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May30,Sbo^3Lp5 Aleniulria,VA 22314 Tekjihona Ms ^ RFCLIVEO FEC MAIL OPEI>ATiO??S CENTER 700] HAY 30 nACUi ? S THE AHeMCAN CONSBIItfATIVE UNION 1007 Cameron' Street May30,Sbo^3lp5 Aleniulria,VA 22314 tekjihona Ms. Ellen Weintraub, Chaiiman ^ ^ f ( (703) 836-8602 Federal Election Commission MUR #,O.^J2i2. ftuaiinOe 999 E Stieet, NW ro <703) 836-8606 Washington, D.C 20463 tfl OFRCER8 RE: Foimal Complaint Against Edwaids fbr Piesident cominittoe, rsi JuUus C3ianiben, Treasurer, John Edwards, candidate for President; and DwUA.KeeM individual Respondents Tab Ttamer, Don Howaiih; Suzell Smith; Stacy Fbit ViGfChaiman Kem; Robert Kem; Elaine Reeves; Else Latinovic; Anita Latinovic; Vildd TlMnnS.Wiiiler Sanchez; Donna Hosea; Linda Moen, John Doe and Jane Doe, otfaer to ,,^ieand Vto«<Chwiii0i umuuned donors to tfae Edwards for President conmiittee. ffl ^DooaUJ.DsviM ^lONMn CBmpripiet Jr* ! Ea RouciimB Dear Chaiiman Weintraub: C^JOffiCIOItS (ftahJcHcHdni ^Rtpi Diucn Homer This is a formal conqslaint against the Edwards for President' Committee, John Edwards, and certain named and unnamed individual BOARD OF DIRECTORS donors to fhe Edwards for President campaign for violation of the Federal JtSktif BcU Chukt Black Electioa Campaign Act of 1971, as amended CTECA**) and tfae Bipaitisan MocttmBkdKwdl Campaign Reform Act of2003 C'BCRA*') ^Complaint"). BcMiBouhcr L.BicBtBofdl|III Ebyd BMWB The Complaint is filed pursuant to 2 U.S.C. §437g(aXl) and 11 MuiidColann B«cky NononDunlop CFJL §111.4 by tfae American Conservative Union, Inc. C'ACIPO. The M. Samoa Bwu undeisigned serves as Chairman of ACU, a S01(cX4) non-profit Alan Gottlieb jMDMV.Uey coiporation and Ifae nation's oldest and laigest conservative grassroots Wsyns LiPiciic lobbying oiganization. MicliMlR.Loi« Robert Luddy 8ni> 8wffpfchi MiliMc This complaint is ba^ upon numeious media rqioits Oeta Mitchell documenting iU^al fimdraising activities by and illegal coniributions to Jotaph A. Motifa Edwards for President, several of which are referenced herein and/or Graver CNoiqidit " attached as exhibits to tfais Conaplaint This Complaint is based on tfae TomPfeuken JuMS Aithur Pope published leports tfaat Edwards for President Committee and John ROB RflbsMB Edwards and numerous donors and fimdraisers have violated tfae AOnRodi Craig Sldrlcy provisions of federal law related to fimdraising finr and contributions to U«liK.Uhlcr presidential campaign committees. KiffayWilbar EXECUnVB DIRECraR W. Stephen Tluiycr amhitot 1964... The HhSanH CUat and iMfUt Qraunof Conmmikm Ckiwnfufinii ACU hereby requests the Federal Eleclion Commission to conduct an audit of ^ contributions to the Edwards finr Piesident committee and tfaat no federal matchingfimds be audiorized for or paid to tfae Edwards fixr President committee until each contribution submitted for fisderal matching fimds has been specifically audited, the donors interviewed and tfae fiinds deemed to be contributions given fipeely and voluntarily torn tfae donora' own resources and otfaerwise not in violation of fisderal campaign finance laws. According to numerous rq>ozts, donors to the Edwards for President Committee 99 were pronused tfaey would be reii^ursed by tfaeir emptoyer(8) fiir contributii ^ the Edwards campaign. Other reports and investigations reveal that maximum level donora appear myt to have tfae finandal resources available to have made tfae reported contributions fixmi theur own fimds. Clearly, a pattem has emerged of illegal fimdraisiiig lfl and contributions mvolving the Edwards fin President canpaign wfaicfa demands action ^ by die Commisrion prior to tfae paymem of fisderal primaiy matching fimds and fiuther ^ whidi requires fhe imposition of penalties for violation of the law by tfaose guilty of sudi ^ violations. <H O H The Edwards fi»r President campaign has admowledgedsonaeiiregularities and «^ wrongdoing, but still not in a manner sufSdent to remedy a dear pattern of illegal ^ activity rqKiited in various public sources. sr The Washington Post, April 18,2003, Page Al, "Edwards Returns Law Fum's O Donations'*, by Thomas B. Edsall and Dan Bab Washington Post Steff Writers rqwited !S that The presidential campaign of Sen. John Edwards (D-N.C.) announced yesterday it Ol will retum $10,000 to employees of a Littie Rock law fiim afier a law cleik said she expected her boss to rdmburse her fin: a $2,000 donation. Federal dection laws prohibit a person fixmi fiumeling donations through someone else to conceal tfaeir source. Sudi practices would enable tfae reimbursed to exceed the legal contribution limit for hidividuals, recentiy raised to $2,000 fixmi $1,000 per peison per election." However, tfae retum of $10,000 does SQt begm to address tfae pattem of illegal activity ui wfaidi die Edwards campdgn faas engaged. Pd)lidied repoits finom tfae Center for Individud Fkeedom's wd>dte state diat twenty (20) peisons identified as paralegals and mne (9) listed as legal assistants employed by Turner & Associates PA in Littie Rock, Aikansas, contributed $2,000 eadi to tfae Edwaids campdgn afier recdving assurances tfaat tfaeir contributions would be reimbursed. From fhis law firm done, more than $58,000 in suspicious contributions to the Edwards campdgn were recdved,* yet only $10,000 was reported by the Edwards campdgn as bdng retumed to the donora fix>m tfaat fiim. See www.cfi£oig, John Edwards: An Oops for ihe Trial Lawyers* PreMentUd Candidate^ posted ^ril 24,2003. See dso **What John Edwards Money Said" by John Samples, www.cato.org, posted on die webdte of fhe Cato InstiUite on May 9,2003. Mr. Td> Tumer, prindpd in die faiw firai Cr^^ ^ employs fhe ^iiqiiidousUttle Rode donora was a major donor to Sen. Edw action committee during the 2002 dection cycle, haviqg contributed $189,000 to fhe New American Optimists PAC, according to die public records filed witii die Conunisdon. See Center for Respondve Politics, www.cip.oig. Mr. Tumer has been intimatdy involved in contributing to and fimdraisiiig for politicd committees assodated with John Edwards, indudhig but not lunited to die Edwards for Preddent Committee accordmg to fhe public records filed with the Commisdcm. Otfaer newspiyers faave sq>aratdy undertaken to investigate donors to the i 1^ Edwards fiir Preddent cainpaign and faave finmd similar illegd activities. (M Nl The Hill newspaper rqported on May 7,2003 that Edwards finr Preddent ^ campdgn documents filed of record witfa tfae FEC reved a pattem of illegd contributions ; ^ by low-level employees of law firms wfaose principals are engaged in contributing to and S fimdrdsing for ffae Edwards for President committee. 2^ According to The Hdl, "Donations to Edwards Questioned", by Sam Dedy, tfae H contributions fixmi low-level employees contributing at the maximum $2,000 level ^ arrived on tfae same day dong witfa contributions fimn tfae paitnera and attorneys of fhe ^ firms employing the individud donora. Further, die FEC records reflect tfaat ^ contiibutions fixmi spouses and other fiunily monben were also made on fhe sm 0 as those fixmi the low-level emptoyees ofthe law films. No conduit reports were filed by (0 fhe law firms whidi employ fhe donor-employees. fM According to The Hdl, questionable contributiqog.wsre recdved fiom Respondents Stacy Kem; Robert Kem; Elame Reeves;; Vikki Sandiez; Donna Hosea; Lmda Moen. Odier individud donors, based on public repoits, have also violated federd law witfa diam contributions to Edwards fiir Preddent committee. Piindpds of law fiims who may have engaged in illegd fimdraising practices include Respondents Td> Tbmer, Don Howartfa, Suzell Smitfa and otfaer trid lawyera may have engaged in coerdng or fiwilitating contributions fixmi or through their employees to fhe Edwards for Preddent campaign. Clearly, fhe Edwards fi>r Piesident committee's retum of a mere $10,000 does not begin to remedy a pattem of dear violation of FECA by tfae campdgn and its donora and fimdrdsing persoimeL The Respondents have violated numerous provinons of federd law, inchidmg but not limited to: 2U.S.C.§441a(a) Mddng excessive campdgn contributions 2U.S.C.§441a(f) Acceptmg excesdve campdgn contributions 2U.S.C.§441f Prohibitions on contributions in the name of anodier 2U.S.C.§441a(a)(8) Failure to report earmaiked contributions / fiiilure to report donor(s) as conduit(s) finr earmaiked contributions ACU deniands a filU and diorougfa investigation and audit of each donor and each rsl contribution to the Edwards finr Preddent committee and moves to enjoin fhe payment to Kl the Edwards finr Preddent campdgn of any fiderd primaiy matching fimds until eadi ST donor's contribution has been reviewed to msure its compliance with applicdile federd ST law. o [See 26 U. S. C. §9034, Umiting eligibility of prinuoy matdimg fiinds to lawfiil Kl o contributions]. H H Please contact me if you have fiirdier questions regarding tfais Coniplaint sr o American Co: Union AFFIDAVIT I hereby swear upon pendty of peijury that due above and foregoing Complaint is true and correct to die best ofmy Imowledge and bm£ based ufion diflinfoimation fix>m fhe public sources referenced herein. David A. Keene Swom and subscribed befine me this " mCT OF INBIA NOTARY SEAL My Omunismim EqriieK QscA .J*/^ 1^ ^ Copyright 2003 The Washington Post The Washington Post April 24, 2003, Thursday, Final Edition SECTION: A SECTION; Fg. A04 i V LENGTH: 585 words .HEADLINE: Law Firm's Donations To Edwards Probed; Justice Dept. ? 2J Reviewing Contributions Kl ^ BYLINE: Thomas B. Edsall, Washington Post Staff Writer Kl BODY: ^ The Justice Department's Criminal Division has Initiated an O Investigation Into contributions made by employees of a ^ ^ prominent Little Rock law firm to the presidential campaign of Sen. John Edwards (D-N.C). ^ The Investigation was prompted by news reports about $ 2,000 ^ contributions to the Edwards campaign made by four legal ^ assistants at the Tumer & Associates firm. One donor, Michelle O D. Abu-Halmeh, told The Washington Post that Tab Tumer, the (0 firm's principal lawyer, said he would reimburse her for her donation. Tumer said last week she would not be reimbursed.
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