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FEDERAL ELECTION COMMISSION Washington, DC 20463 June 1, 2021 CERTIFIED MAIL – RETURN RECEIPT REQUESTED Via Email: Pryan@Commo
FEDERAL ELECTION COMMISSION Washington, DC 20463 June 1, 2021 CERTIFIED MAIL – RETURN RECEIPT REQUESTED Via Email: [email protected] Paul S. Ryan Common Cause 805 15th Street, NW, Suite 800 Washington, DC 20005 RE: MUR 7324 Dear Mr. Ryan: The Federal Election Commission (“Commission”) has considered the allegations contained in your complaint dated February 20, 2018. The Commission found reason to believe that respondents David J. Pecker and American Media, Inc. knowingly and willfully violated 52 U.S.C. § 30118(a). The Factual and Legal Analysis, which formed a basis for the Commission’s finding, is enclosed for your information. On May 17, 2021, a conciliation agreement signed by A360 Media, LLC, as successor in interest to American Media, Inc. was accepted by the Commission and the Commission closed the file as to Pecker and American Media, Inc. A copy of the conciliation agreement is enclosed for your information. There were an insufficient number of votes to find reason to believe that the remaining respondents violated the Federal Election Campaign Act of 1971, as amended (the “Act”). Accordingly, on May 20, 2021, the Commission closed the file in MUR 7324. A Statement of Reasons providing a basis for the Commission’s decision will follow. Documents related to the case will be placed on the public record within 30 days. See Disclosure of Certain Documents in Enforcement and Other Matters, 81 Fed. Reg. 50,702 (Aug. 2, 2016), effective September 1, 2016. MUR 7324 Letter to Paul S. Ryan Page 2 The Act allows a complainant to seek judicial review of the Commission’s dismissal of this action. -
Sexing the Mueller Report
SEXING THE MUELLER REPORT Ruthann Robson* I. INTRODUCTION Sexual indiscretion, misconduct, and deceit percolate throughout the extensive 2019 Report On The Investigation Into Russian Interference In the 2016 Presidential Election—known as the Mueller Report.1 President Trump’s sexual behaviors are certainly not the focus of the Mueller Report, which resulted from the Acting Attorney General’s appointment of Robert S. Mueller, III as Special Counsel for the United States Department of Justice to investigate “any links and/or coordination between the Russian government and individuals associated with the campaign of President Donald Trump,” and “any matters that arose or may arise directly from the investigation.”2 Volume I of the Mueller Report addresses Russian interference with the 2016 election and any Trump campaign links in approximately 200 pages. Volume II of the Mueller Report, which is slightly longer at 241 pages, focuses on the question of whether the president obstructed justice in connection with the Russia-related investigations, including presidential actions related to the Special Counsel’s investigation itself. Given its charge, it is both predictable and understandable that the Mueller Report only obliquely addresses President Trump’s sexual * © 2020, All rights Reserved. Professor of Law & University Distinguished Professor, City University of New York School of Law. Appreciation to the editors and staff of Stetson Law Review, and for discussions on the Mueller Report and the role of sex, to Professors Penelope Andrews, Janet Calvo, Julie Goldscheid, Ellen Podgor, and Sarah Valentine. 1. 1 ROBERT MUELLER, REPORT ON THE INVESTIGATION INTO RUSSIAN INTERFERENCE IN THE 2016 PRESIDENTIAL ELECTION (2019) [hereinafter MUELLER REPORT VOL. -
Amid Trump's Legal Troubles, Two Lawyers' Names Keep Surfacing Together
April 26, 2018 MySanantonio.com Link to original article: https://www.mysanantonio.com/news/article/Amid-Trump-s-legal-troubles-two-lawyers-names-128 67949.php Amid Trump's legal troubles, two lawyers' names keep surfacing together By Beth Reinhard, Emma Brown and Frances Stead Sellers, The Washington Post The two lawyers' names keep surfacing in tandem, again and again, in the context of deals in which women were paid to keep quiet about their alleged affairs with powerful men. Now, the relationship between Michael Cohen and Keith Davidson is drawing public scrutiny as federal authorities investigating Cohen examine payments made to women whose stories could have damaged Donald Trump's presidential campaign. Davidson is cooperating with the probe and has provided investigators with "certain limited electronic information," according to the lawyer's spokesman. Cohen, Trump's longtime adviser, and Davidson, a Los Angeles lawyer, have crossed paths at least five times in the past two years. In the most recent instance, Cohen collected a fee said to be hundreds of thousands of dollars in a deal Davidson helped orchestrate. New attorneys for Davidson's former clients, Stormy Daniels and Karen McDougal, both of whom allege they had affairs with Trump years ago, say the relationship between Cohen and Davidson has seemed too cozy. "This is supposed to be an adversarial process," said Daniels' attorney, Michael Avenatti. "These guys should not be in the same bedroom, let alone the same bed." Cohen did not respond to requests for comment. Nor did his lawyers Brent Blakely and Stephen Ryan. In a recent interview with The Washington Post, Davidson rejected the suggestion that his dealings with Cohen were in any way improper, saying they have a "purely professional" relationship and did not meet in person until early 2018. -
Trout Cacheris & Solomon
TROUT CACHERIS & SOLOMON PUC ATIORNEYS AT IAW 1627 EYE STREET, N .W. SUITE 1130 WASHINGTON, D.C. 20006 [202) 464-3 300 ROBERT P TROUT FAX {202) 464·3319 (2021464-3311 RTROUT@TROUTCACHERIS COM WWW.TROUTCACHERIS COM August 15, 2019 By Email Honorable Jerrold Nadler, Chairman House Committee on the Judiciary Washington, DC 20515-6216 Re: Hope Hicks Dear Chairman Nadler: On behalf of our client, Hope Hicks, we are writing in response to your letter of July 18, 2019 requesting clarification regarding her testimony before the House Judiciary Committee on June 19, 2019. Ms. Hicks stands by her testimony. She had no knowledge of, and was not involved in any conversations about, "hush money" payments to Stormy Daniels during the campaign. The information she provided to the Committee was truthful to the best of her knowledge and recollection. Before we address the specific points in your Jetter, some background is important. Your letter resulted from the release on July 18, 2019 of search warrant affidavits in the Michael Cohen matter. The search warrant affidavit quoted in your letter was dated April 8, 2018, and the search of Mr. Cohen's residence and office, as well as his safe deposit box and his two cellphones, occurred the following day. The government had earlier obtained evidence from Mr. Cohen's email accounts. Over two months later, on June 27, 2018, Ms. Hicks appeared for an interview with the U.S. Attorney's Office in the Southern District of New York. She did not request immunity, nor was it offered. In keeping with routine practice in such circumstances, the U.S. -
BU (Extreme) South
SPRING 2009 INSIDE: Do magnets repel sharks? arts&sciences Revered Dean Elsbeth Melville remembered Notorious traveling French sisters BU (extreme) South Geomorphologist David Marchant and his team of students discover Antarctica’s secret past C ONTENTS from the dean SPRING 2009 10 Open a newspaper or turn on a TV and it’s hard As all of us at BU come together to withstand this period of to avoid being bombarded by stories about economic uncertainty, Arts & Sciences remains strong. I am very “I felt that all the hours failed financial institutions, corporate layoffs, pleased to say that our ambitious program of faculty recruitment 12 and stock market tumbles. Indeed, these are is not affected by the freeze, and we are moving ahead with plans to they were in neither the troubling economic times. strengthen CAS, not only replacing faculty who retire or leave, but also classroom nor the library, This past fall, President Robert Brown expanding the faculty by as many as 100 new positions within the I was responsible for them.” faced the situation head-on. Rather than taking decade. The newest members of our faculty are impressive indeed. To a wait-and-see approach to the ongoing finan- get a sense of what they mean for the future of the College, I invite you Dean Elsbeth Melville (CAS’25) cial turmoil, he was one of the first university to take a look at the brief biographies in the roster of new appointments Photo courtesy of Craig O’Connell presidents to take serious proactive measures in the crisis. -
COMPLAINT for DAMAGES 16 and OTHER RELIEF V
CONFORMED COPY ORIGINAL FILED Superior Court of Ca!ifomia 1 STRIS & MAHER LLP County c! Los Angeles PETER K. STRIS (SBN 216226) 2 [email protected] JUL O6 2018 ELIZABETH R. BRANNEN (SBN 226234) 3 elizabeth. [email protected] Sherri R. Carter, Executive Officer/Clerk of Court DANA BERKOWITZ (SBN 303094) By: Kristina Vargas, Deputy 4 dana. [email protected] KENNETH J. HALPERN (SBN 187663) 5 [email protected] JOHN STOKES (SBN 310847) 6 [email protected] 725 South Figueroa Street, Suite 1830 7 Los Angeles, CA 90017 T: (213) 995-6800 IF: (213) 261-0299 8 SHAUN P. MARTIN (SBN 158480) 9 [email protected] 5998 Alcala Park, Warren Hall 109C 10 San Diego, CA 92110 0 T: (619) 260-2347 IF: (619) 260-7933 '~ 00 11 Counsel for PlaintiffShera Bechard 12 SUPERIOR COURT FOR THE STATE OF CALIFORNIA 13 FOR THE COUNTY OF LOS ANGELES 14 SHERA BECHARD, Case No. BC712913 15 Plaintiff, VERIFIED COMPLAINT FOR DAMAGES 16 AND OTHER RELIEF v. ~ ::r: 17 r< < ELLIOTT BROIDY, an individual, w ;:;S 18 KEITH DAVIDSON, an individual; DEMAND FOR JURY TRIAL MICHAEL AVENATTI, an individual; 19 DAVIDSON &ASSOCIATES, PLC, a professional limited liability company; and 20 DOES 1 through 20, inclusive, 21 Defendants. 22 23 24 25 26 27 28 1 1. Plaintiff Shera Bechard ("Ms. Bechard") brings this Complaint against Defendants 2 Elliott Broidy ("Mr. Broidy"), Keith Davidson and Davidson & Associates, PLC (together, "Mr. 3 Davidson"), and Michael Avenatti ("Mr. Avenatti"), and alleges as follows: 4 2. Ms. Bechard is a model and former Playboy Playmate. -
Stormy Daniels's Former Lawyer Said to Be Cooperating with Federal Probe
April 20, 2018 - Washington Post Link to original article: https://www.washingtonpost.com/politics/stormy-danielss-former-lawyer-said-to-be-cooperating- with-federal-probe-of-michael-cohen/2018/04/20/3011745e-44ae-11e8-baaf-8b3c5a3da888_sto ry.html Stormy Daniels’s former lawyer said to be cooperating with federal probe of Michael Cohen By Beth Reinhard and Emma Brown Keith Davidson, the former attorney for two women who were paid to keep quiet about their alleged affairs with Donald Trump, has been contacted by federal authorities investigating Trump attorney Michael Cohen and is cooperating with them, a spokesman for Davidson confirmed. Davidson was asked to provide “certain limited electronic information” for the probe led by prosecutors in the Southern District of New York, spokesman Dave Wedge said. “He has done so and will continue to cooperate to the fullest extent possible under the law,” Wedge said in a statement Friday. Shortly before the 2016 election, Davidson negotiated a confidentiality agreement with Cohen under which porn star Stormy Daniels was paid $130,000. Davidson also represented Karen McDougal, a Playboy centerfold, in the $150,000 agreement she struck in August 2016 with the National Enquirer’s parent company, American Media Inc., for the rights to her story. AMI never published the story. Both Daniels and McDougal have filed lawsuits to get out of their non-disclosure agreements. Earlier this week, McDougal settled with AMI — whose chief executive, David Pecker, is a friend of Trump — and is no longer bound by her contract with the tabloid publisher. FBI agents raided Cohen’s Manhattan office last week, as well as his home and a hotel room. -
Federal Election Commission 1 First General Counsel's
MUR737900022 1 FEDERAL ELECTION COMMISSION 2 FIRST GENERAL COUNSEL’S REPORT 3 MUR 73131 4 COMPLAINT: Jan. 23, 2018 5 AMEND. COMPLAINT: Mar. 12, 2018 6 NOTIFICATION DATE: Jan. 30, 2018 7 LAST RESPONSE: Apr. 12, 2018 8 ACTIVATION DATE: Sept. 20, 2019 9 10 STATUTE OF LIMITATIONS: 11 Oct. 27, 2021 (earliest) – Dec. 8, 2021 (latest) 12 ELECTION CYCLE: 2016 13 COMPLAINANTS: Common Cause 14 Paul S. Ryan 15 Allen J. Epstein 16 RESPONDENTS: Michael D. Cohen 17 Donald J. Trump 18 Donald J. Trump for President, Inc., and Bradley T. 19 Crate in his official capacity as treasurer 20 Trump Organization, LLC 21 Essential Consultants, LLC 1 The complaint in MUR 7637 (NRA-ILA, et al.) included the allegation that Donald J. Trump, Donald J. Trump for President, Inc., and Bradley T. Crate in his official capacity as treasurer, and Michael Cohen violated the Act due to Cohen paying a woman not to disclose information about Trump. Because this allegation is the subject of MUR 7313, and in order to consider the totality of that allegation, we have administratively severed that allegation from MUR 7637 and joined it with MUR 7313. See First Gen. Counsel’s Report at 1 n.1, MUR 7637 (NRA-ILA, et al.) Consequently, the complainant in MUR 7637, Allen J. Epstein, is now a complainant in MUR 7313; the respondents from MUR 7637 with respect to this allegation were already respondents in MUR 7313. MUR737900023 MURs 7313, 7319, and 7379 (Michael D. Cohen, et al.) First General Counsel’s Report Page 2 of 70 1 MUR 7319 2 COMPLAINT: Feb. -
White Paper: Headline Blues
HEADLINE BLUES: Number 23 ❖ October 2011 Civil Justice In The Age Of New Media BY RUSSELL SMITH TABLE OF CONTENTS Edited by Joanne Doroshow Introduction ….………………………………1 INTRODUCTION How Do People Get Their News Today and What Are They Learning ………………2 In January 2001, the Center for Justice & Democracy released a Our Methodology ……………………………4 White Paper entitled Reading Between the Headlines: The 1 Media and Jury Verdicts. The report analyzed the media’s General Findings …………………………… 4 coverage of civil jury verdicts and found this coverage to be A. Median award …………………………4 B. Plantiff vs. Defense Verdicts ………… 5 deeply skewed, fueling common misperceptions that civil juries C. Failure to Mention Caps ………………6 routinely award plaintiffs eye-popping verdicts for frivolous Maine Medical Malpractice Case … 6 claims. In addition, headlines commonly emphasized large Mississippi Asbestos Case ………… 7 monetary awards and rarely noted the misconduct that led to the 2 Notes ………………………………………… 12 verdict, such as: “$90 Million Awarded in Car Rollover Case,” “Fen-Phen Suit Nets Pair $29.1 Million Jury Award,”3 Appendix …………………………………… 14 4 “Ravenwood patient awarded $55 million,” “Jury Hands Car- Crash Victims A Record $5B,”5 “Jury Awards Two Brothers $105 Million”.6 Citing real world statistics used by legal scholars and empirical researchers, we found that news coverage of verdicts varied widely from what was actually happening in Center for Justice & Democracy at New York Law School the civil courts, namely that significant numbers of juries and 185 -
Interview Of: Hope Hicks
1 COMMITTEE ON THE JUDICIARY, U.S. HOUSE OF REPRESENTATIVES, WASHINGTON, D.C. INTERVIEW OF: HOPE HICKS Wednesday, June 19, 2019 Washington, D.C. The interview in the above matter was held in Room 2237, Rayburn House Office Building, commencing at 9:02 a.m. Members Present: Representatives Nadler, Lofgren, Jackson 2 Lee, Cohen, Johnson of Georgia, Deutch, Bass, Cicilline, Swalwell, Lieu, Raskin, Jayapal, Demings, Correa, Scanlon, Garcia, Neguse, McBath, Stanton, Dean, Mucarsel-Powell, Escobar, Collins, Chabot, Gohmert, Jordan, Ratcliffe, Gaetz, Biggs, McClintock, Lesko, Armstrong, and Steube. 3 Chairman Nadler. Good morning. Let's go on the record. This is a transcribed interview of Ms. Hope Hicks, former communications director for the White House. I requested this interview as part of our investigation into allegations of corruption and abuse of power and other misconduct by the Trump administration. Would the witness please state her name and position in the White House for the record? Ms. Hicks. My name is Hope Hicks, and I was the communications director at the White House. Chairman Nadler. I wish to thank you for appearing here today. I appreciate your willingness to appear voluntarily. Most committees encourage witnesses who appear for a transcribed interview to freely consult with counsel if they so choose, and you are appearing today with private counsel. Could counsel please state your name and current position for the record? Mr. Trout. Yes. My name is Robert Trout. I'm with the firm of Trout Cacheris & Solomon in Washington, D.C., and I'm representing Ms. Hicks. Ms. Solomon. Gloria Solomon, also with Trout Cacheris & Solomon, also representing Ms. -
Broidy's Motion to Seal
1 LATHAM & WATKINS LLP Marvin S. Putnam (212839) 2 [email protected] Jessica Stebbins Bina (248485) 3 [email protected] 10250 Constellation Blvd., Suite 1100 4 Los Angeles, California 90067 Telephone: (424) 653-5500 5 Facsimile: (424) 653-5501 6 Attorneys for Specially Appearing Defendant Elliott Broidy 7 8 9 SUPERIOR COURT OF THE STATE OF CALIFORNIA 10 COUNTY OF LOS ANGELES 11 12 SHERA BECHARD, Case No. BC712913 13 Plaintiff, Hon. Ernest M. Hiroshige, Dept. 54 14 v. FILED CONDITIONALLY UNDER SEAL PURSUANT TO COURT ORDER DATED 15 ELLIOTT BROIDY, an individual, KEITH JULY 6, 2018 PROVISIONALLY SEALING DAVIDSON, an individual; MICHAEL COMPLAINT AND ALL REFERENCES 16 AVENATTI, an individual; DAVIDSON & THERETO ASSOCIATES, PLC, a professional limited 17 liability company; and DOES 1 through 20, inclusive, SPECIALLY APPEARING DEFENDANT 18 ELLIOTT BROIDY’S NOTICE OF Defendants. MOTION AND MOTION TO SEAL OR 19 ALTERNATIVELY STRIKE SENSITIVE AND IMMATERIAL PORTIONS OF THE 20 COMPLAINT; MEMORANDUM OF POINTS AND AUTHORITIES IN 21 SUPPORT 22 Date: August 10, 2018 Time: 9:00 a.m. 23 Dept.: 54 24 HEARING ORDERED BY THE COURT 25 Action Filed: July 6, 2018 Trial Date: None Set 26 And 27 28 MOTION TO SEAL OR ALTERNATIVELY TO ATTO RNEYS AT LAW STRIKE PORTIONS OF THE COMPLAINT CENTURY CITY 1 TO ALL PARTIES AND THEIR COUNSEL OF RECORD: 2 PLEASE TAKE NOTICE that on August 10, 2018 at 9:00 a.m. in Department 54 of the 3 above-entitled court, located at 111 North Hill Street, Los Angeles, California, specially appearing 4 defendant Elliott Broidy will and hereby does move for an order sealing portions of the verified 5 complaint for damages and other relief, filed by plaintiff Shera Bechard. -
Opposition to Hogan's Motion
Filing # 30748485 E-Filed 08/11/2015 05:07:43 PM IN THE CIRCUIT COURT OF THE SIXTH JUDICIAL CIRCUIT IN AND FOR PINELLAS COUNTY, FLORIDA TERRY GENE BOLLEA professionally known as HULK HOGAN, Plaintiff, vs. Case No. 12012447CI-011 HEATHER CLEM, et al., Defendants. ______________________________________/ JOINT OPPOSITION OF THE GAWKER DEFENDANTS AND THEIR COUNSEL TO PLAINTIFF’S EMERGENCY MOTION TO CONDUCT DISCOVERY CONCERNING POTENTIAL VIOLATION OF PROTECTIVE ORDER, TO COMPEL TURNOVER OF CONFIDENTIAL DISCOVERY MATERIALS AND FOR ORDER TO SHOW CAUSE Gawker Media, LLC, Nick Denton, A.J. Daulerio (collectively, “Gawker”) and their counsel – including the law firms of Levine Sullivan Koch & Schulz, LLP (“LSKS”) and Thomas & LoCicero PL (“TLo”) – hereby jointly respond in opposition to the emergency Motion of plaintiff Terry Bollea. Bollea’s Motion seeks relief that is breathtaking in scope against both Gawker and its counsel. By his own admission, Bollea seeks this relief based on nothing but speculation that Gawker, its in-house counsel, or its outside law firms supplied the National Enquirer and its sister publication Radar Online (collectively, “the Enquirer”) with information about racist and homophobic statements he made during one of his recorded sexual encounters with Heather Clem. Given that there is no factual or legal basis to support Bollea’s Motion, it should be denied in its entirety. First, to be entitled to any discovery into an alleged violation of a court order or contempt of court, Bollea must make a meaningful threshold showing both that a court order has been violated and that Gawker or its counsel are the likely culprits.