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I Ndivi Duals Alrld Eommittecss the Respondents May Request An

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I Ndivi Duals Alrld Eommittecss the Respondents May Request An FXDERAL ELEGTION COIVIhl~SSION REPORTING AND D1SBIX)SING REQUIhZF,MENTS @%be Federal Eleation ktampaign Act of 1971 as amended requirets detailed campaign fiwmce reports on eontdbutions and arpend- ftures from candi at- forFederal office and tLei.r supportin? poli tiaal conunittees #as well. as from ?I ndivi duals alrld eommittecss making sxpsndltures on behalf of,w in oppositiom to a eandidnte,n Per the 4wnmissioraqa ow& definition of ft83 fumetion the active !-easive ,am& XEARB long effort to 0pp0Se the; amddaay ...~.. of an udividual for the office of Bresidewt of the United States ...~... .- .. would seem to elearly dictate compliance wftb the above quoted .. ~... Rule Anel Kaquj rernent . .- .- DESCRIPTTON OF PRELIMINARY PROBEDIJRES FOR PROCESSING COMPLAIhTS FILED WITH THE FEDERAL ELEGTION eOMMISSION %he commission shall notify aiLl respondents referenced in the complaint in writing*that the complaint has been filed, and shall indude with such notification a copy of the corn- plaint. Si~ultaneously,the complainant shall be notified that the complaint has been received. Ths'respondents shall. have 15 davs to demoastrata in writing that no action should be takari against them in rosponse to the complaint. If additional time is RBeded in which to respond to the complaint, the respondents may request an extension of" time. The request must be in wriltlna and demonstrate prood cause as to whv an extensiol~should be granted. Please be advised that not a1 rewests are KrantcO.n In the aase of MUR 4927,the Commission notified the respondmts by letter dated August 14,19980 Ike respondents answescld the eorup1ad.int by letter dated September 2,1996. Thla is 1) days from the, Gommissioa's lett,er inforuing then1 of the complaint. Tkc sheaf of documents purport'ing to be the aomplete record of tho case contailss no written request for an extension of time to respond to the aomplaint. 2) MISFEASANCE The @omissionsat; on the earnplaint for a total of 525 days without performhg any aut to investigate the eompla.int even though the Wespondentvs lettar of September 2,1998 gave indioations that it was disingenuous at best anel additionally false iA it’s eladrns. Om more tham one occasion P telephone inquiry to Mr. P. Andrew ‘Rhrley wars met with the explanation that the matter was “aensitivsg and it had to be handled with caution. llhs file of the Case evidences no trace of sensitivity or mution, On the, aontrary,tks total absence of any activity of any sort is elear evidence of an insmsitivo and brazen cover-up OR behalf of the Respondents, LETTER ‘OF SEPTEMBER 2.19% (Response to complaint) The first paragraph of the letter states that notification of the complaint was recaived on August 18,1998 at the office of BitizeRs United., Sinoe the Gomplainant received Ratification of serviee to the respondeats in on envelope that was post marked Auguat l4,19 $,it taust be assumed that the. letter of notifice- tion to the Respondents was also rnaieiled to them on August 14th. The Bespondentos attorney claims fha% it took four days for the letters to travel exactly 19 miles to Fairfax Virgiaria aeross toma It is unfortunate that the date received stamp on the publia records copy is too faded or has been erased to the extent that the date of receipt avamot be determined. tIowever,unless the reply was hand delivered on September 2nd,i5 would have been late, WBails the Rules apnd Regulations doagt specifialdlly allow time to toill from the date of reseipt,tke Oonmissionss letter does so allow for this. Uafortunately there is apparently no docu- mentation to support a oloim of timely responseo There is suffi- oient evidence to tho effect that the reply was not, delivered in time ,, Paragraph five of the response ahins that the complaint identified as MUR 4787 was not in fact a eomplainto Phis dis- ingemupus statement is wordedPhe is merely asking the Qommission to explain why 6U and the American Gonsemative Union ore noL re- uised to file periodic reports with the @ommission." Suck i~ .. -.~. stateneat is sot to be found In Gomplaint MUR-4787. The 8ompIaiat states:*I believe I aim entitled to ask for and receive the, infor- mation regarding where the finanoiol support for all of this comes from," The paragraph further ignores the speaifio request for raporLilsg by the BU-PWp To further obfuscate the matter this group has in the past used the mine PIRESIDEMTIAL VICTORY 6OMMITTEE whd~hshould raise significant questionws regardiag what begiti- mate seasoas'umiarlie the evasions inherent in frocguetlt changes of aame by the same organisaelon. In pm~graphseven of the response it is claimed that CIO is permitted to establish a Separate Segregated Fund(SSF). The: re- sponse goes on to e~plainthat oraly tha SSF is required to file periodic reports of contributions and expenditures. While forth- rightly elaiming that BU was not aw SSE' the response made no nant- ioln that their 8U-PW w29 an 3SF,The statemeat made in this papa- graph does nothing to diminish the Complaint MUR-4787. Imp paragraph eight the Respondent antfully explains what ompleint means for the Federal Election Orsmnission. Alleg- edly the explaation was so good that the FEG accepted it a5 the findings of fact in itss decision. This sort of arrangement is P hallmark of ex parte corruption. This story was so clumsy that F, Andrew Turlep would not allow the Gomplainant to see a aopy 'j.-:\ ,Pi... .. .~ -. of it,olaimiag that it was aonfidential. At the the he made this ... .. =.^ declaratioa Mr, Turley knew that the Responss,sight unsean,would be the Gomissioavs findings of fact,, Zr paragraph eight of the Response, it is ulaiaed that 1.I;J'R- 4787 had charged that *Mr. hle,Ms0 dones,WhStew&er or TroopergatetB had been candidates for federal aleative officea The Respondent steadfastly maintained that @U had not violated FECA'twith respect to any of these indivfduals or eventsn. Pherefore,accbrding to the Respoadent ,the Gomplaint"fai1s to allege a violation of FECA with respect toWitisens United. There is no mention in this windy puagraph of Citizens United rolitfcal Victory Fund. The CU-PW is cited in the Gomplaint MUR-4787. Papagraph nine of the **esponseseeks to capitalize on the confusion resulting from their us@ of multiple and always evol- ving names that they operate under. &ere they state that CU-PVF has"registered with the FEC as required by Paweft The Response goes ora to maintain tha& FEBA*does not require GU-PW to file* Infor- mation on Citisens United. The Respondent then goes on to maintain that the Complaint that Respoadsnt erplained in the prior paragraph fails to make an allegation that Gitiseras United-Political Victory Fu.d has violated the FECA. This is why the Qoniplaiaant named every name that this organization is known to have used. Admit- tedly an organization with an AKA method of operation could very well be using other tRoffioial names" that are unknown to the Corn? plainant as a new name has surfacid since the first filing of the Oomplaint WR-4787. (Presidential Victory Committee) Paragraph ten of the Response is irrelevant with regard to - Messrs. Broh and bossie exercising their First Amendment rfghts, These people were identified in the Qomplalnt(MUR 4787) as officers - of the Organisation identified by it's many aliases,hopefully .=._ ....~.. -...~ .. ....... most having been identified ia Complaint MJR4787. ... .. Xn faeti im all of the kaom instanaes when these two individ- ..~... ... uals have publiely advoaated the defeat of Presidential Candidate William Jefferson Qlinton,they Rwer introduced themselves as pri- eitiams exercising thaix First Amendment Rights, MLorna got on the phone ad 1 identified myself as a representative from Presidential Viatory Gamtittse" David bssie as quoted in 'DBPicrk Willis" "We identified ourselves as being from the Presidential Vietory Gommittee In Washington,D.C.H David Bosnie as quoted in"Slfck Willie1b *The two gumshoes were Dave Bossie,an official of the Presidential Yictory Committae,and dim Murphy,a retired DC policeman, Federal election records show both inen are paid by the Victory Gommittee for work on behalf of Bush's e1ection.W Eric Enberg GBS exerpted from W1i.ck Wil li 8 8' "1 have people who work with me, Ism supported by thousands of individuals who like what Iem doing,who like that I'm aggressive,who like that I?iii taking on the Washington establishment,who like what IQin doing." Floyd Brown as quoted in 'YWLck Willie7a The Floyd Brown quote from his book written to prevent William Jefferson Glinton from becoming President refers to his solicitation of funds from %housands of individualstb for his work. This would seem to be a custom made fit for The Federal EleCtiQR Gommissionts-R~portin~and Disclosing Requirements. By their om words both were on the payroll qnd not exercising free speech as individuals. RESPONDENT’S CLAIM THAT THERE IS NO EVIDENCE THAT CITIZENS UNITED HA3 VIOLATED FEDERAL ELECTION LAW In paragraphs seven and eight of the Respondent‘s letter the claim is made that Citiaens United does not engage In any activity that would be in violation of Federal Election Law. The same Respondent was telling Trudy Lieberman a different ...... L .. .j:: .. tale for her May 1994 article in the Columbia Journalism Review. IVCitirens United.,o conservative RepublfcaB operation,runs an information factory..... Journalists and Hill Republicans have re- cycled much o€ the information provided by GiCitens United into stories that have cast a shadow on the Clinton Presideaay, This would seem to fit the definition
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