Mterrogatory No. 3
i I- BEFORE THE FEDERAL ELjECTlON COMMISSION In the Matter of ) Witness Subpoena to ) m 3774 The National Right to) Work Committee ) SUPPLEMENTAL RESPONSE TO SUBPOENA The National Right to Work Committee (WRTWC), hereby submits this Supplemental Response to the Subpoena ?o Produce Documents/Order to Submit Written Answers served upcln “WC in the above-referenced MUR, following the June 10,1997, decision of the U.S. District Court for the District of Columbia in Misc. Action No. 97-0160, ordering NRWC to respond to Interrogatory No. 3 and Document Request No. 3, as modified by the Court. INTRODUCTORY COAKMENTS Intemgatory No. 3 and Document Request No. 3 relate to activities from more than four years ago. NRTWC has experienced changes in personnel over those years, and documents may no longer exist, if they ever existed. Nonetheless, “WC, with the assistance of counsel and staff, has conducted a diligent search for documents and facts, and responds on the basis of information so gathered. The Court limited the scope of Interrogatory No. 3 and Document Request No. 3 to the 1992 senatorial candidates, and the Commission, by its attorneys in discussions with “WC counsel, has further limited the scope to the 1992 general election senatorial candidates. Thus, NRTWC’s search has focused on the 1992 general election senatorial candidates. Also, the Commission and NRTWC, in briefing and in discussions between counsel, have agreed that NRTWC may redact documents to delete supporter-identitjing information from documents to be produced, and NRTWC is doing so. MTERROGATORY NO. 3 NRlwC did not engage in, or finance, in whole or in pa, “any activities relating to federal elections in October-December 1992 .
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