FIDIRAL ELECIION COMMISSION I SI I N.W w.-%s tNG1ON.D.C. 20463

THIS IS THE END OF IfUR f I I 76S !76,3

Da.te Filmed. Camera No., 2

T Y Cameraman :zm -L 9 FEDERAL ELCTION COMKWSSION MR 1763

A

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i+w~rawjVI PjrS+ AIexalt CAiseIs kepao4 .0 49/ Sb

The above-described material" was removed from this file pursuant to the following exe.ption provided in the Freedo, of Info.mrmation Act. 5 D.S.C. Section 552(b): * 9' 4.,' (1) Classified Information (6) Personal priv Lcy

[p (2) Internal rules and (7) Investivatory practices files F (3) Exem.pted by other (8) Banking statute Informatioz (4) Trade secrets and (9) Well Informat. k~. • co-ercial or (geographic o: fnancial information geophysical) K (5) Internal Documents

.9 Signed 'N&Akf,,r" date 121w/ ? b

: C 9-21-77 4. .1 ~** BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of )) Melvin Purvis ) Melvin Purvis for U.S. Senate ) and Kerryl Lynne Henderson, ) MUR 1763 as treasurer ) Re-elect Thurmond Committee ) and its treasurer )

CERTIF ICATION

recording secretary for the CI, Marjorie W. Emmons, of Federal Election Commission executive session the Commission December 11, 1984, do hereby certify that took the following actions in MUR 1763: reason 1. Decided by a vote of 6-0 to find C:) to believe that Melvin purvis.violated 2 U.S.C. 5 432(e)(1) and take no further action. Commissioners Aikens, Elliott, Harris, McDonald, McGarry, and Reiche voted affirmatively for the decision.

2. Decided by a vote of 6-O to find reason to believe that the Melvin Purvis for U.S. Senate committee and Kerryl Lynne Henderson, as treasurer, violated 2 U.S.C. § 434(a) (2) (A) (iii) and take no further action.

Commissioners Aikens, Elliott, Harris, McDonald, McGarry, and Reiche voted affirmatively.

(continued) Federal Election Commission Page 2 Certification for MUR 1763 December 11, 1984

3. Decided by a vote of 6-0 to close the file with regard to Melvin Purvis and the Melvin Purvis for Senate committee and Kerryl Lynne Henderson, as treasurer. Commissioners Aikens, Elliott, Harris, McDonald, McGarry, and Reiche voted affirmatively.

4. Decided by a vote of 5-1 to find no reason to believe that the Re-Elect Thurmond Committee and its treasurer violated N 2 U.S.C. S 441a(a) (1)(A). €O Commissioners Aikens, Elliott, McDonald, I') McGarry, and Reiche voted affirmatively; Commissioner Harris dissented.

C 5. Decided by a vote of 6-0 to find no reason to believe that the Re-Elect Thurmond Committee and its treasurer violated 2 U.S.C. SS 441a and 441b in connection with 0 expenditures for TV time.

Commissioners Aikens, Elliott, Harris, McDonald, McGarry, and Reiche voted affirmatively.

6. Decided by a vote of 6-0 to close the Ofile as it pertains to the Re-Elect Thurmond Committee. Commissioners Aikens, Elliott, Harris, McDonald, McGarry, and Reiche voted affirmatively.

(continued) U

Page 3 Federal Election Commission Certification for XUR 1763 December 11, 1984

7. Decided by a vote of 6-0 to direct the Office of General Counsel to send appropriate letter pursuant to the actions taken this date.

Commissioners Aikens, Elliott, Harris, McDonald, McGarry, and Reiche voted affirmatively. Attest:

W. Emmons Date Marjorie Secretary of the Commission FEDERAL ELECYION COMMISSION WASHINGTON. D.C 20463

Decear er 19, 1984

Kerryl Lynne Henderson, Treasurer Melvin Purvis for U.S. Senate 801 W. Palmetto Street Florence, South Carolina 29501 Re: MUR 1763 Melvin Purvis for U.S. Senate Kerryl Lynne Henderson, as treasurer Dear Ms. Henderson: On December 11, 1984, the Commission found reason to believe that the Melvin Purvis for U.S. Senate committee and you, as treasurer, had violated 2 U.S.C. S 434(a)(2)(A)(iii), a provision of the Federal Election Campaign Act of 1971, as amended ("the Act"). However, after considering the circumstances of this matter, the Commission has determined to take no further action and close its file. The General Counsel's factual and legal analysis which formed a basis for the Commission's finding is attached for your information. The file in this matter 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 of your receipt of this letter. The Commission reminds you that the late filing of a report is a violation of the Act and steps should be taken to insure that this activity does not occur in the future. If you have any questions, please direct them to Marybeth Tarrant, the staff member assigned to this matter, at (202) 523- 4143. Sincerely,

A~e~nElliott Chairman

Enclosure General Counsel's Factual and Legal Analysis FEDERAL ELECTION COMMISSION WASHINGTON. D C. 20463 pnote 19, 1984

John Weaver, Esquire 401 South Dargan Street Florence, South Carolina 29501 Re: MUR 1763 Melvin Purvis Dear Mr. Weaver: On August 28, 1984, the Commission notified your client of a complaint alleging violations of certain sections of the Federal Election Campaign Act of 1971, as amended. The Commission, on December 11, 1984, determined that on the basis of the information in the complaint and information provided by the respondents, there is reason to believe that your client violated 2 U.S.C. S 432(e)(1). However, after considering the circumstances of this matter, the Commission has determined to take no further action and close its file. The file in this matter 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 of your receipt of this letter. If you have any questions, please call Marybeth Tarrant, the staff member assigned to this matter, at (202) 523-4143. Sincerely,

n Elliott Chairman

Enclosure First General Counsel's Report cc: Melvin Purvis FEDERAL ELECTION COMMISSION WASHINGTON, D.C. 463 ~191 1984

Jan W. Baran, Esquire Baker & Hostetler 818 Connecticut Avenue, N.W. Washington, D.C. 20032 Re: MUR 1763 Re-Elect Thurmond Committee Bristow Marchant, as treasurer Dear Mr. Baran: On August 28, 1984, the Commission notified your clients of a complaint alleging violations of certain sections of the Federal Election Campaign Act of 1971, as amended. The Commission, on December 11, 1984, determined that on the basis of the information in the complaint, there is no reason to believe that a violation of any statute within its jurisdiction has been committed by your clients. Accordingly, the Commission closed its file in this matter. This matter will become a part of the public record within 30 days. Sincerely, Charles N. Steele General Co 1

By: en A.Gros6 Associate Gene al Counsel

Enclosure First General Counsel's Report cc: Bristow Marchant, Treasurer Re-Elect Thurmond Committee The Honorable Strom Thurmond * 0

FEDERAL ELECTION COMMISSION WASHINGION, DC 20463 ct*er 19, 1984

R. H. Cunningham P.O. Box 588 7 Waccamaw Trail Pawleys Island, South Carolina 29585 Re: MUR 1763 Melvin Purvis Re-elect Thurmond Committee Bristow Marchant, as treasurer Dear Mr. Cunningham: The Federal Election Commission has reviewed the allegations of your complaint dated August 17, 1984, and determined that on the basis of the information provided in your complaint and information provided by the Respondents, there is reason to believe that Melvin Purvis violated 2 U.S.C. S 432(e)(i), a provision of the Federal Election Campaign Act of 1971, as amended, ("the Act"). In addition, the Commission found reason to believe that the Melvin Purvis for U.S. Senate Committee and Kerryl Lynne Anderson, as treasurer, violated 2 U.S.C. S 434(a)(2)(A)(iii). However, due to the circumstances of this matter, the Commission determined to take no further action with regard to these violations. Also, the Commission found no reason to believe that the Re-elect Thurmond Committee and Bristow Marchant, as treasurer, violated the Act. Accordingly, the Commission has decided to close the file in this matter. The Federal Election Campaign 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). Should additional information come to your attention which you believe establishes a violation of the Act, you may file a Letter to R. H. Cunningham Page 2

complaint pursuant to the requirements set forth in 2 U.s.c. S 437(a)(1) and 11 C.F.R. S 111.4. Sincerely, Charles N. Steel . General Counsel

." v 1I -, J !

By: Kenneth-A. Gross/ -- Associate General Counsel

Enclosure First General Counsel's Report

Nr 0

FEDERAL ELECTION COMMISSION WASHINGTON, D.C. 20463

MEMORANDUM TO: Office of the Commission Secretary FROM: Office of General Counsel DATE: December 4, 1984 SUBJECT: MUR 1763 -First General Counsel's Report

The attached is submitted as an Agenda document for the Commission Meeting of Open Session Closed Session

CIRCULATIONS DISTRIBUTION 48 Hour Tally Vote [xi Compliance Sensitive [xi [xi Non-Sensitive Audit Matters [I C] 24 Hour No Objection Litigation [I [I Sensitive [I Non-Sensitive Closed MUR [I Letters [I Information Status Sheets Sensitive [I i: J Non-Sensitive C] C I Advisory Opinions Cl Other (see distribution Other [I below) [1 V t1l11,, R EC PEDERAL ELECTION Cow 8SSOilK 1325 K Street, EW. Washington, D.C. 20463 riag e~mr.-All8 55

DIsAoAND M9 SM Jq q : M0.4 1776k,,v By OGto Vog C0N3ESS 0"!"E D~OE - CAIONI. TO

STAfl' NUIRIt ______COMPLAIHAHT'S NAME: Robert H. Cunningham RESPONDINTS NAMES: Melvin Purvis; Melvin Purvis for U.S. Senate and Kerryl Lynne Hendersont as treasurer; Re-elect Thurmond Committee and Euroy M. Sneeden, as treasurer

RELEVANT STATUTE: 2 U.S.C. SS 431(2) (A), 432(e) (1), 433(a), 434(a)(2)(A)(iii), 441a, 441b.

INTERNAL REPORTS CHECKED: Reports filed by Melvin Purvis, Melvin Purvis for U.S. Senate., Re-elect Thurmond Committee and Reagan-Bush '84 FEDERAL AGENCIES CHECKED: None SUUI ARY OF ALLUGATION

The complainant alleges that Senator Thurmond and Governor Riley may have conspired to illegally limit the scope of the U.S. Senate race in South Carolina and that certain persons conspired to manipulate the Democratic primary for the U.S. Senate so that Senator Thurmond could run in November 1984 against Melvin Purvis, a weak opponent. Although these allegations concern matters not under the jurisdiction of the Commission, the complainant does allege the following 3 violations of the Federal Election Campaign Act of 1971, as amended: 1) Melvin Purvis, South Carolina's Democratic senatorial candidate, has not filed a statement of candidacy with the Commission. 2) The Re-Ulect Thurmond Committee (OThuruond Committee") made illegal expenditures in connectiowith 's visit and a Barbara Bush reception,

3) The Thurmond Committee did not make adequate paysents for a 1/2 hour television program whioh.appeared on all the commercial stations in South Carolina.

FAC AT, AN LUGL AWYIX Pursuant to 2 U.S.C. S 431(2)[A), the term '"candidate"means

an individual who seeks nomination fr election, or election, to

federal office and an individual shall be deemed to seek

nomination for election, or election if: 1) such individual has

received contributions aggregating in excess of $5,000 or has

made expenditures aggregating in excess of $5,000 or 2). such

individual has given his or her consent to another person to

receive contributions or make expenditures on behalf of such

individual and if such person has received contributions and/or

has made such expenditures aggregating in excess of $5,000. o Pursuant to 2 U.S.C. S 432(e)(1), each candidate for federal

office is required to designate in writing a political committee

to serve as the principal campaign committee of such candidate no later than 15 days after becoming a candidate. Pursuant to cc~ 2 U.S.C. S 433(a), each authorized campaign committee is required

to file a statement of organization no later than 10 days after

designation pursuant to section 432(e)(1). Under 2 U.S.C. S 434(a)(2)(A)(iii), the treasurer of a principal campaign committee of a candidate is required to file, in any calendar year during which there is a reguarly scheduled election for such candidate is seeking election, quarteri eh Atre to be filed no later than the 15th day after the lstd01 of each calenfr qurter. with regard to the first allegation1/, on Augtut 2t, 1984, Mr. Purvis filed a statement of candidacy and the Melvin Purvis for U.S. Senate committee filed a Statement of Organization. See Attachment 1. In addition, the committee filed a July 15, 1984, Quarterly Report shoving $5,464.58 in total receipts and

$5,202.40 in total disbursements. The report covered 4/20/84 - 7/15/84. See Attachment 2. On September 10, 1984, Mr. Purvis 0 filed a response denying the allegations. See Attachment 3. As

it appears from the reports filed that Mr. Purvis had gone over the $5,000 threshold to qualify as a candidate for purposes of the Act by July 15, 1984, he was required to file his statement oD of candidacy by July 30, 1984. In light of this, the Office of the General Counsel recommends that the Commission find reason to Cbelieve that Melvin Purvis violated 2 U.S.C. S 432(e)(1). Because of the small amount of activity involved however, this Office recommends that no further action be taken. On August 28, 1984, the Melvin Purvis for U.S. Senate committee filed its July 15, 1984 Quarterly report. The report

i/ On September 17, 1984, Mr. Cunningham filed an additional letter with regard to this matter alleging that Mr. Purvis had not filed a Senate Public Disclosure Report. As this issue is not under the jurisdiction of the Commission and as Mr. Cunningham sent a copy of his letter to the U.S. Senate Select Committee on Ethics, no action need be taken. -4-

was due, on July 15, 1984.2/ In light of this, the Office of the General Counsel recommends that the Commission find reason to believe that the Melvin Purvis for U.S. Senate committee and Kerryl Lynne Henderson, as treasurer, violated 2 U.S.C. S 434(a)(2)(A)(iii).3/ However, because the activity exceeded the statutory minimum for filing by a few hundred dollars, this Office recommends that no further action be taken. With regard to the second allegation, although it is not Cvery clear what exactly the complainant is alleging, it appears cv that he may be alleging that the Thurmond Committee made excessive in-kind contributions to Reagan-Bush '84.4/ The N Thurmond Committee reports over $250,000 of expenditures in

connection with a "Reagan letter", "Reagan dinner" or "Reagan fundraiser", apparently held in 1983. See Attachment 4. It 1is not clear whether the dinner was a fundraiser, and if so, whether

Cit was solely for Senator Thurmond or a joint fundraiser for both q7

2/ Because the complaint neither named nor alleged violations of the Act by the Melvin Purvis for U.S. Senate committee and because the committee was not a registered entity at the time the complaint was filed, this Office considers the committee an internally generated respondent.

3/ The Purvis committee's statement of organization is not being considered as a late filing because the Act only requires that it be filed within 10 days of designation, which it was. 4/ Since the allegations were directed to the Thurmond Committee, Reagan-Bush '84 was not made a respondent at the time the complaint was filed and not notified as such. ~&~5

VMS- Senator Thurmond and President Reagan.!/ Reports filed by 4 Reagan-R8ush, '84 do not clearly reflect any disburse...ts.with Sregard tothis fundraiser/dinner.W A response was reoeived fros

Emory Sneeden and the Thurmond Committee (see Attachaetnt wt,..ating that the complaint does not state any violatA,&4-i*f the ~ INCA and that all the allegations are completely false, without addressing then specifically. See Attachment 5. Pursuant to 2 U.S.C. S 441a(a) (1)(A), no person shall make contributions to any candidate and his authorized political committees with respect to any election for federalroffice which, in the aggregate, exceed $1,000. Under 2 U.S.C. S 431.(11), the term Operson" includes a committee. Pursuant to 2 U.S.C. S 441a(f), a candidate or a political committee is prohibited from knowingly accepting a contribution which is in violation of the provisions of section 441a. In light of the questions raised by the Thurmond Committee's characterization in its reports regarding the apparent dinner/fundraiser which raises some questions, and because we have no other information regarding this event (the Thurmond Committee's response failed to address any of the allegations specifically), this Office recommends that the Commission find reason to believe that the Thurmond Committee and Emory Sneeden,

V There were no Requests for Additional Information from the Reports Analysis Division ("RAD") concerning this dinner. The RAD Analyst had no further information with regard to this dinner. / Reagan-Bush'84 filed a statement of organization with the Commission on October 17, 1983. as treasurer, violated 2 U.s.C. S 44a(a) (1)(A) by, making excessive contributions to Reagan-BushO84. In addition, this, Office recommends that the Commission appprove the attaohed questions. The third allegation concerns payments for TV ads which allegedly were given to the committee below the normal charge. The complainant has provided no evidence to show that the payments were inadequate. According to the Thurmond Committee's reports, the Committee made the following expenditures: Payee Purpose Date Amount Black, Manafort & Stone TV time 3/15/84 $32,500.00 Black, Manafort & Stone TV time/ 3/15/84 $37,227.06 newspaper ads Castellanos and Company TV spot- 2/28/84 $10,000.00 directing Pursuant to 2 U.S.C. S 441b(a), a corporation is prohibited from making a contribution in connection with a federal election and a political committee is prohibited from knowingly accepting such a contribution. For purposes of section 441b, the term Wcontribution" includes any direct or indirect payment, distribution, loan, advance, deposit or gift of money or any service or anything of value to any candidate or campaign committee in connection with any election for federal office. See 2 U.S.C. S 441b(b)(2). Pursuant to 11 C.F.R. S 100.7(a) (1) (iii), the term "anything of value* includes the provision of any goods or services at a charge which is less than the usual and normal charge for such goods or services. -7- The complainant has provided no evidence that the Thur-Q 4 Committee accepted either excessive in-kind contributions and/or corporate contributions by not paying the usual-m'd normal charge for television time. As the payments listed above are substantial and there is no evidence other than the allegation that indicates they were below the usual charge, the Office of the General Counsel recommends that the Commission find no reason to believe that the Thurmond Committee and Emory Sneeden, as treasurer, violated the Act with regard to expenditures for TV time.

HMO ICTIOIS 1. Find reason to believe that Melvin Purvis violated 2 U.S.C. S 432(e)(1) and take no further action. 2. Find reason to believe that the Melvin Purvis for U.S. Senate committee and Kerryl Lynne Henderson, as treasurer, violated 2 U.S.C. S 434(a)(2)(A)(iii) and take no further action. 3. Close the file with regard to Melvin Purvis and the Melvin Purvis for Senate committee and Kerryl Lynne Henderson, as treasurer. 4. Find reason to believe that the Re-Elect Thurmond Committee and Emory M. Sneeden, as treasurer, violated 2 U.S.C. S 441a(a) (1)(A). 5. Find no reason to believe that the Re-Elect Thurmond Committee and Emory M. Sneeden, as treasurer, violated 2 U.S.C. SS 441a and 441b in connection with expenditures for TV time. 6. Approve the attached questions. 7. Approve the attached letters.

Charles*3,N. Steele.

Date Kenneth A. Gr Associate General Counsel

Attachments 1. Reports filed by Melvin Purvis 2. Report filed by Melvin Purvis for U.S. Senate 3, Response filed by Melvin Purvis 4. Pages of reports filed by Thurmond Comittee o 5. Response filed by Thurmond Committee 6. Proposed questions 7. Proposed letters 8. General Counsel's Factual and Legal Analysis

CY N:I TMINNO .1w0

SC bt nS TATEMENT OF CANDIDACY. 2 ' QI 1|(4 s ..pq.t' S 60,0 kam.4isallAl|

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'. . ad 1I. Meo" & SWtof OnutddM 6/SC I lorence, SC 29501 DE8IGNATION OF PRINCIPAL CAMPAIGN C0MMITTE _ , . o .,,,,v.toq~wts qh 4hl@,i AV poolme, w my Phl CVSA C.t t oeh . MeotI Wo of ionion oocew

otlaw leswd balow. NOTETis s~get"W to lPed with th mepew

a ? ilvin Purvis for U.S. Senate

801 w. Palmetto St.

It I Coty. Sun WW ZIP OOi Florence, SC 29501 4 4b*dn .I PurvtS11WU.Sent fO DESIGNATION OF OTHER AUT1hORIZED Ct.WITTEES r lori. Iieen Ste295) NIOT: Thiau dnwtmo *laold be filed with the pirtaW MoMhW Ow"011t

bi @*W of CWmniwm fin Pul r -- NONE

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S4JUM&iRVeco SUMMARYv

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via~ to-%604 s rft4#%*r%1 I%"@ I to 1 #116" of ComIuwttes low Fwill t O~k ofYm T4 Melvin Purvis for U.S. Senaite e-iI Sol W. Palmetto St.Ir Id Ce,V. SeeniSOIap C0111, Florence, SC 29501 S TYPOI (if COMMbIrT96 Ichh oft):

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D I4ONE

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Nlte1w 'I 0 I ts Report to 1st pwWtws of 2 U.S C. *4379

P FORM 3@ we * hoIomiL. AM pro"@" sm of PIC S 32d ow -,oo- i FEC FORM 3 10I

J -j--- I I • DETAILED SUMMARY PAU& of Receipts and Oosbuobenivoti Pq 2. FEC FORM 31

040,vt cavCoIf%g the Peeled %0e#V6 GeOf tiO.q 41on PV II elvin Purvis for U. S. Senate 4 corn 4-20-84 To 7-15-84 COLUMNIA COLUMN 6 rata The vied Ciletw vYwe.-.0 I. RECEIPTS

ITRIBUT'% IONS lofvev tian SOaR,) FROM *e' *"d'votjuCII 'P,vI4 OtIer Thien POl*t oCom It ...... 1 tm-,-o Entrv Un,,emed 6 11300 . - - 1130.00 117 it.'PI1ocal Pawt c4mm i)m ...... 11(s) S Ot '. Po.tcI n...... • 4334.58 __ Cand, ale ...... 7 4334.58 4d The * 5464..58 . t ,e' TOTAL CONTRIBUTIONS Iothet ~ o1ins IaN 11lls. 11161. 1110o 5464.58 &nc114dI -.- ~*--~? . 12 12 TRA%SFERS FROM OTHER AUTHORIZE'. COMMITTEES

13 ICOA%S a lot MA or Gwaran t v te Can da"t ...... 13( 13 ib)

*¢s TOTAL LOANS 4adI 13 W &f.d13 Il ...... --I-- Its 14 OFf SETS TO OPERATING EXPENDITURES IR*u#OI. Retcoa. vtc I 1

15 OTHER RECEIPTS 0'w1mds. o..*1411. VIC .16 16 TOTAL RECEIPTS IWO It10. 12 13 1c, 14 oe 1S

It. OISSPREMENTS

,. | 4 I? OPERATING EXPENDITURES ____ 6821 .St j1 - .I 15 TRANSFERS TO OTHER AUTHORIZED COMMITTEES L

I 19 LOAN REPAYMENTS Ot Lamns M& or C0WenMd by the Candame...... b) it, OAI1w" W LW...... 19 I c,, TOTAL LOAN REPAYMENTS Wad 19 to) end 19 b)......

20 RE FUNDS OF CONTRIBUTIONS TO: to 00wwje$Pf~fda Than Pglitv.al CAMwlnu. 1b - poet, Pam'' Comm m ...... ,b Olt, P aotw Ca e"...... 30' idl

ta TOTAL CONTRIBUTION REFUNDS tadd 20 tal.20 WbI.and 20 1c)I 4520iB aS 21 OTHER DISBURSEMENTS ...... 5202.40 L 5202,40 U 22 TOTAL DISBURSEMENTS ISM 17.18.19 60i. 20 Id) "i 21)

Ill. CASI SUWAhY

23 CASrI ON 04ANO AT BEGINNING OF REP41TINGPtRIOO ...... --

24 TOTAL RECEIPTS THIS PERIOD IF',Fn L 161 ...... S _ _ 5464.58 5464.58 2a 25 SueTOTAk rAd ow 23 and Loe 241 5202.40 26 TOTAL OiSS, SEMEhTS THIS PERIOD Iream L2e 21 ...... 5 262.18 27 CA .*ON HAND AT CLOSE'Of THE REPOTING PERIOO (S6uwt Le . 1 twm' 25) S w ITEMIZED RECEIPTS O-.._- SCHIOULE A

sfw #ortethe puesin of uiNwmgw~mVweuefe .ooMe' p4'W~dfm ...9FAmup.l Of swu wo -m be am or by wy Any MoIi. sm~e sommf" lu cIftw~o from~u~'91o5 sews pePSOoffUU stem ~ s"n the ftom Ow adm of env OwW Ito melvin Purvis for U.S. Senate xrmiwd as" I "wmeOf IneWOOWa lo A"4 g I NllIn ^ ,w "...- %A Iiw. m. I ftm" **po!"m NONE m

0 OW 0 pNyI: Sonome Ml a I -ml -mnm i-I Pda. al m 6msM of 56SoVw I AMMMML Md &am& e, ywIlW "som YhM PWGW I

9 4

e"o Pgnwv OC I a OP ee ity): I~n..v w w . AW.M Omsf68 :. Pd ll. MIbq Iwm P C lum W unwomw I ay."wig %w"Th nfVw

ml a 0 boa"u~f): I~ ~W. MOMl w~md ZIP Cew heus .9 Eu~Gyee 0. FUNwn IAM. "W" of b~mlwv ev. weeD P ITu

[A~ Fwmei: a aOWN

I

PAOmipt Far: 0 ftvw 0 Gerini 0 o0 w blmotv)I: -- Y& O W 0

Ome W4900. AWW" Of ffMO pod m-. -"dpAmww ZIP ~ %of ote lo dW. wel IRemint 11 Pmftd

...... s.Iw="TA. of gt=Mw lrb pmp bm"Mo ...... 0- LCMA wtWfepp0 opat rl...... - (k) o.6urewVSMMP ofl4 t0e owDuel ITEMIZED DISBURSEMENTS SCHEDULE S

w w " ' WWq0 l ORewonoiabV for theM guh asnf we sImsWpuanU .w.a fwgh.e and eddies nyt po0l0itS 90l oV" " ...... wW WOW OmwfV 0Pun 0 Melvin Purvis for U.S. Senate

A.~y W 2 CO Wt MNO ym' Ot&4 This Porid South Larolina Democratic Party Filing Fee Street Ohaleywbmfort: UPw. Owwoe 4-27-84 $4334.58 olumbia, SC 29202 o,ewamwl: a t O Imot. Mufot an.and zinsIF Ipanw Of Diu" Pw IObs Fday. Im Cw'Uw"Ov."r Thu ftr

OplAmbwenwt tot: 0 PvyGene 0 Othe tme oy): p o~t~Ot

DidpAwt for: Oft,wy C Gasesel o)ot'w (oweftyI: Pvwoo of t

OiaW ' a: OP~bwy O ahe O Ouhew hmmt): Pumpo of ODidOW""Ut

0"b~pyanior cV'w~w OCJCn*Wa 0 Ounw 40669: O €G

, ...... T.WOTAL * P dOwnanOW 00i WO dd...... * CNIDULlC wh ftWU W I ") -pv~3=1 LOANS ft?

0o me v he~t"Iouvi s U.S e enat NOR".w of "Il

I& o A t440@ mPo o m0111 A. P.01901. oolff A ddm enz Ic Lo.

C.w~ 0end'n looms Do@ owewn

ZIP CAMds hmotIwdfovw 2 i ." to"~~.V4''q &d" 0"

C.6wn~ **:mn

1-.------4 a I 3 F~I ~I'i'~.hb~k~ w~ ZIPCad of Go wov

_mrf" CO

w uhiPY iIi~d ofwTMng I 1L vO " ~~~~~~~~S~~~~~IziLas coWlhTo V.3 m

I CIjV". .Wb"*ddf nd ZIPCfCo"ofd.fm~

......

wThwPwr~ SLJSTOTALSm~ Th mm., TOTLSI-......

.'fht ~~~~wAwWi - 3offml jL SELVIN PURVIS,JR 9 For U. S. Senate *4 1 * 801 West Palmetto Street Florence, South Carolina 29501

Mr. Kenneth A. Gross Associate General Counsel . FEDERAL ELECTION COMMISSION Re: MUR 1763 ": .- 1325 K Street, N.W. Washington, D. C. 20463 " -C.

Dear Mr. Gross: ** -' mo -" At hard I have your communication of August 28th. While I suppose there is some subtle move .among establishment politicians to undermine my candidacy, I do not think that what they're doing amounts to any violation of Federal election laws. But of course, I don't know the details of what they are up to, and really don't expect them to tell me.

However, I do absolutely deny every allegation relating to me in V" Mr. Cun- ningham's series of documents. The man obviously is not addicted to the truth, or he lives in some sort of dream world, or he may be senile, or some combination of the three. Certainly, he is malicious to refer to the tragedies in my family.

0r For example, on page 1 of his letter he claims that one Euford Godwin told him that my funds were put up by some mysterious consortium w of Republi- " cans., Mr. Godwin is a fine gentleman; and when I informed him of this, C74 he was furious. He tdld me that he'd never said any such thing, and that he was prepared, if necessary, to furnish you with an affidavit to that effect. V" Moreover, he intends to confront Mr. Cunningham, and probably already has. 00 Being underfinanced, it is not always easy foi me to obtain legal help. Yet still, I am by separate document designating my friend, John Weaver, as counsel on the matter, in hopes that his services will not be required.

And may I add parenthetically that this ki-nd of ugly nonsense is the very rea- son that more decent people don't run for public office.

Yours very sincerely,

the 5th of September, 1984 Of$ AWOW ."tMIUD RECLIPIS 6 k oil 0ii t A tq,* of I%*(e* 03

+--.. lll ii ._- - 04 0940614 $bqoldl(l-to $o% f .. lelons4191w0-e' ... *,., *el II, ... II*),lotlh 4eg4SA*D4g~l , i A.~~~~~~~~~I, ,I**' l 1440110*4* 511~Iu* Sll.te';Stoe-! , .,-s , *8I *"IIOllqilewillfI*I11e I6I 1W ,.W I.II 1" 1 A, ... k~l.Q + * . o*.,ge €OyamegII O4 It+Nl a * *e'~I~thult.+ 0++ e$ 1 4 ll * ", *1, '6- t "" ...... *,** 0*.*, ,+,*..* . eIsms lge l •* 41ht J*4ll .j *l 1944of+o01l , t hu it; Com.on ttec -Refund5 * A rp A 0 wit 140me. Me.404m A'O#SW4 ~d6 **~ of amviove lisle I ~~ &mAftvn of tct~ T i..tate Envelope of .0aryland, Inc. de ,.ot I lSotf%,. ,,, 6i)u riiqle Roc.: %efund for overp18yment3 ectsville, MD 20705 , of envelopes 1230/83 23.62

A&wVA. of aCo, . 9mM 1MOD. Mmmls Addiil 0" ZIP COO jte"O of I e Ce lineminS. O tional Reoubliran Senatorial Cam. Refund for expenses do,., m ,.,,,,*. 404 C. St. 2et, ..L 'or Reagan Dinner 4ashnqton, DC 20002 I 9/30/83 10,000.00 I DC I ______

OlftS 4WOOMv YO 4--0810-5- Coft PNOMW of fw C. F wit e.me, Mwlq A41re.nwW ZIP noaI Th ft,-ad

m I | I

t Pot Gaea.'A63 a 0 9W a" ." I ~ffW@I ~ 0. ire IO "AA" A"e e" Z 0 Ceft It" of 10106111Vol f 1'4 sPW6,

Oi iO

PWI'CDt 0:0 - Ge'.'.

W9~S~ Igp~aPwI I~ I.~w I-'-I-- -Ye.W~WY ~I Oft"I4w.@e 00 1"WOMW Iw.Pv hem,. md Aid . a" ZIP C41t iw. w F Tka Poe$

11lecm Fo 0 Pvgway - .. Ge'.' ~ZL ' vw44o-.5- -I 03 U.~ m f - -I Meme .9 ~ffI~W I ~ F. Fwi tf4.. Md*mu Aim* - ZIP Cede kvtOf Effa"WOV D.U 1-mmeft qWOW4 of tolllld d@V. vQW)

a111c.o. Fo 0 P wv a Ge~4o ______l O"w0 4.v1 ~,m. vw...~...S ______I -l Oe i0 G.P-AUl 06~. Mod"e )--do oraAVdf P e o S ON. YlneTI Slld

tq -+. ....al Ow"41)Ckfw om0 Dptrev Ye4*-$ *. e° "e I mew..° TOAL.Yh° P°...... lR mq WeOIi 7'Yw'V 1 . J10,523.42 IOTALT ofiPe d £1 Th e h O - ...... 1,236 I il"MOme49~ ~ ~ O ~ ~ . ~a ~mc4WLT . 0

0 0 , L2" . . I St#01 1-LE B I I EMIZED jj1S(j1j1ASEW.L%1N .,, .1

OW4t.04 Oufp t.gfit" MomAtfisF610 AV and dbo of GOl 0041C6 Combo"41190 o 0000 #11 teblA 0%440 O61

-- U~~ttt Re-Elect Thurmond Couiittee / 3 Y69 ' J

of~ to A 9l96haf e Me '01 &AkUM -1111OP CONs NPOpe of9G~.V% 0...- Keenan and Brinkley. Inc. ,*. .vmni.., 1310 Lady Street Ren for Jul 7/7/83 S200.0j Columbia, SC 29201 IOs~WWA01 IV XP.woVt * ..

Diversified Mailing Services o 'eaa olovs /777 Leesburg Pike letter in June 7/7/83 , 7,898.75

Iffin14%. *49wftl o ES&' C owl' NO-sf Mdq £os OW ZIP CO IP111111 of Oswew'w9- *%IDa The Viguerie Company Reagan letter mailout "V. V, O-w o"" To%*%ftr 7777 Leesburg Pike 'pkg/list rental 7/78 1,19 Falls Church, VA 22043 @ -lnw Bftovwv ______

0. Full lkial. M9q &MSM 0- ZV Caboeol1111100 111 wor% ANAIO S $0~16577pno United Envelope Corporation Printing of envelopes 4w WW 102 ShiW-fid 1 // 1S7 Sterling, Virginia 22170 tow *PWw O0gWge

envltrhd fr mailin 7/7/8 On3,14b.14%-jftg 011OU t I Carolina Republican Party tlb1 Post office Box 5247 ev'tth.frmiig7/8 Colubias SC 29250 0 6110111:100w_ _11111101 o g Ft. Fal ftse. -~h"d OW Z Ce"O Wn.dsW Directech.s InC y6n mue w W 111O--oT*fn 11600 Riebel 'Street ,tape for Thurond Donors 778 9. CRockvilless 10 20852 0~0S~ 5P,.wfwy O 77/8OS9WO

o OA lw wl, ______oot_"ef ot.VITof" cc Smith Lithograph Corporation 01"ter torm coded 1029 East Gude Drive for mailing. //3$,41 Rockville. ND 20850 N vww C 7//83$2,84.1

Mr. Jon L"AnTravel Expense 7/7/83 01WI111410

St.~ SC~ ~ 2913 pwtes

S.WTA4.' e ~ YWP......

mVOAL MeiOw~ OW0 O WwsofI...... -m "4 0. '1 oft# 34 0. t ITEMIZED DISSUASEMENTS LU WS1WM sW..qIl ScHF UUL* 8 twwos x~I

Awy ~ smi~ hfWR ws ~me~s - Smemmern ~sy ~g W by v'v PW 6*' t'W ~.Sue .9 ~u~q ~ w ,~, ini~ .5 LAP ebuseAs 4u.~ wgh opmm.,mw £~u.6I ~ .me . em.Aa g6mem~s wi eii'ea.9 mu Meiu~ s~flm ~ I Re-Elect Thurmnond Committee /tg3 Yg*4 asivb C A. PU 60w~IS MAde oW Z9 Cei PWNW of asseu. ~V% Of F*oesq. Post Office Box 38400 travel expense Louisville, KY 4023348400 ~ , p~,Omwi918 185

- I

6West Lake Road Salarywo 9/1/83 1271.55 Coluffbia, S.C. 29204a

*wow .5 Goo I C. F~d-Aftm UW m W"-i IVco Puom of@1 0uwmt~ ams 10"NOW0. John Morman Travel Expense ~" SMI~~ ~ e 1743 Roslyn Drive 0.'iinwo*1w. 1Pv4'w owsww 9/1/83 $205.00 Colunfbia, S.C, 29206 a 0110wIM411l: _____ Afis, ofGo 0. P-A 111101 U--t *AUn 41" G0111cV 0 1WW am OwN Judy Ott Expenses is". VWw 0~s' 'Tow 0111 257 414 Old Plantation Drive ~OgwI918 2S7 West Colubia. S.C. 29169 00Mhwv1 1~1918 M w"u 9. iw t~. Nat M=wW Z Caft 0wow Of 060"ot 0Mw Diretithgrahero. Mil nc, computer form5 for Reaga ft. ,m"I lw Rec Mai46c Lihorahes letter and pre-printed frus 3 $503 Prince Frederick, Md 20678 -- SwAfo"ao 98 n Dam.9Ofam F.oUa.P. MWO *AMd tv coo PWM of DiwwsDO O. Diversified Mailing Services shipout photocards for or.'~WI0 1ow" 11* PW"~ /88 1035 Post Office Box 537 W4j3400~ $0.5 Waldorf, Maryland 20601 N -MOW 1 "wv0Ga@1983 of E0 G.0 oe. Mof AdMW mW* Caft ft"9 -1 "Won-. W o - W-74f" Tri-State Envelope Corp. of MD window envelopes and dW 6900 Faigle Abad hutaLs- X'l*nVl1~ Blsil.Md 20705 w.'wfe: splm D§AN 9/8/83 11108."

of. IKU It. Fid 16M, Ndfi A~ s ZIF Cef PWw. of a *o The ViguenieCompanycomputer services for ,, ~ Im Reagan letter,tape work 7777 Leesburg Pike $387 Falls Church. Va 22043 w:o., VPubwv Gan w 9/8/83 a 01'mw 10601w):

Mark Ruilova Expnse VWywl Tut-" J-35 Broawre Apts.e 1:i'aigy 988983 1600100 Weost Columbiso S.C. 29169

WOIMAL G#I Tf po wa...... _____

""AL ftft & INV 06 Wo - *...... 3t~P @5 0 *'.* '.jI.teqm 0 4

SCHEO)ULE B ITEMIZEO 01SSUREMENTS Ej t*.q £~ * Pet,.

e Amp~~cp honm..e%$mg 04010gge4 SMw40%.O ft" Wg" Istemd Ow &AV Posen I, 040 O Of.sdg6Rs~~e*s*e COMM M..atesa .hfi ofas ~ Um Ow amoe ei*.M eq any 0401O geowno to soft of £@A9ftSow town unit

Re-Elect Thurmond Comittee /7M e* &J 0 Ew1m'. **-uWo" of E" Pum "W~p bbA*" *&M aw PZPCf MWOi American Mailing Lists Corporation ailing list for' Reagan INV. vw' OdewumW"I Tme e" 7777 Leesburg Pike 'mm...., FalsChurch, V44 22043 a cw'' 3P"urir1: ~ w 9//8 toleft .~ *0001"ofim 6* Pon %wa. M"&Wm0"z UMo ONOZPC.W Do". Tod 'Lafn Reagan Dinner Expenses ft.wWI 0.wwv The, %...d Coluwn-bia, SC 29202 01900"Wt@t 1fe wr v 00m.*s 9/21/83 $75.oo0 f

ofumEach~ C. luNA %o.q -oW rca P..gs. of~ h 0gw bf.siih. Smith Lithograph Corporation for COfRTC-693 and RTC ftV.~ O"VIm..trow~e 1029 East Gude Drive 7S Rockville, MD 20850 a 4009/9/83300M $2645.94

o. pod NNO. OWN - - cam PW"= of 911M~ lowgs6.f of IS 1PGreg DeLoach- Salary'*i '" s. Apt. 1 1606 Heyward Street Coiwibia, S.C. 29205 I~'eftv 0G."we 9/8/83 $613.06 0 ow 1 IVdI.______08" 4"W"A. %*t let 180 i. P4 .m Waift Ol-A1M : CM P...M of ONMwW IN Carl.Bennett Reagan Dinner Expense 41M WIw %00h4"~L'.

C g'mwo 9/22/83 M0 Colubia, SC 29202 Owwwm.W ftI *PwwY0 AMPNW of a* V P. Piew.m w& Ao ad t Go Pse at ONW mm ONka41lO. OOW"" %rowns 4r. Janie Bennett Reagan Dinner Expense 'r.'Wo P0 Box 393 fr Pw Ow 92/3 $75.00 Columbia, SC 29202 b" fwfj,.w 0gvl9228

Republican National Committee deposit for Reagan's vis' t~'*''"" w The"P% 404 CStreet, NE th sg: ~ig9158 2,0' DO~ Washington, OC 2002M Chm ---- : ______MO/I/3 M9000

Internal Revenue Service Federal and FICA Taxes o.'~vow I t Te f" Georgia 1 a XMi Atlanta, - IFWWT- -- or GWPO 9/15/83 $761.67

1.UAw~ii. M" aw a Y'U nae- ihe d8 fes,. "o gt Ur Carolina Tax Conission at TiwTYheIdam South 9/15/83 $115.66 Colu~a sU.nd o..

SIArOTAL of M~ hpOWPft ......

oUVLlm w ...... QL3) Wo **eK9Le* ITEMIZED Oist5R~MNle

Wff 01$0n too I%@bwooI~ w w O DowIto%$. 4 W fmW ~ ~U" IS of W0W 4I 10,@oaf * U ~ * ~~I~~~Pe. A 0so

bIIi R - lect ThurmOnd Comwitte 1 3 6tFImnt. &ewas of, .act A, "i hekod fte" Aowtowarft NwofDes,

Markoadmoe Exptnse

O"bWneqV 9/15/8ef3 $19-00 155 Hradden S Arets

ieColu bi S.C. 294 00I180) m I 9. *~*nt of Eeco .e eee i De tw -f OW- air W coo C 64000N 4d~ depogsrite o Southernsutn Corloratioional 202are Sre Ext 4-Mtw OremV 9/15/83 $11822.1 Coua.ntnS.C. 200020 &"a ofoat Df~0 t01 " N CG o l e . PFV fto mst" a w * A ~ i n i t Reeaganedinefr xpens''"Ti Sotrn Benet $3009.OO, Coibia S.C 290 W4 GV92/3 9/13ooe/vv S.C. Colubiat, hffmm 0@Ed ~@ 0w40"44. Cot~ . ~ t

el 9/2/83 $75.00 Pst Offie oxd 39 isn" Wu~V0 Co Coubia, S.C. 29202 -'w Exene eOft" Heart0MUNOof Coh bi ReaganweDine

7 a101M,DIP4101 Atn services-fo Copoato POYA Cnting tsoa4Pu epne

1182.1 ow-WWv oon" 9/1583 202 N Steet, w W- .. -- C Wa hi gt n, DC~: 2000 * ~ !

'~~4 ~ U' ~.%@ t.gM~~ 9 9 ~ t ~j.. ~a..w m .w a SCHEDULE 8 ITEMIZED DISBURSEMENTS hwftW~q.~ 9~.

ARV ;;:,Ino =W 6#60 j0A ow owbe 0 r "admtv oWft4WI ow wwa.WI 6st"I ftiw I # o of Com o O Re -El e c t Thu r ond Co mit te e / 9 1 3 Y6 4 9-bo

o" n awIf *m c Ahi of Onenift'iP ** of 980 Dinner Expense f w Ii Carolina Inn Reagan 937 Assecbly Street o,, q.w:, oo.,w 9/22/83 $141.34 Coluiat, S.C. a OW 6______: L. 0%4 ton W~f 2VZed i- eqN cm-(on"" - of 0hP Carolina Inn Reagan Dinner Expense fty. o mw nTa 937 Assembly Street [ Columbia$ S.C. "o -:Pwv o. 9/22/83 $122.84

C. P ~,,, ~ -* Wd. Cm hism-e O imw , Ou t.m. .,, , The Elite Restaurant Reagan Dinner Expense on. " ownwm Th W.,d 1736 Main Street WNWON/ 81 . Columbia. S.C. ow:Jpnwv o m 9/22/83 $153.0 Cb U. p Nom w AddSk Ct e m -o4aes Exxon Company. U.S.A. Travel Expense OW. Y=" I M@n*1WW 2519 Devine Street -- 9/22/83 $90.81 --- ft. af o Columtia, S.C. 0oa 108"11a~: a. " NW101 "son #AM= aw zr, aeft 616001W am~m-C 1"n 0000104, O,,f6,,,, invitations, envelopes, .,-1, m -. Dependable Printing. Inc. response cards-Reagan f d Fow.707 Montgomery Street . Wftrp" 'd u' 9/22/83 $2396. Alexandria, VA 22314 60000: ______

Jams Dean typesetting. pastlng.la Ij %W. o 0 The 714 Avenue. S.E. invitaOns-Raea n fund iser Washington, D.C. ZO05 oww.opila XoW01 9/22/83 S344.0:] Dom si : _ __._.___ --.-

Invitations and envelo .v.w' tehii ,n Robey Graphics for Reapn Fund Raiser 1339 Pennsylvania Avenue, SE % 5. 9/22/83 $104.4 1 Washington, D.C. 20003 oa m~t: _ _ _ __ Pd~~or~w eO~ awww"N The/dtef udm Goodwin Buick-ANCoInc. auto lease for w. of t.*w 2600 Broad Street. Ext. Post Office Box 758 dhtwwr o 9/22/83 $364.00 Sumter. S.C. 291S1-0758EEN. Directech, Inc.~ 11600 Nebel Street data entX Thu d Rockville, HD 208S2 ow pmw Dawm 9/22/83 $255.61

l~rA do P 0nn 0 p in gJ o ......

tTMAL fThkwe a apm 6ft WW0*1...... 0 rep 49.111 4.141eL cS64EDULE a ITIEMIZED DISBURSEMENTS Iwon e1p4's 'm So ""W Vow.,PS0,..

A~~~o IWO ow W d " 4- "N" to """wo 0W*es~~ ebe tV~

-Cemf lb dI Re-Elect Thurmond Committee /7 3 )W44_eAMb @worm ~ so On.. 4. Ms oAY0 oPwf, NO afit .."s me Wsotevak ...... Keenan and Srinkleys Inc. rent for October ad am. om The ow 1310 Lady Street rent___rOctober __d Columbia. S.C 29201 omIw:44' ovavuw 9/27/83 $305.00

L, PO Non adP be am bwwao ofuS ~s I~ Dependable Printing, Inc. -CWqpsm.I %U0WWW W 707 Montgomery Drive r 19/27/83 Alexandria. VA 22341 a 40*1 C. a W I aw a&owbe m I be t . The Viguerie Comany 1st rental and/or mili g d o,.,, W'T "" 7777 Leesburg Pike $*mgt o*MWO- 1/27/83 $2324.86 Falls Church, Va. 22043 o ftl- IL M-ft W be be ovwf Wf fU com ,0. 1rtwn9 National Republican Senatorial 7S mt e of uter 9/27/83 $60.00 F't fthmm& 4 ,qm1 , oi 9/27/83 560.00 404Stanton j Street, Square Office. o1 ,Townhouses Wi~hngnn e 00w I69=00: "_ M Nom NO Ad WV be& pwron165" 0M~mb eaf A o o Carolyn Evans Expenses for reception ,. ~1 T.. J 3S09 Devine Street-- I_ Columbia, SC 2920S -. M: aa.cw 9/29/83 $50.30

in d1d, In o sd South Carolina State Fair ~ gd~ro.Oak H e-" Pst Office Box 393 meyecmi an. extrbies Columbia. S.C. 29202 r-, 9/29/83 57071.65

3eanie Dellinger reimbursemnt for guest aw.vud 0iWhMbTb Manor Dr., Apt. N register and desk trays 18 Crin11 $3S.34 Columbia, SC 29210 She owm,.Io: 9/29/83

, Columbia Tent and Awning Coqpany Mnt rentals for Reagan*, "w., 1314 Rose ood Drive M umm fn It h o",,, 9/29/83 $837.20 Columbla S.C. a o0W 6000: . M M 016 *A& = O Zrm=..09, i for .wi in am , s NW W t W 0 Comosition System, Inc. for ling '. 0 Thb I011 Arlington Blvd., Suite V141 __,___t_____,______Arlington, Va 22209 1: 9/29/83 12750

m ti J M d 8 Vp 1......

...... 006.1 kiWW"*(S _ SC14EDULE B ITEMIZED DISBURSEMENTS LuMO.#p 0

&AV IRIOW414 w" bwot ~NP..now V' m~~ Ww wy 6e 6eIV Oft fw.'g ee~.wet or lwe

ftrro $"e lif PC ulRe-Elect Thurmond Co wvittee /18 3 Y e g & N b 11

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1555 Harden Street Ext. Sill/8fSamnh fSp. m ~ et~~~e Columbia, SC 29201 OGOWe ~ 1058 $85

Te Sta .m ~ ThePn P0 Box 6095 lorintino of stationary 10/5/83 $254.10 North Augusta, SC 29641 P~wvc

Keenan and Brinkley, Inc. OWVW -ww_ 1-11 Two Pwad 1310 Lady Street Additiona Insurance Cov. 1//3 $~0 Columbia, SC .29201 fo 10s8 S1000 ______o w b"011:______6.0. O ftw Ndb and 29* qr 01st abeme m . ftlSef too a, Cashion Electricians, Inc &ar & material for l ight ngoi.vudw 100-007~~ 3415~a~st..tfor Reagan Di nner 10/5/83 $40.001 Columbia, SC 29201 OPbeft N. @.5 %Noo ft &A* a" aw Gco WP f NUEM m be ". mow O Ls Sound Systs, Supply Co. nstall lights 6 sound, a.,.r' Owwflw The ft""u 3138 Carlisle Street 2erate & v for Reao Dinner Coubia, SC 2920 fo. Sowwv OGw 10/5/83 3950

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Reag n Digr 10/13/83 62. Rosewood Florit / C 2824 Rosewoo Drive R1 Columbia, SC 29205 00' ~ ~~ ,, Of &L V. 10 . . Z.3W e-AW, Mid-Town Kvik-Kopy copies of miaterial for oh3mwUS1S'..1 1204 Sumter Street -a-_an ninner 10/13/83 $4.13 Colw~ia, SC .29201 a CkWw 00MW1 ,, e, G. Oe %No .W *W C, Om ow ,,t. The Viguerie CMoMny list rental and/or me 11 0/.3/ o792 4.4 7777 Leesburg Pike fs for mil.ot 10/13/83 $7,84.47 Falls Church, VA 22043 ea s: P o0 0Oe0M i"MVI:______

Mark Ruilova 10/13/83 $145.75 6-35 Sroadre APts. om West colabia, SC 291692 o 6 Gu w: ):_____P

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po a 0, V, o,@,,6'. ' a 6. Po aem,. a ZIP €,Gedea P @6 Greg DeLoach 10/19/9 3 S " "' 1601 Heyward St. Apt. 1 Salry 10/19/83 $441.4S Columbias SC 29205 W: .v oa,,,,. a 00 16y5Ov:_____

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awftM...... 10*677.76 ,MAL ~~ ~ - ...~ ~ %01PWWN"-110111Flo~~ ~ ~ ~ ~ ~ i September 12, 1984 71 -o" :.--.-,

Honorable Kenneth A. Gross Associate General Counsel . Federal Election Commission z Washington, D C. 20463 C=. Dear Mr. Gross: I have received your letter dated August 28, 1984, ,with its attached copy of a Complaint filed by Mr. R. H. Cunningham and referenced MUR 1763. This letter is my response to Mr. Cunningham' s allegations. First, neither of the Complaint's two principal allegations, nor any of his other various allegations, whether considered individually or collectively, state any colorable violation of Federal election law (or any election law of which I am aware). Second, even if any of the allegations made by Mr. Cunningham might be considered relevant under Federal election law, all of his allegations are completely false and totally without any basis.

Because Mr. Cunningham makes charges which unjustly name completely innocent third parties. I would like to reserve the right to make his allegations and my response public at a later date, in case any of his charges should be made public. Thank you for allowing me to respond to this matter and to demonstrate why no action should be taken against the Re-elect Thurmond Committee, or me as Treasurer, in connection with this matter. Accordingly, I request that the Commission close the file on this Complaint by Mr. Cunningham. Sincerely,

Emory M. Sneeden Treasurer Re-elect Thurmond Committee

Enclosure

4cAedil 5 0

MUR 1763 Emory Sneeden

QUESTIONS On its 1983 Year End Report, the Re-Elect Thurmond Committee reports thousands of dollars of expenditures in connection.with a "Reagan letter", "Reagan dinner", or *Reagan fundraiser." Pertaini ng to this fact, please answer the following:

1. Please explain what was meant by the "Reagan letter." 2. Please explain what was meant by the "Reagan dinner." 3. Please explain what was meant by "Reagan fundraiser." cr 4. State whether the "Reagan dinner" and the "Reagan fundraiser" were the same event. CV4 a. If so, state the date on which the event was held. b. If not, state on what dates the two events 0 were held. IT 5. State whether the "Reagan fundraiser" was a fundraiser solely for President Reagan. CD a. If so, please state what costs associated with the fundraiser were paid for by Reagan- Bush '84. b. If so, please state how much money was raised for Reagan-Bush '84. c. If not, please state why the event was described as a "Reagan fundraiser." 6. State whether the "Reagan fundraiser" was a joint fundraiser for both President Reagan and Senator Thurmond. a. If so, please state what costs associated with the fundraiser were paid for by Reagan- Bush '84. b. If so, please state how much money was raised for the Re-Elect Thurmond Committee. c. If so, please state how much money was raised for Reagan-Bush '84. d. If not, please state why the event was described as a "Reagan fundraiser." rnkJ0VeV~f40( 7. State whether the "Reagan fundraiser" was solely a fundraiser for Senator Thurmond. If so* state whether President Reagan appeared at the fundraiser. 8. State whether the "Reagan letter" solicited contributions for President Reagan* 9. State whether the "Reagan letter" advocateed the re- election of President Reagan. 10. Please furnish a copy of the "Reagan letter."

CMJ

N~

0% 0* 0

FEDERAL ELECTION COMMISSION WASHINCTON, D C.20463

John Weaver, Esquire 401 South Dargan Street Florence, South Carolina 29501 Re: MUR 1763 Melvin Purvis Dear Mr. Weaver: On August 28, 1984, the Commission notified your client of a complaint alleging violations of certain sections of the Federal Election Campaign Act of 1971, as amended.

The Commission, on December , 1984, determined that on the basis of the information in the complaint and information CM provided by the respondents, there is reason to believe that your client violated 2 U.S.C. S 432(e)(1). However, after considering 0%, the circumstances of this matter, the Commission has determined to take no further action. The file will be made part of the public record within 30 days after this matter has been closed o with respect to all other respondents involved. Should you wish to submit any materials to appear on the public record, please do so wi-thin 10 days of your receipt of this letter (C, The confidentiality provisions of 2 U.S.Co SS 437g(a) (4)(B) V" closed.and 437g(a) The (12) Commission (A) remain will in notify effect youuntil when the the entire entire matter file hasis CO been closed. If you have any questions, please call Maybeth Tarrant, the staff member assigned to this matter, at (202) 523-4143. Sincerely,

cc: Melvin Purvis FEDERAL ELECTION COMMISSION WASHINGTON. D C 20463

Kerryl Lynne Henderson, Treasurer Melvin Purvis for U.S. Senate 801 W. Palmetto Street Florence, South Carolina 29501 Re: MUR 1763 Melvin Purvis for U.S. Senate Kerryl Lynne Henderson, as treasurer Dear Ms. Henderson: cOn December , 1984, the Commission found reason to believe that the Melvin Purvis for U.S. Senate committee and you, as treasurer, had violated 2 U.S.C. S 434(a)(2)(A)(iii), a provision 04 of the Federal Election Campaign Act of 1971, as amended ("the Act"). However, after considering the circumstances of this matter, the Commission has determined to take no further action and close its file. The General Counsel's factual and legal analysis which formed a basis for the Commission's finding is attached for your information. The file will be made part of the public record within 30 days after this matter has been closed with respect to all other , respondents involved. Should you wish to submit any materials to appear on the public record, please do so within 10 days of your receipt of this letter.

The confidentiality provisions of 2 U.S.C. 55 437g(a) (4)(B) and 437g(a) (12) (A) remain in effect until the entire matter is closed. The Commission will notify you when the entire file has been closed. The Commission reminds you that the late filing of a report is a violation of the Act and immediate steps should be taken to insure that this activity does not occur in the future. Letter to Kerryl Lynne Henderson, Treasurer Page Two

If you have any questions, please direct them to Marybeth Tarrant, the staff member assigned to this matter, at (202) 523- 4143.

Sincerely,

Enclosure General Counsel's Factual and Legal Analysis

! 0 FEDERAL ELECTION COMMISSION WASHINCTON, DC 20463

Jan W. Baran, Esquire Baker & Hostetler 818 Connecticut Avenue, N.W. Washington, D.C. 20032e RE: MUR 1763 Re-Elect Thurmond Committee Emory Sneeden, as treasurer Dear Mr. Baran: The Federal Election Commission notified your clients on t August 28, 1984, of a complaint alleging violations of certain sections of the Federal Election Campaign Act of 1971, as amended ("the Act"). A copy of the complaint was forwarded to your * clients at that time.

Upon further review of the allegations contained in the complaint, and information supplied by your clients, the Y Commission, on December , 1984, determined that there is reason to believe that your clients have violated 2 U.S.C. S 441a(a) (1)(A), a provision of the Act. Specifically, it Co appears that the Re-Elect Thurmond Committee and Emory Sneeden, as treasurer, made excessive contributions to Reagan-Bush '84. In addition, the Commission found no reason to believe that the Thurmond Committee and Emory Sneeden, as treasurer, violated 2 U.S.C. SS 441a and 441b in connection with expenditures for TV V time. Your client's response to the Commission's initial notification of this complaint did not provide complete information regarding the matters in question. Please submit answers to the enclosed questions within 10 days of receipt of this letter. Statements should be submitted under oath.

The Office of General Counsel would like to settle this matter through conciliation prior to a finding of probable cause. However, in the absence of any information which demonstrates that no further action should be taken against your clients, the Office of General Counsel must proceed to the next compliance stage as noted on page 2, paragraph 2, of the enclosed procedures. Letter to Jan W. Baran, Esquire Page Two

This matter will remain confidential in accordance with. 2 U.S.C. SS 437g(a)(4)(B) and 437g(a)(12)(A) unless you notify the Commission in writing that you wish the matter to be made public. If you have any questions, please contact Marybeth Tarrant, the staff member assigned to this matter, at (202) 523-4143. Sincerely,

Enclosure Procedures

cc: Emory Sneeden, Treasurer Re-Elect Thurmond Committee

CD FEDERAL ELECTION COMMISSION GENERAL COUNSEL'S FACTUAL AND LEGAL ANALYSIS

DATE MUR NO. 1763 STAFF MEMBER Marybeth Tarrant (202) 523-4143 RESPONDENTS: Melvin PurVis for U.S. Senate Kerryl Lynne Henderson, as treasurer SOURCE OF IMtUR: Complaint (Respondent Internally Generated) SUMMARY OF ALLEGATIONS

Based on information filed in response to a complaint (see attached) and reports filed by the Respondents, it is alleged that the Melvin Purvis for U.S. Senate committee (the

"Committee") and Kerryl Lynne Henderson, as treasurer, violated 2 U.S.C. S 434(a) (2) (A)(iii) by failing to timely file the 1984 July Quarterly Report. 0

FACTUAL BASIS AND LEGAL ANALYSIS Pursuant to 2 U.S.C. S 431(2)(A), the term "candidate" means

o an individual who seeks nomination for election, or election, to federal office and an individual shall be deemed to seek

nomination for election, or election if: 1) such individual has received contributions aggregating in excess of $5,000 or has made expenditures aggregating in excess of $5,000; 2) such individual has given his or her consent to another person to receive contributions or make expenditures on behalf of such individual and if such person has received contributions and/or has made such expenditures aggregating in excess of $5,000. -2- Pursuant to 2 U.S.C. S 432(e)(1), each candidate for federal office is required to designate in writing a political committee to serve as the principal campaign committee of such candidate no later than 15 days after becoming a candidate. Pursuant to 2 U.S.C. S 433(a), each authorized campaign committee is required to file a statement of organization no later than 10 days after designation pursuant to section 432(e)(1). Under 2 U.S.C. s 434(a)(2)(A)(iii), the treasurer of a principal campaign committee of a candidate is required to file, in any calendar year during which there is a regularly scheduled election for which such candidate is seeking election, quarterly reports which are to filed no later than the 15th day after the last day of each calendar quarter. On August 28, 1984, Mr. Purvis filed a statement of r candidacy and the Melvin Purvis for U.S. Senate committee filed a r' Statement of Organization. In addition, the Committee filed a July 15, 1984, Quarterly Report showing $5,464.58 in total receipts and $5,202.40 in total disbursements. The report covered 4/20/84 - 7/15/84. As the Committee did not file the July 15, 1984, Quarterly Report, which was due July 15, 1984, until August 28, 1984, the Office of the General Counsel recommends that the Commission find reason to believe that the Committee and Kerryl Lynne Henderson, as treasurer, violated 2 U.S.C. S 434(a)(2)(A)(iii). However, due to the circumstances of this matter, this Office recommends that no further action be taken. Attachment Complaint 0* V.•

FEDERAL ELECTION COMMISSION WASHINGTON. D.C. 20463

September 24, 1984

Robert H. Cunningham P.O. Box 588 Pawleys Island, South Carolina 29585 Re: MUR 1763 Dear Mr. Cunningham: This is to acknowledge the receipt of the supplemental material relating to your August 17, 1984, complaint. The material has been given to the staff person handling that matter. If you have ahy questions, please contact Marybeth Tarrant at (202) 523-4143. Sincerely, Charles N. Steele General Counsel

C

Associate Genera ounsel AT TI*

/ ) S I1 eAl ctI. cuntningfan

,AoI ., 7-I* Sep't. j4, 1984

Kenneth A. Gross UP?! Associate General Counsel # ~ -f r Federal Election Com.mission Washington, D.C. 20463 tY,'

Dear Mr. Gross:

Reference my sworn statement of Aug. 17, 1984

In checking with the Senate Ethics Cointttee yesterday I learned that Melvin Purvis had not filed his Senate Public Disclosure Report. As a result of Corittee intervention yesterday, the report apparently is now on the way. But the question remains whether Purvis naively or deliberately contravened Federal law.

Purvis had told me on June 21 that he had no knowledge of the Senate report or that it-was required to be filed 7 days before the Primary -- see (3) of my Aug. 17 letter.

A lawyer for the Senate Ethics Committee named Wilson (first name, I believe), telephoned me yesterday afternoon and advised the Senate Ethics Com ittee forms and instructions had been sent to Purvis the day after the Primary, which would have been June 13. Therefore, either Purvis had not received the forms eight days later, or was lying.

Considering his failure to meet FEC requirements, including filing a pre- Primary report on Aug. 28, I suspect he deliberately avoided compliance.

There is considerable urgency in resolving the matter since Purvis' name should not be placed on the S.C. ballot unless he has met all required financial disclosures. The latest episode reinforces my belief that Purvis probably was involved in a conspiracy to deny the Democratic nomination to his opponent.

1 tincrerel cc: S.C. State Election Commission PO Box 5987 S)RN to before me s 14th. day of Columbia, SC 29250 Septemb 1984(SEA U.S. Senate Select Com ittee on Ethics Notary Public for South Carolina Washington, D.C. 20510 My commission expires 6/10/90 SALI,AIAYS

zAn _AT 2 P 4

:;q., 6nning/iam

7 l~ccamaw 9hair 4 ,~'ffifnJS C. zqs'&5

C-0 Kenneth A. Gross -r. Associate General Counsel coo,,, Federal Election Coaission Washington, D.C. 20463 ' 0l 0el 9E September 12, 1984 C

Honorable Kenneth A. Gross Associate General Counsel Federal Election Commission Washington, D. C. 20463 CZ Dear Mr. Gross: I have received your letter dated August 28, 1984, %with its attached copy of a Complaint filed by Mr. R. H. Cunningham and referenced MUR 1763. This letter is my response to Mr. Cunningham's allegations. First, neither of the Complaint's two principal allegations, nor any of his other various allegations, whether considered individually or collectively, state any colorable violation of Federal election law (or any election law of which I am aware). Second, even if any of the allegations made by Mr. Cunningham might be considered relevant under Federal election law, all of his allegations are completely false and totally without any basis. Because Mr. Cunningham makes charges which unjustly name completely innocent third parties, I would like to reserve the right to make his allegations and my response public at a later date, in case any of his charges should be made public. Thank you for allowing me to respond to this matter and to demonstrate why no action should be taken against the Re-elect Thurmond Committee, or me as Treasurer, in connection with this matter. Accordingly, I request that the Commission close the file on this Complaint by Mr. Cunningham. Sincerely,

Emory M. Sneeden Treasurer Re-elect Thurmond Committee

Enclosure STTOCTO DESIGNATIONW 0?qds

MUR h A 0? COUNSEL: Jan W. Baran, Esq. ADDR.SSB: . Baker & Hostetler rr- 818 Connecticut Avenue, N.W. Washington, D. C. 20032 as

TZL BONE:

The above-named individual ii heZeby designated as my

counsel and is authorized to receive any notifica&ions and other

coWir,cations from the Comiission and tc act on my behalf before

the Co-mmission.

Signatu -

RZSPO!ND- T 'S N2- : Emory M. Sneeden, Treasurer

ADzR) S : Re-elect Thurmond Committee

Post Office Box 7745

Columbia, South Carolina 29202

EO 2 PEOI-: (803) 776-9394 (803) 799-9800 BUSIIMSS PBON: M--

~'vj.

The Honorable Kenneth A. Gross Associate General Counsel Federal Election Commission Washington, D.C. 20463 (1325 K Street, N.W.) MALVIN PURVIiJR %tb(Z * * * * * ,,,,NU. S. Set. 801 West Palmetto Street Florence, South Carolina 29501

Mr, Kenneth A. Gross F, Associate General Counsel FE6P RAL ELECTION COMMISSION Re: MUR 1763 0. 1325 K Street, N.W."T Washington, D. C. 20463 "

Dear Mr. Gross:

At hand I have your communication of August 28th.

While I suppose there is some subtle move among establishment politicians to undermine my candidacy, I do not think that what they're doing amounts to any violation of Federal election laws. But of course, I don't know the C1_ details of what they are up to, and really don't expect them to tell me.

However, I do absolutely deny every allegation relating to me in Mr. Cun- ningham's series of documents. The man obviously Is not addicted to the truth, or he lives in some sort of dream world, or he may be senile, or some combination of the three. Certainly, he is malicious to refer to the tragedies in my family.

For example, on page 1 of his letter he claims that one Euford Godwin told 0 him that my funds were put up by some mysterious consortium of Republi- cans. Mr. Godwin is a fine gentleman; and when I informed him of this, he was furious. He told me that he'd never said any such thing, and that C he was prepared, ifnecessary, to furnish you with an affidavit to that effect. Moreover, he intends to confront Mr. Cunningham, and probably already has.

00 Being underfinanced, it is not always easy for me to obtain legal help. Yet still, I am by separate document designating my friend, John Weaver, as counsel on the matter, in hopes that his services will not be required.

And may I add parenthetically that this kind of ugly nonsense is the very rea - son that more decent people don't run for public office. Yours very sincerely,

the 5th of September, 1984 •, 6 m i • :i STATZLOC ESIGKArO. CT

? UR 1763

NA_- 0? COUNSEL: JOHN WEAVER

ZDDRSS: 401 South Dargan Street

Florence, S.C. 29501

803/ 662-0486

The above-named individual is hereby des'ated as counsel and is authorized to receive any 7o tifications and other C -- i cation s from the Com-wmision an! to act on my behalf before -the Com-.mission.

5. September. 1984 Cy Date- .. Signature

"RESPON'DZY1 S NA_ : MELVIN PURVIS

q ,DDZSS: 801 West Palmetto St.

Florence, S.C. 29501

803/ 665-4860

BUSIlhSS PBOhM: 803/ 662-6881 MELVIN PURVIS, JR. , , For U. S. Senate 801 West Palmetto Street Florence, S. C. 29501 I

Mr. Kenneth A. Gross Associate General Counsel FEDERAL ELECTION COMMISSION 1325 K Street, N.W. Washington, D.C. 20463

, 'p 581 459 055 FEDERAL ELECTION COMMISSION WASHINGTON, D.C. 2063

August 31, 1984

Emory M. Sneeden, Treasurer Reelect Thurmond Committee 1835 Assembly Street Columbia, South Carolina 29201 Re: MUR 1763 Dear Mr. Sneeden: On July 31, 1984, you were notified that the Federal Election Commission had received a complaint alleging violations of sections of the Federal Election Campaign Act of 1971, as amended. On August 27, 1984, the Commission received an additional document submitted by the complainant in connection with the above-captioned matter. A copy of that document is enclosed for your information. If you have any questions, please contact Marybeth Tarrant, the staff person assigned to this matter at (202)523-4143. Sincerely, Charles N. Steele General Counsel

By: Kenneth A. Gross Associate General Coun 1 V

Enclosure

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Plea.e add as Enl. 9 to we complaint dated 17 Aug. 1 Ty-. to lot, P.O. 47.r aey turned th d p..so g "fly .ose om- conviction 4i0 " PAWLS LAN. S.C. 298M5 man charged _ _ _ _ ba~y hslaUwas carrying.- -Geogetown Cow in a unanius de- emergency room cision, Horne's eon covered -that the v"cto could be upheld beme she was deUl the killing In child was'secion. dq iot. unlawful:at ofdw te cnti Th7w * cthe- but opens the door Aforpr -r~-. rostio the futm. chu was by -Yueverheard I result of the motber about 'Wni the ablood S €elso mg-the -war'?' D yo.se.dVi MuAe Horne,y..Wlout ai. that'szwhat did, batat east we" Al mthe Sealf. got a * 1 w_ -t' vo was adr -. '1r certainly glad -tbey've must serve2O Made that-distincton 'fdr.-fura batty with cases' esi.-- stAbbingof his wife

" - . .' " .i- ". " . -" : < " .The Greater. Horry County Board of R, spo nsors the AMERICAN RED CROSS BLO4

:;om- -din -:- U be lots -.. m mJue mite, ,,zl.... -- - ...... :-* . -. _; ...- ."- - . -ATh.Ainocaat.Pvs7w

.-J " ' . md - ". . At the conrvention,,.; . . .. .- :

e' Former 6th District Rep.*Jobn Napler of Bennettsville, T ft,and( .. :. .3: . Ic Sen. Strom Thurmond,.-S.C. take part In theopening sesion :-f.c'3:..;i',i ---"_."'.,F,-- 17 Republican National Convention at the. Dallas.Convention Center ,...Monday. .. .. The .. convention-.. ::t.:- s runs. !,-j through.,.4 -~Thusay."I-,:'.;. .... -'. •- ;.. ., FEDERAL ELECTION COMMISSION WASHINCTON, D.C. 20463.

August 31, 1984

Robert H. Cunningham P.O. Box 588 Pawleys Island, S.C. 29585

Re: MUR 1763

Dear Mr. Cunningham: This is to acknowledge the receipt of the supplemental material relating to your August 17, 1984 complaint. The material has been given to the staff person handling that matter. VIf you have any questions, please contact Marybeth MTarrant at (202) 523-4143.

Sincerely, Charles N. Steele General Counsel

By Kenneth A. Gross Associate General 1~une 7 6i~~aw9i iw1c-;Q nd 3- C2,8

Office of General Counsel Federal Election Commission Attn.: Kenneth A. Gross Washington, D.C. 20463 I FEDERAL ELECTION COMMISSION * WASHINGTON, D.C. 20463 August 28, 1984

Robert H. Cunningham 7 Waccamaw Trail Pawleys Island, South Carolina 29585 Dear Mr. Cunningham: - This letter is to acknowledge receipt of your complaint which we received on August 20, 1984 which alleges violations of the Federal Election Campaign laws. A staff member has been assigned to analyze your allegations. The respondent will be notified of this complaint within five days. 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. We suggest that this information be sworn to in the same manner as your original complaint. For your information, we have attached a brief description of the Commission's procedure for handling complaints. If you have any questions, please contact Barbara A. Johnson at (202) 523-4143. Sincerely, Charles N. Steele General Counsel By 4)tOIJ. By Kenneth A. Gross Associate General Counsel

Enclosure FEDERAL ELECTION COMMISSION WASHINCTON. D.C 20463

iv August 28, 1984

CERTIFIED MAIL RETURN RECEIPT REQUESTED Emory M. Sneeden Treasurer Re-Elect Thurmond Committee 1835 Assembly Street Columbia, S.C. 29201 Re: MUR 1763 Dear Mr. Sneeden: This letter is to notify you that on August 20, 1984 the Federal Election Commission received a complaint which alleges that the committee and you, as treasurer, may have violated certain sections of the Federal Election Campaign Act of 1971, as amended ("the Act"). A copy of the complaint is enclosed. We have numbered this matter MUR 1763. 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 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. 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 a statement authorizing such counsel to receive any notifications and other communications from the Commission. - 2 -

If you have any questions, please contact Lois Lerner, the attorney assigned to the case at (202) 523-4143. For your information, we have attached a brief description of the Commission's procedure for handling complaints. Sincerely,

Charles N. Steele General Counsel

By: Kenneth A. Gross Associate General Counsel

Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement cc: The Honorable Strom Thurmond FEDERAL ELECTION COMMISSION WASHINGTON, D.C. 20463

IN Aukst 28, 1984

CERTIFIED MAIL RETURN RECEIPT REQUESTED Melvin Purvis 801 West Palmetto Florence, South Carolina Re: MUR 1763 Dear Mr. Purvis:' This letter is to notify you that on August 20, 1984 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"). A copy of the complaint is enclosed. We have numbered this matter MUR 1763. 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 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 urder oath. This matter will remain confidential in accordance with 2 U.S.C. S 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 a statement authorizing such counsel to receive any notifications and other communications from the Commission. -2-

If you have any questions, please contact Lois Lerner, the attorney assigned to this matter at (202) 523-4143. For your information, we have attached a brief description of the Commission's procedure for handling complaints. Sincerely,

Charles N. Steele General Counsel

By: Kenneth A. Gross Associate General Counsel

Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement *T THE FEC ( / / / ( 4"4A1! : 4f

£Pa.~w Atd &"oa Cawfbu eoj?' t831. restAug. 20, 1984

Office of General Counsel Federal Election Commission Washinston, D.C. 20463 Attn.: Kenneth A. Gross

Please add the attached clippings from the 19 Aug. 1984 State, o newspaper as Encl. 8 to my Aug. 17 complaint. They demonstrate: (1) the closeness of to Senator ond and Atwater's Machavellian turn of mind which would encourage hm to come up with something like the Purvis gambit, and (2) the association with Charlie Appleby and his daughter alluded to by Senator Thurmond in Encl. 6. Atwater generally is described by his contemporaries in four letter terms. He brings to mind people who used to work for me in CIA, like Howard Hunt, who were all right so long as held on a tight tether but became loose cannon after gaining access to the heady power and relative indiscipline of the White House. 49 *. qqr bo) ' ~~AL

w~y, i~nd -S C 29525r

Office of General Counsel Federal Election Comuission Washington, D.C. 20463

OOttn.: Kenneth A. Gross EAT WAR~4

( 94AUG/g Af :

SR. di. (asnninglirn

t8o / .. k ' Aug. 17, 1984

Office of General Counsel Federal Election Cosission Washington, D.C. 20463 l,,- Attn.: Kenneth A. Gross

I, Robert H. Cunningham of 7 Waccamaw Trail, Pawleys Island, 29585 (Tel. 803-237-2282), make the following sworn and notarized compl*aLit regarding probable violation of the Federal Election Campaign Act of 1971; as amended. Facts and conclusions from facts stated herein, where known, are true, and where not known, are believed to be true.

Lf (1) Attention is invited to Encs. 1 & 2, photocopies of articles appearing on 8 July and 1 April 1984 in the State newspaper, Columbia, SC, written respectively by the Governmental Affairs Editor and the Washington Bureau Chief. The collective inference of these two articles is that both the Dem- ocratic and Republican Parties of South Carolina wanted Senator Thurmond to N4 be unopposed in both the Primary and General elections in his 1984 campaign. In this connection, numerous press and media reports described the support 01. for Senator Thurmond of all major Democratic figures, with the exception of Senator Hollings.

CD (2) The question arising from (1) is whether the agreements and understandings between Republican and Democratic leaders in the State were part of the normal, IV acceptable, political process or whether there were agreements, understandings and undertakings which resulted in a conspiracy or conspiracies violating the 0 Constitutional rights of South Carolina voters. I was told by a prominent South Carolina Democrat, Atty. Tom Turnipseed (1417 Gregg St., Columbia, SC 29201 - refer to Encls. 3 & 4), that he was aware of a "deal" between S.C. Governor on Richard W. Riley (1100 Gervais St., Columbia, SC 29201), a Democrat, and Senator Strom Thurmond (209 Russell Senate Office Bldg., Washington, D.C. 20510), a Republican, for Thurmond to win his reelection unopposed.

(3) My suspicion that an illegal conspiracy or conspiracies existed is based primarily on two factors: the manner in which the two Primaries were conducted, see (8) below, and the otherwise inexplicable conduct of the declared winner of the SC Democratic Primary, Melvin Purvis of Florence, SC. As late as today South Carolina Network broadcasts were reporting Purvis had not filed with the Federal Election Commission because he had not received $5,000 in contributions. Please note the sixth paragraph of Encl. I which notes "rumors that Purvis didn't have enough money to file and that pro-Strom Thurmond Democrats helped pay the $4,300 fee to enter the race." I was told by a prominent Republican in the Florence area, J. Euford Godwin (Rt. 2, Box 192, Pamplico, SC 29583), that the funds for Purvis' race had been put up by Florence Republicans. When I specifically queried Purvis about his failure to comply with FEC requirements (cf 11-CFR 101-102) he told me he did not have to since he had not received $5,000 in contributions and had spent only $4,942.40. The latter, at least, is an obvious absurdity. Purvis also told me he had not complied with the Statutory requirement to file a Senate Public Financial Disclosure Report 7 days prior to the June 12 Primary (of S. Pub. 98-10, Page 2, United States Senate Select Committee on Ethics).

(4) Purvis' last minute entry as a Democratic candi4ate raises the qpest on of a conspiracy to have Purvis contest the race against black Democratic candidate Cecil Williams and defeat him (fraudulently, according to Williams), so Thurmond would not have to run against a black in November, with the 1iklbsood of dredg- Ing up ThurIond's history of racial bigotry. The fact a candidate (Purvis) was selected from the Florence area may be significant since two of the most powrful Republican figures in the area are Atty. and former Congressman John Napier of Bennettaville, SC (Tel. 803-479-7270), a Thrmond protege, and VI District Republican Chairman Charles Appleby (PO Box 3286, Florence, SC 29502). The close relationship among Thurmond, Napier and Appleby is apparent from Encl. 5,6 & 7. Napier also has told me he is close to Lee Atwater, Deputy Director of the Reagan-Bush Campaign (440 1st. St. NW, Washington, DC 20001).

(5) Obviously Senator Thurmond and Gov. Riley, on the one hand, or Napier, Atwater and Appleby, on the other, are unlikely to confirm any conspiracy not confirmed by investigation. Purvis, however, has placed himself in an invidious position and the chances seem good that a forced revelation of his financial backing would help uncover any illegal Republican plot.

(6) Except for the "deal" referred to by Tom Turnipseed the involvement of Senator Thurmond and Gov. Riley in an illegal agreement can only be estimated at this juncture from relevant circumAtances. In this connection it is curious that Gov. Riley has made no apparent effort to investigate or suspend Sheriff Michael Carter (Encl. 5). Failure to do so would seem to indicate protection of Thurmond. Yet, if Carter is unfit to be U.S. Marshal he probably is unfit to be Sheriff of Georgetown County. One would assume Riley would strive to be purer than Caesar's wife, in this matter, since he appointed Michael as Sheriff in the first place, after Michael's father, Woodrow, resigned for that purpose. Senator Thurmond's Star Chamber approach to the Carter matter (Encl. 6) also would seem to be relevant. And I have no doubt that Thurmond's inclusion of Carter in the correspondence chain was meant to threaten and intimidate me.

(7) Other questions concerning Senator Thurmond come out of the 1983 Disbursements of his Committee. There are expenditures, probably into six figures, for the Reagan visit, questionable travel and items like the Barbara Bush reception, all charged to Thurmond's Primary campaign. Unless these involved fund raising, which I doubt, they would appear to be inappropriate, perhaps illegal. Also there seems to be some question whether Thurmond's Committee made adequate payment for the half hour television program, in prime time, on all South Carolina commercial stations, announcing his reelection bid. (I have not enclosed pertinent copies of Schedule B since the Commission already has them.)

(8) Returning to the Primaries, see (3) supra, the media have reported the requests of Williams and Jesse Jackson for a Justice Department investigation. I have been advised by the State Election Commission that the extent of double voting will not be available until September or October.

In sum, the two major allegations emerging from this complLtut are, 1,-3.

first, that Senator Thurmond and Governor Riley may have conspiredto illegally limit the scope of the U.S. Senate race in South Carolina and, second, persons unknown, but probably Including Melvin Purvyi, Jobh Napier, Charles Appleby and Lee Atwater probably conspired to umnipulate the Democratic Primary for the U.S. Senate so Senator Thurmond could run in November against a weak, white opponent with a long history of personal and faily misfortunes.

SiWRN to before me this 17th. day of August, 1984 Robert H. Ine

&(SEAL)

My co0fission expires: 6/10/90 pr L 4 8 ;iqjj ii

V.,

-----t- W- 3ISAM"Y I'I WAUSWIM ft%," ~ Aoieamind Ie~,h The S,. C- bm empublc Z aq anpa Pa has a p m- Ismma is Rebut C-- 10-0 d POW hb - anod mada . land, a retird0CA ap wb ays he Statew mp ieisie..... wml rm ae. I&AN "me" I i.n b in u d b; live as OP -OW Pelue It's ad n much do1 the rty llams, leu Ornanaqumil thi- chieftains ae worried about settin the Si- year-old sM tar. The cam- seses is he doen't dtad a chance api" pelm use khave to rve TowmendL gematis a tle ano Re- What both- pul'av thea mo onrof ere S.C. Re- Dumorat oula d ave wrlnd vu publican lead- Bedy ers is the state- foran upe or-man eprram dumemme Tund. either wide plrmy will cos eb party as Citing pdt Rm Patto id muh as PM - mney l state Wie the tum-n -u lw , AOP lead-. GOP dommiet hav. erTmee it aeIdnngt twoi Re- 'lb net loe will be 'hieen ulis tamd a sicint nar-a $50,W and SNL Thats how no* il c nm lvacknewleia " warm TN114 ate pty -=- psmrWedwhrchTl, e lb turouqbfld heedewasd-- Nae viaa r.andGOP am sawelead et ecutive dwier. Iman thanGP eith Tmp says he's been gtd f Mod I* "a ean pei t A pesn W&WmOd lo t cab" frm Repudan C ingam R hpubepmW be in wanting to know hber It in"mew sary for the party to put am a sle.- hes wuln 3 he o be wie pliary thin yur." w t The puty, em mi abet the 1d 11 ms eOWN n do GOP. co at rnmq a s latewide Imary, asked Republic attending the h Cpl pm up a ale gt DWM GOP csmvendtNa I week whether y - n a by sate couvention or by prinary. bi with P g ur to punovL "It was S-SO," said Tompkins. solnmt wnldm y tae to het out Cunningham, suspecting that dit, a job fdr your son or what?" same of the urmmmd people are be sayn they asked he 0 to do away with the behind an effort dacikeh Im-Ceatm~ with to epiofstionul d -hae ppoahe&ur that oum*' e primary thin year. charges that some w-ud withdraw if Repulcans could Republcans have put pr mo him Cua m asp ano the om to withdraw. He s finers former Rep. Johm L Naplr of Den- the Na- uettsaille and Rick Reed o 'mehat ole you take toet eu 0 tional Repubbkan Sentorial Cam- 0 paign Commute. to tuy and wilo fore his Amorfee to He says that Napier caned him bppe id inhima the GOP from Washington and "asked me not that Reed flew to Myrtle to run," and Curnngre gmiv to act ke ateal I. Beach two weeks ago to try to talk would,- a state If ebutiv col- running as an Independmt. him Into m "aoWve Reed couldn't be reached for comn- gttee mneat. got to opbast m to te peope 94 a callipua nWe *tthe Prtysim t Nap erac oWdg rm to the 1ftim polties of te 0 0p 0 ntnhkam, but he says he did so to correct a false story theGOP asp-ian a was spreading about an earlier con- miemmbeopoOe ind intsometd"yuv lbow* pn or- versatom he two had. pym pir to m or the mom- "I told him that if he did run mau (far bMa Oy uto con S Cl) statewid I didnt think he would stand a prayer against Sen. & an but mmemimed thee will be Thurmoid.... I also told him that It a swulW bu lbearys Imahg the would c tl epartyanu dne amount party cul affrd it of money to run a statewide pria-

mmmmmmmmmmmmm 0 .0 TURNIPSEED, BOGAN AND DEW ATTORNEYS AT LAW 1417 sotU STREET COLUMBIA, SOUTH CAROUNA 29201

TOM TUNIPSEI-D P.O. Box 5 j. STEDOLY 9OAN COLUMNA. SOUTH CARKUNA ,RUCE a. DEW is 947 April 30, 1984

Mr. Robert Cunningham P.O. Box 558 Pawleys Island, SC 29585 Dear Mr. Cunningham: It was a pleasure to talk with you Sunday night. Please call me when you get to Columbia and we will get together. Enclosed is a paper I recently presented to our church discussion group. Sincerely, TUN BOGAN AND DEW

Tom Turnipseed

TT/dcd

Enclosure 3 I

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April 23, 1984

Senator Strom Thurmond Senate Office Bldg. Washington, DC 20510

Dear Senator Thurmond:

Seeing Gov. Dick Riley and the former and present Georgetown County Sheriffs Carter (father and son) at the Georgetown Propellor Club's annual fish fry last Saturday suggested a possible solution to a weighty problem presented to me early in February by Charlie Appleby.

Charlie Appleby, you mey recall, is the cement salesman who is Chairman of South Carolina's Sixth District Republican Party. We met at the Coachman restaurant in Florence at 2:30 p.m. on Friday, Feb. 3rd and he told me the following unsolicited story:

Following President Reagan's election you (Sen. Thurmond) contacted Charlie and John Napier, advising you would se- lect the next U.S. Marshal and something should be done about the voting situation in Georgetown County...John and Charlie looked into the matter and decided the job should be offered to Michael Carter....Michael agreed to cooperate and so did his father, Woodrow ....both Carters visited you in Washington, "bowed down" and promised they would deliver.. the FBI clearance of Michael was initiated ....after some time the FBI came back and told John and Charlie that if the in- vestigation continued they would have to arrest Michael... John and Charlie then told Michael he would have to find some way out ....Michael subsequently announced that if he didn't receive his clearance by a certain time he would withdraw his name.

Although I had heard rumors about Michael's appointment as Marshal this was the first time the story was so explicitly detailed by someone who claimed to be in on the action. Following Appleby's account I checked around and heard that: (a) some local newspeople believe Michael's with- drawal was tied to allegations of drug irvolvement and (b) Federal author- ities are supposed to be reluctant to work with Michael on drug cases.

I, personally,aam inclined to doubt the drug allegations. However, if it is true the FBI had uncovered sufficient evidence of some purported crime that they were about to arrest Michael this would be a matter of serious import to the people of Ceorgetown County.

Enclosure 5 By copy of this letter, therefore, I am suggesting that Gov. Riley may wish to initiate an investigation into this matter.

There is a remaining point, which may involve you. Appleby's allegation that the FBI traded, in effect, for termination of their investigation does not ring true. I was involved in liaison with the FBI, off and on, for 25 years. Appleby's report of their conduct does not correspond with the Bureau's modus operandi, as I know it.

It could be possible their investigation was terminated by order of the U.S. Attorney General's office. This would require considerable influence, like that you possess as Chairman of the Judiciary Comnittee. In other words someone at a high level of the Executive Branch,or you or someone purporting to act for you, almost certainly would have to have intervened.

If that should be true, namely that the Bureau did not act on its own, the question arises what else, if anything, may have been involved in seeking termination of the FBI investigation?

It may be, of course, that all actions in this matter were legal and aboveboard, although logic suggests otherwise.

You may want to look into the matter, therefore, and make some public disclosure if you feel such to be justified.

In addition to copying this letter for Governor Riley I am sending copies, also, to the FBI and my attorneys.

Sincerely, W " STROMSIOUTH THURMOND CAOWINA

4rt Urtsibet Pro Snmport UNITED STATES SENATE

April 26, 1984

Mr. Robert H. Cunningham 7 Waccamaw Trail Pawleys Island, SC 29585 Dear Mr. Cwrmigm: Your letter dated April 23, 1935, which of c:ourse you meant to be April 23, 1984, has been received. It appears from the contents of your letter that you are making two false insinuations.

First, you insinuate that Sheriff Michael Carter was recammended for the position of U.S. Marshal by me in exchange for votes. This is untrue. (%4 Your second insinuation is that I influenced the FBI to drop ok. its investigation of Sheriff Carter's ncmination. This is also untrue. In no way did I ever attempt to influence FBI actions Wwith respect to this matter. 0 In addition, Mr. Appleby was in Washington this week visiting his daughter, and I showed him your letter. While Mr. Appleby said he had talked with you, he vigorously denied to me and several cof my assistants making the remarks outlined in your letter.

Vr I hope this clears up the misinformation on this matter.

With kind regards,

Sincerely,

Strm Thuromnd

ST/ks

cc: Judge William Webster, Director, Federal Bureau of Investigation Honorable Richard W. Riley, Governor, State of South Carolina Sheriff Michael Carter, County of Georgetown, South Carolina Honorable John L. Napier Mr. Charles L. Appleby, Jr.

Enclosure 6 April 30. 1984.

Senator Strom Thurmond Senate Office Bldg. Washington, DC 20510

Dear Senator Thurmond:

I have your letter of April 26, 1984.

I can certify I accurately reported Mr. Appleby's remarks of Feb. 3rd in my letter of April 23rd. I would be willing to submit to a polygraph examination on this point.

Also it is true the press and media reported that Sheriff Carter withdrew his candidacy for U.S. Marshal on the basis he could no longer await clearance.

Thus I believe the Department of Justice should make public the reason-or reasons why Sheriff Carter was not cleared and whether or not he was about to be arrested and, if so, why.

If I should undergo a polygraph examination I believe Charlie Appleby should too. Also since your own credibility seems to leave something to be desired, e.g. In the matter of the 82nd Airborne Division, so should you.

I return your kind regards,

Sincerely, CC: FBI, Gov. Riley.

Enclosure 7 8404049 2 4 6'--6

FIRSrtCu

W~sb~ipem .0,com3

Atta, Keeth A. ftees .,, ".

FEDERAL ELECTION COMMISSION

112S K SiRII N.W WASIIINC1ON.DC. 20463

TIllS IS THE BEGIURING OF !JUR f I2Ze~ a qIm Date Filmed 10/110 4 camera No. --- 2

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