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/ ii 14 Irn~ 0 FEnIERAL ELECTION COMMISSION WASHINGTON, D.C. 20463

CERTIFIED MAIL RETURN RECEIPT REQUESTED

J. Griffeth, Treasurer Pauken for Congress Committee 303 Meadows Building Dallas, Texas 75206 Re: MUR 1336

Dear Mr. Griffeth:

On March 3 , 1981, the Commission found reason to believe that your committee violated 2 U.S.C. S 441d, a provision of the Federal Election Campaign Act of 1971, as amended (the "Act") in connection with the above refer- enced MUR. However, after considering the circumstances of this matter, the Commission has determined to take no further action and close its file. The file will be made part of the public record within 30 days. Should you wish to submit any materials to appear on the public record, please do so within 10 days. If you have any questions, please direct them to Duane A. Brown at (202)523-4057.

Chairman FEDER-AL ELECt1ION.COM4itSS[ON WASHINGTON, D.C. 20463"

March 5, 3961

CERTIFIED MAIL RETURN RECEIPT REQUESTED

John Oeffinger 8035 East R.L. Thornton Parkway Suite 420 Dallas, Texas 75228 Dear Mr. Oeffinger:

The Federal Election Commission has reviewed the allegations of your complaint dated November 3, 1980 and determined on the basis of the information provided in your complaint and information provided by the Respondent that there is reason to believe that a violation of the Federal Election Campaign Act of 1971, as amended (the "Act") had been committed. However, information provided by the respondent and the Dallas Weekly indicates that a proper disclaimer was in fact included on the ad when sent to the newspaper, but the disclaimer was lost due to a reduction in the size of the ad by the newspaper.

Accordingly, the Commission has decided to close the file in this matter. Should additional information come to your attention which you believe establishes a violation of the Act, please contact Duane A. Brown, the attorney assigned this matter at (202)523-4057.

General Counsel FEDERAL ELECTION COMMISSION WASIIlNGTON. D(. 20461

CERTIFIED MAIL RETURN RECEIPT RE.QUESTED

John Oeffinger 8035 East R.L. Thornton Parkway Suite 420 Dallas, Texas 75228

Dear Mr. Oeffinger:

The Federal 1±ection Commission has reviewed the allegations of your conplaint dated November 3, 1980 and determined on the basis of the information provided in your complaint and information provided by the Respondent that there is reason to believe that a violation of the Federal Election Campaign Act of L,-71, as amended (the "Act") had boen committed. However, information provided by the respondent and the Dallas Weekly indicates that a proper disclaimer was in fact included on the ad when sent to the newspaper, but the disclaimer was lost due to a reduction in the size of the ad by the newspaper.

Accordingly, the Commission has decided to close the file in this matter.

Should additional inforwmation cort to your attcrntion which you believe establishes a violation of the Act, please contact Diane A. Brown, the attcuLney as;signed this m-tter ,it (202)523-4057.

Sincereiy,

Charl.ecs 11. Steele General Counsel BEV 7lE FlAML EBC'ICR CO-DESSICN

In the Matter of ) IER 1336 Pauken for Cmnress Omittee )

=W32ICATION

I, Lena L. Stafford, 1 dcoring Secretary for the Feral Election Omuission's meeting on March 3, 1981, do hereby certify that the Ommnissicn decided by a vote of 6-0 to take the follwing actions regarding MR 1336: 1. Find REASCN 7O BIEVE the Pauken for mnress C ittee violated 2 U.s.c. S441d. 2. Take no further action. 3. Close the file. iuntissioners Aikens, Harris, McGarx, Reiche, Thmson, and Tiernan voted for these actions. Attest:

Date Lena L. Stafford Rcording Secretary FEDERAL ELECTION COMMISSION WASHINGTON, D.C. 20463

MEMORANDUM TO: CHARLES STEELE

FROM: MARJORIE W. EMONS/MARGARET CKANEY.E,-A.U DATE: FEBRUARY 27, 1981

SUBJECT: OBJECTION - MUR 1336 - First General Counsel's Report dated 2-25-81; Received in OCS 2-25-81, 1:52 The above-named document was circulated on a 48 hour vote basis at 11:00, February 26, 1981.

Counissioner Aikens submitted an objection at 5:1? February 26, 1981. This matter will be placed on the Executive Session Agenda for Tuesday, March 3, 1981. February 25, 1981

N33MM DUM TO: Marjorie W. Dm FROS IlissaT Garr SU3BJCT: UR 1336

Please have the attemhe First General ounsel's Report distributed to the Cmlssion on a 48 hour tally basis. Thank you.

Attachment

pakayson:2-25-81 cc: D.Brown FIRST GENERAL COUNSEL'S REPORT 5

DATE AND TINE OF TRANSMITTAL NUR # 1336 BY OGC TO THE COMMISSION: 2/aS/ DATE COMPLAINT RECEIVED BY OGC: STAFF MEMBER: Duane A. Brown

COMPLAINANT'S NAME: John Oeffinger

RESPONDENT'S NAME: Pauken for Congress Committee

RELEVANT STATUTE: 2 U.S.C. S 441d

INTERNAL REPORTS CHECKED: Pauken for Congress Committee

FEDERAL AGENCIES CHECKED: None

SUMMARY OF ALLEGATIONS

In a complaint filed by a John Oeffinger (Attachment 1), allegations are made which indicate that the respondent Pauken for Congress Committee purchased space for a half page political ad, but failed to include the proper disclaimer with that ad as proscribed in 2 U.S.C. S 441d.

FACTUAL AND LEGAL ANALYSIS A copy of the ad attached to the complaint clearly shows the absence of a proper disclaimer. However, once notified of the complaint by the Commission, the respondent, through the newspaper publisher Tony Davis, produced information which indicates that an ad identical to that submitted by the complainant, was submitted to the newspaper with a proper disclaimer (Attachment 2). Mr. Davis further notes that due to a reduction in the size of the ad, the disclaimer literally disappeared. Mr. Davis on behalf of the newspaper accepted full responsibility for the omission. M2- ., 4

CONCLUS ION It is evident from the information submitted by both the complainant and respondent that an ad which was presented to the newspaper with a disclaimer, failed to appear with that disclaimer at the time the ad was published. Although there is no information which would indicate an intent to omit the disclaimer on the part of the respondent, a violation of the Act has occurred. Based on the circumstances, however, the Office of General Counsel recommends that the Commission find reason to believe that the Pauken for Congress Committee violated 2 U.S.C. 5 441d but take no further action and close the file.

RECOMMENDATIONS C' 1. Find reason to believe the Pauken for Congress Committee violated 2 U.S.C. 5 441d. 2. Take no further action. 3. Close the file.

Attachments 1. Complaint 2. Respondent's Reply C" 3. Letter to Complainant 4. Letter to Respondent COSIPMINANT, ~3O MDV? Mr. John Oeffinger 8035 East R.L. Thornton Freeway Suite 420 Dallas, Texas BEFORE THE FEDERAL RESPONDENT, ELECTION COMMISSION Thomas W. Pauken OF THE UNITED STATES 600 Elm Circle Mesquite, Texas 75149

In accordance with the provisions of 2 USC 1437g(a)(1) and 11 CFR §11.4, Complainant hereby files this complaint. Complainant would p show the following: COMPLAINT Respondent failed to comply with 2 USC §441d and 11 CPR §110.11 in taking out a political advertisement without proper disclosure.

Facts On or before October 29, 1980, Respondent or his authorized agents % took out a political advertisement in the Dallas Weekly newspaper, a ~ copy of which is attached. The Dallas Weekly comes out on Thursday of each week and has an approximate circulation of 50,000. Respondent paid approximately $150 for the half-page political advertisement, which clearly omits the required disclosure statemenf.

Subscribed and sworn to before thd i a hority on the 3rd day of November, 1980.

Notary Public in and for Dallas County, Texas REBECCA PACE Notry Publlc My Com,~ssio Expires 11-22-30 j *~:; * ~W~iw.ms bacfir, both I

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Amnm0111p. Ibm Sadmula 4M 3Mibuim to atdMi WIW. P11100 a~h aM"d ft e bli UPPu, 1 ONa n@ 1WO wDalls~ Uisai Way W ~M U 6@ bfhim gnplyM. Mr. GemhoMauqV endorse' Meya.

lated by Black could be YOUR VO'E AN. they never TI DEFAMATION ;-ite dig the real LEAGUE suretmilSWW it .. JUST ONE tion to the aedlWa of the i do so much it ='Kand than of r aslm. Tom Pauken, tiof... our Wqky a M b DALLAS bad, them sg that tig wuw VW M CONTROL" and TIHAT THEY WERE NOT dthe ASLEEP ON THE JO; ... whatever that ueans...1!! ams DalsTimes Herald Some think ds PERSONAL joined theDallas Morning News with a Sunday ediutia e010ndorsmen PROBLEMS of the tha keeps ThseHeadendorsement ofPauken wascniee many of the minnids away n TUame Herald ent on to sa:. ?SYCMC from poiling places ... this Maaffxoz'rinepopuiwts ua-'e hAmienrsof wedanmukurpe amMda must NOT happen ... your ,tifunor kerpsfiordg Too. it it rmainglv d.la*alo inaiwduw mots know ma aJke ns, he vote could go long way to phig so marY sW-made holer M Iu dAke.* Earlier the Dallas IS towards solving your par- %Iorvng News had endorsed Tom Pauken ad Smie MantaO's sonal problems also...!! ampaign tactics. The News said of Macto: effevenes. .% or arr aw onpresme 'a ojfsmainsslw mawr hums hu byv f Mroxzjir) me nwcU on Pakken. xnTEE Continued on Pap 24 a mspowtole consermvnve candaW%. m ANSWERS XE.X. STARS.TARS.. ASWIRS "* Mattoxss repeated slursve erorsmentsaarnst Pauken. follow Even ancreals" and widespread public conern over RLD'S FORE . Coninu . from Pap 19 knowl gd in Oc . 19th rr sHeraldstoy that Mattosn,,t's d spoke-e d y vosaMike.n. saShnno bd .gn., IO RE ":O U 2 1 -J an w y 2 0 ' w t m m Mdtf o x ,o j um p up On BEFORE YOU Peo*l a a be p 4 a km * o d iw a a m e w o w%P . IF LIFE is After the stress expect him~(,t ma Hera str hat S111141011is e bydg*aa- bd u D. SEELIE IS Afr Of this rConcern over .Lattot's the ef t arly Tom Pauken s receiving behavior is shown by the gowing mmber E part In addition to the two major newspape. of endorsements ot the week. thin will the Dallas Paken ia up-oed 1 Police .Assx'at:on.the National Alliance U SOLVEAL level ouniceay oey of Senior tit,,ns the _ and. the National Federation orIndepende~t Busins ithe leading small busine organization in S IN LOVE.: break You deservedly nee. America P. f. DIVORCE. The number I can guide you Pauken. a Republican. is even receiving 5. SHE R. this week. CAPRICORN MattoS support from Democratic leaders turned off by taCXoi •like DOCdTe.a B entSon Democrat and 1978Dallas County chaiman for Bob . OE . BORN: Lloyd A. Wi-l am. -- Kreuger. in endorsing Paukn. had this to sav -Ton Paukeaas a mW of dwmr." executive officer of the New Partcular,. )U. CALL FOR York Uptown worth% of note is that Pauken is One of the CQanaba of endorsed by the DallastmThn few Republican candidates to be )CATES LOST Commerce. Herald and the Dallas Potic Association. Manv local observers believe )UR FRIENDS AQUARIUS that. when voters separate truth fron fiction on - loamy 21. November 4th. Pauken election day %,il be their choice. The two editorials endorstn T ASKIING A Febury19 below. Tom Pauken appear Much of .the=.,.~%-• early .. i...wwk is g ~la r=9 Wrualasltmes Herald EFAILED no" for anydting. So m q accordingly H for the bn House of Representativeso ae sick . rmults. The 9 will allow you Iu, t ueea - *:m to inish things. AQUARIUS I-ger Tom Psua BORN: Far anlltiM, M iim , Minister Henry M. tatm2 Turner-n the Rt.m uwm 1870'B, wrote m S de atm iulm. mWam rPmiA Olin. .s 1 n. Xm document defming the stUUs atlis abrov, e " :: Cnmicof the parties.Republican Ovaand 4 millionDemo- ham Ilia- we w ul"!!a b - nouMu.,m #0111 PWM-u

EINL, E wre aircie * ewml e oaaarm n Club mam womTm a PISCES - Fewb y d4l m, bmmM. ae ' a Ism 10 "ldl Marc 0 work " a Wi Mes 1 Ut ow i a.1 Up until Friday the 319. WMAUsaag aeam" d a period of ret is i=idicated.a. & 0 mini in Ou' Judgaa Atmn:. Afterwards, however, be metr wenftau,um mm.-ia am6- mwl m a"- awlmfmWU careful of trying to fiihrusm i .,,tig .. m things. Use tan. Let the 7 work for you this week. PISCES BORN: Elaton ". - ' Howard-former baseball at_... - Co

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- I- 25 November 1980 ~ ~ ~

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To Whom It May Concern:

When Tom Pauken placed his Ad with this NewspaperTHE DALLAS WEEKLY. it contained a proper Disclaimer. The one Ad that did not have a Disclaimer was simply because of in reduction of the sizespecified in the insertionthe Disclaimer literally disappeared.

As proof, we here with submit the original Ad. As you will notice has a proper Disclaimer.

We regret any problem this might have causedand this Newspaper takes full responsibility. , -. Mum :

Very truly yours,

Tiy D ,Publisher TD/mlw

Public Relations 9 Advertising e Ideas e Multiple Association Services e Acme Bonded Delivery Co. * B - K Bonded Delivery Services Sepia International Travel. Inc. * Mac's Shoes. Inc. 0 Sivad Productions vadPress e Publishers: * Dallas Weekly e Ft. Worth Weekly -Great CircleNews- East "Great Circle News- West- ,Ne•w.., , New *a Ht /rWoflo consideredWt. a injor . abd..... Alto- blow to Mattox who had 197 been supported by the Herald in 8. In its t-eme blow to al Own o ohsay:~ o aiAx'qomwpopidkssyleh deeiorawed •w s~h an abrvuveperoauzlid, nor,k inrr. oo.it isnc'wbly di)iukt m to Plug 0 Rmy Nl -m eholes in hi dike.' to know wi,he sn,,,, S&. hW Earlier the Dallas morning New had endorsed Tom Paue an crithuid&MaOct c tc. .11 The News said of Mattox 'an often aWimi 91W il.venes.Noam mpresedb nna Auuvs A* y hs(Ma ox') bitrpM aacb0,Pauk,, a respordble consvadve candida•e.' The Newspapr endorsements follow increasing a D d ef a puic e e.r KnOWledgIedMattox's repeated sIr against in an .c k"1,.- Pauken.u- _ ,Even .. Mattox,'s. . "_k chief spokesman,- lgtl Sn9 Times Herald Mike Swhannon. J111acumNm~ 1 a -ft- story that Mattox is prceived by People expect him (Ma"ox) lunf voters as a bad gW. to u on a pidi a knife"able and wade Concern over Ma.ox.s behavior is into de cr.od. . Tom shown by the growing number of endorsements the DallasPauken Polc is receiving.Ascati~nth In addition --to'a the ... new.pars, Pauken cthe two major e is d by Natinal Alliance of National Federation of Senior Citizens, the F and the ndeende - s (the leading small America). business Orgnization in Pauken, a Republican. is even receiving support Mattox's tactics. Mike Dodge, from Democratic leade turned off by a Dentson Democrat and 1978 Dallas county chairman Kreuger, in endorsing Pauken, had this to say- -Tom Pauken for Bob Particularly worthy is a man of Characg& of note is that Pauken is one of the few endorsed by the Dallas Republican candidates to be Times Herald and the Dallas Police Association. Many local observers believe that. November 4th, when voters separate truth from fiction Pauken will be their choice. The two on election day below. editorials endorsing Tom Pauken appear

Dallas Times Hemid House of Representatives in the fth Dlw cha . Congress endorsements ,le011r TIm pIunhmn A m.an that 24.rm Rep. Ji Mmox MW To mld ""nmdummW :o caline Moan 1Fr ha toned dow his liberal. wetg electuon tMandm m Who we wholly dftult Which No m during the prsent trM/ or partially in Dai away,, and t an often abrmsive manner hur hi euectvenM. Nor M~g are we premedt it btuer / Wthe loca raem for she U.& Barf of personal atuack o Pankeln a mawtts fotmaor popuh respo"slble n.,uveW can. / Style has deturiorated with an -ahead, pemNOmmi. didate. Puen a awm .ha ity that neither win. nor keep binti. incsiamly To%, It ic worked as a White Noune ftr as he momdifficult to plug to mWowm whet hle WM6 aide. knows his w around tmae hl Washington and would pro. In hWdie. Mr. Pauken loao Wm to th pl". col right than Matx and about half t -I vide,. In our Judgment, acel. in the diiatrict pooli lentrepreseatn ingly but he piment hhrnll am-via. on.a| th.s yar n One who and0. will week SEPT 21. 160 ufnaothly with all clum rf OCT 1. IeND

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TO WHOM IT MAY CONCERN:

As media adviser to the Tom Pauken campaign, part of my responsibility was to place some of the newspaper and radio advertisements. I understand there is some question about an ad placed in the local paper, The Dallas Weekly. The half-page, 150 dollar ad was purchased on October 28th for that week's edition of the paper. The ad had my approval. As can be shown, the "camera-ready" copy delivered to the paper possessed the proper disclaimer as required by Federal law. It is my firm belief that the Tom Pauken For Congress Committee made every effort to obey the law and to abide by the regulations allowing for a fair and honest election.

Lisa LeMaster Vice President

Management Consultants in Media Communications FEDERAL ELECTION COMMISSION, WASHINGTON, DC 20463

CERTIFIED MAIL RETURN RECEIPT REQUESTED

John Oeffinger 8035 East R.L. Thornton Parkway Suite 420 Dallas, Texas 75228

Dear Mr. Oeffinger:

The Federal Election Commission has reviewed the allegations of your complaint dated November 3, 1980 and determined on the Dasis of the information provided in your complaint and information provided by the Respondent that there is reason to believe that a violation of the Federal Election Campaign Act of 197i, as amended (the "Act") had Leen committed. However, information providled by the respondent and the Dallas Weekly indicates that a proper disclaimer was in fact included on the ad when sent to the newspaper, but the disclaimer wos lost due to a red,,ction in the size of the ad by the newspaper.

Accordingly, the Cooimission has decided to closL the file in this matter.

Shouid additional information cuofe to yourLti tion which you believe establishes a violatiuin of the Act, please contact Duane A. hkron, the at-torn'e, a.-signed this matter at (202)523-4057.

General Counsel I 7ED IALELEC lION", COiHMiS51i( WASH INGMINI, 1)C Zo461

CERTIFIED MAIL RETURN RECEIPT REQUESTED

J. Griffeth, Treasurer Pauken for Congress Committee 303 Meadows Building Dallas, Tvclas 75206 Re: rMUR 1336

Dear Mr. (7ritfeth:

On , 1981, the Commission found reason to believe that your committee violated 2 U.S.C. S 441d, a provision )f the Federal Flection Campaign Act of 1971, as amended (the "Act") in connection with the above refer- enced MUR. llowrver, after considering the circumstances of this matter, the Commission has determined to take no further action and close its file. The file will be made part of the p'iblic record within 30 days. Should you wish to submit any T)aterials to appear on the public record, please do zo -it'in 10 clays.

If you havJe any questions, please direct them to Duane A. Provii at (202)523-4057. Sincerely, I, '1 *'*1 i Octebs 3I-Nombw 6, no

4F Uox tactics

backfire, both -A I) - t . D allas' * **

it Manager, announced that Procter & Gamble 'rocter & Gamble Fund has contributed S25,000 to Has campaign. These total contributions represent Iributon to the United Way. Procter & Gamble's newspapers uted to the enthusiastic support of the employees "er of the Dallas United Way for many yeas. both f Individual employees. Mr. Gilesple has served.an t two yeas..

nated by Black entdorse. could be YOUR VOTE. AN- they never TI DEFAMATION 4uite dig the real LEAGUE sure called atten- it .. JUST ONE tion to the activities of the ido so much ... it KKK and then offered a solu- TomII iP Pauken.I a ui k tion _. n.or incuirv at FBI in DALLAS kg had them statinjR that things were "UNDEF meC CONTROL" and THAI r A THEY WERE NO T 'vL ASLEEP ON THE JOB;;.. DALLAS-Saying that it 'favors challenger Tom Pauken over incumbent Jim Maox' the m . whatever that means...?! Dallas Times Herald joined the Dallas Morning News with a Sunday editorial endorsement of the Some think tis PERSONALL candidacy of Tom Pauken for U.S. Congress. - s The Herald endorsement of Pauken was considered a major surprise - and a significant E s AND PROBLEMS that keep blow to Mattox who had been supported by the Herald in 1978. In its endorsement of Pauken. the many of the minorities awa,ky Times Herald went on to say:. iSYCHIC from polling places ...thi "Marrox' former populist syle has deteriorated with an abrasive personality that neither r wins nor keeps friends. Too, it is increasingly must NOT happen ...you difficult to know what he stands for as he y mores to phg so many self-made holes in his dike."Ma "m.o1. .. vote could go long wa, Earlier the Dallas Morning News had endorsed Tom Pauken and criticized Mattox's -- towards solving your per campaign tactics. The News said of Mattox "an often abrasive manner hurts his ,S sonal problems also...!! effectiveness. Nor are we impressed by his (Manox s) bitter personal attacks on Paliken, NTEED Continued on Page 24 a responsible conservative candidate.- The newspaper endorsements follow increasing and widespread public concern over :E. ANSWERS STARS... Mattox's repeated slurs against Pauken. Even Mattox's chief spokesman. Mike Shannon. ac- RLD'S FORE- Continued from page 19 knowledged in an Oct. 19th imes Herald story that Mattox is perceived by voters as a 'bad guy". BEFORF "Peopleexpect him (Mattox to jump up on a table, pull a knife and wade into the crowd. YOU -21-January 20 Concern over Mattoxis behavior is shown by the growing number of endorsements D. IF LIFE IS After the stress of this early Tom Pauken is receiving. In addition to the two major newspapers. Pauken is supported by ro SEE THE part of the week, things wilil the Dallas Police Association, the National Alliance of Senior Citizens. the VFW and the U SOLVE ALL. level off nicely to give you th National Federation of lIndpendent Business (the leading small business organization in .S IN LOVE, break you deservedly need 4 America). DIVORCE The number I can guide yoxu Pauken. a Republican. is even receiving support from Democratic leaders turned off by Mattox's tactics. Mike Dodge. a Bentson Democrat and 1978 Dallas SS. SHE RE- thisBORN: week. Lloyd CAPRICORtA. Williams- I. County chairman for Bob Kreuger. in endorsing Pauken. had this to say - 'Tom Pauken is a man of character.' FROM YOU. executive officer of the Nei Particularly worthy of note is that Pauken isOne of the few Republican candidates to be )U. CALL FOR .*N York Uptown Chamber oDf endorsed by the Dallas Times Herald and the Dallas Police Association., )CATES LOST i:I Commerce. Many local observers believe that. when voters separate truth from fiction on election day )UR FRIENDS AQUARIUS - January 21I-N November 4th. Pauken will be their choice. The two editorials endorsing Tom Pauken appear t below. T ASKING A February 19 W Much of the early week iis indicated as a definite "no:t DallasTimes Herald 'E FAILED E accordinglyno" for anything. So acct for the bes House of Representatives results. The 9 will allow yoi Inm t th Dtsrick chat- Congress endorsements "1 Ti5m maIwi1.ndsm1 w Jnm ,1are sick or to finish things. AQUARIU1 S r 'r omPa des. Pot an :. IV Cdmar.arwa r ad Pha Gm . who a 'me Williams- BORN: Minister Henry M dankitre-e4l4aa rn dbtuicu whkLO@ --- Turner-in the 1870's, wrot whely opa fy In Dllm usmoty. and ta3 Jim dul'tu the wgt on e he U. Ho, e of no e document defining the statu am ofte abrave manor I n"ti ea l V of the Republican and Demo hurt hw effecttveaen Nor RepmmSauva. " in arwmtmprmen by i btter rate parties. Over 4 millior Persnal attacks on Pask". a style hamdetekmWd with an Aid ENUE were circulated. repoetbo coarmvve camw Ity tMt neithe wmiu nor keeptA Ia 2 m, it l diam. Pmn. a lawyw. ham ke Wy diffkiuk to know WimW be atenb PISCES - February 20 fw e bs mva to plug *naffySWIM& bal March 20 WWId e WWIteson known bia w anmde In bb ddi.. Ur. Pana. -MSft 00 PeI- 0.Up until Friday the 31st,a c m d hnMatewsOa a &W 60 -~ Whmlapes andwee*am W the dMerut,K A heVI*Mil Wm period of rest is indicated, vide. In Our Judg~maW.excel- Afterwards, however, Im uibly wih a diV s careful of trying to rushh ______SEPT.21. SOW OCT. teIM things. Use tact. Let the I7 work for you this week PISCES BORN: Elstor 1 Howard-former basebal !.great. f omPaukenfor~T avauh~,~E~gNews with. a Sun d cafd~dPayu~ aCongrmw tonaq Herald endorse c P5 ken was considered blow to attoxX who had been a major surrise at" " n supported by the Herald in 1978. In it endrseme imes Herald went on to "MatoxqIformer populistsay: style has deterioratedwith an abrasive personality wis nor keeps ffiends. Too, it is that neiher increasingly difficult to know what he stands moves to plug so many self-made for as I Earlier the Dallas M.. holes in his dike." camari tealcs morning 19. . News had endorsed Tom Pauken ahd criticized campaign tactics. The News said of Mattox Mattox's effectiveness. -an often abrasive manner hurts hi Nor are we impressed by his (Matox's) bitter personal attacks on Pauken, a responsible conservative candidate." The newspaper endorsements D allas Mm ran N ews Sep Mattox's follow increasing and widespread public . 21. 19 repeated slurs against Pauken. Even Mattox's concern over knowledged in an Oct. chief spokesman, Mike Shannon, ac- 19th Times Herald story that Mattox is "People expect him (Mattox) perceived by voters as a "bad guy". to juip up on a table, pull a knife and Concern over Mattox's behavior wade into the crowd." Tom is shown by the growing number Pauken is receiving. In addition to the of endorsements the Dallas Police two major newspapers, Pauken is supported Association, the National Alliance of Senior by ,wNational Federation of Independent Citizens, the VFW and the Business (the leading small business ,America). organization Pauken, a Republican, is even receiving support from . Mattox's tactics. Mike Dodge, Democratic leaders turned off by a Bentson Democrat and 1978 Dallas County Kreuger, in endorsing Pauken, had this chairman for Bob Particularly to say - "Tom Pauken is a man of character. worthy of note is that Pauken is "o %'endorsed one of the few Republican candidates to by the Dallas Times Herald and the Dallas be 7,. Many Police Association. local observers believe that, when voters separate November 4th, Pauken will be their truth from fiction on election day choice. The two editorials endorsing Tom Ctelow. Pauken appear

Dallas Times Herald House of Representatives In the Fifth Dstuict, chal. Congress endorsements longer Tom Pauken. For all The Times Herald endW"e that 2-termn Rep. Jim Mattox Collins, Martin congrmOO1 Jim has Frost and h Gram, who ar toned down his liberal. seeking re-election from districts which lie lam during the present wholly or partially an term,, in Dallas Comnty, and tLYQp often abrasive manner hl grTorn Pauken O rincumbent Jim hurts his Mautox effectiveness. Nor in the local rame for the U.S. H Ousf are we Impressed by his bitter Representatives. personal attacks on Pauken. a Mattox's former populist responsible conservative can. style has deteriorated with an abrasive persona. didate. Pauken, a lawyer, has ity that neither wins nor keeps friends. Tbo, it is worked as a White increasingly difficult to know what he stands House for as he moves aide, knows his way around in his to plug so many self-made hohat Washington dike. Mr. Pauken leans more to the polit. and would pro. cal right than Mattox vide, in our Judgment, and about half the pbop excel. in the district, but he presents himsel .3 lent representation. ingly convtn-. this year as one who can and wigl work SEPT. 21. 1980 1 smoothly with all citizens. I OCT 19, 1960 -r

Paid for by Tom Pauken for Congress Committee. J~I ft. 4

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cv G~f~av~ almp"& SCORPIO BUILDING FOREST AVENUE AT MEADOW P.O.BOX 15832 DALLAS, TEXAS 75215

AC - 214/428-6956 fU3 (~j1 ('Us ~P'~

25 November 1980 ,e~. &

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To Whom It May Concern:

When Tom Pauken placed his Ad with this Newspaper,THE DALLAS WEEKLY. it contained a proper Disclaimer. The one Ad that did not have a Disclaimer was simply because of in reduction of the size,specified in the insertionthe Disclaimer literally disappeared.

As proof, we here with submit the original Ad. As you will notice has a proper Disclaimer.-

We regret any problem this might have caused, and this Newspaper takes full responsibility.

Very truly yours,

,Publisher TD/mlw

Public Relations e Advertising * Ideas 9 Multiple Association Services * Acme Bonded Delivery Co. e B - K Bonded Delivery Services Sepia International Travel. Inc. 9 Mac's Shoes. Inc. * Sived Productions Sivad Press e Publishers: * Dallas Weekly * Ft. Worth Weekly 9 Great Circle News - East" "Great Circle News - West" ~LF1LLdb - saying f54u lies Herald joinedlthat tha it ,fa,AS cwilNge Tobi kn ovJc las Morning News with a Sunca tolg e canhda yof Ibm Pauken for U. Congress. l Herald endorsement blow of Pauken was considered a major surise to Mattox who had been supported by the and a _ "ban Herald in 1978. In its endorsement oft Times Herald went on to say: t Mattox sformer W'6 populist style has deteriorated with an abrasive wins nor keeps friends. Too, personality that neither it is increasingly difficult to know what he stands moves to plug so many self-made for a he holes in hii dike." Dallas Times Earlier Herald. Oct. 19. 1". the Dallas Morning News had endorsed Tom campaign tactics. Pauken and criticized Mattox's The News said of Mattox "an often abrasive effectiveness. Nor are we impressed manner hurts hs by his (Mattox 's) bitter personal attacks on Pauen, a responsible conservative candidate." Dallas Morsing News. The newspaper endorsements follow ept. 21. 1en Mattox's increasing and widespread public concern repeated slurs against Pauken. Even Mattox's over knowledged in an chief spokesman, Mike Shannon, ac- Oct. 19th Times Herald story that Mattox is "Peopleexpect him (Mattox) perceived by voters as a "bad guy*. to jump up on a table, pull a knife and wade Concern over Mattox's behavior into the crowd." Tom Pauken is shown by the growing number of is receiving. In addition to the two major endorsements ,,the Dallas Police newspapers, Pauken is supported by Association, the National Alliance of Senior National Federation of Independent Citizens. the VFW and the Business (the leading small business organization fAmerica). in - Pauken, a Republican, is even receiving support from Democratic Mattox's tactics. Mike Dodge. a Bentson leaders turned off by Democrat and 1978 Dallas County chairman 'Kreuger, in endorsing Pauken. had this to for Bob Particularly say- "Tom Pauken is a mant of character." worthy of note is that Pauken is one endorsed of the few Republican candidates to be by the Dallas Times Herald and the Dallas Many local observers Police Association. believe that, when voters separate truth from c"November 4th, Pauken will be their choice. fiction on election day The two editorials endorsing Tom Pauken .below. appear I aa i (rn1iDallas p Times Herald House of Representatives Congress endorsements In the nifth lenlwe TOM District, cCohe ess endorse n ts tht 2bw Ptaken.Jim Fror anl The TiM Herald endorme mattox Collins, Martin Jim haston"2 mownRe i imberat PrMt and Phil Gram, who are has toned seeking re-election from districts which down his liberal. wholly lie am dng the present or partially in Dallas County, and tay term, Pauken an often abrasive manner F - ,xi telcl ae hurts his effectiveness Nor Re.presetai o t h Ouse Ofof are we impresed by his bitter personal attacks Mattox's former on Pauken, a style populi reponslblo e has deteriorated with an abraive penOalM. c. ity that neither didate. Pauken, wins nor keeps friends. Too.It ib a lawy, has increasingly aid*.worked as a White House difficult to know what he gjald knows is way around for as he moves to plug so many sV1f-Inl& Wahington and would pro. in his dike. Mr. Pauken leans lde vide In our judgment, cal right than Mattox more to the poll. eel. in and about half the people lent repreentatUodn, the district, but he presents hinsel ocnvlnc. ingly this year as one who lent re1rese1t8o can and Wil work on. smoothly with all citimzuaO SEPT 21. 1980 OCT. 19, 19600 ,

______.....--__ Paid for by Tom Pauken for Congress Committee. p, 1111 W. MockIngb& LLr Butte I RQ8 Oeli, Texas 75241

(214)834-7808

November 25, 1980

TO WHOM IT MAY CONCERN:

,W,. law. It is my firm belief that the Tom Pauken For Congress Committee made every effort to obey the law and to abide by the regulations allowing for a fair and honest election.

Lisa LeMaster Vice President

Management Consultants in Media Communications 75MB

~At ZicZ GMNe EMOvq COAM~ M'1ffOy AkifrftiCON b.c. zo~'~J OXgC CERTIFIED PUBLIC ACCOUNTANTS

November 18, 1980

Mr. Duane Brown 7, Federal Election Commission 1% - Washington, D.C. 20463 RE: MUR 1336 R%*

Dear Hr. Brown: -

This letter is in confirmation of our telephone conversation today concerning the Pauken for Congress Committee. Please be advised that I have not been associated with this Committee in any capacity since my resignation as treasurer in late November, 1978. Several times I have received communications from the Commission and each time I have notified the appropriate representative of the Commission that I am no longer associated with this Committee in any capacity whatsoever. At your request, I have forwarded your letter of November 13, 1980 with enclosures directly to Mr. Tom Pauken at 600 Elm Circle, Mesquite, Texas 75149. If you need any further information concerning this matter, please do not hesitate to contact me. Yours truly,

DO & WOLFF

H. D. Pedlar, Jr... HDP :vh RECEiVEO

.DW A80MNO PIZ: 63 Dohm&Wjf F ACCOUNTANTS S I ETIFIED PUBLIC 3575 FIRST INTERNATIONAL BUILDING DALLASTEXAS 75270

Mr. Duane Brown Federal Election Commission Washington, D.C. 20463 FEDERAL ELECTION COMMISSION WASHINGTON, D.C. 20463

MEMORANDUM TO: Charles N. Steele THROUGH: Gary L. Johansen FROM: Duane A. Brown SUBJECT: Retransmittal of 5 Day Notice - MUR 1336

On November 18, 1980, I received a telephone call from a Skip Pedlar, an individual thought to be the treasurer of the respondent committee in response to our letter informing him that his committee may be in violation of our Act. In fact, RAD's most recent communication with the respondent at the time this complaint was received indicated that that office was also under the belief that Mr. Pedlar was the respondent's treasurer. However, Mr. Pedlar informed me by telephone that he had not been treasurer of this committee since 1978, yet the candidate continued to use his name as such. Subsequent investigation did determine that a J. Griffeth was now the treasurer for the respondent and a new 5 day notice (which is attached) must be sent.

For your information, I did request that Mr. Pedlar inform this office in writing that he was no longer the treasurer for the respondent. FEDERAL. .LECT WASHINGTON. i6Ct 20*0

Vqoaber, 2-1,8 190&

CERTIFIED MAIL RETUI4 RECEIPT REQUESTED

J. Griffeth, Treasurer Pauken for Congress Committee 303 Meadows Building Dallas, Texas 75206 Re: MUR 1336

Dear Mr. Griffeth: This letter is to notify you that on November 7, 1980, the Federal Election Commission received a complaint which alleges that your Committee may have violated certain sections of the Federal Election Campaign Act of 1971, as amended (the "Act"). A copy of this complaint is enclosed. We have numbered this matter MUR 1336. Please refer to this number in all future correspondence. 2 U.S.C. S 437g(a)(1) indicates that within five days after receiving a complaint, the Commission shall notify, in writing, any person alleged in the complaint to have committed such a violation. The Commission's files indicated that another individual rather than yourself was treasurer and this caused a delay in your receiving this letter. Under the Act, you have the opportunity to demonstrate, in writing, that no action should be taken against your Com- mittee in connection with this matter. Your response 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. 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. This matter will remain confidential in accordance with 2 U.S.C. S 437g(a)(4)(B) and S 437g(a)(12)(A) unless you notify the Commission in writing that you wish the matter to be made public. J.* Griffeth Page Two

If you intend to be represented by counsel in this a.t, please advise the Commission by sending a letter: of req)* .t_ tion stating the name, address and telephone number 'of #I000 counsel, and a statement authorizing such counsel to reoetv. any notifications and other communications from the Commiss ion.

h If you have any questions, pelase contact Duane orown, the attorney assigned to this matter at (202)523-4057. .or your information, we have attached a brief description of the Commission's procedures for handling complaints. Since.

Charles N. Steele General Counsel Enclosures 1. Complaint 2. Procedures 4.

- POSts 4Mb ~ts PAW

- - -

60O CTcle Nszqu L Tenas 75149

S87 CERI FI EL 6HU K; lit -4w/' '' 472"S ~'6A dL62~I2A(4{

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2 j~'V~f. ~ FEDERAL tLECTKON CdMMISsION1 WASHINCTON.-O.C. 20463

NOVeme 13, 1,80 CERTIFrED MAIL flETURN RECEIPT REQUESTED Pauken for Congress Coumittee Skip Pedlar, Treasurer 3575 First International Building Dallas, Texas 74220

Re: MUR 1336 Dear Mx. Pedlar:

This letter is to.-notify you that on November 7, 1910, the Federal Election Commission received a complaint which alleges that your Committee may have violated certain sections of the Federal Election Campaign Act of 1971, as amended ('the Act") or Chapters 95 and 96 of Title 26, U.S. Code. A copy of this complaint is enclosed. We have numbered this matter MUR 1336. 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 your Committee in connection with this matter. Your response must he 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. 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. This matter will remain confidential in accordance with 2 U.S.C. S 437g(a)(4)(B) and S 437g(a)(12) (A) unless you notify the Commission in writing that you wish the matter to 6e made public. If you intend to be represented by counsel in this matter, please advise the Commission by sending a letter of representation stating the name, address and telephone number of such counsel, and a statement authorizing such counsel to receive any notifications and other communications from the Commission. Lettert: > Page!v

If you have any questions, please contact Duane Brown, the attorney assigned to this matter at (202) 523-4057. For your information, we have attached a brief description of the Commission's procedures for handling complaints. since .

General Counsel

Enclosure 1. Complaint 2. Procedures

- . , .*_ .- I - ,. , . . 1., . IiI.- I I ., - FEDERAL ELICTQPN tMMISIQK'; WASHINGTON. .C 20463

November" 3, liSO'1'9

CERTIFIED MAIL RETURN RECEIPT REQUESTED Mr. John Oef finger 8035 East R. L. Thornton Parkway Suite 420 Dallas, Texas 75228 Dear Mr. Qeffinger: This letter is to acknowledge receipt of your complaint of November 3, 1980, against Thomas W. Pauken and the Pauken for Congress Commuittee which alleges violations of the Federal Election Campaign laws. A staff member-has been assigned to analyze your allegations. The respondents will be notified of this complaint within 5 days and a recommendation to the Federal Election Commission as to how this matter. should be initially handled will be made 15 days after the respondents' notification. You will be notified as soon as the Commission takes final action on your complaint. Should you have or receive any additional information in this matter, please forward it to this office. For your information, we have attached a brief description of the Commission's procedures for handling complaints.

GeerlN. Steee GenralCounsel Enclosure 7, 7 7" ) '

3.3tum&~~aim~

iUmDULIVEt toA6dau

-M Wfw'mVw'o Thomas W. Pauken 600 Elm Circle Mesquite, Texas 75149

Re: MUR 1336 Dear Mr. Pauken: This letter is to notify you that on November 7, 1980p the Federal Election Commission received a complaint which alleges that you may have violated certain sections of the Federal Election Campaign Act of 1971, as amended ("the Act") or Chapters 95 and 96 of Title 26, Uo.s Code. A copy of this complaint is enclosed. We have numbered this matter MUR 1336. 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 your Committee in connection with this matter. Your response 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.

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. This matter will remain confidential in adcordance with 2 U.S.C. S 437g(a)(4)(B) and S 437g(a)(12)(A) unless you notify the Commission in writing that you wish the matter to be made public.

If you intend to be represented by counsel in this matter, please advise the Commission by sending a letter of representation stating the name, address and telephone number of such counsel, and a statement authorizing such counsel to receive any notifications and other communications from the Commission. theatt~y ~#~~etO th~is uxtik at (2, lOi nfomati, vwhave, attuched a, brief co~~s~kk's procedures for' handling, copli Sin'.

Genera of

Enclosure 1. Complaint 2. Procedures .273

COMPLANANT, aO NOV ,PI :3g

Mr *John Oeffinger 8035 East R.L. Thornton Freeway Suite 420 Dallas, Texas BEFORE THE FEDERAL RESPONDENT, ELECTION COMMISSION Thomas W. Pauken OF THE UNITED STATES 600 Elm Circle Mesquite, Texas 75149

In accordance with the provisions of 2 USC 1437g(a)(1) and 11 CFR 111.4, Complainant hereby files this complaint. Complainant would show the following: COMPLAINT ow Respondent failed to comply with 2 USC 9441d and 11 CFR 1110.11 t in taking out a political advertisement without proper disclosure.

Facts On or before October 29, 1980, Respondent or his authorized agents took out a political advertisement in the Dallas Weekly newspaper, a copy of which is attached. The Dallas Weekly comes out on Thursday of each week and has an approximate circulation of 50,000. Respondent paid approximately $150 for the half-page political advertisement, 0 which clearly omits the required disclosure statement.

Subscribed and sworn to th rsigned a hority on the 3rd day of November, 1980.

Notary Public in and for Dallas County, Texas REBECCA PACM Notary Pubite My Comnission Expires 11-22.30 75)22

IUV'T

General Counsel Federal Election Conission 1325 K St. N.W. .Washington, D.C. 20463 °- .0,,*°-

TillS IS THE BEGI4UMING OF HUR - (I-§m 1*,

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