WY *1 FEDERAL ELECTION COMMISSION WASHINGTO. D.C. 23 THIS IS1TEBIN6J _____, I ITEFIqhED I [1Cl NO. __ Federa Elcto ommission 999 E Stret N.W. Washingo D.C.206 Devd ~ia Unbin Stats ial Suy regbmnd OYUIB w di ml. U SJS. Ctai reblpi I Z M~l UP 56. U.SJ'. Exlpim Ma Reep # 3F41232U. Dear Sir or Madam: Please e this leter as my mwm forml coqplait filed in trlet acodn 00 the provisiom set forth in 2 U.S.C. Section 437g (a) (1) of the Federal Elcto Campaignu Act. I fully understad my re~ iility umler sustion (c) that all seaems made in this cwuplaim are subject to the federa statues goerin perjury. My uylai seeks a full inetgto by the FEC " of probable vioato of the Act by United Stte Sumter Kay Daule I ibsm a canlidme for re- , election in Texas, the Kay Bailey Huehio for Seame Committe, anl Ray Huthmn My mine iuRobin Ramugh. My full -m awl ofic ulks ae primd bedow my sigouur at the cml of this cosuplajL !am tim caqaaiP mmw for R u Fishe, the D.lemoca~tic nominee for United States Seint from Teas. At approximately 10:.0 am. on Monday, Jul 25, boarded Soudhwest Airlines flight fl09, S deparin Dalla Love Fiel airor for Austin. The airlie has unassigned, open seatig. As I boarded the plane, most of the seats wer - already tken. ! apr achd pry of four seated in one of the lune areas" near the rear of the plane, and asked if ! could join them. One of the men seated there assured me it was all right to join them, so ! took the middle seat on the side facing the front of the plane, with two gentlemen in business suits on either side of me. Across from me, die middle seat was empty. The aisle seat was occupied by a white-haired man wearing glasses and a business suit. The window seat was occupied by a young blonde woman wearing a red skin. Shortly after takeoff, one of my fellow passengers in the lounge area began a conversation with the others, and it became obvious they knew each other. The white-haired gentleman spoke for some time, and the conversation turned to the subject of the United States Senate race in Texas. 3850 W. NORTHWEST HIGHWAY, SUITE 500 * DALLAS, TX 75220 * 214/357-0293 * FAX 214/357-6382 PAID FOR BY FISHER FOR SENATE '94.*JAMES HOWARD. TREASURER.* POU TICAL CONTRIBUTIONS ARE NOT TAX-ODEDUCTIBLE ,ersomi_t.odctio to m, I leanmd tha my JMlo pmsqw tudwl enagl in wvrslnwas Ray Hueicl ht~d e Humihn a~l the frmu' Cln of lb m Rp~*1lan Pary. With him were Teas Rep~huca Par amkr Tom PuR lbaadDDO u my Sheriff ii Bowles. Maolpari ,tn acivl Intlb ,avuis,- wu a you lady who itleied hersef as a campaign saffer for "Tex'Lemar, Tern RqwMican mdlcai for Listm atmGoiro. 1 knew from our campaign schedule that Mr. Hiuio was to qya on behalf of Semw Huechison at 1:30 p.m. that afeno in Austin at a meta of the state Shrifs Auociton so b folwdimmediately by Mr. Fisher. I surmised that lbe meeting was Sheriff Dowles' destiution as well. Mr. Huhison spo alnthwithebtwole gmlemenseaed on eiflbrside of ma. Iwas ramble to move to anothe sea loato beas lb plane wm still aeling and lb seat belt sign were still lit. Mr. Hutcisn told lbe others in lbe loung area that 'We've had a spy over there intlb -- Fisher campaign since May. We know everythingthey're doing." c Mr. Hutchison quote figue from privat interna Democraic Pary polls, saying "weknw C- what's going on from East Dallas strething all lbe way out to Tyler.' Mr. Hutchison dbn askd Mdr. Pah. to tak to due guys at lb NRA, aying, "We've got - o get lbm to get down here into th~is ruce. They need tospeai - mam oei us.' After a while, Mr. Hutchison addkemed ma diectl, asking 'Wht do you do fer a livingi, S yunglady?" I responded, 'Actually, i'm indl m lsm syou flsare.' ML~r. Huthio smiled and said, 'Who do you work tor?" !answered him tha !am lb campaign manage for Rihad Fisher. There followed a fairly log silence. Mr. Hutbio visily blushed. Then Mr. ' Hutchison exclaimed, 'Well that's just gr"eat!' He then asked me to repeat my name, and proceeded c.. to introduce me one by one to everyone seated in lbloh e area. Ray Hutchison is a name partner in the law firm of Hutchison, Boyle, Brooks and Fisher in Dallas. My understanding is that his practice is based in public bond tractions. Inthe most recent reports to the FEC by the Kay Bailey Hutchison Legal Defense Fund, the firm of Hutchison, Price, Boyle and Brooks is listed as the recipient of payments totaling more than $17,500 for reimbursement of expenses, including 'meetings.' Ray Hu ko, Smor Hu'ebb m n, do erv -hirrl nm ip rqenwezlve, caqupga comultam, cmpsln oredisr and lega ind. Wedd Sen Huteho's lus avkr Ray Husabbon ither 4e mme. mer. lk kanwlugaof and Complicity Inthe 'spy" ctivty axmltbut viohtkin of"PDC iqutMki 11 C.F.R. Nt 110., (o), Paarah(2), which rei 'W'diuly an kuwnl prtcim Inor aiqw to pylcit In plan or design to violat paragrap (b)(1) of th section.' Vl loin of hdea law. CvL Mr. Huochison's comme~m that 'We've had a spy over there in the Fisher campaign sice May. We kno~w everthn they're &oing," inmkum that a person or pomuom puprtn t be Fisher suprtr, votuaes andlor employees rove been engaged inFisher autmign activity n order to report interal information o thde Himhiion caqpuig. Or it could indicat that suvilao techn ology has been employe by th Huihio cmaqfgn. "As a result of the 'spy' disckuure by Ray Hutchison the Fisher caqupg 3 diverting essenteial resouces of employee hours and hours to undertak additiouml mr t m ummto prv such activity. A camlpaign for public offie qates in a coiettv envku, e arnd casee afor s"o have the security of inenal strategic -! coimi. An exml of just such a coqwomamng disckomwn isdeucrbedin Mr. Huchiso. quota of N" figue from prvt iuieru Demami Party pol, sayng " kuww wlm's psng on from Da , De:l~llas stretching all the way out to Tyler." The 'spy' activity reporte by Mr. Huchiso coamih~s a violakxm of th letter and the pirit C of FEC regulations in Title I1I of the Code of Federal Reglato, Part 110.9 (b), atitded SFrauder miirepresentaioui. The subsection reads (my editing): 'No person who is a candidate for Federal office or an employee or agent of such a candidate shall - (1) Frauduleatly misreprese Chimself .., as ... acting on behalf of any other candidate ... on a mtte" which isdamaging to such other candidate."m Count UI. During the same conversation, Mr. Hutchison urged Mr. Pauken to 'talk to those guys at the NRA," saying, 'We've got to get them to get down here into this race. They need to spend some money to help us.' My U&. ~1U~ 4 to mlat e cin,Besides the NRA PAC is co.mrbtwkibern kno~wn forand msiv la~kz "Intndetexpuditrns '(Hmlnd -e.m -----$,O0 ce beheifper of uuarsper' candidates. NR.A atvte usualy indude - uulan e uid~ fdrabh nuihp, uiwiseand radio a,,w,,semm and highway billboads. By directl advising and solkting th administraor (Mr. Panken of a 'Part Committee (Un Trn Rq ia Puty) to ee "hxepmlen" exei from the NR, Mr. Hmichon and the Huechison camlsagn have violated 11 C.F.R. 109.1 regulating indepemlert exeulm . Section rad - flo s: '(a) !nepudr upada' means an expemltr by a person for a communicato expressy advocatin theton or defeat of a cll ideirile candidate whch as not made wih the coprto or with the prior comeat of, or incoumultaton with, or at the reuest or suggestin of, a candidate or any ager or authorized committe of such cauadidae.' Paragraph (b)(4) (i) defu sthis 'cooperatio" ac., as 'Any ... dieto by th candidate or his or her agern pri o the ... communicaton ... An expenditur will be pumed to be so nme when it is- (A) red Won information ulact the candidate's plato, pe or anetk prvie t the eenigpence by the candidat, or by the caddt's astom, with a visw towar having an expenitur -- 'hese activitie by the NRA would heuucefonh be onahmbd by Uh. in.kind coam~utio limits as sd~ in 109.1l(c). C Regardless of whte th NR actuall doe Mtenq to engae n" dn"exa eu C benefiting the hio candidacy i Turs, the atep by Mdr. H iw to solicit such .- expenditures by €--. -:_the caqwin's p1ans and minds Ikmg the COmir of the Turns .Prays- fur FE cto C When Ray Hutchison, the defeico campatign maager for Senator Huechism, said that "We've , had a spy over there inthe Fisher campaign since May. We know everything they're doing,' he revealed a callous disregard for both the letter and the spirit of the 'Dirty Tricku/Segrett" provisions S of the Federal Election Campaign Act. Th'is knowing, willful and ongoing conduct islikely to persist if not immediately halted through FEC action. ! request that the FEC conduct a prompt and thorough investigation into this matter, and seek all civil and criminal remedies deemed appropriate by the FEC, including but not limited to monetary damages and administrative or injunctive cease and desist orders.