mahan Los Angeles, CA 90017 Fix st Interstate Bank I CA 93C K Street ramento, LA .9.58L4 -1 16 AUG 93 Blue Cross of California Int ermediary: 500.00 500.00 21555 Oxnard Street J. Richard Eichman Woodland Hills, CA 91367 Ce tified PUblic Accour tant 11 7 11th Street, 300

SUBTOTAL S 2 750.0 0

/~~b I, C (1 9 £ ( SI 11111A) 11 V~ A (t mil ) Schedule A lContinuatio Sheet) Type. of., 199543Ik#I. Stalonvost 4coveis poted Monetary Contributions Received Amovowhd may be Jul.

______~3 1 1)t1:(e 913

N" 470rFEEl,~ 041n G 54EMIE4)U I tEt**t0__ 6- I'I -- Friends of Assemblywoman Andrea Seastrand 33 Club

l)AF 10 e'It* IAUINV4 4sue'MAW1g;4%I WA&*Pb1w4s (XI~IINA114 hIII 'OrIW1A0II8 AM(14 10 4 IVI 1) 1S11AtNAllNl Il0iAll t 5A A IIA1VlIf)Sit iI 1*100v :1 IgtltlD aNU scott011.1u*11 1,114cANss ASIN IN A&s(W01 4%olIn e at Eysm1)1 lStn'1ii~ to I4Al I W4AIl ~IYAlI M5111I4 IN~H llAmONdOSOMM A AIXIII SS) HA14 (oi tins#4 S3 4 IAtJ S1i~ (All 1 (If Ali I 1(A#41 I I

16@OG 9 3Shell Good Government Fund In ermediary:Tam pollx 500.00 1000.00 P.O. Box 2463 Sh 11 Oil Company Houston, TX 77252 11 0 J Street, 720 Sacramento, Ca 95814

16 AUG 9 3 Oak Tree Racing Association 500.00 500.00 285 W. Huntington Drive Arcadia, CA 91007

16 AUG 9 3 Agricultural Council of California 500.00 500.00 P.O. Box 831 Sacramento, CA 95812 ID 761092

16 AUG 93 California Association of Psyc iatric Technicians, Inc. PAC 2400 22nd Street, 110 565.00 1565.00 Sacramento, CA 95818 40 _ 882070 - -I 25 AUG 93 Household International 500.00 1000.00 980 Ninth Street, 16th Floor Sacramento, CA 95814

25 AUG 9 3Pacific Telesis Intermediary: 500.00 1000.00 131 Kearny Street Dennis LeBlanc San Francisco, CA 94108 Pacific Telesis Group 925 11Street, 850

-~ -~ s~cr iuw- -CA 958-14 ~ - SUSTOTAL $ 3065.00

P~ I C 0 9 £ 7U 1 ( Schedule A (Continuation Sheet) TYPO of,.ftintI Ink. m. *nt severe poried Monetary Contributions Received AlWtlmlrpm"" , Jub~ 93

.31 1)F ( 9.3 - Silweugli Friends of Assemblywoman Andrea Seastrand 33 Club

FRk NAME AND AIXV*SS Of(cONIIUNfit)" DAlE INCOMMnu ItfINA1uulvw1 14) MAN It US POA41AAn uSs. X PISAW114AM) EL44oYEII AM(AIN I INu. IV11) I #*AtNAIIVV I () VA I (.IIMIJIAIIVE I)AIF CAl UNDAII 'iSAl ItlHO ON $ 14$HAW AA4AU intN-.51 (if rwIIW S51 I lAItI -l1*t 11) III AIV'if "tAitI ~UG 93 Peach PAC State Account 500.00 500.00 WCling Peach Growers for Effective Government P.O. Box 7001 Lafayette, CA 94549

25 AUG 93 California Fefuse Removal Coun ii PAC 500.00 500.00 1121 L Street, 309 Sacramento, CA 95814 ID 923445 29 AUG 91 The Pacific Lumber Company 500.00 500.00 Scotia, CA 95565

25 AUG 9: Atlantic Richfield Co. 500.00 500.00 1201 K Street, 1990 Sacramento, CA 95814

7 JUL 93 California Credit Union League AC 750.00 1250.00 2350 South Garey Avenue Pomona, CA 91766 ID 760225

7 JUL 93 Mobil Oil Corportation Internediary: 500.00 500.00 Fairfax, VA Elizabeth T. Walker Mobil Dil Corporation 1201 KtStreet, 1920

SUNTOTAL S 3250.00 prim-

.%CIINA 11.1'. C Typo or PAiM In Iu& Stlamnt coveir. pow"e Arnetimie myh e roemid aTContributions Received to vwet dollars. fo.0 JU-L 9-3- 31 DEC 9 3 through-- -- jpae - 22.- st 4 5 - SE~E11SU100* ON REVERSE tIO OF OFFKIC ORCNIAEif71 W AN rOKflxI ruo~I( istrand 33 Cluib 910281 Friends of Assemblywoman Andrea Sea I1S(~UPtKJN- - OF I r I CIRAIR AlIVE to DAlE PAIION AND EMPIOYER CIJAAIAIVE 10 DATE CIOMIV 10 D FIR L NJA&*AND) ADD1NSS OIfCUNIHIIUJI110t (IUOUS OR SERVICES VAL(* C;At ENrIA') YIAH slif 416111101 141 (JAN I -[)EC 31) tW&%of sumi6S) 11111UINAWGHLD.tNuRIHARWUISP4AL1 s AIXV*SS)j 1000.00 Bob Gordon Owrier f lowers 1000.00 . SEP 9 3 1532 Monterey Street FlI)ral Design San Luis obispo, CA St idi o

800.00 AUG 9 3 Kathryn Williams SeiLf food 800.00 123 S. College Re iltor Santa Maria, CA 93454

171 .00 171 .00 26 AUG 93 Talley Vineyards wine P.O. Box 360 Arroyo Grande, CA 93421

114.00 114.00 31 AUG Morgan Winery wine 526 Brunken Avenue Salinas, CA 93901

wine 200.00 200.00 31 AUG 9 3 Corbett Canyon Vineyar~ s P.O. Box 3149I San Luis obispo, CA 934 13

SUSTOTALS 2555.00

Anode additionalinfoimatioa on apprprately Noenftary Conibuion Smy kibeld contination sheas. AI. CiAmi~vikiPCnad wi n1JocaFy4Aw)IlwsikNs(IO04Wn"KIM. 2555.00 (MCkmIC A SC11011111kC Vhk~ab.) ...... I...... I ...... 2. Ankwu irc~val this perid - uaon1-111ewlaay UIN1III)bIIiIHS (A ICess "1 $140. (D 0 le iz ...... 7 5.5 5 5 .-.56$ 1 Tutal eirn-uismismhaty wemihaibiknis ueevedIh Iwoili. .310.56 (Ashi 1 11104 1 ne INeI Ie ne1OIIN 114111 Ilk! S1111111I.y l (a'e,41hIuitAl I.end 4.)IL .i ..9 .... $OTR7L . # FORM 490 01 JUL 93 31 DEC 9 3

Friends of Assemblywoman Andrea Seastrand 33 Club 910281 23 of 45

31 AUG 9 3 Parker Station wine 108.00 108.00 P.O. Box 908 Los Olivos, CA 93441

Cottonwood Canyon Vineyards wine 162.00 1 62.00 jAUG9 3 P.O. Box 3459 San Luis Obispo, CA 93403

I I I U Cl 9 ~? 6I. SCl IIi UIA It'I a,. ml tauk. Istatement covers pervted U EE Adu~e be rmlded I ipYwSnsta and Contributions Ilel 1UM_U '103kM Than Loans) Made

MWCF~fIMENOLE3A MOAMTDAEANTRAW I ED)COMMII ICE Friends of Assemblywoman Andrea Seastrand 33 Club OAPORIANI WWONI ItEMIZE THE PAY#ENI (iF KCRAWEXPENSE:SON SCHEMIE E WWi AM AOIJISS OF PAM, E1110~IR. ORlRECMNI OF CON~IFOW 111M UIEP(II MJY IIE IPSMOF SUPAYMNISONt"J 4 Of 1#E SMARY SECION W I )W_ WCOW.It(.VANUWONocvtsm S I AMN"SNA ASANIN** SS)u~ E*SCOikIO 0 PAYMENW - - I COE 11 Telegram-Tribune Mid-State Fair Tabloid Advertising 200.00 3825 S. Higuera Street San Luis Obispo, CA 93401 I JUL 93 290.00 Postmaster Postage stamps 1655 Dalidio Drive San Luis Obispo, CA 93401 2 JUL 93

144.00J Rotary Club IAnnual Dues c/o 1394 Andrews San Luis Obispo, CA 93405 6 JUL 93 140.00 Sirlin Photography Member's Official Portrait 2354 Fair Oakds Blvd. Sacramento, CA 95825

6 JUL 93 I .. _ SUBTOTAL S 774.00

Payna-ents and ContributSions Made Summary $ 3.92 .3 1. Payments nixie tis perIo tif SIM0 tw mwe. (hwltitk all Schedtule E subtitls.) ...... 36-..36 0 2.. PP niyms st aletxibistic peler$i10ofinom icin c.)...... _...... $ 3. Titl 0C1 pmmlIPatti~ thu periok~ on IISIMI(ktti4g k1..s. (lFiticiasommnt luuSchenk . P11, in I. (utios(d).) ...... ). 4. TWat-wcuil eiAumses pilai thlis ~InCINeat(DoIn ol i~vin,,,c tumicl 41samummIIII Wil stIt-II1 I.*line 4.) ...... TOTAI It 44 1 19j. v 1 IMiii 4 1111:2 ,, I , S'11wX S "I#,j it to 4 ., ,-towi nt e .,ito- i, wi I A a lt I is.. I 1 1 ;111# -1114W-144111 ~.1 Two or Pt h. Ien.d Statement cevere perod .841fhedulo E Amuuide usoph.' -C~ktHnuAtIonSheet) to 100114116l tro 1 Jul, 93_ and Contributions Payents e~eegh31DEC 9 3 age 4 (Other Than Loans) Made

Andrea Seastrand 33 Club Friends of Assemblywomanit *A A~ef iI nrF "AME Atlt)AIN)4t4 * PAWt. UlIt.NIL411I CilWt#41 (11 (ANI1htI11itK)N If #III) 1164**h I# U "I I It, W JSIMJ 10Ct**AIKESNADM( ANI)NNWlidSSJ it I**IUPIKI(W* I'AYL4141 & AIN (SS) 4IN* ( IFSNWI)D &*4 A W A5" )I4I II$I A .IK$I4S IAU rt isment Mozart Festival i P.O. Box 311 1500 San luis Obispo, CA 93406 7 JUL 93 1 09.1 2 Butt Dnl Supplies Button King 2355 Oakland Road San Jose, CA 95131 7 JUL 93

Sophomore/Veteran Member Dinner 289.71 California Fats 1015 Front Street 95814 S Old Sacramento, CA 7 JUL 93 590.54 Computer Lease June Computerland 1422 Monterey Street San Luis Obispo, CA 93401 8 JUL 93 624 .60 Member's travel in District June Dell Hinn 28 San Pedro Pilot service Salinas, CA 93901 596 OTHER VENDOR UNDER 596 $00 SUBTOTAL 1748.97

£ I I 0 C) 9 , V k'- t, ( - Type *9 Pdi 1" 11 Staenmis, cover* peiod S S4heBIo E Anse.UsSSON* berM #fContInuation Shoot) to wsoleu. . ie 6ri Ju. 93 Payiments and Contributions Iwuh31 DEC 9 3 p~e2.'45 (Other Than Loans) Made 1k jilEEU11SIUJ IN114S1N1SE'AO AD W JC1410 11CM 910281 33 Club Friends of Assemblywoman Andrea Seast~rand

AMt 941 A9I (gCFggUPI)N( I'AYI N M1NJIP 1 PYf14 11S "AJ &AIN91FSS) tIN* 41111NO F IS I fitU."*#IlIAS MEENASSE"O. JNIMR II!AkAIll*

Salinas, CA 93905 115.00 Postage Stamps 213.00 Postmaster 1655 Dalidio Drive San Luis Obispo, CA 93401 8 JUL 93

July 300.00 Pete Agalos Service/Treasurer P.O. Box 4601 San Luis Obispo, CA 9340313JL9

577.25 Blake Printing and Publishing Printing P.O. Box 12338 San Luis Obispo, CA 93403 16 JUL 93 __

Stamps 290.00 Postmaster Postage 1655 Dalidio Drive San Luis Obispo, CA 93401 18 JUL 93 SUNTOTAL S 1380.

0 0 9 2 V SCI IEDI J1.1. E (Cofil I w . SN.IABA Imk ddUl0Eor Amsne sb euitUaietwtnt covers purl..l 0Cantlnuatlon Sheet) fro 1,eJUT, _3- --. Paymnts and Contributions (othr Than Loans) Made ke091- DC93ao _____ SEERA6 N; isW6(I"REV(E NA~nCE U- lottill(IA C A~f N?)A1A4C*411141411 C(l)1*.*i I 9 Friends of Assemblywoman Andrea Seastrand 33 Club

N"AIM ) AIIIIISS (U IAYEL. ClII-DI D11(111l lt A Wll 141(1 CItNIIIlIII')t4 S, I f Of# 1) t~o (in 11FC(W1Al Ik 3w4 A WNil 11i()r)(d*I I S MAW til AtMN i*SG111P 1- lAYMENI llk4 A~I & At4 11tSS) (Ax ()it IFtWKI I 1t) **14 1S WENASSIGNE0 E If H1t.lASIA 274.89 mailing Postmaster Bulk 1655 Dalidio Drive San Luis Obispo, CA 93401 18 JUL 93 252.00 Volunteer Passes CA Mid-State Fair P.O. Box 8 Paso Robles, CA 93447 20 JUL 93____ 290.00 Stamps Postmaster Postage 1655 Dalidio Drive San Luis Obispo, CA 93401 21JL9

590. 54 Lease July Computerland Computer 1422 Monterey Street San Luis Obispo, CA 93401 2 AUG 93 __ 300.00 service/Treasurer August Pete Agalos P.O. Box 4601 San Luis Obispo, CA 93403 2 AUG 93 1707.43 SUBTOTAL S

.7 1 U Cl 9 ~: ~- t7 ( staeent covere period nwewo one- S"hdule 1E *,m1 JUT. 93 ~sflualon Seet) Pa nts and Contributions 31 DEC 9 3 (other Than Loans) Made M~ 114Wwo6t~~ 14 I ifrlI)IC*1(*aAlI U Club Friends of Assemblywoman Andrea Seastrand 33

II)BSS CF PAYEE. CflEtNW011 MWlit lCi11 1 (. welIIIK)N N4AMEAlit )Al AWUNlii1 P~AID AMI i l WiII S. MtIt I I 1 1 16sdU4(NO J* CS I~ CItj1AI) IIIII I0E(A"4 IffESNA*& fill A!ASiItI, NAAA A A 104 !; *341* It tijIb I I t )IIAS MEEN ASSWKiII. El II 603. 63 ees Travel in District Jul1y Membi Hinn Service Dell P1ilc ~t 28 San Pedro Salinas, CA 93901 93 OTHER VENDOR UNDER 530.40 8 AUG ---"$100 1163.11 Pr int ing Watsonville Press P.O. Box 1240 Watsonville, CA 95077 9 AUG 93 1 27.4 4 Supp lies Wins. Bros. P.O. Box 30850 Los Angeles, CA 90030 9 AUG 93 435.00 Post:age Stamps Postmaster 1655 Dalidio Drive San Luis Obispo, CA 93401 10 AUG 93 399. 36 Prii rting Blake Printing and Publishing P.O. Box 12338 San Luis Obispo, CA 93406 16 AUG 93 SUBTOTAL $ 2728.54

9 1 0 0 9 ~ 81'0WI liiir )Ip I I (oul Typo. a nO n k. S~hduae E Ammes may be ,.Mde6110 to wbowS dommae. ~ ~ jewolmmm'atIfl Sheet) from,1si JT, 93 Pametnts and Contributions 31 DEC9329 4 (Other Than Loans) Made MEE06111111111 11ISEVERSE 0I1W1114l It (. AtIIAIII I ii (f lOI *i KVI I (A-VCNEAl 1 E At ) C( 910281 flub Assemblywomait Andrea Seastrand 33( Friends of PAil) AM(M itiI NAME~ ANt) AINIESS OF PAYEE. CH(INIAI ()IItl11f(fN1t V((41l~1) (Vt t*StIU1PIO#401 IPAYMI ViNIWU1"4OC(JAMITFE-SI(Ai AtMUUC11SS LJFII)NAH% t#i(AU.qAj1111 *FUS#AL*A Ai1ti0SS) CANt* ift I I D I P ILI* IIAS I*L ASS~i(I ill &IJ (itiAS~Af 454.71 Printing Viking Printing 1125 11th Street Sacramento, CA 95814 16 AUG 93 1 50.00 Depos it GTE /CAS Political Accounts P.O. Box 6023 CA 90702 Cerritos, 16 AUG 93 1 00.00 Easter Seal Society Dinner Let's Do Dinner c/o Easter Seal Society 977 Pismo Street San Luis Obispo, CA 93401 19 AUG 93 0s 300.00 Bulk Mailing Permit 529 Postmaster 1655 Dalidio Drive San Luis Obispo, CA 93401 23 AUG 93 474.30 Annual space rent Derrel's MiniStorage 3650 Broad Street San Luis Obispo, CA 93401 31 AUG 9 3 1479.01 SUBTOTAL I

/_ I I () /0 II C9 C . ~c -77

~g b*I~ b link. Period ."hedilo 1E Anwwfeui MaY be reunified ume CV'I ' h.nmnatlon Sheet) to Whole dellars 1 JUT,. 92 Payments and Contributions C 93 gouh31 DE. (Other Then Loans) Made ME 9W t*6W4 0"WIEWERM i N" WfFEWKER A01PCANflIAIE N1971C(4411144 I tI)Cl*JMIII Friends of Assemblywoman Andrea Seastrand 33 Club

( tIiIItIIII(M N"A40 AI)NWSS (V PAYEE. CJIENI(NI (1411111-11I NI NAAM AIN1111: 5S. W11:11 10 1014WI4(" j aif ~IffIN uAMIKWN 10C(AIfS 1 1SUWPIPM ( PAYINT NAM 4 MNW1ILSS) COM1 (11 F "U 11) NI*WIHIIAS KEN ASSMN"[), E(#411If% ASIWIM'S 487.09 office holder related expense Bank Americard travel to and in district P.O. Box 53148 Phoenix, AZ 85072 30 AUG 93

VENDORS: ittee Fundraising Conm The Office Restaurant Meeting with 2712 Santa Maria Way Santa Maria CA 93455 OTHER VENDORS UNDkR $100.00 109.80 100.00 Entertainmnent 8/31/93 John R. Kubatech Musical 1570 Response Road, 3074 Fundraiser Sacramento, CA 9581531AG9

134.06 LazerJet Toner Wells Fargo MasterCard HPCD 665 Marsh Street San Luis Obispo, CA 93401 3 SEP -93 1 80.1 9 Flowers Greenery's Bouquet 670 Higuera Street San Luis Obispo, CA 93401 3 SEP 93 SUBTOTAL $ 901 .34

G C0 9 't U 1 C S(:IIiI)II.I Ii(tn. niuk. Statement cower* period *Mbemmmv ml.. ScheduloEeme 1 *Wblustion Sheet) .. ,. a ,rem -JUT, 93 Payments and Contributions Si uh3 -1-D EC ---93 (Other Then Loans) Made KE"WUNEE64KE*IASE (r X"ALiiW E Ai&f -~fO1EAJIOCOIll 11IIMI i Friends of Assemblywoman Andrea Seast rand 33 Club

NAME AMNAIM IESS (** PAYEE. CHIION0 (At lit (1111NNI(* (:IN4IIII011iK)

A.IM1141SS) CW*OM IF 001) i uU4IHIASSEI ASSKNII) illifil lilt ASIWIII AL & ~uter Lease August 590.354 Computerland ComF 1422 Monterey Street San Luis Obispo, CA 93401 3 SEP 93 ,ice/Treasurer September 300.00 Mildred Dostalek SerN 2875 Del Camupo San Luis Obispo, CA 93401

4 SEP 93 - 1 00.80 Paso Robles Newspapers, Inc. Adv 3rtising P.O. Box 427 Paso Robles, CA 93447 8SP9

1218.32 Blake Printing and Publishing Priirting P.O. Box 12338 San Luis Obispo, CA 93406 9 SEP j3 tage Stamps 145.00 Postmaster Pos Marsh Street San Luis Obispo, CA 93401 10 SEP 93 2354.66 SUBTOTAL S

61 1 ( 9 ( JUT. 93 t~bSdN'.hm1 '(C;g thuatloh Shoot) 8632 Pay~glments and Contributionls 31 DEC 93 p.. 2* 4 (Other Than Loans) Made SEE Mum I PUBIW4 MWASEF NAMEOF nrrEIfl~lEA~OC*JMI II CAD~f~lE ~fl.(UJII(III 910281 33 Club iFriends of Assemblywoman Andrea seastrand A 1* 4Ilfl NAME ANDtAIMtb (* PAYEE. UIEINIME (14 i (It'l N11 (I A I A Y M f I141I MR I fit I*CAf P R AIEI M ) 111 SIWIS ,I M fill,& NI14 LS w i fl F#.* % l t I~g451 AI J I ILN A & N 695 Lodging/Republican Convent ion t111~-h-' it. P -k- 1855 S. Harbor Sept. 18&19 Anaheim, CA 9 SEP 93 8/31/93 Event Coordinator 2000.00 Bonnie Knight 1100 N Street, 410 Sacramento, CA 95814 13 SEP 93 231 .53 & Aug Mobilecolflunications June, July Comtech P.O. Box 5033 Hayward, CA 94540

13 SEP 93 144.24 Telephone GTE CA Payment Processing Inglewood, CA 90313 13 SEP 93 300.00 Bulk Mailing Permit 529 Postmaster 1655 Dalidio Drive San Luis Obispo, CA 93401 20 SEP 93 SUBTOTAL $2845 .27

0 j (d 0;I 9 t W1111AM1.1; E (Coill.)

P . E Typeof Prhi In hh. slaenen COY.,. potied ArneeMNI may be rounded gtutonl Sheet) to We.o. dolaws. Pamnts and Contributions 31 DEC 9 3 (Other Than Loans) Made IPageIOI~#AOER ~ .3 45 SEE P451"0-K alsim M1EMtE Niw Ofk4C(-1wtI fifl ~f (6 CANWE MN)CCWJIINi( WII ()I'(*AMII If 910281 Friends of Assemblywoman Andrea Seastrand 33 Club -T- I NAUEk Atli) AINIIt:S!.i(* 'AYf E. (Ilt.1)I()9t ()It i 161-1 NI (1 CI()NIIIIIIMON l*A*14 00. (O WN111PI t I AAIWNlIKUJ 10 C(*AI It S NAM& AiAl 1)4VitSS. t141 o1 10 VAYMINI AM01 44 1 PAID 4 ( N* f*fv('lIIPll0N0I IPaI)itb fILI*HI4AS W t 14 ASS 4a I i. tN It 11114 ASl'(OfIftII ALA A AIN *SS)

TableclotheS and tableskirts 182.36 0 Taylor Rents 9/25/93 fundraiser 1738 South Broadway Santa Maria, CA 93454 21 SEP 93 1 Postage Stamps Postmaster 1655 Dalidio Drive 580.*00 San Luis obispo, CA 93401 22 SEP 93 38.70 Supplies for catering 9/25/93 1 Smart and Final tundra iser 277 Higuera Street San Luis Obispo, CA 93401 0s 23 SEP 93 Luncheon Fundraiser 9/25/93 1276.28 old Country Deli 600 Marsh Street San Luis Obispo, CA 93401 25 SEP 93 348.40 Coordination Services for 9/25/93 Ann Botts 3165 Tepusquet Road Fundra iser Santa Maria, CA 93454 30 SEP 93.j SUBTOTAL *2525.74

Ig j o C) 9 £ k ' ( Trype of Ponts Ine b. Seeonnl covers period AnuMeeo sall be romnde 19S-*.diE 10 whole d"Mae. 9 3 - -- ontlmnuation Sheet) from 1 -JUrT,. Payments and Contributions Seuh31 DEC 9 3 (other Than Loans) Made SEE USIMM~K3t* I4WHIE NAE *c*ENt fWi tCANIDI AIC* 1 70~ COL)A**IIU Friends of Assemblywomfan Andrea Seastrand 33 Club

(* (t *IItIIII IWN NAME AND) AtDtIISS OF PAME. CREIN101 "t t I(AIIA M) 14*01IHO. 1WCWA~f~f. g M~ IOjjCOM*wIIEES NAAO AW) AI**SS. INtI

w1W A 64A5ati- I t1 w:AA1 Services/Treasurer 300.00 Dostalek Mildred October 1993 2375 Del Campo San Luis Obispo, CA 93401 30 SEP 93 460.00 Member's Travel in District Dell Hinn Pilot Service 28 San Pedro Salinas, CA 93901 304.60 1 OCT 9 3 VENDORS: Pilot Service Air Trails, Inc. 280 Mortensen Avenue Salinas, CA 93905 156.00 * ER VENDORS UNDQQ Computer Lease September Computer land 590. 54 1422 Monterey Street San Luis Obispo, CA 93401 4 OCT 9 3 Tent Rental for 9/25/93 Fundraiser 1114.02 Got You Cover'd tables, chairs, trash cans 3681E Sacramento Drive San Luis Obispo, CA 93401 6 OCT 9 3 SUBTOTAL S 2464.56 T- -M,

CI IIlMtIiE Eih~". Two* o ft~hoIGs* Oak. as~sloment co,. period 5~9sdele E ueueueve'undd owledi.. m 1 .JIII 9-3. '(Cmnlnuatlon Sheet) payments and Contributions *asgh .3.I [-:-)1- 93 (Other Than Loans) Madegi 4111 IVi nMI I 11 1NAiE (I 1(.. 11II04 1 (AC' f A I N( 1 III If Frienids of Assemblywoman Andrea Seastrand 33 Club

M PAM~. UKl INW114 (At fit ItlP0 144 N I I tt4tttttItkN HAWE A141)AIAJHS5 AM(A)IJIj PAID) L4IHIII0 INiAIM(NI gvc*0E *wl If. f 1iCON 10 C140IWES NAME AIIHAIW4*SS I(EI1 IA5ti59itS NAM* 4 AIdIISS) 4,00E IEII ,.,,LIIHIAS[*ENIASSN CAIfftfIM 249.00 Theft Insurance Poli ::y Farmers Insurance P.O. Box 9071 Van Nuys, CA 91409 30 SEP 93 1 45.00 Postage Stamps Postmaster 1655 Dalidio Drive San Luis Obispo, CA93401 12 OCT 93__ 2258.36 Member's Travel in District Sept. Dell Hinn 28 San Pedro Salinas, CA 93901

VENDORS: 12 OCT_93 Fuel Air Trails, Inc. Aviation 280 Mortensen Avenue Salinas, CA 93905 195.52 Service John O'Dell Pilot 28 San Qedro Salinas, CA 93901 190.00

SUBTOTAL $ 2652.36

1 0 0 9 S: V W(1 lliI; D1 H. It (Contl.) Two. of Pvki In 1, Wlement coves. Poedd S1011dule E Ameu * M.v qContinuatibn Sheet) to wos&d.Sauu owm 1 'Ul1. -93- Payments and Contributions 31 DEC 9 3 ~* 36 4at5 (Other Than Loans) Made

(*AMIJII 4iA4E (1fi-fcjrrrlv'3(lA OCANIIW)AIE NN)0(J(11111111)4 r 910281 Friends of Assemblywoman Andrea Seastrand 33 Club I1I10N NJAM Atli IAl3)HtbS54* PAYEE. CHDfl1(J101 II II NI 4* (;(441111111 1141111111 14le*AII-f114 SA.1'(:I( Of- I1AYMI HI AMOIN AIAI Ifuwamili IN NIIK IMAttU UsSHAW ANII AN4INS. :431~I *31 It%gIS4A & AIN *# SS) *IN) I II IISS"it ItI $S5W t1JAS$*W*I.tt4 ItIII# I411 & Aircraft Maintenance and (continued) Engine VENDORS RRepair Cal-Pacific Airmotive 1330 Mercer Way Salinas, CA 93905 2797.44 254.83 Printing Poor Richard's Press P.O. Box 12338 San Luis Obispo# CA 93406 13 OCT 93 343.96 Officeholder rel a ted eape BankAmer icard Travel and meals inan related P.O. Box 53148 to district, Phoenix, AZ 85072 0 13 OCT 93 VENDORS: dinner meetings Charlie's Grill 998 Monterey Street San Luis Obis P CA 93401 OTHER VENDORS UNDER 172.12 290.00 $100 Postage Stamps Postmaster 1655 Dalidia Drive San Luis Obispo, CA 93401 16 OCT 9.3 1388.79 SUBTOTAL $

0 9 I SWlIri)II.IM Arn

*Cm0tbhation Shoot) ~~3 DEC93m pagev -3-7B.14 Payments and Contributions (Other Than Loans) Made

D44C(*lWl. ~ t.Jl f pfi 114114t n"(W1M1~OI 908 54i~-ii 33 C lub Friends of Assemblywomani Andrea Seastrand

AMI A #41 VAll)

t11 ItI ANI4 115fift & Nli04 * S) I~ * I X) 11)1b Aue* it 10A5 I 11I ASSM3NI1). 953.16 officeholder related expenses BankAmer icard meals and travel related to district P.O. Box 53148 Phoenix, AZ 85072 24 OCT 93 Lodging and Meals Republican VENDORS: Convention Sept. 18 & 19 Hilton Hotels 777 Convention Way Anaheim, CA 299.01 267 .54 MobilecommfUnicat ions Sept. Comtech P.O. Box 5033 Hayward, CA 94540 25 OCT 93 0 479.94 Mobi leCOmmunlficat ions Oct. Comtech P.O. Box 5033 Hayward, CA 94540 25 OCT 93 3992.00 Register to Vote Announcements Suggs, Lombardi Advertising on Radio 520 Hiquera Street CA 93401 San Luis Obispo, 25 OCT 93 VENDORS: 100.00 5692.64 SUBTOTAL $

or9 U SCI FiD0J.iF (cfrnt.) Typo "qpri go Wak. Statement aswore period eia1E Ameems umay be vWOMW led to whs d~me. 1.tainuaton Sheet) ftem 11 J U T,- -9 3 - - Ire Paynhents and Contributions 31 DEC 93 9 U38_01 e 1 45_ (Other Than Loans) Made skE esVVEIK *6 (I KvRf 10 fXAA*R if CI"UC 1 ACA1fAEM).*l~) 66uUI 910281 33 Club Friends of Assemblywoman Andrea Seastrand

N~ti6KIiiONC 41 PAID HAW&Atil) A Xffl SS M PAYEE:- CN* IIOvt (II fit NI 1141111fit fooAlf'14 it Fli'.1*111014 0I IDAYW NI COMM.04CdF 1N9 1"06flMI11"UNA# MN) AMUW1*% I AW 4At40 '$IIM%1 41 I o ,LL it IISIf"AS )Itillit Its kAtitItS 0 VENDORS: (continued) 9/1 /93-9/30/93 KPRL Radio

Paso Robles, CA 93447 504.00 9/1 /93-9/30/93 KUHL/KKFM Radio P.O. Box 1964 Santa Maria, CA 93456 792.00

Radio 9/1 /93-9/30/93 KTMS 1W P.O. Box 4458 Santa Barbarat CA 93140 0 1980.00 9/1 /93-9/30/93 KGLO Radio P.O. Box 170 Arroyo Grande, CA 93421

616.00 11 78. 73 Food, Beverage, Rental for Food for Thought 8/31/93 fundraiser 2405 K Street CA 95816 Sacramento, 26 OCT 93 178.73 SUBTOTAL 1

9 ~ C)9 v IFW

Typo~~~S1I~)J.Stt of Pon me t ourlero (cIn

Amesune iNWv be W tOfUlUCNe.pe~d Soe ule IE 93 1ConintION Shoot) ,~h I.wsOd~oeJUT, Payments and Contributions31DC9 Pao,9_o__4. 45 (Other Than Loans) Made*jD''9~r, ii1 tjk4AUEF (WfEEI f iiicAmfiuAI Amfcmtiwii" inci*-wii

MSstn 33)O Mb9128 Fred ~.&,IAIofI AssIGelwomnIIIl AndreSaA

1025 Ninth Street, 201 Sacramento, CA 59814 29 OCT 93

Computer Lease October 594.54 Computerland 1422 Monterey Street San Luis Obispo, CA 93401 29 OCT_93- 168.66 Pacific Bell Telephone Payment Center Sacramento, CA 1NV9

Services/Treasurer November 300.00 Mildred Dostalek 2375 Del Campo San Luis Obispo, CA 93401 1 NOV 93

Repair 161 .84 Computerland Computer 1422 Monterey Street San Luis Obispo, CA 93401 3 NOV 91

SUBTOTAL $1725.25 1 0 0C 9 t Typo of ft bI 1 h. Imedule EAbedAmweu may be m .~. 10Centnuation Sheet) I hl Orem 1 JU. 9 3 Payments and Contributions (Other Than Loans) Made l~eah31 DEC 9 3 ___40 1 SEE 111ITI(MON HEA -R In"*"A ADC01uJIIIOE I 10 COMII It t mnAiL c(ruxiorin onRcmiAIIAE 9102 Friends of Assemblywoman Andrea Seastrand 33 Club .81

NAME AM) AINIESS OIF PAYEE. CAEI)II0fl Oil ll-C1111-N I (* CONIIIIIJI)ON I# uwwalief. *a maU1KJ InOc(SAII1FES NAL. AND) AIWlS NIk14I1II W OR,~~i0 (NI(SJIPKN1 PAYMNI AWA 1141PAff) FIS IJI) H0W&HILASU*N ASS~iC~tNIF"NIEBlASI fltISHMI &AMMUSS) I GoI* 0 q1zz . 00 Dell Hmnn off iceholder related expenses 28 San Pedro Pilot Services Salinas, CA93901 8 NOV 9 3

VENDORS: Aviation Fuel Air Trails, Inc. 280 Mortensen Avenue Salinas, CA 93901 410.18 580.00 Postmaster Postage Stamps 1655 Dalidio Drive San Luis Obispo, CA 93401 16 NOV 93 375.38 Computer land Envelope feed 1422 Monterey Street San Luis Obispoo, CA 93401 16 NOV 93 Directories 376.00, Communications 250 Legislative Dutra Deposit P.O. Box 1772 Sacramento, CA 95812

19 NOV 921 _ -_ _ SUBTOTAL $1754.06 SCIlIliIJIE Ii (coII) Sleent cevere peuiod fSeIsdule E AUtomUS10U bue IOhuh. *oCnItauatlon Shoet) VAIG delife~.d Irm1 -JtULT -9 3. and Contributions Payments DEC 9 3 Page- 41-o_4 (Other Than Loans) Made Sleh3-1 SEEMSIN 11 *HEVESWE I NAI. 1-W06011" 1*11 0)NCARNfl)AIE MKAIJC(WIOtN II I)CM4*MIII 91 0 ~811 Friends of Assemblywoman Andrea Seastrand 33 Club I I NAME AtI) ADIILSS OF PAYEE. CIIEIRII OIf Ift CII. NI 4111111 E~IUihK)N) I*SE ItSPIh#IOF-I1AYM1NI AMO UI ~A()JIM 16 5K)I i) IISW ISEN ASII"iGNI"TIES IIFA SII SNAMI & MN*SS)141#1* 41" ('.()I* - t 156.00 Wis. Bros. Supplies P.O. Box 30850 Los Angeles, CA 90050 14605 11 NOV 93 Telephone Pacific Bell Payment Center Sacramento, CA 95887 30 NOV 93 December 300.00 Mildred Dostalek Services/Treasurer 2375 Del Campo San Luis Obispo, CA 93401 30 NOV 93 related expenses 439.57 BankAmer icard Officeholder meals and travel related to district P.O. Box 53148 Phoenix, AZ 85072

ALL VENDORS UNDER $100 30 NOV 93 1 20. 12 Smart and Final Supplies 277 Higuera Street San Luis Obispo, CA 93401 120.12 .20 SUBTOTAL 6 11 56

.- A 66~ 0 9 ?~t Tp e o Prb.S in. Sttemen cevele period1 A S~~heduule Ed £amia y bor -umdk Item 1- JU, IC..tht'atfl Sheet) a Payments and Contributions 3.1D.E ao_.42_o iD 3Pge4 * 4 (Other Than Loans) Made

3Cub908 ~FrUiendKWsI*ERofAsmbyoaAde___ta Ii0II0.E t J INAM1W k 04fA114liEN 1OACA ITFIE- M~fC(411A II f)C1II5S.MIFI

1422 Monterey Street San Luis Obispo, CA 93401 4 DEC 93 168.68 Blake Printing and Publishing Printing P.O. Box 12338 San Luis Obispo, CA 93447

93 -- _ -- ~4DEC to Vote Announcement 1008.00 Suggs, Lombardi Advertising Register 520 Higuera Street on radio

0 San Luis Obispo, CA 93401 4DC9

VENDORS: 10/25/93-10/29/93 KPRL Radio P.O. Box 7 Paso Robles, CA 934 120.00

KUHL Radio 10/25/93-10/29/93 P.O. Box 1964 Santa Maria, CA 93456 180.00 GUNTOTAL $

/ % I- 6 0 9 1. 7 SCIIEDULE ti (Colit.) slalooot ovois period Abbdul 1EA..ouMw w be rounidod q00onuatiofl Sheet) ~oodsas Paymee'ts and Contributions 31 DEC 93 Pago 43 ol 45 _ (Other Than Loans) Made 10 t5AE~ER 910281_0#_-4-5-..- Friends of Assemblywomanl Andrea Seastrand 33 Club I p&qo__43

NAWf AND AIN 1IRtS3(* I'AyI . (tILDII (WIII li (31 NI I ('01,111111111100 ifWWO0II Ift. V4IjI N1KIJCOOjjI1U SHA&&FAM idNWW*SS. [It I Dl I41M*iRO 111El r sCII(N OF IPAYMNI AMOI(Nd PAID) If1* AS1I*11S NAMI& AAINI4SS) ,A* 19111) M*.*ItIASj(IEN ASSMII). ENIEI 4ENDORS: (continued) 10/25/93-11/1/93 KGLO Radio

168.00 10/25/93-11/01/93 KTMS Radio P.O. Box 4458 Santa Barbara, CA 93140 540.00 Services/treasurer Sept. 1-14, 1993 Pete Agalos 1 50.00 P.O. Box 4601 San luis Obispo, CA 93403 8 DEC 9 3

Santa Maria Thunder and Lighting Soccer Advertising 100.00 organization c/o Laura Roth 995 Via Esmaralda 93 -Santa- Maria,_-CA- 934' 55 12 DEC Campaign Clerical Service 200.00 Donna Schmualz 1880 8th Street Los Osos, CA 93402 12 DEC 93 450.00 SUBTOTAL S

o 9 :: t 0 E

staement SI Gwves period Ameume 'woV be weunded 44 .9 45KWOM nikkawaof Sheet) to whole dollas. 1,~:JU 1. 9 3 P ents and Contributions (Other Than Loans) Made --31 9 3 page 441- et 45 SIt *610%0IlisW4*4IFWeI II) (hASh All 141011I lIf 4i&Ill II *4AWI(NAI11 OWUil1i*11 (NIC AWaN)AII- 9102 .81 Fri nris of Assemblywoman Andrea Seastrand 33 Club I

NAUE AI4I)AIX)IES( * PAYEE. CIIE f(N(H(1II II* (1)NhhhthIiiK) AWA #dI PAID IA *SS. III ItItI I tit(I VIO OFU(vAIIIIEE IN AUNDI *1OC(*"%1jfSfA& ANI I A (101 * W 35jI) jj**FI#AS 1(11(4ASSItiNEI) IIAIIIE9(5 S NDSDSIAI&ANIDSMSS( 415'.61 Dell Hinn Member's travel in Distric- PAYMNIDecember Pilot Services 28 San Pedro Salinas, CA 93901 309.40 13 DEC 93 VENDORS: Aviation Fuel Air Trails, Inc. 280 Mortensen Avenu e Salinas, CA 93905 106.21 290.00 Postmaster Postage Stamps 1655 Dalidio Drive San Luis Obispo, CA 93401 20 DEIC 93

Mobilecommfunicatiofls November Comtech 322.70 P.O. BOX 5033 Hayward, CA 94540 20 DEC 93

SUOTOTAL $ 1028.31

I 0 1C9 ? ' V . .

r~5iuFi)iii t. i Wpp..r M4iS Ink. 82010~1en **e Perod Schedule I use may be seund g mmus Increases to Cash . mVmeS. detintif. jr. 07 JUL 93

31 DEC 9 3 5. ---. f_5_ - r M5ST IONSON REVERSE jPaso I: '# F OFFICHODR ORCANJIOAEANOCONIR(IEl)COMwiILL 9102811 Friends of Assemblywoman Andrea Seastrand 33 Club 1 I T OAIE RAI NAKAEAND AI X SS (I S01 k'( DESAIPIK* OF RIECLIF'! AM(A NIT (A (*CoMWIfit. I~N IIO)IOCOM11111BO S14A~ MAtN)AENWS I HiMII10 044111 MAFEASE TOCAS14 (of a NoSIE) HAJMIUNfS ItASSKICA). INIHit 11AS111411HS MW IhMSS) 1181.08 3@&EC 9 3 Friends of Andrea Seastrand Computer sub lease for Congress Sept, Oct. Nov., & Dec. 1993 P.O. Box 14002 San Luis Obispo, CA 93403 of Deposit 140.51 21 DEC Pacific Bell refund Payment Center Sacramento, CA 95887

______- I______SUBTOTALS 1321 .59 Aah &"#~awJ W~k ~oi~ep&be mee~~e h Mbc~n.Oes hsrrne to Cash Swanmauy 1321 .59 g. Imceus och of$ ID a mwlhil 'Ivikl...... 2. amvam so co unkr $ 0odis pcrwtx. 91.79 (I~mn wmim) ...... 3. TOWi nf dll uWes! iweAved this pcnudi ion alt:umi III allhcz. 0 (Sdcdsulc 11. Par 11jb).) ...... 4. I.Mal MniwcllMcNmS Wnciac k) Cashmls 5)CIIINS, 3 (Atkl im 1nu. 2 soul J. V'nkc hcsc itni to 1Sh IilloEimI y Shuge, hinc 15 ...... I...... Q-).... OTMj. _141 Almndmnit to Tip.o r In Waik CampignDisclosure Statement MEIMI) AND FILED A For 011CWUS*UlV

This fonmmunt be used to amenad statements Irded pursuant to Government Code Sectionrs 84200-14216.5. and must be filed witha&N1(shag officcrs who reeved doe statement being umnded. NOTE: Do an us this twin to amend a APR 2 1 199 Statment of Orgauuizato. Form 4 10, Candidate Intention. Form 501, or a Campaiign Bank Account. Form 502. Use the actual Form 410,501 or 502. respctisvely. so mnake aincridhnents. The ifoirnation required i P'art I must correspond to the Information provided on the campaign statement. ILEA*I Scry ot SW I Nainiof Flier (See inrpoaa Wromion on reverse) 11 £smnndmmSt UsIiratUon I A PSUE 1.0 "WISDOM A. The lollowng Wnation amnends campaign duacloiwre stalement. Form No 490____ Friends of Assemblywoman 2 3 1 . 0291 eusctedon28 &J.anl94 Iorlheperixl 7-1-93 thoughL -_ -93 Andrea Seastrand 33 Club 191 P DRY. pIt *O. wo.QV"I two (hC).ly WI MONMIS1s OF MW 4110 MI l11t 0 The amnded Wnormetlon affects Items on the

P.O. Rox 14004 ______Cowe Pop E Alloca5In Pae Li- summary Ppe o1 2 7 Div hIAiF [ja Uhe detoeL). U] Paige) Pg. & 4 3__ Ran Luis obispo, CA 93406 C. Describe the changes below Inc"d in detaii allt mlotmatin you wish to becoine a pad ol yawmoll canpoip statemntr Plas, attacheascver page, summary page and/or AN A OOOUMYIW RO MI eppreprile seheitie(s) to isle Form 4056Vneceesary far ctarllcation. Intclude addional (805) 549-33R1 1dosmatll an apprelattytbjed continuation sheets. etrn us wmaeuinm MOG 01~uMsoiairias (Nmr~w d1 shebtls attached_____ Mildred Dostalek______Pg. 27, payment made to Pete Agalos description 19 Iv~an.WI MIMUWWAIMIAFA~I PAO)9AW~ 1111111 amended to read: Services/Treasurer August 1-20, 2375 Del Campo_____ Consulting August 21-31, 199 and $200 and $100 respectively. San LuObispo, A 9340 Pg. 43, payment made to Pete Agalos descr-iption MA COMuvAMn nuIur ineum amended to read: Consulting Sept. 1-14, 199-, 0 U VeiluaIIn (See iaysNa iVormuio on reverse) I1hae used all reaonabl diligen preparing this stitnent. I have reviewed the atatement and to the best of my knowledge the infonnation, contained hercin and ill tile attached seheales is true and complete. I certify undler penalty of perjury under the laws of the State of Califonia thot the foregloing is true a~coriect. __

Et.ealedon _April 13, 1994 A _ San Luis Obispo, CA - By_ _ DAN Oil MISIAIC IMMUME OFa M145UAIR OR11111 O 1ctikr cWandde st measure proponent, or "powedcommuittees unp onwitbe offilcer vurifiestite I1v aduse all reasonable dui~c ad to the best of msy knowledge ilw Werer asuse a reaeebldiigucehirearig hissttemnt I at retee d saeentand to t~hfmy knowledge inunnation contained herein is true andl ipt I certify nder penalty of perjury under the laws of the Stat of California that the foregolin s ~ j w L f Exasaded on Aor i 13 19 94 mj San Luis ObiS2o. CA Inv 6%lKa~i UlM~ Aia 01etn.M OF csncncWIOI 0AMIF. MKiICird. 01WCNM ~IrL (X ic4iM

Executed an______~.~~~- A_ __ -- W SM A1W- or jX fLl -1.CMGAI lPWlGN

Execuedon- -mMIC -A~ By (NIICIKE-tl (All -6flK

tK I CG C) 9 ?, 'u ST~6o Catlereit. Fair Potlicat Practices Commtssion. S.,Sethcoves.e 1141,0d I VP of Pt tell hil Ink. lype*i ofa*,,ovionp i,,g .A-1111 Ametwis "11' 090 10 Sahedule E dSe. 'fCoftiInuaibon S12061)Sewo psymvessts ansd CoostibhiOils 1 E P,021o (Other Than Loans) Made

0 q~ i gII I il' O U)AIIMN ) A,*j,11114Il 4 1 IIALIq loop40IIoIIO 1 (' it'IS Amth v-l 1'o 11sO 1'r i('(s t)1 Assembi0) yw0.lllim

AIMEA ll Al II Il 4 of'PAVI III too %.0 00 it'i AIl A At 'I ofW0% 1I4fill o5 OIsI luCASt * 11 A~ NiNPl 110t. ItfIf If A!-lW

Sall Luis Obispo, CA 93401 III3 JUl. 91 ' 00 V()ltill I~cCUlr~~E! CA Mid-SLaLe Fair Paso 1oblest CA 93447

290). 00 p'0 s-.Ecle SLauiips Pos wa stecr 165~5 ialidio Drive Sail Luis Obispo, CA 93401 21 JIi.l 93

4) 4) i y '(0I0II 1101- 1*(ci i(' Cuoupul1ev Jatd 1 42 Moile rey Sti cwl, ~aoI' i tbi spo, (:A 9,1401 2AII(; 9.1 0 1-20, 1993 200.0 Services /Treasurer AtooJUSI.August 21-31,1993 100.0 Pe ylsConsulting P.O. Box 4601 Sail Luis Obispo, CA 93403 PAll(; 91~ SUBTOTAL$ 1/1.1

Ur 9 , 7 U -77 P

.%cI 11-DI 11F 1.. 6 111111 10199110111 covet*oste lyusor 11011911In leek. Schdule E Aeoww.ee 91114111111110 6ISWid 1tells 9 CnifUIOUSheet)

pylvients anid CoestrihiliSoes (OIIter Thans Loanus) Made

It Ill(I LI I 86~ I I tIII IKt -ItIifA16 lI t IF?I I fm t'A)V:.it~tt AINl11110

t gp1e1gtI88486I ItIWt P111IAYMIIII AIAIA t1il I8 3tI SIfAN 111011111111 1 11111A WIEW.AJ AI WM AIMS';IW 81PYUEI86 I I8686 too1461 IIII Vilt.5,M It 5 1IALI A AIN It$ Y~j to I I)' , It. I #AS W t I ASSNI*11t~.11

(cotiinued) f"VNDORS: 10/25/93-i 1/1/93 KGLO( Radio

10(8 . 00

10/25/93-1 1/01/93 IVVMS Radio P.O. Box 4458 SaiiLa Barbara, CA 93140 540I.oo Sept. 1 14, 1993 Consulting A~). .00 Pete Aqalos P'.O. Box 4601 San luis Obispo, CA 93403 it DEIC 9 3

100.00il iby Soccer A dve rtLIs .ig Sant~a Mar ia Thunder an-d bight Organi za tiotn c/o Laura Roth 995 Via E.smaralila CA 93455 12 DEC' 113 Sata Maria, 20(J .00 seor vice Campatliit Clerical Donina Schmalz 1880 811i Street Los Osos, CA 93402 12 DE'C 9 3 4') 0 . 0 G; SUBTOTAL $ FEDER~ALRcE'C EIELECTION vE f

FEDERAL ELECTION comnissiE& 31 3 57 ?H'SN 999 E Street, MN. t a~~E~ Washington, D.C. 20463 LOTV FIRST GENERAL COUNSEL'S REPORT

MIR 3855 DATE COMPLAINT FILED: January 21, 1994 DATE OF NOTIFICATION: January 31, 1994 DATE ACTIVATED: June 1, 1994 STAFF MEMBER: Andrea Low

COMPLAINANT: Stephen F. Anderson RESPONDENTS: Andrea Seastrand Friends of Andrea Seastrand for Congress Committee and Pete Agalos, as treasurer Friends of Assemblywoman Andrea Seastrand (33 Club) Committee, and Mildred Dostalek, as treasurer Suggs, Lombardi Advertising

XR 3937 DATE COMPLAINT FILED: February 28, 1994 DATE OF NOTIFICATION: March 7. 1994 DATE ACTIVATED: June 1, 1994 STAFF MEMBER: Andrea Low COMPLAINANT: Mike Stoker for Congress Committee RESPONDENTS: Andrea Seastrand Friends of Andrea Seastrand for Congress Committee and Pete Agalos, as treasurer Friends of Assemblywoman Andrea Seastrand (33 Club) Committee, and Mildred Dostalek, as treasurer Suggs, Lombardi Advertising RELEVANT STATUTES: 2 U.S.C. S 433 2 U.S.C. 5 434 2 U.S.C. 5 441a(a) 2 U.S.C. S 441a(f) 2 U.S.C. 5 441b(a) 11 C.F.R. S 110.3(d)

INTERNAL REPORTS CHECKED: Disclosure Reports MUR index Advisory Opinion index FEDERAL AGENCIES CHECKED: None -2- I. GENERATION OF RATTERS

Stephen Anderson filed the complaint in MUR 3855 (the "Anderson complaint") against Assemblywoman Andrea Seastrand for "use of State Campaign funds to finance advertising potentially benefiting her federal campaign efforts." Anderson is an attorney whose office is at the same address as the Mike Stoker for Congress Committee, Andrea Seastrand's opponent committee in the Republican primary for the 22nd congressional district of California. A month later, the Mike Stoker for Congress Committee filed a complaint in M4UR 3937 (the "Stoker complaint") alleging that California Assemblywoman Andrea Seastrand "has engaged in communications and other activities involving the expenditure of non-federal funds to 'influence a federal election.'"'

Combined responses from Respondents Andrea Seastrand, Friends of Assemblywoman Andrea Seastrand and Mildred Dostalek, as treasurer, and Friends of Andrea Seastrand for Congress, and Pete Agalos, as treasurer, submitted by counsel have been received in response to both complaints. These Respondents deny all allegations in the complaints in their entirety, and allege that the Stoker complaint was politically motivated. The response in HUE 3937 describes complicated negotiations between the two candidates and the filing of complaints with the Commission as

1. Mike Stoker is currently a Santa Barbara County Supervisor. He, like Respondent Andrea Seastrand, was a Republican candidate for the 22nd congressional district of California. He lost the primary election to Seastrand on June 7. 1994. Seastrand primary won the with 59% of the vote. Stoker received 36% of the vote. A third candidate, Wayne Reddoch, received 5% of the vote. -3- leverage in the negotiations.2 The Commission has also received responses to both complaints from Respondent Suggs, Lombardi Advertising ("Suggs, Lombardi") dated February 14, 1994 and March 24, 1994. 3 These responses deny "knowledge about any of the issues raised in the complaint letter~s) except the ones dealing with the radio ads and the expenditures in the Federal report for artwork and design.* II. FACTUAL AND LEGAL ANALYSIS A. Statement of the Law The Federal Election Campaign Act of 1971, as amended (the "Act")# prohibits persons from making contributions to any candidate and his authorized political committees with respect to any election for Federal office which, in the aggregate, exceed $1,000. 2 U.S.C. 5 441a(a)(1)(A). No political committee shall knowingly accept any contribution in violation of Section 441a(a). 2 u.S.C. 5 441a(f). The Act also prohibits contributions from national banks, corporations, and labor unions. 2 U.S.C. 5 441b(a). Under Commission regulations, transfers of funds or assets from a candidate's campaign committee or account for a non-federal election to his or her principal campaign committee or other authorized committee for a federal election are prohibited as of

2. A separate complaint against Mike Stoker, Mike Stoker for Congress Committee, and Ed Murray, as treasurer, was submitted by counsel on behalf of the Seastrand committees for consideration by the Commission. That MUR was closed on August 1, 1994, alleged a violation of 11 C.F.R. 5 111.21(a).

3. Suggs, Lombardi indicates thaft it*- is anct incorpora~ed. -4- July 1, 1993. 11 C.F.R. 5 110.3(d). Although the Commission was reluctant to reverse its long-standing policy of allowing non-federal campaign committees to transfer funds to an authorized federal committee of the same candidate, so long as the funds transferred did not contain impermissible contributions, it was also concerned about the indirect use of impermissible funds in federal elections. In the context of such transfers, there was evidence that non-federal committees could use soft money to finance the solicitation of hard money contributions that would be permissible under the Act. These permissible contributions could then be transferred to a federal committee for use in the federal campaign. Consequently, the Commission decided to promulgate new rules that would more effectively prevent the indirect use of impermissible funds in federal elections. This decision resulted in the absolute prohibition of Section 110.3(d). Exp~lanation and Justification and Revised Implementation Plan for Second Submission of Regulations orn Transfers of Funds From State to Federal Campaigns, 58 Fed. Reg. 3474, 3474-75, (January 8, 1993). 4 The Commission has frequently considered whether particular

4. The rationale prohibiting such transfers would also prohibit a non-federal account of a committee from making expenditures benefiting federal candidates, with no direct transfer of funds. See MUR 1079. In that MUR, this office recommended that the Commission find reason to believe that a violation occurred based on the theory that "although the state funds were not directly deposited into the federal account, a 'constructive' transfer was made in that the state account funds were used in a manner which benefited federal candidates." MUR 1079, First General Counsel's Report dated December 14, 1979 at 2. The Commission approved that recommendation under this theory. Under this same theory, when a non-federal committee makes an expenditure on behalf of a federal candidate, a constructive transfer of assets prohibited under 11 C.F.R. 5 110.3(d) occurs. -5- activities involving the participation of a Federal candidate, or communications referring to a Federal candidate, result in a contribution to or expenditure on behalf of such a candidate under the Act. The Commission has determined that financing such activities will result in a contribution to or expenditure on behalf of a candidate if the activities involve Mi the solicitation, making or acceptance of contributions to the candidate's campaign, or (ii) communications expressly advocating the nomination, election or defeat of any candidate. See, e.g., Advisory opinions 1994-15, 1992-37, 1992-5, 1989-32. The

Commission has also indicated that the absence of solicitations or express advocacy will not preclude a determination that an activity is campaign-related. See, e.g., Advisory Opinions 1992-37, 1992-6, 1990-5, 1989-32. When direct solicitations or express advocacy are not present, the Commission will consider various factors such as geographical reach and timing of the activities, and the scope of officeholder duties, to determine whether activities are undertaken to influence a federal campaign. id.

The Act defines a "political committee," inter alia, as any camndidate committee which makes expenditures aggregating in excess of $1,000 during a calendar year. 2 U.s.c. 5 431(4)(A). Under 2 U.S.c. 5 433 of the Act, every campaign committee engaged in federal activity is required to file a federal statement of organization. Furthermore, federal committees are required to report receipts and disbursements in accordance with 2 U.S.c. 5 434. -6- B. Legal Analysis

The Stoker complaint "alleges that the candidate, using funds of a non-federal campaign committee which she controls under California law, has engaged in communications and other activities involving the expenditure of non-federal funds to 'influence a federal election.'" See Attachment 1. The Stoker complaint alleges that expenditures were made by federal candidate

Seastrand, using the candidate's non-federal funds and that these expenditures constitute prohibited transfers under 11 C.F.R. S 110.3(d). It further alleges that these non-federal funds also include excessive contributions under 2 U.S.C. S 441a(a) and prohibited contributions under 2 U.S.C. 5 441b(a). The Stoker complaint lists four types of federal campaign activity, allegedly financed from the Assemblywoman's non-federal committee. First, the Stoker complaint states that Ms. Seastrand broadcast an ad over radio stations whose primary coverage areas are within the congressional district in which she is running for

Congress. 5Second, the Stoker complaint alleges that the non-federal committee -paid Pete hgal-os for treasurer services of Ms. Seastrand's federal campaign committee. Third, it alleges payment for extensive computer services and for postage stamps used to benefit Ms. Seastrand's federal campaign. Fourth, the Stoker complaint alleges that non-federal funds paid for extensive

5. The Anderson complaint also challenges these radio ads although the complaint is less specific as to particular violations of the Act and it does not reference the other activities challenged by the Stoker complaint. Because the Stoker complaint encompasses the Anderson complaint's allegations, this report refers primarily to the Stoker complaint. -7- campaign travel to Ms. Seastrand's assembly district for appearances at which her federal campaign was discussed. Each of the challenged expenditures is discussed below: 1. Radio Advertisements

The complaints advance various reasons why Respondents' broadcast activity was for the purpose of influencing Ms. Seastrand's federal election. Complainants allege that Ms. Seastrand began running radio advertisements urging

constituents to register to vote and later to get out and vote in the upcoming November 1993 elections on or about the time that she announced her intentions to seek nomination to the office of United States Representative for the 22nd congressional district of California. They contend that Assemblywoman Seastrand had no particular reason to engage in broadcast communications other than to increase her name identification for her federal campaign. Complainants point to the fact that the ads allegedly were heavily run on radio stations within the intended congressional district to support their contention. 6 Complainants argue that the campaign ressages focused on identification of Ms. Seastr-aad as an elected officeholder, a factor she is stressing in her federal campaign. The radio announcements contained a tagline of "Paid for by Friends of Assemblywoman Andrea Seastrand" which

6. The complaints suggest that the Respondent non-federal committee's expenditures included a substantial expenditure on a Santa Barbara radio station which broadcasts primarily to an audience outside Ms. Seastrand's state assembly district, but within the 22nd congressional district, in addition to radio stations that broadcast within both the state assembly district and the congressional district. -8- Complainants contend is substantially similar to the name of Ms. Seastrandis federal campaign committee. It is also alleged that Ms. Seastrand, an announced federal candidate, controlled and coordinated the activities of her non-federal committee. 7

The responses to the complaints acknowledge that the

broadcasts ocurd8Respondents argue, however, that the radio ads did not include express advocacy or solicitation with respect to any federal candidate or federal election and that Ms. Seastrand was engaged in state officeholder functions by communicating with her constituents about state ballot issues through the radio advertisements. Accordingly, Respondents argue that Ms. Seastrand's activities in the ads are not subject to the Act. Respondents claim that the non-federal committee funds were thus used only for voter education in the 33rd California assembly

7. Co- plainants make a number of additional allegations only on information and bP~e.They claim, e.a iele 4 that the proiper' maiiAL.ion of Ms. Seastrand's status as an officeholder and a *conservative Republican" were made concurrently with widespread publicity about her federal candidacy. These broadcast communications are also alleged to have reinforced other communications to the public that expressly advocated Ms. Seastrand's federal candidacy. However, no evidence of other communications or widespread publicity has been provided by Complainants and Respondents claim that there were no other communications on television or radio paid for by the federal committee during this time period.

8. Respondents admit that one radio station broadcasts from outside Ms. Seastrand's assembly district but highlight that its coverage area includes the northern part of Senta Barbara County, which Ms. Seastrand currently represents in the California Assembly. The responses claim that the four radio stations which carried the radio advertisements either have a broadcast range entirely within Assemblywoman Seastrand's 33rd Assembly District, or broadcast partially within her district. There appears to be no dispute that three of the radio stations transmit entirely within her state assembly district. -9- district and not to promote a federal candidate in the 22nd congressional district. With regard to the text of the ads, Complainants concede that the media advertisements do not employ the words "vote for" or "support," but merely prominently mention Ms. Seastrand. indeed, the plain text of the ads submitted with the responses appears to confirm that there is no mention of federal candidate Seastrand or any federal election, nor anything approaching advocating the election or defeat of any candidate for federal office. Additionally, voters were not solicited for contributions to any federal committees or on behalf of any federal candidates. The ads address only voter registration and turnout for a state ballot initiative, identify Ms. Seastrand only as an assemblywoman and not as a candidate for federal office, and urge voters to join with Ms. Seastrand by fighting higher taxes, fee increases, burdensome regulation, and the constant growth of big government

-- issues in the upcoming state referenda. Therefore, there is no express advocacy nor solicitation of contributions. However as noted, when direct solicitations or express advocacy are not present, the Commission will consider other factors, such as the scope of officeholder duties and the timing of the activities. The Commission has concluded that broadcasts in which federal officeholders participate in the performance of their duties as officeholders are not campaign-related simply because the officeholders may be candidates for election or re-election to federal office, and that payments associated with the expenses of such broadcasts are not contributions to that officeholder's -10- campaign, absent any campaign-related activity in that broadcast. Advisory Opinions 1994-15 (production and broadcast of a monthly, half-hour public affairs cable series with candidate as host not a contribution or expenditure), 1992-5 (production and broadcast of two monthly series of public affairs forums featuring a Member of Congress on cable channels in the Member's district during an election year not a contribution or expenditure), 1992-37 (production and broadcast of a talk show hosted by a candidate not a contribution or expenditure). In all of these instances, the candidates represented that they did not intend to use the broadcasts to promote or raise funds for their candidacies, and that they comitted to refrain from attacks on their opponents. The broadcasts in these cited Advisory opinions were not commercials, as here in MURs 3855 and 3937. Nevertheless, the Advisory opinions buttress the principle that officeholder communications, even if they express a point of view on public policy, are not necessarily campaign-related.9

9. MoreoveT, when candidates for federal office have expressed their politLical views by endorsing another candidate for state or local office, the Commission has concluded that the activity was not campaign-related. In Advisory opinion 1982-56, the Commission determined that a congressman could endorse a candidate for state office without accepting an in-kind contribution provided that the activity did not advocate the election of the federal candidate or the defeat of his or her opponent; r'c~r S^1i'^it f-d~ r the federal candidate's camr_%I~ri. The Commission has used a similar standard in other instances where a candidate made media appearances in activities purportedly unrelated to his or her campaign. See, e.g., Advisory Opinions 1981-37 and 1977-42. Furthermore, in MUR 2161, the Commission found no reason to believe that a federal car~iidate who appeared as a local official in an ad to defeat a state judge was engaged in activities subject to the Act. By analogy, an officeholder who endorses a ballot initiative rather than a state or local official would not be promoting her federal candidacy either. Because Section 110.3(d) -11- The Commission has acknowledged that officeholders should be allowed broad latitude in discussing legislative issues in their communications or constituent services. Officeholders may participate in events in which they discuss legislative issues or public affairs so long as there is no advocacy of their candidacy or solicitation of contributions. See, e~. Advisory Opinion 1980-22 (incorporated trade association may sponsor issue-related meetings in which officeholders participate if there is no candidate advocacy or solicitation of contributions), Advisory opinion 1980-89 (contribution to a Member's advisory committee on the arts is permissible as long as there is no electioneering), Advisory opinion 1988-27 (a corporation may pay a member of Congress an honorarium for speaking when the speech is in performance of duties as an officeholder). Here, it appears that Ms. Seastrand was discussing state legislative issues in her capacity as an assemblywoman, which would be clearly sanctioned under prior Commission advisory opinions even if there was an incidental benefit to her federal candidacy. The Commission has previously recognized the distinction between a candidate-related election and an issue-related ballot initiative. The Commission has stated that contributions or expenditures relating only or exclusively to ballot referenda issues, and not to election to any political office, do not fall

(Footnote 9 continued from previous page) had not been promulgated when the Commission considered MUR 2161, the Commission analyzed the possible violation as a contribution of prohibited source funds only under Section 441b(a) rather than a prohibited transfer under Section 110.3(d). -12- within the purview of the Act. Advisory opinions 1989-32, 1984-62, n.2, and 1980-95. Here, it is clear that there were no federal candidates on the ballot in the November 1993 election. It thus would be difficult to link the expenditures for the November 1993 ballot referenda to the 1994 federal election in which Ms. Seastrand was a candidate. 10 Considering the remoteness of the federal election to the state ballot initiative election, and the apparent distinctness of the federal and non-federal committees, Ms. Seastrand's broadcast ads for the initiatives do not appear to constitute campaign-related activity. Complainants suggest that the ads were prepared around the time Ms. Seastrand announced her federal candidacy, and therefore, promoted her federal candidacy at that time. However, Stephen Lombardi, owner of Respondent Suggs, Lombardi, submitted a signed declaration stating that the first advertisement, encouraging voter registration, was produced on August 30, 1993 and the second ad, encouraging voter participation at the polls, was produced on October 20, 1993. He states that the ad copies for both ads were written prior to the foregoing production dates. Thus, Lombardi

10. As noted, the absence of solicitations for contributions or express advocacy regarding candidates will not preclude a determination that an activity is "campaign-related." In Advisory opinion 1989-32, the Commission concluded that contributions to a non-federal initiative committee would be considered as contributions to the candidate who was sponsor of the initiative. Factors examined were how inextricably linked the non-federal committee supporting an initiative was with the candidate before the same electorate and whether the two committees appear to be functioning as one, including a substantial overlap of key personnel for all major facets of the campaigns. See Advisory opinion 1989-32. But there, the initiative's primary sponsor was the candidate, and both were on the statewide ballot at the same time. -13- claims that at least some of the ads were written and produced prior to Ms. Seastrand's announcement of her candidacy for federal office. 11Moreover, these voter registration ads were produced in the period right before voter registration closed and these get-out-the-vote ads were produced after voter registration closed and only two weeks before the November 1993 Election. Both complaints challenge whether payments to Suggs,

Lombardi for these ads came from the non-federal committee. The Stoker complaint claims that there is no indication that Suggs, Lombardi was paid any creative fee or production costs by the Seastrand non-federal committee although the 1993 year-end report of the Seastrand federal committee reflects payment to the Suggs, Lombard firm for what complainant alleges may be production costs related to this broadcast advertising. Respondent Suggs, Lombardi states in its February 14, 1993 response that it was *hired by the Friends of Assemblywoman Andrea Seastrand to produce radio commercials that encouraged voter registration and voter participation at the polls" and that "(tihere were no references what so ever (sic) regarding Mrs. Seastrand's potential congressional bid in the commercials." In its March 24, 1993 response, the firm explains that "[tihe artwork and design costs of $380 as shown in the Federal report were for a brochure for the Federal committee," a "totally separate transaction from the radio ads." This directly refutes

11. The records on file with the Commission indicate that Ms. Seastrand's statement of candidacy was filed September 23, 1993. She dated the statement of candidacy form September 14, 1993. -14-

Complainant Stoker's assertion that the Seastrand federal committee paid production costs related to the broadcast ads at issue. The other Respondents claim that the federal committee's $380 payment to Suggs, Lombardi was for a brochure for the federal campaign that eventually was not produced, not for the broadcast ads at issue. It appears that there was a legitimate federal expense, unrelated to the ads challenged in the complaint. The announcements on the radio communications contained a tagline of "Paid for by Friends of Assemblywoman Andrea Seastrand" which Complainant states is substantially similar to the name of her federal campaign committee, the Friends of Andrea Seastrand Committee. Complainant concludes from this that Respondents' activity constituted "influencing a federal election." There is no apparent violation when a candidate has both a federal and a non-federal campaign committee with similar names. Finally, the Stoker complaint points out that substantial non-federal committee expenditures occurred after Seastrand's announcement of her federal candidacy. The complaint states that of the $43,255.26 raised by the non-federal committee, virtually all of the funds were reported as received after Seastrand announced her candidacy for federal office. It also states that the non-federal committee expended $44,739.83 after Seastrand announced her candidacy for federal office. The issue here is whether Seastrand was using the non-federal funds toward the federal election, not whether Seastrand merely expended non-federal funds after announcing that she was seeking election -15- to federal office. AS Respondents note, under state law, elected officials in California may legally continue to raise and expend funds out of their state election accounts for officeholder activities after a state election is held. Moreover, there is no evidence that the non-federal committee was subsidizing the federal committee during this period. Cf. HUE 2695. (In that matter, there were indicia of subsidization such as shared staff and services that were allocated to the non-federal committee, and unusually active fundraising and spending during a period that was not near a state election.) indeed, while Ms. Seastrand's non-federal committee was financing communications regarding the upcoming state ballot initiative, the federal committee was engaged in its own fundraising and spending efforts. The federal year-end report shows receipts of $61,277 and disbursements of $22,828. The first quarter reports shows receipts of $39,796 and disbursements of $63,816. The 12-day pre-primary report shows expenditures of $63,021 and disbursements of $68,806. The federal committee appears to have been paying market rates for all services, such as treasurer and computer as discussed below, that it procured from the non-federal committee. Therefore, there is no appearance of subsidization by the non-federal committee of advertisements. 2. Treasurer Services In response to the second through fourth allegations of substantial federal campaign activity financed through non-federal funds, the Respondent committees state that other expenditures by the Friends of Assemblywoman Andrea Seastrand Committee for -16- treasurer consultant services, computer services, postage stamps, and travel expenses were not 3ade, "not even remotely," in connection with any federal election or for the purpose of influencing any federal election. Respondents state that they were made solely for Ms. Seastrand to carry out her duties as a state assemblywoman. As analyzed above, carrying out officeholder duties may incidentally benefit the federal campaign, but the activities do not necessarily result in an expenditure on behalf of or transfer to the federal committee. Complainant Stoker submitted Attachment A, a copy of

selected pages of the Friends of Assemblywoman Andrea Seastrand non-federal committee report for the period July 1, 1993 through December 31, 1993 with markings in the margins to denote what he believes are non-federal funds paying for consultant services to Pete Agalos, treasurer of the federal committee. On the state comittee report's Schedule E, Payments and Contributions Made, there is a payment to Pete Agalos: $150 on December 8, 1993. The

"Description of Payment" is listed as "Services/treasurer Sept.

1-14, 1993" Complainant alleges that this was an expenditure for the federal campaign.1

In response to Complainant Stoker's assertion that the non-federal committee made illegal expenditures to Pete Agalos while he served as treasurer of the federal committee, Respondents state that Agalos was providing consultant services to train the

12. The disclosure reports received from California also show payments of $300 on July 13, 1993 and $300 on August 2, 1993 for treasurer services. These payments are not alleged to violate the Act. -17- new treasurer of the non-federal committee, Mildred Dostalek. According to Respondents, Agalos had been the treasurer of the non-federal committee until he became the treasurer of the federal committee. According to the response, he provided consultant services to the non-federal committee after he left the non-federal committee and before he became the treasurer of the federal committee.

Complainant Stoker has neither alleged nor presented evidence to demonstrate that Agalos did not provide bona fide compensable services to the non-federal committee. Instead, he appears only to allege a violation because the same individual who was the treasurer of the non-federal committee later became the treasurer of the federal committee, but was paid as a "consultant" after terminating his position with the non-federal committee. It is not illegal under the Act for the treasurer of a federal committee to perform consultant services to a non-federal committee, or for the treasurer of a non-federal committee subsequently to become treasurer of a federal committee. A review of the federal disclosure reports indicates that the federal Friends of Andrea Seastrand Committee had several disbursements for "treasurer services" to Pete Agalos, but not until after the end of 1993. The 1993 year-end reports list no payments to Agalos. However, the 1994 first quarter disclosure reports list two disbursements to Agalos for "treasurer service:-" $300 on January 7, 1994 and $300 on February 2, 1994. An amendment to the 1993 year end report filed April 15, 1994 shows a debt of $900 incurred to Pete Agalos during the second half of -18- 1993. The amended Schedule D accompanying the 1994 first quarter reports discloses a "payment this period" of $1,500. The payments disclosed on Schedule B of the 1994 first quarter reports only total $600. There is an apparent omission of $900 on Schedule B. Therefore, it appears that the federal committee was incurring debt for Agalos's services in 1993, but did not disclose this debt until April of 1994, after the complaint was filed.1 3 Although there appears to be an omission of $900 from the federal disclosure reports, this alone does not support complainant's assertion that Pete Agalos was not performing duties as treasurer to the federal committee that were distinct from services for the non-federal committee.

3. Computer and Postage a. Cmue

As to allegation three, Complainant Stoker submitted California public disclosure documents that indicate several expenditures for a monthly computer lease and claims that these expenditures were for federal use. He presents no evidence that the non-federal committee was not using computers for its own purposes. He also presents no evidence that the value of the computer services that the federal committee subleased from the non-federal committee was greater than what Respondent federal committee paid. He does not even explain how much the federal committee would have paid to sublease the computers at fair market

13. The federal committee was sent an Informational Notice on May 27, 1994 asking the committee to clarify the underreporting on the Schedule B. According to the Reports Analysis Division, no response has been received. -19- value. He does not present an alternative allocation method that shows Respondents using more of the total computer services than 4 what they paid for. 1 Respondents state that the federal committee subleased a computer from the non-federal committee, based on what Respondents claim is a reasonable allocation method. Respondents later clarified that under this method the federal committee paid for one-half of a leasing package that included computer equipment, hardware, software, and unlimited usage time. They also state that the federal committee rented the non-federal committee's mailing list twice over a six-month period. The 1993 federal year-end report lists a disbursement of $787.84 to "Capitol Miro Systems" for "software" on October 14, 1993 and $1,181.08 to the non-federal committee for "computer sub lease" on December 31, 1993. Although Complainant alleges that NZ7 the $1,181.08 was below market value for a computer sublease, he

- ~ 14. Complainant appears to make two separate charges. First, the non-federal disclosure reports list expenditures of $590.54 on October 4. 1993 for "Computer Lease September,' $594.54 on October 29, 1993 for 'Computer Lease October," and $590.54 on December 4, 1993 for 'Computer Lease November" which Complainant alleges are for federal use. The reports also show disbursements for computer lease for June, July, and August of $590.54 for each month. These are not alleged to have been dedicated to federal use. Complainant does not explain how the same monthly charges were sometimes dedicated to federal use and sometimes to non-federal use.

Second, Commission public disclosure reports show that the Seastrand federal committee disbursed $1181.08 to the Seastrand non-federal committee for "computer sub lease." The non-federal committee reported as a miscellaneous Increase to Cash an entry for $1181.08 for "Computer sub lease Sept., Oct., Nov., & Dec. 1993." Complainant notes that this apparent reimbursement is an underpayment, under the usual and normal charge. -20- 1 5 states no facts to support that allegation. It is difficult to determine from the federal disclosure reports when the federal committee rented the non-federal committee's mailing list. The 1993 year-end reports do not show any disbursements for mailing list rental, nor do the 1994 first quarter reports. All computer expenses listed are for leasing, supplies or repair. It would have been legal for the federal committee to rent the non-federal committee's mailing lists as it indicated. At any rate, Complainant does not appear to have stated sufficient facts to show that the federal committee ever rented the non-federal committee's computer lists at low or no cost. b. Postage Complainant Stoker submitted California public disclosure documents that indicate several purchases of postage by the Seastrand non-federal account from "Postmaster": $300 for *Bulk Mailing Permit 529" on September 20, 1993, $580 for "Postage Stamps" on September 22, 1993, $145 for "Postage Stamps" on October 12, 1993, $580 for "Postage Stamps" on November 16, 1993,

15. Compare MUR 2695, in which similar treasurer services and legal services by the same provider appeared to cost the non-federal committee over five times as much as they cost the affiliated federal committee. Similarly, in MUR 2695, the joint employment of staff raised questions about whether salary was appropriately apportioned between the federal and non-federal committees when three-quarters was allocated to the non-federal committee. -21- and $290 for "Postage Stamps" on December 20, 1993.16 Complainant Stoker marks these expenditures as for federal use although he does not indicate the basis for that assertion other than stating that "the purchase of postage stamps permits almost undetected use of those stamps for federal campaign mailings." moreover, he provides no evidence that the non-federal campaign did not need or use postage for assembly district purposes or that the federal campaign somehow appropriated the stamps for federal campaign use. Respondents state that the respective committees' records show that each committee paid for its own postage. Respondents' federal disclosure reports, listing amount and purpose of disbursements, show that the federal committee made its own expenditures for postage. 17Thus, the federal committee appears to have been paying for its own postage. 4. Travel

Complainant Stoker alleges that Ms. Seastrand traveled to promote her federal campaign with funds from her non-federal committee. Complainant Stoker fails to allege or demonstrate that any travel was mandated for federal campaign activity specifically. He vaguely asserts that some of Seastrand's travel

16. There is also a disclosed expenditure of $290 for "Postage Stamps" on October 16, 1993, which Complainant has not marked as for federal use. It is unclear whether this is an oversight, or whether Complainant knows or believes that this expenditure out of the non-federal account was not for federal use. 17. The 1993 year-end report shows seven (7) entries for postage from September 20, 1993 to December 10, 1993 totaling $3,350. The 1994 first quarter report shows forty-one (41) entries for postage from January 7, 1994 to March 31, 1994. The 1994 pre-primary report shows twenty-two (22) entries for postage from April 1, 1994 to May 17, 1994. I I--

-22- as an assemblywoman took her to places where her federal campaign was discussed, but does not specify any such events. Complainant does not present an analysis of the cost figures over time to show some substantial or excessive increase during the last quarter 1993. Without facts that reveal any discussion, planning, or promotion of Seastrand's federal campaign during any of her travel between her assembly district and Sacramento, there appears to be no prohibited transfer of funds from the non-federal to the federal campaign. Respondents state that there was no greater or lesser amount of travel between the district and the state capitol after declaring her federal candidacy than Seastrand normally traveled as an assemblywoman. 18As with the postage allegation, here it appears that the non-federal and federal committees have reported separate disbursements for travel expenses during the same period. 19on the face of the reports, it does not appear that the non-federal committee was subsidizing the federal committee for travel expenses. 5. Suary In light of the foregoing, it does not appear that the non-federal committee expended prohibited non-federal funds to promote federal candidate Seastrand for federal office in

18. California disclosure reports show that the assemblywoman on nine occasions spent a total of $7,008.66 on travel during the second half of 1993. 19. The federal disclosure reports show disbursements for gasoline" and "travel" for various individuals and airfare for Seastrand, including a disbursement for a flight to Washington, D.C. -23- contravention of 11 C.F.R. 5 110.3(d) and 2 U.S.C. 55 441a(a) and 441b(a). Nor does it appear that the non-federal committee had any obligation to register and report with the Commission based on the allegations in the complaints. Thus, this office recommends that the Commission find no reason to believe that the Friends of Assemblywoman Andrea Seastrand Committee and Mildred Dostalek, as treasurer, violated 2 U.S.C. 5 4331 434, 441a(a), 441b(a), and 11 C.F.R. 5 110.3(d). This Office also recommends that the Comission find no reason to believe that the Friends of Andrea Seastrand Committee and Pete Agalos, as treasurer, violated 2 U.S.C. S 441a(f), 2 U.S.C. S 441b(a), and 11 C.F.R. 5 110.3(d). Because Respondent Suggs, Lombardi Advertising does not appear to have made excessive contributions to the federal committee, this office recommends that the Commission find no reason to believe that it violated 2 U.S.C. 5 441a(a)(l)(A). Finally, there is no evidence that Andrea Seastrand violated any provision of the Act.

III. RSCORIIEND&TIONS 1. Find no reason to believe that the Friends of Assemblywoman Andrea Seastrand Committee, and Mildred Dostalek, as treasurer, violated 2 U.S.C. 5 433, 2 u.S.C. s 434, 2 U.S.C. 5 441a(a), 2 U.S.C. 5 441b(a), and 11 C.F.R. 5 110.3(d) in MUR 3855 and MUR 3937. 2. Find no reason to believe that the Friends of Andrea Seastrand for Congress Committee and Pete Agalos, as treasurer, violated 2 U.S.C. S 441a(f), 2 U.S.C. 5 441b(a), and 11 C.F.R. 5 110.3(d) in MUR 3855 and HUR 3937. 3. Find no reason to believe that Andrea Seastrand violated any provision of the Act in MUR 3855 and HUR 3937. 4. Find no reason to believe that Suggs, Lombardi Advertising violated 2 U.S.C. 5 441a(a)(1)(A) in HUE 3855 and MUR 3937. -24- 5. Close the files. 6. Approve the appropriate letters.

Lawrence M. Noble General Counsel

/4 BY: Date Loi s G. erner Associa e.General Counsel Attachments 1. Responses of Andrea Seastrand, Friends of Assemblywoman Andrea Seastrand Committee and Mildred Dostalek, as treasurer, Friends of Andrea Seastrand Committee and Pete Agalos, as treasurer 2. Responses of Suggs, Lombardi Advertising BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of) Andrea Seastrand; ) MUJPs 3855/ Friends of Andrea Seastrand for Congress )3937 Committee and Pete Agalos, as treasurer; ) Friends of Assemblywoman Andrea Seastrand ) (33 Club) Committee and Mildred Dostalek, ) as treasurer;) Suggs, Lombardi Advertising.

CERTI FICATION

1, Marjorie W. Emmons, Secretary of the Federal Election Commission, do hereby certify that on November 4, 1994, the Commission decided by a vote of 5-0 to take the following actions in MURs 3855/3937: 1. rind no reason to believe that the Friends of Assemblywoman Andrea Seastrand Com ittee, and Mildred Dostalek, as treasurer, violated 2 U.S.C. 5 433, 2 U.S.C. 5 434t 2 U.S.C. 5 441a(a), 2 U.S.C. 5 441b(a) and 11 C.F.R. 5 110.3(d) in MUR 3655 and HUR 3937. 2. Find no reason to believe that the Friends of Andrea Seastrand for Congress Committee and Pete Agalos, as treasurer, violated 2 U.S.C. S 441a(f), 2 U.S.C. I 441b(a), and 11 C.F.R. 5 110.3(d) in MUR 3855 and MUR 3937.

3. Find no reason to believe that Andrea Seastrand violated any provision of the Act in MUR 3855 and MUR 3937. 4. Find no reason to believe that Suggs, Lombardi Advertising violated 2 U.S.C. 5 441a(a)(1)(A) in MUR 3855 and MUR 3937.

(Continued) Federal Election Commission Page 2 Certification for HU~s 3855/3937 November 4, 1994

5. Close the files.

6. Approve the appropriate letters, as recommended in the General Counsel's Report dated October 28, 1994.

Commissioners Aikens, Elliott, McDonald, McGarry, and Potter voted affirmatively for the decision; Coamissioner Thomas did not cast a vote. Attest:

1IL).W IdA/d1 Date Marjorie 'N. tJs ( Sec rotary of the Comission

Received in the Secretariat: Mon., Oct 31, 1994 3:57 p.m. Circulated to the Commission: Tues., Nov 01, 1994 11:00 a.mi. Deadline for vote: Fri., Nov 04, 1994 4:00 p.m. esh FEDERAL ELECTION COMMISSION WASHINGTO %DC .0463No e b r 1 , 9 4

Peter A. Bagatelos, Esq. Bagatelos & Fadem The international Building 601 California Street, Suite 1801 San Francisco, CA 94108

RE: MUR 3855/MUR 3937 Friends of Assemblywoman Andrea Seastrand Committee and Mildred Dostalek, as treasurer Friends of Andrea Seastrand for Congress Committee and Pete Agalos, as treasurer Andrea Seastrand

Dear Mr. Bagatelos: On January 31, 1994, the Federal Election Commission notified your clients of a complaint alleging violations of certain sections of the Federal Election Campaign Act of 1971, as amended (*the Act"). This complaint was designated MUR 3855. on March 7. 1994, the Commission notified your clients of an additional complaint alleging similar violations of the Act. This complaint was designated MUR 3937. on November 4. 1994, the Commission found, on the basis of the information in the complaints, and information provided by you on behalf of your clients, that there is no reason to believe that the Friends of Assemblywoman Andrea Seastrand Committee and Mildred Dostalek, as treasurer, violated 2 U.S.C. SS 4331 434, 441a(a), 441b(a) and 11 C.F.R. 5 110.3(d) in MUR 3855 and MUR 3897. The Commission found no reason to believe that the Friends of Andrea Seastrand for Congress Committee and Pete Agalos, as treasurer, violated 2 U.S.C. SS 441a(f), 441b(a), and 11 C.F.R. 5 110.3(d) in MUR 3855 and MUR 3937. The Commission found no reason to believe that Andrea Seastrand violated any provisions of the Act in MUR 3855 and MUR 3937. Accordingly, the Commission closed the file in each of these matters. The confidentiality provisions at 2 U.S.C. S 437g(a)(12) no longer apply and this matter is now public. In addition, although the complete file must be placed on the public record within 30 days, this could occur at any time following certification of Peter A. Bagatelos, Esq. Page 2 the Commission's vote. If you wish to submit any factual or legal materials to appear on the public record, please do so as soon as possible. While the file may be placed on the public record before receiving your additional materials, any permissible submissions will be added to the public record upon receipt. Sincerely,

Lawrence M. Noble General Counsel

BY: Lois G. re Associate General Counsel

Enclosure General Counsel's Report FEDERAL ELECTION COMMISSION WASHINGTON, DC 204b3

I V November 15, 1994

Mr. Stephen Lombardi Suggs, Lombardi Advertising 520 ffiguera Street San Luis Obispo, CA 93401 RE: MUR 3855/MUR 3937 Suggs, Lombardi Advertising

Dear Mr. Lombardi: on January 31, 1994, the Federal Election Commission notified you of a complaint alleging violations of certain sections of the Federal Election Campaign Act of 1971, as amended ("the Act"). This complaint vas designated as MUR 3855. on March 7. 1994, the Commission notified you of another complaint alleging similar violations of the Act, designated as MUR 3937. on November 4, 1994, the Commission found, on the basis of the information in the complaints, and information provided by you, that there is no reason to believe Suggs, Lombardi Advertising violated 2 U.S.C. 5 441a(a)(l)(A) in MUR 3855 and MUR 3937. Accordingly, the Commission closed the file in each of these matters. The confidentiality provisions at 2 U.S.C. 5 437g(a)(12) no longer apply and this matter is now public. in addition, although the complete file must be placed on the public record vithin 30 days, this could occur at any time following certification of the Commission's vote. if you wish to submit any factual or legal materials to appear on the public record, please do so as soon as possible. While the file may be placed on the public record before receiving your additional materials, any permissible submissions will be added to the public record upon receipt. Sincerely, Lawrence M. Noble General Counsel

BY: Lois G. Lerner Associate General Counsel

Enclosure General Counsel's Report FEDERAL ELECTION COMMISSION ~W~1II) WASHINGTON, DC 20463

my November 15, 1994 CERTIFIED NAIL RETUR RECEIPT REQUESTED Stephen P. Anderson, Esq. 201 South Miller Street Suite 107 Santa Maria, CA 93454 RE: MUR 3855/MUR 3937 Dear Mr. Anderson: on November 4, 1994, the Federal Election Commission revieved the allegations of your complaint filed on January 21. 1994 (MUR 3855) and a complaint involving similar issues filed on February 28, 1994 (NUN 3937). The Commission found that on the basis of the information provided in your complaint, and information provided by the Respondents, there is no reason to believe that the Friends of Assemblywoman Andrea Seastrand Committee and Mildred Dostalek, as treasurer, violated 2 U.S.C. sS 433, 434, 441a(a), 441b(a) and 11 C.F.R. 5 110.3(d) in NUR 3855 and MUR 3897. The Commission found no reason to believe that the Friends of Andrea Seastrand for Congress Committee and Pete Agalos, as treasurer, violated 2 U.S.C. SS 441a(f)v 441b(a), and 11 COFOR. 5 110.3(d) in MUR 3855 and MUR 3937. The Commission found no reason to believe that Andrea Seastrand violated any provision of the Act in NUR 3855 and NUR 3937 and the Commission found no reason to believe that Suggs, Lombardi Advertising violated 2 U.S.C. 5 441a(a)(l)(A) in MUR 3855 and NUR 3937. Accordingly, the Commission closed the file in each of these matters. The Federal Election Campaign Act Of 1971, as amended ("the Act") allows a complainant to seek judicial review of the Commission's dismissal of this action. See 2 U.S.C. 5 437g(a)(8). Sincerely, Lawrence M. Noble General Counsel

BY: Lois G. Lerner Associate General Counsel

Enclosure General Counsel's Report FEDERAL ELECTION COMMISSION WASHIN(7,TON, DC 204b3

THIS ISTHEEND OF!R # .?t-P

DATE FILMED CPMMR NO, ar C~EM~N