Washington, DC 20005

4 FEDERAL ELECTION COMMISSION WASSESIO. DC X*3

THIS ISTE GII4NII5 OF MWR # i47E FILED CNA O. 4 - R PORTS ANALYSIS REFERRAL TO

OFFICE OF GENERAL COUNSEL

DATE: 26 Apr11 1989

ANALYST: Anthony D. Raymond I. COUITTt3: Keep Hope Alive Political Action Committee (C00229286) Cirilo A. McSween, Treasurer (October 15, 1988 - Present) Alvin J. Boutte, Treasurer (June 28, 1988 - October 14 1988) 733 15th Street, NW, Room 7001/ Washington, DC 20005

II. RELEVANT STATUTE: 11 CFR 102.5(a) (1) (i) I I I. BACKGROUND: Receipt of Apparent Impermissible Contributions From Unregistered Organizations The Keep Hope Alive Political Action Committee ("the Committee*) received apparent impermissible contributions from four (4) unregistered organizations totalling $5,850 during the 1988 October Quarterly reporting period. The 1988 October Quarterly Report disclosed the following contributions from unregistered organizations: $5,000 from Friends of Jesse Jackson on July 13, 1988; $250 from the John Wiley Price Campaign on July 9, 1988; $500 from the Committee to Elect Rev. A.R. Polk on July 10, 1988; and $100 from the Mid-Brooklyn Political Association on September 15, 1983 (Attachment 2). On December 7, 1988, a Request for Additional Information (wRFAI" ) was sent to the Committee concerning the permissibility of the funds received from the unregistered organ' zations. The RFAI stated that if the funds were impermissible, the Committee should refund the amounts to the donors or transfer the funds to a non-federal account with the donor's consent (Attachment 3).

l/ Prior to the 1988 Year End Report, the Committee listed its address as 1074 Thomas Jefferson Street, Washington DC 20007. KXEP ROPE ALXVE POLITICAL ACTION COMSTTEE RPORTS ANALYSIS OGC REFERRAL PAGE 2

On December 15, 1988, Cirilo A. NcSween, the Comittee1.', treasurer, filed a response that stated: We have transferred $6,975 from our Federal funds account to our Non-Federal funds account, while we work to verify the source of the money donated by the following groups--$5,000 from Friends of Jackson; $100 from the Mid-Brooklyn Political Association; $500 from the Committee to Elect Rev. A. R. Polk; $250 from the John Wiley Price Campaign; and $1,000 from Eddie Bernice Johnson; and another $125 to cover two checks which may be corporate. (Attachment 4 ). On December 30, 1988, a Second Notice was sent to the Committee requesting a photocopy of the transfer (Attachment 5)- On January 13, 1989, Steve Cobble, the Committee's Executive Director, met with the Reports Analysis Division (uRAD") analyst to discuss the Second Notice. The RAD analyst stated that a photocopy of the transfer-out was needed. Mr. Cobble explained that logistics problems had probably caused the omission but he was not certain the transfer had occurred. He stated he would investigate and that a written response to the Second Notice would be filed soon (Attachment6 ).

On January 30, 1989, Mr. Cobble submitted a letter addressing issues discussed in the meeting with the RAD analyst. Mr. Cobble acknowledged the transfer-out; however, the photocopy of the transfer-out was again omitted (Attachment 7 ).

On January 31, 1989, the Committee filed a copy of a debt memo for $6,975 noting the transfer-out which occurred on January 24, 1989 (Attachment8 ).

IV. OTHER PENDING MATTERS INITIATED BY RAD:

None. 0* ATTACHIIEMT #1 F w BETION COISSION DATE 14APR9 197-1999 C(N'IITIEE 1UEK OF 919CLOg1 9O9CWENTS - (C) PAGE 3

CITTEE DOCDENT RECEIPTS D19MR1MENTS 0 OF MICROFILM COEME DATES PAGES LOCATION TYPE OF FILER

KEEP HOPE ALIVE POLITICAL ACTION COMIITTEE ID C0022929 NON-PMTY NON-QUALIFIED 3IECTED OWIIATION: WE 1999 STATEMENT OF ORGANIZATION 303UNDS 3 99FEC/532/1035 STATEMENT OF ORGANIZATION - AIMN 2NT 27OCT9 I 99FEC/561/3639 JULY UMIER.LY 0 0 2931LH9 -30D08 3 98FEC/541/13'3 OCTOBER WTERLY 219,417 23,399 -30SEP98 24 88FEC/561/3641 131199IJLki3 OCTOBER UARTERLY - AflMEtOENT -30SEP9 2 BFEC/574i4746 25 OCTOBER QUARTERY - AFM ENT -30SE98 99FEC/581/0690 OCTOBER QARTERLY - Nw IJLILB1JUL99 -30SEPBB I 99'EC1591/0687 OCTOBER QUARTERLY - 3I -30SEP9 3 B9FEC/581/1298 V(ELST FOR ADDITIONAL INFORATION 13LIL98 -30SEP99 4 88FECt568/2721 FELF.ST FOR ADDITIONAL. INFORMATION -30SEP9 3 99FEC/575/4818 .'NT-GEERAL 2,969 18,290 1OCT99 -29NV 5 88FEC/574i4516 -r YEAR-END 1,096 26,922 29NOV8 -31DEC88 8 89FEC/583/2706 YEAR-END - AMENDMENT 1,096 35,797 29NOV8 -31DEC86 6 M9ECI599/4946 REQUEST FOR ADDITIONAL INFORMATION 29NOV8 -31DEC8 I B9FEC586/0159

TOTAL 223,481 0 77,486 89 TOTAL PAGES

All reports have been reviewed. Cash-on-hand as of 12/31/88: $ 146,045

Debts and obligations owed to the committee as of 12/31/38: S-0- Debts and obligations owed by the committee as of 12/31/300: S-- - I A 1 en Met,L . .Io

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N4mtf~tISO mom a C O 4M ' "is l t W-rvie t (7/r/e/30/SO D.z . lmeasm Ibis letter is pceqpted b/ the lissims p---_t -b- - review of the repet(Ia, ereoed aOraies quetiinS @omncralm certain informutioa cataimed In t.. report(s). Am itemiation followas

- th leetifIeation of om @cmtsibuto.e iNG& the coes om~ o and Seof ~le~u be .Aproed t epm hasbtibute isin_0e $2e in the ggregate during the oseaSar year Pasm a..nd Schoelo A =fMqP, tiay. ime ll(a)(i) h e entry lacking a coat betor a eoIupti oad of

Notes iIf rt cemlttee as mae at least eO effort per solicitation, either by a written request or by an oral request documnted in writing to obtain this Information from the contributoc, your =mitte 357 have ezercised "best efforts.' Under 11 C3 L4.7(b). wcb effort shall consist of a clear request for the Information (i.e. am, sailing address. m, etie5, and name of eeplqer) M~h g j~ n

st a•es U e best efforts e provision. y" al4 provide a copy of your solicitation or an epl-astios of the method (s) used to obtain catribut ic information. Clarifioation regarding 'beet efforts' should be disclosed dgri-e _ck two year aleU O"a beginning witb the first report f11d4 t e election year. 11 C€PS 104.3 (a) (4) (M) -T cu report discloses limited paymnts foC administrative expenses. Adminitrative eepemoes are payments made for the purpose of operating a politioel . 0e- r.

PAGE 2 OF ATTACHMENT #3

Oe te inlding# but not limited to. J utillities@. Sla lea. telepbm service, am an!d sl liege aW" pay s to a *10 ngg4in is 3005 of .Mo toa alendar so"t im o_ btORrDetil"e 8uaw I SoebduleP00,99 D,(2 Quportins9.8.c. 434Liae (b) (So I SdIiom. it eave boon imcred but -m is a [email protected], the activitW shuid be diewseed as a ~ O seele, Do if the obIlgtion i OW mere or 0Gtatanding for sixty (60) day8 or mOeO -i 164.11.

if a* expene* age being paid by a eew eailtlos, your statement of Organimation ml be minded to reflect this relationaship a u.S.0. 3433(b) (2). Any goods or services provided to your cmittee b, a pe•ma, except volunteer activity (i.e.. mc 's time). w d be considered as in-kind contributIm tram that persono, and muld be subject to the dIMlomero 2 irementg of 2 U.S.C. 1434(b) (3) and 11 Cft 104.13, tie limitations and prohibitions of 2 U.S.C. 15441 and 44lb. Plueae provide carifLicstion regarding admielotrative expenms incurred by your committee and/or memO you repart to disclose mach expenses according to tIe refecenced provisions of the Act and Os=86108 regulations. Clarifietion regarding admimistreeto ePeoses should be disclosed b gg NLj-rt a" tiLt Sxck beginning with the first report 1 is th inilecton year. -Aebodule A of your report (pertinet portiels) atta hed) discloses a contribtion(5) I ro an organisation(s) whicb is not a plitiosl omittee registered with tbe Cission. der 11 Clt 101.5()b. organizatios which are not political emittees w" the Act must either& 1) establish a soparate samset wbicb contains only those funds pecitted ender the Act* or 2) deownstrate through a reason6lo ecostise method that the organisetion he received ufficlieat funds subject to the limitations and preiblitiae In order to make the conttibution. It your Cmittee doe not finanCe aOm-fodoe I activity* the receipt of the referenced contrihtlnle) 10y violate the Isitat iona oan prohibitime of the Act. (2 U.S.C. 694410(f) ad 441b) If Your Venittue onsqes in both federal and noN-tedetol activity. *ithef through a separat* nocn-federal aocmant0 at " acount that financoo artivity in cootectioa with beth .v.

'3 PAGE 3 OF ATTACHMENT #3

edeal me se-federal eleotionss your emOite• loy be in wiolation of 11 C"3 102.S(a). Plase elatify vbtbet the ointribution(s) .tweoLd ft= th roeafenoed organlsatiss) Is prmisiblee. 9 W- *stoat that your canittee bas received tM Webih age not perueisible. the Comisson t r Sa that, At refund the Iue raissible aaoumt(s) to the bmw(s) to acoordance vi 11 CFi 13.3(h). Alternetieelr f Is cto t transfer the fnds to an soomant no see to sf me federal olectilos the C Oissimo advies that yo Inform te ontelbutot In writ a"d pro mid the costributer with the option of teCeivi mm reo-de Tn may wish to seek a wtittem autbocizatlo (eitbot before or after the transfer-out) from ti dase fo ny7 transfe-aut to protect the dono '5 Interests I olease infor the Coasission lmdiately Is weiti mad pbotocu ~ of your cbeck foe the refund o provtrasferaato ide a taeU s and trasferc-out ould disclosed on a supporting Schedule 8 for Line 36 or 3 of the report coering the period durla which tiey ae sede-- If the cautribution(s) is question Was incOWpletolY W your o dgiL5S C:) incorectly disclosed, you sbould awe*d report With tb clarifying ialtmautlem. / Althaulb the Cmission my take 9urther legal stWp8 contibtietsse 0o concecning the acceptane of prohibited prompt action by your Committee in refuedife or tcansfering-out the asnta will he takes late cons lder at ion. J A written response o r asmndest& to ywor 0l161010 treport(s) cocrrctinq the be proolel(s) should be filed 010 the Federal alection ComIssion witlin fifteen (IS) by *I the S date of this letter. It nageed assistae. lWas feel free to contect me on our toll-(ue uwt . o0$) 4WO!5)4. Ve U081 suerbo is (202) 376-2460.

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Sep~nteeoesitor bielysispots5 *alslievsalygt ATTACHMENT #4

am# mov Noeme 44'99 Keep3O~Alive Political& Action Cmittee 1074 Itomas Jefferson St* 4 Vashiflngtono D.C. 2000? ;V"

m. Anthony D. saymond ik Semior Anlyst Federal glectioD Commission "t a Street* U.. weseingtore., D.C. 20463 Dear Hr. Raymond. This letter will amend the third quarter report of the Kmp Hope Alive Political Action Comittee. We bhYO undertaken the following steps since the submission of that report, in order to rectify some inadequacies in the original submission: *We have sent out a letter from the PAC to all those donors who gave over $200, asking then their employer's name and their occupation (a copy of this letter is attached). have sent a letter to NMs. Beverlee Bruce. Ph.D., r 'We her asking if the $50 she gave us was personal# and asking to verify that she is a citizen. *We have added in the activity fzom the Atlanta bank account established at the time of the Democratic National Convention, which was inadvertently left off of the first third quarter report. (These new figures are attached. $6,975 from our Federal fund ewe have transferred to account to our Non-Federal funds account, while we work verify the source of the money donated by the following groups--$5,000 from Friends of Jackson; $100 from the Kid- Brooklyn Political Association; $500 from the Committee to Rev. A. R. Polk: $2c. from the John Wiley Price Elect and Campaign; and S1,000 from Eddie Bernice Johnson; another $125 to cover two checks which may be corporate. We trust this improves our submission. In the future, we will endeavor to file timely, complete, and accurate partic.larly as we gain more experience in the reports, in this FEC'PAC prozess. Thank you for yo.;r assista.ce -atter. Sincerely.,

Cirilo A. S e Treasirer ATTACO#ENT #5

F|OIA ELECTION COMMISSION W,3

~DS@Ser 30t 1966

C1410 save. mm"e Imp sope liy ftliticsl hails COMMt" 1074 thomrn Jeffso Wteet " Waebigtom. 0O MOW?

Identifiaotion numbers C00229266 References Ootober Quarterly Report (7/]./3!-9/N/II Dear Mr. 6o0veen8 On December 7@ 1968 you Were Gotified that a CeView Of the above-referenced report(s) raised UstioUs to pVoIl IS -- contributions and/or expenditures, sad the reporting of certain information required by the Federal Bleotion Campaigl aot. 4.40 Your December 15# 198 response is inoamplete because you have not provided all the requested information. ftc this ,0 response to be considered adequate, the following information is still required. 0: -Your report discloses limited payments fog administrative expenses. Administrative expenses are payments made for the purpose of operating a politicsl coimittee including, but not limited to, rent, utilities, salaries, telephone service, office equipment and supplies. Any such payments to a person aggregating in excess of $200 in a calendar year mast be disclosed on Schedule a, supporting Line 19 of the Detailed Sumary Page. (2 U.S.C. 5434(b)(S)) In addition, if expenses have been incurred but not paid in a reporting period, the activity should be disclosed as a debt on Schedule D, if the obligation is $500 or more, or outstanding for sixty (60) days or more. 11 CPR 104.11. If these expenses are being paid by a conected organization, your Statement of Organization must be amended to reflect this relationship. 2 U.8.C. 3433(b) (2). Any goods oc services provided to your cmmittee by a person, except volunteer activity (i.e., a person's time), would be considered an in-kind contribution from that person, and would be subject to the disclosure a.mam AuLnM i r"c", Aim m PAGE 2 OF ATTACHMENT #5

reui cements of 2 U.S.C. 5434(b)(3) and 11 C12 104.1, a the limitations and prohibitions of 2 U.s.C. SS443A and 441b. Please provide olarification regarding administrative expenses incurred by your committee and/or amend 3esg ert to disclose such expenses accocing to tM foleceaed' pcovisios of the Act and Commission regulations. Clacification regarding administrative eupenses should be disclosed Ouri • ,1g tt~ o-Iclnyear, n cl* obeginning with the- rst rpot f I

-Schedule A of your report (pertinent portion(s) attached) discloses a contribution(s) from an too% organization(s) which is not a political committee registered with the Commission. Under 11 Cit 102.5(b), organizations which are not political comittees under the Act must eithet 1) establish a separate acoount - which contains only those funds permitted under the Act, or 2) demonstrate through a reasonable accounting method that the organization has received sufficient 44) funds subject to the limitations and prohibitions in order to make the contribution. If your committee does not finance non-federal 0 .activity, the receipt of the referenced contribution(s) may violate the limitations and prohibitions of the Act. (2 U.S.C. S544la(f) and 441b) If your committee engages in both federal and non-federal activity, either through a separate non-federal account, or one account that finances activity in connection with both federal and non-federal elections, your committee may ~ be in violation of 11 CrR 102.5(a). Please clarify whether the contribution(s) received from the referenced organization(s) is permissible. To the extent that your committee has received funds which are not permissible, the Commission recommends that you refund the impermissible amount(s) to the donor(s) in accordance with 11 CPR 103.3(b). Alternatively, if you choose to transfer the funds to an account not used to influence federal elections, the Commission advises that you inform the contributor in writing and provide the contributor with the option of receiving a refund. You may wish to seek a written authorization (either before or after the transfer-out) from the donor for any transfer-out to protect the donor's interests.

...... U ..... - II II II I _i,9 ---- I ,-K- V ._

low POWI~hLPAGEm UL 3 OF ATTACHMIENT #5

If the mtr ibution (5) if question vms incompletely W Imercectl disclosed. you should m your Oillae1l report vit1 the lartifying stcnation. Altbohb the Comissin may take further legal tupe conoerning the acceptance of prohibited contributiom. prompt ction by your committee in refunding er tranferring-out the amounts will be taken into consideration. If this infornation is not received by the Camisie Within, c jeissem fifteen (15) days from the date of this notice, the action. ef may choose to initiate audit or legal enforcement sautt6O If you should have any questions related to this our toll-free number (o00) 424- t" please .contact Anthony Raymond on 9530 or our local number (202) 376-2480. Sincerely.

/" John D. Gibson Assistant Staff Director Reports Analysis Division , 4' IrELIECON ATTACHM4ENT #6

( ANIALYST: Tony Raymond CONVEItSATION MITN: Steve Cobble CO NNTEE: Keep Hope Alive MTCt January 13. 1989 SUIJECT(S): Second Notice

Mr. Cobble came in to discuss the December 30, 1988, Second Notice for the 1988 October Quarterly Report. We discussed "best efforts" and the receipt of possible impermissible funds. fir. Cobble explained that letters to contributors requesting information had been sent. Mr. Cobble then stated that he was not sure that the transfer-out of possible impermissible funds had occurred. He stated that he was in the process of establishing an office in DC, and that he would check with Chicago to get a copy of the bank transfer. He said that logistics had been a problem. Mr. Cobble was informed that the contribution from the Friends of Jesse Jackson was not a contribution from a federally registerdd committee. He said that he believed the funds were made up of individual contributions, but that his committee would take a conservative approach and transfer-out the funds. He said pr) that a written response to the Second Notice would be filed soon. ATTACHMENT #7 ,, KAU 161 weep Nope Alive Politice Action Comittee 733 ISth St., %..l AoM 0700 washington, D.C. 2000S January 130 14010

John D. Gibson Assistant Staff Director Reports Analysis Division rederal leotion Commission 999 a St.* N.V. washington. D.C. 20463 Gibsons Dear Mr. to 30. 1968 uld In response to your letter of December the Keep Hope Alive Political Action Comuittee@ I wO like to report the following: --You noted that during the period July 1. 196 low expenses through September 30. 1988. the PAC had very functions. That is correct. As it for administrative money the Keep Hope Alive PAC raised its early happens, at no cOsts at gatherings during the Atlanta Convention, the convention, and, from one direct mail effort after detailed in the for which the consultant expenses were section of the report. disbursement 196. had no staff until after October 15, The PAC (although no office space until December 1. 1986 It had for the PAC r r) of the PAC did agree to collect mail friends The PAC had our old Thomas Jefferson St. address). I-" at we had almost no phone until December 21, 1988. Thus, only the third no administrative expenses during not the post-election quarteL reporting perkod, but also for reporting perivd. a telephone (202) We now have an executive director; address above. Thew 737-4673; and a new office, at thq report, and in all costs will be reported in our next subsequent reports. contribution --The other question you had involved a was not registered the PAC received from a committee which Since that time, this $5,J00 contribution, with the FEC. we could another $1,975 in ,-ontributions which along with account, verify as qualified for our federal not quickly account. (The have been transferred to our non-federal verification.) -# 4e1 6"*A. deposit/transfer slip is attached for questions. I trust these res)onses will a nswer your .jiestionl, pl",ASe contact me If you have any furtlhir ' tO- - ' 'tbble, at throuqh the PAC *'ot i-'s in Wa 5 fln, 7117-467 1. 0' i) .; ~d

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FEDERAL ELECTION CONRISSIOSl 999 E Street, N.W. VE Washington, D.C. 20463 iii am FIRST GENERALCOUNSEL F REPORT AUG 1519 RAD Referral #89L-11

STAFF MEMBER: Daniel Blesgington SOURCE: I N T E R N A L L Y G E N E R A T E D RESPONDENTS: Keep Hope Alive Political Action Committee and Cirilo A. McSween, as treasurer RELEVANT STATUTES: 11 C.F.R. S 102.5(a)(1) '1 INTERNAL REPORTS CHECKED: Referral Materials ,0 FEDERAL AGENCIES CHECKED: None I. GENERATION OF RATTER

This matter was generated as a result of the review by the Reports Analysis Division ("RAD") of reports filed by the Keep Hope Alive Political Action Committee ("Committee"). RAD has indicated that the Committee's 1988 October Quarterly Report disclosed contributions from four unregistered organizations

totaling $5,850. Of this amount, $5,000 was reported as having been received from the Friends of Jesse Jackson on July 13, 1988; $250 from the John Wiley Price Campaign on July 9, 1988; $500 from the Committee to Elect Rev. A.R. Polk on July 10, 1988; and $100 from the Mid-Brooklyn Political Association on September 15, 1988.

The Committee responded to a request for additional information ("RFAI") by representing that it had transferred moneys from its federal funds account to its non-federal funds account while it sought to verify the source of the above-described and other contributions. In fact, funds were not -2- transferred until after the issuance of a second RFAI and a meeting between the Committee's executive director and a MWD analyst. The funds covering the $5,850 questioned by RAD were finally transferred out of the Committee's federal account on January 24, 1989; the total amount of the transfer was $6,975. The Committee established a non-federal account after receiving the RFAIs, having been unable to establish that the contributions from the Friends of Jesse Jackson and others were permissible. According to the Committee's executive director, the $5,000 contribution from the Friends of Jesse Jackson was from individuals unknown. Whether or not a formal entity by this name actually exists cannot be determined from the referral. The Committee registered in June of 1988. According to its executive director, the Committee was founded by Jesse Jackson; its purpose is described in its literature as helping "to deliver Reverend Jackson's message throughout the nation... (Attachment 2) II. FACTUAL AND LEGAL ANALYSIS Commission regulations at 11 C.F.R. 5 102.5(a)(1) require organizations that finance political activity in connection with both federal and non-federal elections to either establish separate federal and non-federal accounts or establish a political committee that only receives contributions subject to the limitations and prohibitions of the Federal Election Campaign Act of 1971, as amended. The Committee, by failing to establish a non-federal account until after receiving apparently impermissible contributions, violated this provision. -3-

R.IC .wTONS

1. Open a NUR.

2. Find reason to believe that the Keep Hope Alive Political Action Committee and Cirilo A. McSween, as treasurer, violated 11 C.F.a. I 102.5(a)(1).

3. Approve the attached letter, factual and legal analysis, questions, and document requests.

Lawrence M. Noble General Counsel

BY: Date Aoscae rner Associate General Counsel

Attachments: 1. Referral Materials 2. Letter to RAD 3. Proposed Letter and Factual and Legal Analysis 4. Questions, document requests t .

FEDERAL ELECTION COMMISSION WASHINCTON D C 0463

MEMORANDUM

TO: LAWRENCE M. NOBLE GENERAL COUNSEL

FROM: MARJORIE W. EMMONS /DELORES R. HARRIS COMMISSION SECRETARY DATE: AUGUST 7, 1989 SUBJECT: RAD REFERRAL 89L-11 - GENERAL COUNSELS REPORT DATED AUGUST 2, 1989

The above-captioned document was circulated to the Commission on uhursday.Agust3, 1989 at 4:00 p.m.

Objection(s) have been received from the Commissioner(s) as indicated by the name(s) checked below:

Commissioner Aikens

Commissioner Elliott x

Commissioner Josefiak x Commissioner McDonald Commissioner McGarry Commissioner Thomas

This matter will be placed on the meeting agenda for Tuesday, August 15, 1989 at 10:00 a.m. Please notify us who will represent your Division before the Commission on this matter. BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of ) Keep Hope Alive Political Action ) RAD Referral 89L-1 Committee and Cirilo A. McSween, as treasurer )

CERTIFICATION

I, Marjorie W. Emmons, recording secretary for the Federal Election Commission executive session of August 22, 1989, do hereby certify that the Commission decided by a vote of 5-0 to take the following actions with respect to the above-captioned referral: 1. Open a Matter Under Review (MUR). 2. Find reason to believe that the Keep Hope Alive Political aciton Committee and Cirilo A. McSween, as treasurer, violated 11 C.F.R. S 102.5(a)(I) and 2 U.S.C. S 441b.

3. Direct the Office of General Counsel to send an appropriate letter, factual and legal analysis, questions and document requests pursuant to the above-noted actions. Commissioners Aikens, Elliott, Josefiak, McDonald, and McGarry voted affirmatively for the decision. Attest:

Date Marjorie W. Emmons Secretary of the Commission FEDERAL ELECTION COMMISSION WASHINGTON. DC.20463

September 12, 1989

Crilo A. McSween, Treasurer Keep Hope Alive Political Action Comittee 733 15th Street, N.W. - Room 700 Washington, D.C. 20005 RE: MUR 2939 Keep Hope Alive Political Action Committee

Dear Mr. EcSween: On August 22, 1989, the Federal Election Commission found that there is reason to believe that the Keep Hope Alive Political Action Committee ("Committee") and you, as treasurer, violated 2 U.S.C. 5 441b, a provision of the Federal Election Campaign Act of 1971, as amended, and 11 C.F.R. S 102.5(a)(1) of the Commission's regulations. The Factual and Legal Analysis, which formed a basis for the Commission's finding, is attached for your information.

Under the Federal Election Campaign Act of 1971, as amended you have an opportunity to demonstrate that no action should be taken against the Committee and you, as treasurer. You may submit any factual or legal materials that you believe are relevant to the Commission's consideration of this matter. Please submit such materials to the General Counsel's Office along with responses to the enclosed questions and request for documents within 15 days of your receipt of this letter. Where appropriate, statements should be submitted under oath. In the absence of any additional information demonstrating -that no further action should be taken against the Committee and you, as treasurer, the Commission may find probable cause to believe that a violation has occurred and proceed with conciliation. If you are interested in pursuing pre-probable cause conciliation, you should so request in writing. See 11 C.F.R. 5 111.18(d). Upon receipt of the request, the Of-ice of the General Counsel will make recommendations to the Commission either proposing an agreement in settlement of the matter or recommending declining that pre-probable cause conciliation be pursued. Cirilo A. McSween Page 2

The Office of the General Counsel may recommend that pre-probable cause conciliation not be entered into at this time so that it may complete its investigation of the matter. Further, the Commission will not entertain requests for pre-probable cause conciliation after briefs on probable cause have been sailed to the respondent.

Requests for extensions of time will not be routinely granted. Requests must be made in writing and specific good cause must be demonstrated. In addition, the Office of the General Counsel ordinarily will not give extensions beyond 20 days.

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 authorizing such counsel to receive any notifications and other communications from the Commission.

This matter will remain confidential in accordance with 2 U.S.C. 5S 437g(a)(4)(B) and 437g(a)(12)(A), unless you notify the Commission in writing that you wish the investigation to be made public.

For your information, we have attached a brief description o of the Commission's procedures for handling possible violations. If you have any questions, please contact Daniel J. Blessington of this Office at (202) 376-5690. incerely,

Danny7L. McDonald Chairman

Enclosures Factual and Legal Analysis Procedures Designation of Counsel Form Questions and Document Request i~i- .....ii . ... ~. ... .-

FEDRAL ELECTION CONISSION

FACTUAL AND LEGAL ANALYS1S RESPONDENTS: Keep Rope Alive Political Action Committee and MUR 2939 Cirilo A. Ncsween, as treasurer

This matter was generated as a result of the review by the

Reports Analysis Division ("RAD") of reports filed by the Keep

Hope Alive Political Action Committee ("Committee"). RAD has

indicated that the Committee's 1988 October Quarterly Report

disclosed contributi6ns from four unregistered organizations

totaling $5,850. Of this amount, $5,000 was reported as having

\been received from the Friends of Jesse Jackson on July 13, 1988;

$500 from the Committee to Elect Rev. A.R. Polk on July 10, 1988;

and $100 from the Mid-Brooklyn Political Association on September

15, 1988. CD The Committee responded to a request for additional

information ("RFAI") by representing that it had transferred

- moneys from its federal funds account to its non-federal funds

account while it sought to verify the source of the

above-described and other contributions. In fact, funds were not

transferred until after the issuance of a second RFAI and a

meeting between the Committee's executive director and a RAD

analyst. The funds covering the $5,850 questioned by RAD were

finally transferred out of the Committee's federal account on

January 24, 1989; the total amount of the transfer was $6,975.

The Committee established a non-federal account after

receiving the RFAIs, having been unable to to establish that the -2- contributions from the friends of Josse Jackson and others yore permissible. According to the Committees executive director, the $5000 contribution from the Friends of Jesse Jackson was from individuals unknown. whether or not a formal entity by this name actually exists cannot be determined from the referral. The Committee registered in June of 1988. According to its executive director, the Committee was founded by Jesse Jackson; its purpose is described in its literature as helping "to deliver

Reverend Jackson's message throughout the nation... ." The Federal Election Campaign Act of 1971, as amended ("the Act"), prohibits "any corporation whatever" from "directly or indirectly" making any contribution or expenditure in connection with any federal election and prohibits any federal political committee f rom knowingly accepting any such contribution or expenditure. 2 U.S.C. 5 441b. Commission regulations at 11 C.F.R. 5 102.5 require organizations that finance political activity in connection with both federal and non-federal elections to either establish separate federal and non-federal accounts or establish a political committee that only receives contributions subject to the limitations and prohibitions of the Act. The Committee, in that it has accepted contributions from unregistered organizations in states and other jurisdictions that permit corporate or union contributions, received apparently impermissible contributions into its federal account. Therefore, there is reason to believe that the Committee and its treasurer, Cirilo A. Mcsween, violated 2 U.S.C 5 441b and 11 C.F.R.

5 102.5(a)(1) . BEFORE THE FEDERAL ELECTION COMMISSION In the Matter of ) ) ) MUR 2939 )

XNT3RD.OaTO33S AND 3GJ3MT FOR PROWUCTXON OF DOCUNEEITS

TO: Cirilo A. McSween, Treasurer Keep Hope Alive Political Action Committee 733 15th Street, N.W. Room 700 Washington, D.C. 20005

In furtherance of its investigation in the above-captioned matter, the Federal Election Commission hereby requests that you submit answers in writing and under oath to the questions set forth below within 15 days of your receipt of this request. In addition, the Commission hereby requests that you produce the documents specified below, in their entirety, for inspection and copying at the Office of the General Counsel, Federal Election Commission, Room 659, 999 E Street, N.W., Washington, D.C. 20463, on or before the same deadline, and- continue to produce those documents each day thereafter as may be necessary for counsel for the Commission to complete their examination and reproduction of those documents. Clear and legible copies or duplicates of the documents which, where applicable, show both sides of the documents may be submitted in lieu of the production of the originals. Keep Hope Alive XUR 2939 INSTRUCTIONS In answering these interrogatories and request for production of documents, furnish all documents and other information, however obtained, including hearsay, that is in possession of, known by or otherwise available to your including documents and information appearing in your records. Each answer is to be given separately and independently, and unless specifically stated in the particular discovery request, no answer shall be given solely by reference either to another answer or to an exhibit attached to your response. The response to each interrogatory propounded herein shall set forth separately the identification of each person capable of furnishing testimony concerning the response given, denoting separately those individuals who provided informational, documentary or other input, and those who assisted in drafting the interrogatory response. If you cannot answer the following interrogatories in full after exercising due diligence to secure the full information to do so, answer to the extent possible and indicate your inability C) to answer the remainder, stating whatever information or knowledge you have concerning the unanswered portion and detailing what you did in attempting to secure the unknown information. Should you claim a privilege with respect to any documents, communications, or other items about which information is requested by any of the following interrogatories and requests for production of documents, describe such items in sufficient detail to provide justification for the claim. Each claim of privilege must specify in detail all the grounds on which it rests. Unless otherwise indicated, the discovery request shall refer to the time period from June 1. 1988 to the present. The following interrogatories and requests for production of documents are continuing in nature so as to require you to file supplementary responses or amendments during the course of this investigation if you obtain further or different information prior to or during the pendency of this matter. include in any supplemental answers the date upon which and the manner in which such further or different information came to your attention. Keep Hope Alive mm 2939 DMINITIONS For the purpose of these discovery requestso including the instructions thereto, the terms listed below are defined as follows: "You" shall mean the named respondent in this action to whom these discovery requests are addressed, including all officers, employees, agents or attorneys thereof. "Persons" shall be doomed to include both singular and plural, and shall mean any natural person, partnership, committee, association, corporation, or any other type of organization or entity. "Document" shall mean the original and all non-identical copiest including drafts, of all papers and records of every type in your possession, custody, or control, or known by you to exist. The term document includes, but is not limited to books, letters, contracts, notes, diaries, log sheets, records of telephone communications, transcripts, vouchers, accounting statements, ledgers, checks, money orders or other commercial paper, telegrams, telexes, pamphlets, circulars, leaflets, reports, memoranda, correspondence, surveys, tabulations, audio and video recordings, drawings, photographs, graphs, chartse diagrams, lists, computer print-cuts, and all other writings and other data compilations from which information can be obtained. "Identify" with respect to a document shall mean state the nature or type of document (e.g., letter, memorandum), the date, if any, appearing thereon, the date on which the document was prepared, the title of the document, the general subject matter of the document, the location of the document, the number of pages comprising the document. "Identify" with respect to a person shall mean state the full name, the most recent business and residence addresses and the telephone numbers, the present occupation or position of such person, the nature of the connection or association that person has to any party in this proceeding. if the person to be identified is not a natural person, provide the legal and trade names, the address and telephone number, and the full names of both the chief executive officer and the agent designated to receive service of process for such person. "And" as well as "or" shall be construed disjunctively or conjunctively as necessary to bring within the scope of these interrogatories and requests for the production of documents any documents and materials which may otherwise be construed to be out of their scope. BEFORE TEE FEDERAL ELECTION COMMIISS ION Keep Hope Alive MUR 2939

QUESTIONS AND REQUEST FOR DOCUMENTS A. Questions

1. Please describe the circumstances surrounding the receipt of a $5,000 contribution from the Friends of Jesse Jackson, reported as having been made on July 13, 1988. include any discussions between you and representatives of the contributor.

2. Please describe the Friends of Jesse Jackson, referred to in question #1. State whether or not it is a formal organization. if it is a formal organization, provide its address and the names of its officers. If not a formal organization, provide the names and addresses of those individuals comprising the group. B. Document Request

1. Please provide all documents and materials that relate, refer or pertain to the following contributions that you reported receiving.

a. $5,000 from the Friends of Jesse Jackson (July 13, 1988).

b. $250 from the John Wiley Price Campaign (July 9, 1988); C. $500 from the Committee to Elect Rev. A. R. Polk (July 19, 1988); and

d. $100 from the Mid-Brooklyn Political Association (September 15, 1988). -~ ~ ~

PATTON, BOGGS & BLOW ...... AM 2680 M STREET, N.W. 4A&Ak WASHINGTON. D.C. 20037-1350 a- 44p (202) 457-6000 TELECOPER 457-6315 MOWIN. MYLM0 21201 R79 -178MMMCMA P

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Mr. Jeff Long Office of General Counsel Federal Election Commission BY HAND 999 E Street, N.W. Washington, D.C. 20463 Re: M4UR 2939, Keep Hope Alive PAC Dear Mr. Long: As we discussed this morning by telephone, Patton, Boggs& Blow has been designated as counsel to Keep Hope Alive Political Action Committee ("Keep Hope Alive PAC") in the above-referenced _ MUR. Attached is the designation of counsel form. This letter confirms our request for a 14-day extension to respond to the Commission's inquiry by October 17, 1989. This extension is necessary to enable us to obtain relevant documents from the PAC's bank in Chicago and to contact by letter people D who may be familiar with the making of the contributions at issue in this MUR. The PAC's Executive Director, Steven Cobble, already has been successful in contacting some of these people by

telephone, but others are reachable only by letter. If we do not receive responses to our written inquiries by October 17, we will - file as complete a preliminary response as possible and supplement that response as we receive more information. Thank you for your cooperation. I look forward to receiving formal approval of our extension shortly.

Sincerely,

Katharine Y. Boce Counsel to Keep Hope Alive PAC KRB/tsp Attachment cc: Steven B. Cobble, Executive Director Keep Hope Alive PAC Roger Ballentine, Esquire sTAT, 07Of DBSIAT 0f COUOSL

1DM #2932 Ms. Kate Boyce

Patton. Boggs & Blow

VADNIC 2550 M Street, N.W. Washington, D.C. 20037

(202) 457-6094

The above-named individual is hereby designated as my counsel and is authorized to receive any notifications an4.other communications from the Commission and to act on my bebalt efore the Commission.

9/20/89 (Dr. Mary F. Berry) / Signature Date (Secretary/Treasurer, Keep Hope Alive PAC)

(Keep Hope Alive PAC) RESPONDENT'S NAME: Cirilo A. McSween ADDRESS: 230 South State Street

Chicago, Illinois 60604

BONN PROEt (312) 786-1918 (w) SUSIaS " 61,1 FEDERAL ELECTION COMMISSION WASHINCTON. D C 20463

October 6, 1989

Katharine R. Boyce, Esquire Patton, Boggs & Blow 2550 R Street, N.W. Washington, D.C. 20037-1350 RE: MUR 2939 Keep Hope Alive PAC and Cirilo A. McSween, as treasurer

Dear Ms. Boyce: This is in response to your letter dated October 3, 1989, which we received on October 4, requesting an extension of 14 days until October 17 to respond to the Commission's findings and request for information. After considering the circumstances presented in your letter, I have granted the requested extension. Accordingly, your response is due by the close of business on October 17, 1989. If you have any questions, please contact Jeffrey D. Long, the staff member assigned to this matter, at (202) 376-5690. Sincerely, Lawrence M. Noble General Counsel

BY: George F. Rishel Assistant General Counsel PATTON, BOGGS & BLOW 2550 M STREET. N.W. WASHINGTON. D.C. 20037-1350 (202) 457-6000 TELMOPMt 457-6316 TRT TEEX. 197780 104 NORTHELM STREET BALTIMORE.20 WESTMAYNDN ATT *1 REETL912M R.MRN NORTH CARftJNA 070 (31) MW N 1027-1r3

700 RALEGONF10@%L wAv*s BAN it".ASIT1oM KENNEDYOWL.EU ALJEON. NORTHCAROLINA 270W A1 Am EUER==D 014832-41114N)2- October 17t 1989

457-6094 2 -V VIA HAND DELIVERY Mr. Danny L. McDonald Chairman Federal Election Commission 999 E Street, N.W. Washington D.C. 20463 Re: MUR 2939, Keep Hope Alive PAC Dear Chairman McDonald: By this letter and enclosed documents, the Keep Hope Alive Political Action Committee ("Keep Hope Alive PAC"), by and through its attorneys, Patton, Boggs & Blow, responds to the Federal Election Commission's Interrogatories and Request for Production of Documents dated September 12, 1989. Thank you again for your extension of time for the filing of this Answer. Having sought and obtained, by all reasonable means, the information relating to the contributions to the Keep Hope Alive PAC in question, your questions can now be answered as follows: Answer to Question 1. On June 20, 1988, a twenty-five dollar ($25) per plate dinner was held at the Shiloh Baptist Church located at 9th and P Streets, N.W., Washington D.C.. The dinner was advertised throughout the community, via flyers and invitations, as a dinner featuring the Reverend Jesse Jackson. Reverend Jackson had planned to attend, but could not due to a scheduling conflict. The guest speakers who did attend included Mayor Marion Barry and Congressman Walter Fauntroy. Approximately three hundred (300) people were at the dinner. The organizers of the dinner opened an account at the Industrial Bank of Washington specifically for this event. The account was opened in the name "Friends of Jesse Jackson". The profits from the dinner-- five thousand dollars ($5000) -- were placed into this account. Shortly after the dinner, according to one of the organizers of the event, Mr. Joseph Beavers, the organizers consulted with Jesse Jackson who suggested that the PATTON. BOGGS & BLOW

Chairman Danny L. McDonald Page 2 October 17, 1989 proceeds of the dinner be contributed to the Keep Hope Alive PAC. On July 13, 1988, a five thousand dollar check representing all of the profits from the dinner was written to the Keep Hope Alive PAC. The "Friends of Jesse Jackson" bank account was thereupon closed out. Answer to Question 2. As discussed above, "Friends of Jesse Jackson" is not a formal organization. This was merely the name given to the bank account opened for the purpose of receiving and transferring the proceeds of a dinner held in Washington D.C. at the Shiloh Baptist Church. The head organizer for this event was Mr. Joseph Beavers. Mr. Beavers is a clerk and a trustee of the Shiloh Baptist Church. Mr. Beavers can be reached at (202) 654-6391, and correspondence may be sent care of the Shiloh Baptist Church.

Although your Questions do not seek a description of the circumstances surrounding the three other contributions to the Keep Hope Alive PAC mentioned in your Factual and Legal Analysis enclosed with the Commission's September 12, 1989 letter, we have now obtained information pertaining to those contributions, and we wish to share that information with you. Mr. John Wiley Price is a county commissioner from Dallas, Texas. On July 9, 1988, he wrote a check to the Keep Hope Alive PAC from his campaign fund in the amount of $250. We have spoken with Mr. Price, and he has stated that there was at that time no corporate or labor money in his campaign account, nor did his campaign receive any personal contributions greater than $5000. Mr. James Conolly is the District Leader of the 42nd State Assembly District in New York, and on September 15, 1988 he signed a check for $100 made out to the Keep Hope Alive PAC from the Mid-Brooklyn Political Association. The Mid-Brooklyn Political Association was an account opened for the purpose of impacting local races in Brooklyn. Mr. Conolly has informed us that the account contained no corporate or union money and no individual contributions of more than $5000. We are still seeking information pertaining to the $500 check to the Keep Hope Alive PAC from the Committee to Elect Rev. A. R. Polk dated July 19, 1988. We have written to the last known address of this organization and we are awaiting a reply. We can supply any such information that we obtain. PATTON, BOGGS & BLOW

Chairman Danny L. McDonald Page 3 October 17, 1989

As this information indicates, all of the contributions in question received by the Keep Hope Alive PAC were properly deposited into the PAC's federal account. Furthermore, we believe that the $5000 representing the profits of the dinner at the Shiloh Baptist Church was properly transferred to the Keep Hope Alive PAC under 11 C.F.R. S 102.6. We do acknowledge, however, that this receipt originally was not properly reported. By virtue of 11 C.F.R. SS 102.6(c)(5),(7) and $ 104.3(a), the Keep Hope Alive PAC was not obligated to report the names of the individual attendees at the dinner, but it should have reported the aggregate $5000 amount as a memo entry of unitemized contributions. Instead, the amount was reported as a receipt from a committee. This $5000 and the other three contributions have since been transferred out of the Keep Hope Alive PAC's federal account and into its non-federal account, and the PAC's reports have been amended to reflect this transfer. Therefore, we do not presently see a need to amend further the initial reports listing these contributions.

Document Request. Enclosed please find all of the documents, excluding only attorney-client communications, that pertain to the transactions discussed above.

We trust that this information satisfies the Commission's requests and demonstrates that no prohibited funds were deposited into the federal account of the Keep Hope Alive PAC. We will be happy to provide any further assistance needed by the Commission in order to close this matter without further action.

Very truly yours,

Katharine R. Boyce PATTON, BOGGS & BLOW Encls. cc: Daniel Blessington, Esquire PATTON. OGS & BLOW 4C Mmoz 250 SON.u PC40. JU030 0002O 0a) 4474000f.

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Re: Reglstration of the eep ROe Alive PAC To Whom It May Concern:

As counsel to the Keep Hope Committee. I am forvarding Alive Political Action the attached Statement tc register of Organization the Committee with the Comission. Thank you in advance for handling the PACos registration

Sincerely,

Ratharine R. Boyce K B 'er.c £closure cc: Alvin '. Bouts.e

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Gent leen Inclosed is the first querterly report filing for Keep P.) Political Action Committee mope Alive which was due m July IS, 198. Please n' accept my apology for not having now filed this report On a timely basis. We were formed on Jue 28, deadline 1908 and were not aere of the filing of July 15. There was so activity for this period. You my V assured that the next report be due on October 13 and all subsequent reports will be filed on time. Thank you for your consideration.

eo Alvin J 4 utte Treasurer

AJB/Jm Enclosure

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Keep Hope Alive Political Action Committee ADDRESS (numer I and sw 0 Check Ndfferee than previously ;epWrtd_ 2. FCIOMNTIFICATION NUMBER 7936 S. Cottage Grove Avenue Coo229286 CMY STATE an ZIP CMC 3.I This axwMste quelld asamuocnmdt Chicago, Illinois 60619 CIeon e OU( PPX" datped 4. TYE OF EPOR 4. TYPE OF REPORT

(a)[3Apri 15 Ouatiy Repor Monthly Report Due On: 0 Febuary [-] July ISOuartedy Repor 20 0 June20 0 Octoer20 0 March20 0 July20 0 November20 April 20 LIOctober1ISQuarterly Report o 0 August 20 0 December20 o May 20 0 Septeber20 0 JAnmary31 L- January31 Yea End Rpo [ Twefth day report preceding (TrPea Eeciion) July 31 Mid Yew Report (Non-election Year Only) elction on n the State of_-

[j] Thirtieth day report foll owne General Election on [) Termination Report in the State of_ ____

(b) Is this Report an Amendment? [YES [jNo

SUMMARY COLUMN A COLUMN B 5. Covering Penod 6/28/88 _through 6/30/88 This Pw Calender Year-to-Date 6. (a) Cash on Hand January 1, 19 88 . -0- (b) Cash on Hand at Beginning of Reporting Period $ --

(c) Total Receipts (from Line 18) ...... $ -0-$ - (d) Subtotal (add Lines 6(b) and 6(c) for Column Aand ...... Unes 6(a) and 6(c) or Column 8) $ -0- -n-

7. Total Disbursements (from Line 28) . • o TT$ -0- $ -0- Cash on Hand at Close of Reportng Period (subtract Line 7 from Line 6(d)). $ -- 9. Debts and Obligations Owed TO the Committee For further Information (Itemize all on Schedule C and/or Schedule D)...... $ -0- con 10. Debts and Obligations Owed BY the Committee Feder Election Commissn (Itemize al on Schedule C and/or Schedule D) ...... $ -0- Washington,999 E Stron, DCNW 20463 cerlify that I have examined this Report and to the best of my knowledge and belief it is true, correct Toll Free 800-424-9530 and complete. Local 202-376-3120 Type or Print Name of Treasurer Alvin J. Boutte Signature of Treasurer Date

NOTE: Submission of faii erroneous, or incomplete information may sublect the person signing ts Report to the penalties of 2 U.S.C. §437g.

II I I I I 000j4 FEC FORM3X(revise Q37) I I I I I I 4/ 4 don",oM PAGE*

Mne of"Cormmitee (in Wi) ... I C ow Po" Keep Hope Alive Political Action Committee From: 6/2888 To: 6/30/88 . COLUMN1 A COLUMN 8 L RICEMT 11 11. CONTRIBUTIONS (other than loans) FROM:...... (a) Individuals/Persons Other Than Political Committees .... (i) Itemized (use Schedule A) ...... (ii)Unitemized...... (iii) Total of contribulions from individuals...... (b) Political Party Committees ...... (c) Other Political Committees (such as PAC) ...... (d) TOTAL CONTRIBUTIONS (add 11(a)(ii), (b)..and ()).

12. TRANSFERS FROM AFFILIATED/OTHER PARTY COMMITTEES -0- -0- 13. ALL LOANS RECEIVED ...... -- -0

14. LOAN REPAYMENTS RECEIVED ...... -0- -0-

15. OFFSETS TO OPERATING EXPENDITURES (Refunds.Rebates. etc.) -0- -0- 16. REFUNDS OF CONTRIBUTIONS MADE TO FEDERAL CANDIDATES AND OTHER POLITICAL COMMITTEES ...... - 0- -0- 17. OTHER RECEIPTS (Dividends.Interest. etc.) ...... -0- -0-

18. TOTAL RECEIPTS (add 11(d), 12, 13, 14. 15. 16 and 17) -0- -0- II.DISBURSEMENTS 19. OPERATING EXPENDITURES...... -

20. TRANSFERS TO AFFILIATED/OTHER PARTY COMMITTEES -0--0 21. CONTRIBUTIONS TO FEDERAL CANDIDATES AND OTHER POLITICAL COMMITTEES -0- -0- 22. INDEPENDENT EXPENDITURES (use Schedule E) ...... -0- 23. COORDINATED EXPENDITURES MADE BY PARTY COMMITTEES (2 U S.C. 441a(d)) (use Schedule F)...... -0- -0- 24. LOAN REPAYMENTS MADE -0-

25. LOANS MADE ...... - o- -0- 26. REFUNDS OF CONTRIBUTIONS TO: (a) Individuals/Persons Other Than Political Committees ... -0- -0- 26(s) (b) Political Party Committees ...... - 0- -0- 26(b, (C)Other Political Committees (such as PACs) ...... - 0- -0- 26(c) (d) TOTAL CONTRIBUTION REFUNDS (add 26(a), (b), and (c)) -0- -0- 26d) 27. OTHER DISBURSEMENTS ...... 28. TOTAL DISBURSEMENTS (add 19, 20, 21, 22, 23, 24, 25, 26d) and 27) ...... -0- -0- III. NET CONTRIBUTIONS/OPERATING EXPENDITURES 29. TOTAL CONTRIBUTIONS (other than loans)( from Line 11 (d)). . . -0- -0- 30. TOTAL CONTRIBUTION REFUNDS (from Line 26(d)) . -0- -0- 31. NET CONTRIBUTIONS (other than Ioans)(subtract Line 30 from 29). -0- -0-

32. TOTAL OPERATlI ; EXPENDITURES (from Line 19) -0- -0- 33. OFFSETS TO OPERATING EXPENDITURES (from Une 15).... -0- -0- 34. NET OPERATINQ EXPENDITURES (subtract Line 33 from 32) . .. -0- -0-

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Mr. Cirilo A. McSween 230 S. State St. Chicago, Illinois 60604 Dear Mr. McSween, How are you? Well, I hope. I met with our analyst at the FEC for the Keep Hope Alive PAC, regarding our third quarter submission. He made several suggestions for improving our report, which I talk about below. He also said that if we acted quickly to fix some of the inadequacies of the report, and sent him a letter to that effect right away, it would improve the report before he "officially" had a chance to review it. Therefore: *I have sent a letter out to all our donors over $200, asking for their employer's name and occupation, which the FEC requires us to ask. *I have sent a letter to a woman who donated to us from Liberia, verifying that she is not a foreign national, since they are barred from donating to PACs. *I have identified the following steps that the PAC needs to take right away, which fall under your jurisdiction as PAC Treasurer (these are all related to problems which our FEC analyst noticed): --we should transfer $6,975.00 from our Federal PAC account to our Non-Federal PAC account. This will cover donations which may have included, unintentionally, corporate or union funds, such as the $5,000 from the Friends of Jackson (address unknown); $1,000 from Eddie Bernice Johnson; $500 from the Committee to Elect Rev. A. R. Polk; $250 from the John Wiley Price Campaign; $100 from the Mid-Brooklyn Political Association; and $125 from two small checks we received, possibly corporate. --We need the campaign to bill the PAC for the use of the list to mail our first batch of letters last July. --We need to add in the new information from the bank account in Atlanta, which I will be glad to do as soon as you can send it to me. --We need to send the FEC the attached letter to our analyst, Mr. Anthony Raymond, pointing out that we have taken 'all these steps. If you would sign this letter, and send it to me as soon as possible, I will complete the Atlanta information, and turn it in to the FEC immediately. Thanks. This should greatly improve our submission. Sincerely,

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00001I3 o lso er . iss sep Nope Alil" political Ation Comittee 1074 emas Jefferson St. Wtehington, D.C. 20007 Xr. knthony D. taymn Senior Analyst redeTal 3lection Coamission 999 3 Street* N.W. Washington, D.C. 20463 Dear r. Raymondv This letter vii amend the third quarter report the Keep Hope Alive Political of undertaken Action COmmittee. We have the folloving steps since the submission that report, in order to of rectify some inadequacies in the original submissions *We have sent out a letter donors who from the PAC to all those gave over $200, asking them their name and their occupation employers (a copy of this letter is attached). *We have sent a letter to Ns. Deverlee asking if the $50 she gave ruee, Ph.D., us was personal, and asking her to verify that she Is a citizen. *We have added in the activity from the Atlanta account established at the time bank Convention, of the Democratic National which was inadvertently left third quarter report. off of the first (These nay figures are eWe have transferred attached.) $6,975 from our Federal funds account to our Non-Federal funds verify account, while vs work to the source of the money donated groups--$S5,O00 from by the following Friends of Jackson: $100 from Brooklyn Political Association; the Kid- $500 from the Comittee Elect Rev. A. R. Polk; $250 to Campaign; from the John Wiley Price and $1,000 from Eddie Bernice $125 to cover Johnson; and another two checks which may be corporate. We trust this improves our we submission. In the future, will endeavor to file timely, complete, reports, and accurate particularly as we gain more FP-C/PAC experience in the process. Thank you for your assistance -Itter. in this

Treasurer

.OO014 lin- ',-

M. AnjKW D. ,,.rd smximj kanjv, P a1 EdElecticn Oami Sjum 999wind.r,,q 3 Stzt, D.C.W.V. 20463

.000015

I ItIII lIISIIIIIsII,,,~II~gI~IJ (Summary Page) I 1. NAME OF COMMITTEE (% .i |1 ii 1U' Oti Lkx1vIlAd " ' mm:Je *1 ADDRESS ( n.b 0 91110 1 In .,PIously r, d 2. FC IFICATMO NUM13ER ~

CITY, STATE and ZIP COOE 3. ] This =owmiW qualified as a murftlnddats Do-unite DURIN ThI Reporting Period I I__OR, on _(date). 4. TYPE OF REPORT

(a) [] April 15 Quaftdy PA Monthly Rep Due On: o Februay20 0 June20 - 0 Ocftaer20 []I July15uartey Re 20 0 July 20 0 NOvember20

October15O-' O m 0 April20 0 Augus20 0 December 20 o May20 0 SW ~eme200 January 31 ]January 31 Year End Repas [Twelft da re ______(Type of Election) -" July 31 Mid Year Repao (Non-election Year Only) election on in the State of

-,/'Thirtieth day report following the General Election on

(I Termiunation Report I1 in t oete~ - 1kS

(b) Is this Report an Amendmem? ] YES -

SUMMARY COLUMN A COLUMN B 1 5. Covering Period. ( -through A^, '_ 1Jj Ts Peod Calendar Year-to-Dat.

6. (a) Cash on Hand January 1. 19L.. . $ COc

(b) Cash on Hand at Beginning of Reporting Period . .. . $

(d) Subtotal (add Lines 6(b) and 6(c) for Column A and ...... Unes 6(a) and 6(c) for Column ) $ iR L.$ :lu g, .3 7. Total Disbursements (from Line 28) ......

8. CashonHandatCloseooRePWOngPeriod(subtractL ne 7from .ne 6(d)) $ IRL . , $ 9. Debts and Obligations Owed TO the Commttee For further Information (Itemize all on Schedule C andor Schedule 0) . $ Cu contact: 10. Debts and Obligations Owed BY the Committee Federal Election Commission (Itemize all on Schedule C and/or Schedule 0) ...... $ C Washington.9 NC 20463

1 certify that I have examined this Report and to the best of my knowledge and behef i is true, correct Toll Free 800-424-9530 J and complete. Local 202-376-3120 Type or Print Name of Treasurer

bignature ov Ireasurer

IDate NOTE: Submission of false, erroneous, or incomplete information may subject the person signing this Report to the penalties iI of 2 U S C. §43'g 0004016 FEC FORM 3X (revised 4,87) ER PAGE FOAM 3X - .. . A

L RECEIPTS 11. CONTRIBUTIONS (other than loans) FROM: ...... (a)IndvlWualsjPrson Oew Than Politi Commiees. (I) Itemized (use Sfhdle A)...... ~2NSOe ii Unteed.. ) ..... 2.-14.1. Xt 11(a)) (w)Towa of trblosfrom idividuals 11(11) (b)Political Party Corm ...... 11(83(w) 6, j L 00b, 11(b) (c) Other Political Committee (such as PACE) . (d) TOTAL CONTRIBUTIONS aM 1Ifafliti II aiv tli 11(c) li ri@ lit" Alt I /li i 11(d) 12. TRANSFERS FROM AFFILIATEDIOTHER PARTY COMMITTEES

13. ALL LOANS RECEIVED ......

14. LOAN REPAYMENTS RECEIVED ...... (Refunds,Rbates, etc.) 15. OFFSETS TO OPERATING EXPENDITURES

16. REFUNDS OF CONTRIBUTIONS MADE TO FEDERAL CANDIDATES AND OTHER POLITICAL COMMITTEES ...... 17. OTHER RECEIPTS (Dividends.Interest. etc.) ......

18. TOTAL RECEIPTS (add 11(d), 12, 13, 14, 15, 16 and 17) ...... 11.DISBURSEMENTS Im

19. OPERATING EXPENDITURES.(d=t tlM). w., k,, is4t i#t.r -,*I4L0 7-1

20. TRANSFERS TO AFFILIATED/OTHER PARTY COMMITTEES . . . 21. CONTRIBUTIONS TO FEDERAL CANDIDATES AND OTHER POLITICAL COMMITTEES ... 22. INDEPENDENT EXPENDITURES (use Schedule E)...... 23. COORDINATED EXPENDITURES MADE BY PARTY COMMITTEES U.s.C. (2 441a(d)) (use Schedule F)...... C 24. LO AN REPAYM ENTS MADE ...... ,,Or

25. LOANS MADE...... 26. REFUNDS OF CONTRIBUTIONS TO: (a) Individuals/Persons Other Than Political Committees . (b) Political Party Committees .. ._._._._...... m6a) (c) Other Political Committees (such as PACs) ...... 26(b) (d) TOTAL CONTRIBUTION REFUNDS (add 26(a), (b), and (c)) C 26(c) 26(d) 27. OTHER DISBURSEMENTS ...... C 28. TOTAL DISBURSEMENTS (add 19, 20. 21.22, 23, 24. 25, 26(d) and 27) ...... III. NET CONTRIBUTIONS/OPERATING EXPENDITURES 29. TOTAL CONTRIBUTIONS (other than Ioans)(from Une 11d.( . • .d1 .i ._1___1.__ 30. TOTAL CONTRIBUTION REFUNDS (from Line 26(d)) • , 7 __ "__,_____ - 31. NET CONTRIBUTIONS (other than loans)(subtract" :e 30 from 29). s I. is

32. TOTAL OPERATING EXPENDITURES (from Line 19) I 0, Si .I

33. OFFSETS TO OPERATING EXPENDITURES (from Line 15) . .,______,.______34. NET OPERATING EXPENDITURES (subtract Line 33 from 32) J23, 11i , PaOp SCHEDULE A RECEIPTS !ue. cotagey of dw O ofed Summary Ptp IFOR LINE NUmSER PII A*~ /A Any mn-fOtion Copied from such RutRp,_ OWs ernan may not be sold or se by any peson for the purpoe of soliciting iupoee. other en using the name M contributions or for commercl Ode Oof eny politicalcommittee to socit contr butlons from ouch coenmltn. An OF C--,Y?5TIE (in Ful. Amo.ntrof Eac

I A. F, Nae. Maiing Addrw I an ZIP COeO Name of Employer Date (month. Amount of Each HMII day, yer) Reelt this Period .1% Oceupation AVcc Receipt For: [_ Oriory U General Yv. n Other (specify ): h I Aggrete Yew-w-at-e S%• €-,r^ C. luName. Mailing Address and ZIP Cod Name of Employer1"411. Date (month, Amount of Each day, yew) Receipt this Period

Othe Iseciy):Aggregate YmSr-t biis 7&A Occupation Receipt For: L Primary Li General f-] Other (specify): Aggregate Ye-.,o..te I> D. Full Name, Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each

day, year) Receipt this Period

Receipt For: L Primary L General - Other (specify): Aggregate Year -to-Date S E. Full Name, Mailing Address and ZIP Code Name of Employer Date (month, ______Occupation Amount of Each day, year) Receipt this Period

Receipt For : Primary U General Other (specify): Aggregate Year-to-Date " S E. Full Name, Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each day, yearl Receipt this Period

Occupation

F. Full Name, Mailing Address and ZIP Code Name of Employer Date ('vonth. Amount of Each day, year) Receipt this Period

Recept For Primary L General -]Other (specify). Aggregate Year-to.Date $ fl. C..ll &,l. -- I1 :.'- J...... , - -' A _1.. . ' ., rful nimw. maiing aorui an1 4iur LOO Name of Employer Date (month, Amount of Each day. year) Receipt this Period

Occupation Receipt For. SPri mary L I General - a n Other (specify) OccupationAggranatp YoAr.t*.rat e SUSTOTAL of Receipts This Page loptional) . ... 00

TOTAL This Period Ilast page this line number only I...... "itFT " SCHEDULE B I PAG E OF I tW@teO;ry of the1 Detaled Summer hP FOR LINE NUMBER1

Any Information copied from such Reorte an ttements may not be sold or used by any person for the Purpose of soltinkq contributions or for Commerclal uro ises, other then using the name and ddre"e of any political committee to solIcit contributions from such committe. IIIAME OF COMMITTEE fin Pva!

m LAI hAuL 4 (*MktiIJDD C 1 A. I 1 ( i | n. nanoillyn.Mil11 AiuigUoft lls Wi ZIP Purpose of Disbursement Dote imonth Amount of Each dly0 yer) Diabursement This Period L6.At Iam ok ,A@ wok sv. 6~k .i _, Disbursement for: UJ Primary v Geneal 11C3,7T SOther (specify)

S. Full Name. Mailing Adi md ZIP cede Purpose of Disbursement Oate lmonth. Amount of Each Sk_I, I ". a4. soi-;lkb i -- I ot. , twe, -- Alw day, year) Disbursement This Period

an f. lii:; t IN - I I C Disbursement for: UJPrimary Ui General u/&/ta . C O.t;,O seify)rseOe h AmontofEa C. Full Name, Mailing Address and ZIP Code Purpose of Disbursement Date (month. Amount of Each VIA iTu 0day, Year) Disbursement This Period

tiI)V f.I~Disbursement for: U Primary [ General 08115s6 *?~Cc

D. Full Name, Mailing Addres and ZIP Code Purpose of Disbursement Date (month. Amount of Each A fn 4 et 66K day, year) Disbursement This Period t2.. ameli SI. Disbursement for: [UPrimary eGeneral SITttCO7.ch Tod 4164 9 _ Other (specify) E. Full Name. Mailing Addreu and ZIP Code Purpose of Disbursement Date (month. Amount of Each A'WItil~k.LI day. year) Disbursement This Period

Disbursement for: PPrimary L_. General

F. Full Name, Mailing Address and ZIP Code Purpose of Disbursement Date (month. Amount of Each Af &day. year) Disbursement This Period

KA4. "A.etT7Iat, 5 Disbursement for: ULJPriamry LJ.J General l/t.&W+ . Other (specify) G. Full Name. Mailing Addr and.. ZIP Coda Purpose of Disbursement Date (month, 4 Amount of Each ~tD~~% *~L A;c~~A~ .~~e' ]day. year) Disbursement This Period 3 44 q L4.6jKs iif INtI Disbursement for: U Primary LU General ,'T Lts.6 oJ l'-1 & .Z.c Other (specifyV)______H. Full Name. Mailing Address and ZIP Code Purpose of Disbursement Date (month, Amount of Each day. year) Disbursement This Period

Disbursement for. U Primary- jJ ers

I ...... --- IOther Ispecify)______u. Pull Name. Mailing Addres and ZIP Cod Purpose of Disbursement Date (month. Amount of Each day. year) Disbursement This Period

Disbursement for: U Primary Lj General] 1 Other (specify)

SUBTOTAL of ofbuirsements This Page (optional)......

1 __

TOTAL Thi Period lsstpage this line number only ...... ) ...... e* ,* ) , o.?t I

1 14

St""~ - £~l074rae J.fr

Clf 110e -- A.230Soa State - - O w 6 11 Stree 1 Itertu

&Somme----wwMW -mmmmuft _w"TOMMIUM #%Agft un 40 OW ftm Ind;PendencsBank Of F oat* #I~ Nat lon1 an k of j46,o

Illilol - Atfe00(0020 a-A &Lh- IMULN I F * T16U6 A Uoel Comuv (Summary Page) 1. NAME OF COMMITTEE (in l)

I ADDRESS (number and -0 Check If d fferent than previously reported 2. FEC IDENTIFICATION NUMBER 10.4 lwilits 4.k S1. CcooqX CITY. STATE and ZIP CODE 3. ] This comwirtee qualified as a mullicandidate I N' J committee DURING THIS Reporting Period L_ ...... _ .. .. .,_,, _,,,Of(date). on ,-_,_ -- 4. TYPE OF REPORT

(a)r- April 15 Quarterly Report Monthly Report Due On: 0 February20 0 June20 0 October20 SJuly 15 Quarte0y Report " March 20 0 July 20 0 November 20 0 April 20 ] August 20 0 December 20 October015 Quarterly Repo May 20 0 September 20 0 January 31 , January 31 Year End Report f] Twelfth day report preceding (Type of Electon) July 31 Mid Year Report (Non-election Year Only) election on in the State of

F] Thirtieth day report following the General Election on

Termination Report inthe State of

(b) Is this Report an Amendment? 7 YES NO

SUMMARY COLUMN A COLUMN B 5. Covering Period S through r This Period Calendar Year-to-Date

6. (a) Cash on Hand January 1. 19a . .$..

(b) Cash on Hand at Beginning of Reporting Period ..

(d) Subtotal (add Lines 6(b) and 6(c) for Column A and .. Lines 6(a) and 6(c) for Column B) $ 2R4ll 1,4.M7.4t. j $

7. Total Disbursements (from Line 28) .. . . . $ Z3,,.i I$ 7(, 8. Cash on Hand at Close of Reporting Period (subtract Line 7 from Line 6(d)) $ Ii ot'T $ iq(,L ci7,li

9. Debts and Obligations Owed TO the Committee For further Information (Itemize all on Schedule C andor Schedule D) ...... $ contact: 10. Debts and Obligations Owed BY the Committee Federal Election Commission (Itemize all on Schedule C and/or Schedule D)...... , $ 999 E Street, NW i certify that I have examined this Report and to the best of my knowledge and belief it is true, correct Toll Free 800-424-9530 and complete. Local 202-376-3120 Type or Print Name of Treasurer

Signature of Treasurer Date

NOTE: Submission of false, erroneous, or incomplete information may subject the person signing this Report to the penalties of 2 U.S.C. §437g. 00 021 FEC FORM 3X (revised 4/87) PAGE ;QUIM x)

L RECEIM 1 I. CONTRIBUTIONS (other than loans) FROM: ...... (a) Individu&IuPws Omh r Than Political Commilees. (1) NiOMIzed (use Schedule A) ...... 7Iio. -u446, to (ii) Unitemized ...... (ii) Toal of coi *butios from idviu l . . I11(apii (b) Political Paity Comiis...... 13 (c) Other M 11(b) Political Comite (such as PAC) .. C.O0 d) TOTAL CONTRIBUTIONS (add 11 fa)Oii). f). and (c)). 0.06 111c) 11(d) 12. TRANSFERS FROM AFFILIATED0THER PARTY COMMITTEES C 0 13. ALL LOANS RECEIVED ...... 0 0 0 14. LOAN REPAYMENTS RECEIVED ......

15. OFFSETS TO OPERATING EXPENDITURES (Refunds,Rebates, etc.) c 16. REFUNDS OF CONTRIBUTIONS MADE TO FEDERAL CANDIDATES . AND OTHER POLITICAL COMMITTEES. 0 0 17. OTHER RECEIPTS (Dividends.Interest, etc.).,-, .3". . ., 0. 18. TOTAL RECEIPTS (add 11(d). 12. 13. 14, 15, 16 and 17).. + 4lj 1,.DISOURSEMENTS -

1.OPERATING EXPENDITURES. ' k-I41 4t.tt .. 3T7031. 20. TRANSFERS TO AFFILIATED/OTHER PARTY COMMITTEES " " c e 21, CONTRIBUTIONS TO FEDERAL CANDIDATES AND OTHER POLITICAL COMMITTEES C 0 22. INDEPENDENT EXPENDITURES (use Schedule E)...... 0 23. COORDINATED EXPENDITURES MADE BY PARTY COMMITTEES -(2U.S.C.44la(d))(us, ScheduieF).. C 2 24. LOAN REPAYMENTS MADE...... C

25. LOANS MADE . 26. REFUNDS OF CONTRIBUTIONS TO: (a) Individuals/Persons Other Than Political Committees . (b) Political Party Committees. 5(a) (c) Other Political Committees (such as PACs) . W(b (d) TOTAL CONTRIBUTION REFUNDS (add 26(a), (b), and (c)) 215(C) 5d) 27.OTHER DISBURSEMENTS

28. TOTAL DISBURSEMENTS (add 19, 20, 21,22, 23, 24, 25, 26(d) and 27) ...t'. .. . ,; .". 33',7'C III. NET CONTRIBUTIONS/OPERATING EXPENDITURES 29. TOTAL CONTRIBUTIONS (other than loans)( from Line 11(d)). 31,. 2S 30. TOTAL CONTRIBUTION REFUNDS (from Line 26(d)) L C e. 1. NET CONTRIBUTIONS(other thanIoans)(subtract Line <,from 29).. . I 3

32. TOTAL OPERATING EXPENDITURES (from Line19 ).. 7c , '" 33. OFFSETS TO OPERATING EXPENDITURES (from Line 15) z c 3. 34. NET OPERATING EXPENDITURES (subtract Line 33 from 32) . . 7. . ; .".C SCHEDULE A ITI RECEIPTS categairy of t1W Summary PpFRUl Ule

Anyinformation copied from such Reports end Statements may not be sold or used by any person for the purpose of soliciting contributions or fo commercial purposes, other then using the name and oddres of any political committee to solicit contributions from such committee. ME OF COMMITTEE K I_,t (in Full. t Itha. Ar....

A. Full Name. Mailing Addrue and ZIP Cade Name of Employer Date (month. Amount of Each day, year I Receipt this Period

..... 71 . u _aI_O Occupation SAW/a? 44C.- e Receipt For" I Primary LjGeneral r-M Other (specify): II I I II Il l Agregate Ye-to-Date .S S I ~ L B. Full Name. Mailing Address ad ZIP Code Name of Employer Date (month. Amount of Each day, year) Receipt this Period { ,k*.i ".ruj ),'.gliwJ,WL,,N {I,. _" tL. J, , Iilg 7/3o/ut TOO.00 II m I _ -- Occupaion Receipt For: Li Primary L General f Other (specify): Aggregate Year-to-Date > S St C. Full Name, Mailing Addre &rdZIP Code Name of Employer Date (month. Amount of Each . iul aA ks day, year) eceiPt this Perod

Ak.~~raL 101OccuaionA Receipt For [_ Primary vf General. f-jOther (specify): Aggregate Year-to-Dat. S; ______0. Full Name, Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each 96A. . i. day, year) Receipt this Period

~ ?cck,~ I~.4Occupation Receipt For U Primary [jJ General

[7 Cther Ispeciy): Aggregate Year-to-Date S _ _,_

E. Full Name. Mailing Address and ZIP Code Name of Employer Date (month, Amount of Each O day. year Receipt this Period

3h1+to& LAsr. f*i6v.L 3.2cG1 Occupation iI2&ce. o

Receipt For. III Primary t 1J General ______Other______Aggregate Year-to-Date S

F. Full Name, Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each AlK , i;.1day. year) Receipt this Period

Aj Occupation Receipt For Primary General 0fOthe, (spec i fyv Aggregate Year -to-Oate5S-i

G. Full Name, Mailjng Address and ZIP Code Name of Employer Date (month. Amount of Each day, year) Receipt this Period &Rf QNA 6,W o~

Occupation ;¢o. o,'. Receipt For L Primary IWJ General 7 Other (specify) S o..eeit i P r Agreate ear-to &&teS 2L, SU13TOTAL of Receipts This Page (optional) ......

TOTAL This Period (last page this line number only) ...... 000023 SCHEDULE A IT 0 ED RECEIPTS meor of the d Summary Pege FOR LINEI.I NUMBER Any Information copied from such Reports end Statements may not be sold or used by any person for the Purpose Purposes. other of soliciting Contributions or for commercial then using the name and address of any political committee to solicit contributions from such committee. ME OF COMMITTEE (in Nllt ...... - t (""1 / u Ali 6 6k( m Waian i • I I A. Full Name, Mailing Addrw xnA 71P Cod& I S Name of Employer Date (month, Amount of Each day, yew) Receipt this Period $41 U611i CA StA 1% 6S 6&.M1 U013 Occupation .,,n. 0 Receipt For: %F - U Primary Lj General I I I I F] Other (specify): Aggregaetei Yer-to-DateII I I I III I -* z q)rs ! B. Full Name, Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each W "i I:day. year) Receipt this Period

-] Other (specify): Aggregate Year-to-Date $ z , C. Full Name. Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each Receipt For: Li Primary L Generll (. ' day. year) Feceipt this Period

Ak..AJ~j ~0e IO&4 Ocupation Receipt For: L Primary GeneriI - ] Other (specify): Aggregate Year.to.Dgte $ w 0. Full Name, Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each ~toy day, yeer) Receipt this Period

Receipt For i . Primary J General Other (specify): Aggregate Year-to-Date > S __ E. Full Name, Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each '. IZ W kday, Year) Receipt this Period

iAlT 4L 4 Occupation CC Receipt For LI Primary U General ] Other ,specify Aggregate Year-to-Oate> S . _ _ F. Full Name, Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each day, year) Receipt this Period I~ ~ 44 i%I . St.I.

~4~C7 ~ Occupation Receipt For [jPriimarvJ 14j General Other (specify) AggregateYear -to-Date $ ______G. Full Name, Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each

day. year) Receipt this Period

.. . 1.2. 2 L... .. Oc ..c up a t i o..n ...... I ' Receipt For [+rim.ar[ J General F7Other(specify) Aggregate Year-to-Date $ 'w SUBTOTAL of Receipts This Page (optional)......

TOTAL This PeriodI (last Pag ge t.this hine number only) " ...... 0...... 000024.. . . SCHEDULE A -q ITEO'iD RECEIPTS d &WSm... mar Pa... FOR LINE/A( NUMIIm Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions or for commercial purposes, other then using the name and address of any polltical committee to solicit contributons from such Committee. iOF COMMITTEE (in Full) A~~~~Otm~jt (month.-m

U A. Full Name. V I I Moiling Address and ZIP Code Nae of Employer Date (month. Amount of Each day, yew) Receipt this Period N.4 uju1 t

Occuptioin A00.00 Receipt For: " Primary General Other (specify). Aggregate Yearto.Dote " $ - s 8. Full Name. Mailing Address and ZIP Cede Name of Employer T Date (month, Amount of Each Rag (11?404 day, year) Receipt this Period L p IAWoA CP43 4oo,o Occupation Receipt For: LJ primary [Ij General r-1ite spcf) Ag~sgste Yearto-Oate ~ S lAP C. Full Name, Moiling Addrew and ZIP Code Name of Employer Oate (month. Amount of Each ' &#" T U. day. yea) Receipt this Per od

ArLhA, W L I10l70 Occupation 300 Receipt For: Li Primary LIJ General i--] Other (specify): Agrate Y.,.,o.eot, $ . " 0. Full Name. Mailing Address and ZIP Code Name of Employer Date (month, Amount of Each A'w 5 !ra,.o., d. Wi- ' day, year) Receipt this Period 31 t- ,____3i__ a Receipt For ' _Prm ay L General F-] Other (spcfy): Aggregate Year.to-Oate s;

E. Full Name. Mailing Address and ZIP Cods Name of Employer Date (month. Amount of Each day. yer) Receipt this Period

fL(.ST Pwas 'U ol ccupat ion Receipt For: LJ Primarv LiGeneral Other 5 F] (specify) Aggregate Year.toDate > s _ _

F. IullName. Mailing Address and ZIP Code Name of Employer Date (month, Amount of Each day, year) Receipt this Period

IiS(,A,,41 &0,6 tl , 9 !CCZx Occupation ./ ,]C,CC Receipt For: LiPrimary j[J General F] Other (specify): Aggregate Year -to-Dote ' S . 0. Full Name, Mailing Address and ZIP Code Namneof Employer Amount of Each Ms . . Receipt this Period

Occupation t.I CL" Receipt For: Li Primary General F-10ther (spify' Aggregate Year-to-08t-'> 5 2' SUTOTAL of Receipts This Page (optional)......

TOTAL This Period (last page this line number only)...... o000 . flOO A watesdsedule( M: eOF SCHEDULE A ITEI*D RECEIPTS Category of the JA Summary Pp FORr , 11LiNE1AW NUmeER

Any Information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contriobmons of for commercial p, --vees. other than using the name and address of any political committee to solkit contributions from such committee. JAE OF COMMITTEE (in Full)

__ , , , 6?kApe• • AtYoli~ce II I &16o-. -Tlr i I Njmi wjfc U A. Full Name. Mailing Addres and ZIP Code t I I Name of Employer Oate (month. Amount of Each day, year) Receipt this Period

AM".P4I6o11. Occupation ' • in I - General Receipt For: U Primary M Other (specify): A~omate Year-to-Oat. • ,, 8. Full Name. Mailing Address an.d ZIP Coda Name of Employer Date (month. Amount of Each

1 1 day, year) Receipt this Period slot 'P~i? D.* 7s.,

tw~ ~ Aii CI Occupation 0 Receipt For: _ Primary W General

C. Full Name, Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each C) s.L C)

Receipt For: j Genets year)mary i

_7 Other (specify I: Aggregate Year-to-Date S 0. Full Name. Mailing Addres and ZIP Code Name of Employer Date (month. Amount of Each day. year). Receipt this Period

0 Receipt For, LJ Primary 1 'I General O_her (specify): Aggregate Year-to-Date S

E. Full Name. Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each I day, year) Receipt this Period

Le-?~ltkl ,' l CS Occupation Receipt For: H-.PrimafV "4'j General Oher (specify).,, Aggregate Year.to.Oate S ' _ ____

F. Full Name, Mailing Address and ZIP Code Name of Employer Date (mon'h. Amount of Each %.Llht;.Lday, k Ak year)I Receipt this Period

R e7p or spcf General Aomary a t -- ' O7ther (specify): Aggregate Year -to-Dtto ls .

U. Full Name, Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each 'D&. C,I~t, day. year) Receipt this Period toa,- B& M

~2.24. Thr Occupation fO. oil ...... ~ ~ ... ~ l ~ 2 3 v Receipt For: [J"rinary . W4'General I T 7--"er (specify): Aggregate Year-to-Date S qIAF ,- I ... .- '; - ,, ' SLTOTAL of Receipts This Page (optional) ...... 3 3)

TOTAL This Permiod (ast page this line number only) ...... Vt~feetIM SCHEDULE A ITEM9 RECEIPTS ctory f the111 Summary Page FOR LINE NUMStER

Any Information copied from such Reports end Statements may not be sold or used by any person for the purpose of soliciting contributlons or for commercial purposes, other than using the name and addres of any politicl conmittee to soliit contributions from such committee.

It OF COMMITTEE tin Full)

A6I ilIUvi A. Full Name. Mailing Addri and ZiP Cod Name of Employer Date (month. Amount of Each day. year) Receipt this Period ...... tu Occupetio 2,1 bus t Receipt For: m )lmary ] General,J FlOther (specify): Aggregate Yew-to-Date'* S -2A&. B. Full Name,. Mailing Addres and ZIP Code Name of Employer Date (month. Amount of Each day. year) Receipt this Period

, FOr: LvlA Occupation itPrryGer

0l Other (specify): Aggegate Year-to-Date C. Full Name. Mailing Addres end ZIP Code Name of Employer Date (month. Amount of Each 7,0 , tut day. year) Receipt thit Prifod

hiho CM8Occupation Receipt For: Primary L General "

[--] Other (specify): Aggregate Year-to-tOe S _ _._, D. Full Name, Mailing Address and ZIP Code Name of Employer Date (month, Amount of Each wotC wcv day. year) Receipt this Per iod

tk t 1Twoikv "~, 'cl K V17 Occupation

Other______Agregate Year-to-Date0 Si E.Receipt Full Name.For Mailing Address_L andPrimary ZIP Code v] General Name of Employer Date (month. Amount of Each r--'. Oh (sp6I~erifr day, year)I Receipt this Period U3 ?78. St.10.2 - A______Reepo ! t IC& Occupation

M] Other ispecify): 1Piav L/ eea Aggregate Year-to-Date S ______F. Full Name, Mailing Address and ZIP Code Name of Employer Date (month, Amount of Each r~t ljday. year) Receipt this Period

Recip Fr st ~ ~Arv" Occupation ReeptFr Primary L General______F]Other (specify): Agreat Year-to-Date: S . G. Full Name, Mailing Addreu and ZIP Code Name of Employer Date (month, Amount of Each T.W(if k , ,, day. year) Receipt this Period RM~O Occupation Receipt For: rJ 'Primary r-7 Other (specify): W General Aggregate Yeer.to-.Dte > S j Cu

SUBTOTAL of Receipts This Page loptional) ......

TOTAL This Period (last page this line numbet only) ...... 000027 SCHEDULE A ITEI@O RECEIPTS I Summary...... Pa FOR LiNIMMtf NUMBERw Ay nformation copied from such Reports end Statements may not be eld or used by any pe for the purpose of soliciting contributlons or fi commercils pupneS. other then using the nam end eddem of any poiltioal committee to solicit contrbtlon from such committee. A OF COMITTEI in PI I I

A. FUNl Nome. Maoiling Address and ZIP Code Name of Employer Date Imonth. Amount of Each W.toos A- ,4k. day. vor) Receipt this Period

W~oL.1imw% 31410 Occupation ilxpa SDO, 0o Receipt For: LPr ,ar 1II .Gneral " Other (spocify): Agremate Veer-to-Dete -*.S*6 q B. Full Ne. Mailing Addrss en ZiP Code Name of Employer Date (month, Amount of Each -n-day, year) Receipt this Period

~ Occupation

07 Other _(specify): lPrmy- U3Gnal Aggregate Year-to-Date $a&______C. Full Name, Mailing Addre and ZIP Code Name of Employer Date (month, Amount of Each U - day. year) Receipt this Period

It ______occupation /, 300 Re c eip t Fo r : L J P im ry, Ge r al , 17 Other Ispecifyl: Aggregate Veer-to-Dateg

0. Full Name. Mailing Address and ZIP Code Name of Employer Date (month, Amount of Each Receipt this Period AK rK, 0I",'64. day, yer)

-,i.,H.! ~' &0,, ." - -)f Occupation -_ 1,1z 18n6 Receipt For Li LI'nrGenral______

[71 Other (specify): Aggregate Year-to-Date > S 2 ______E. Full Name. Mailing Addres and ZIP Code Name of Emplover Date (month. Amount of Each Receipt this Period i-thu-t Va I ,t , day. yer) &x 79/R, t4 ______-,~i"c~ i it ---- Occupation z o Receipt For Lj1 Primary iGeneral Other (specify). Aggregate Yearto-Dat....

F. Full Name. Mailing Address and ZIP Cod* Name of Employer Date (month. Amount of Each

1. ( ~ i&~. L~ day. year) Receipt this Period

44jL Ls+l A1bii~E Occupation ~i*

O-1ther (specify) Aggregate Year -to.Date S ____Iy______G. Full Name. Mailirvq Address and ZIP Code Name of Employer Date (month. Amount of Each day. year) Receipt this Period

Occupation ,- . • .. ., . , - Receipt For W Primary Li General -- Other (specifyl Aggregate Year-to-Oate 7>

SUBTOTAL of Receipts This Page (optional) ..

TOTAL This Period (last page this line numOer only)......

-00002 i SCHEDULE A ifr*ED RECEIPTS a.ch categOry Of the ailed Summalnry Pg FOR LINE NUMBER

Any Information copied from such Reports nd Statements may not be sold or used by ay pedon for he purpose of oliciting ontributon. or for ommercil purposes, other then using the name and address of any political committe to solicit controwtion from such committee. MEOF COMMITTEE tin Po to Kepj Hope Alive Political Action Committee C0022926 .. k.I -kl .. .-1 a lL 1 _ .Amount. Y Date (month.. of"Each . ru" 110M iniiungAdfeUr m -9 71F GO Name of Employer Dowe (month. Amountl of Each Barbara A. Allen day,yew) Receipt this Period 9534 S. Paxton 7/13/88 $500.00 Chicago, Ill. 60617 Occupation Receipt For: U Primary Lxi General F] Other (specify): Agregte Year-to-Dete > S Cb S. Full Name, Mailing Addrs and ZIP Code Name of Employer Date (month. Amount of Each Eonidas H. Berryl MdD.ay, year) Receipt this Period 5142 S. Ellis Ave. 7/10/88 $250.00 Chicago# Illinois 60615" Receipt For: _]Primay X General Doctor

[1 Other (swecify): Aggregae Year-to-Date' S C. Full ime. Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each Dr. K. Middleton Brown day, year) Feceipt this Period 287 Barfield Avenue, S.W. 7/11/88 $1,000.00 Atlanta, GA 30310 Receipt For: LJPrimary [j General -Doctor F] Other (specify): Aggregate Yar-to-Date S t ' 0. Full Name.Mailing Address and ZIP Code Name of Employer Date (month, Amount of Each David C. Coleman, Jr. day. yew) Receipt this Period ~~ D.. C mi 1035vE. 42th St.j 7/10/88 $1,000.00 1035 E. 49th St. Chiean_ T 1 1 - 0I5 Occuption Receipt For Lj Primary [J General , Other (specify): Aggregate Year-to-Date SiCCC E. Full Name. Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each James W. Compton day, year) Receipt this Period

JamesOW.uCompto .7/13/88 $500.00

[XJ General Occuation Receipt For Primary Other (specify) Aggregate Year.to-Date 5s Sic F. Full Nam6.Mailing Addresa and ZIP Code Name of Employer Date (month, Amount of Each C6 W3nf. n.l Ly . ,, day. year) Receipt thisPerioo 2955 Ribault Scenic Dr. Jacksonville, FL 32208 7/10/88 $1,000.00 Occupation Primary [X General Receipt For i I Other (specify): Aggregate Year-to-Date S jcc,

G. Full Name, Mailing Addres and ZIP Code Name Date (month. of Employer Amount of Each Floyd H. Flake day. year) Receipt this Period 130-46 Laurelton Parkway 6/12/88 $1 ,000.OO Rosedale, NY 11420 Occupation -.--_.,, Receipt For: L_ Primary LA General 7 Other (specify) Aggregate Ye.

SUBTOTAL of Receipts This Page (optional) ......

TOTAL This Period (last page this line number only) ...... 000029 PAU& SCHEDULE A ITWED RECEIPTS FOR LOWl NUMIER-

Any information copied from such Report an Statements may not be sold or used by any person for the purpose of soliciting contributions or for commercial purposes, other than using the name and eddies of any Political committee to solicit contributions from such committee. AME OF COMITTEE (in Full)

Keep Hope Alive Political Action Commi-ttee C02296 Name of Employer Data (month. Amount of Each John H. Adams day, yer) Receipt this Period 209 Stoneham Lane 7/10/88 McLean, Virginia $1,000.00 22101 Occupation Receipt For: U Primary W General M Other Ispecify): Aggregate Year-to-Date S [At1 11. Full Name, Mailing Address and ZIP Code Name of Employer Date (month, Amount of Each Rev. .dy C.C. Akins year) Receapt this Period Box 134 7/11/88 $250.00 Gillett, AR 72055 Occupation Receipt For: UPrimary .J. General Preacher [ Other (specify): Agregte Year. , o. e _at_ C. Full Name. Mailing Address and ZIP Code Name of Employer Date (month, Amount of Each Vinton R. Anderson day, year) Feceipt this Period " .ir ,,:. L. Aderson 7748 Peach Tree Lane _ 7/10/88 $500.00 611. n801 l R.eceipUniversity For: C ULPr~* bk]1 GeneralA Occupation Other (specifyi: Aggregate Year- o-Date 5S 500.00 0. Full Name. Mailing Address and ZIP Code Name of Employer Date (month, Vinton Anderson Amount of Each R. day. year) Receipt this Period 7748 Peach Tree Lane 7/10/88 $500.00 University City, MO 63180 occupation Receipt For: [ Primary i General F] Other(specify): Aggregate Year -to-Date S 1 OO.Q0Q00O E. Full Name, Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each Vinton R. Anderson day. year) Receipt this PerioW

7748 Peach Tree Lane 7/10/88 $1,000.00 University City, MO 63180 Occupation Receipt For: U Primary jGeneralI -- Other (specify) Aggregate Year-to-Date> s 2 . t______- F. Full Name. Mailing Address and ZIP Code Name of Employer Date (month, Amount of Each Dr. Leroy Attles, Sr. day. year I Receipt this Period 10 Scahill Drive 7/10/88 $1,000.00 Randolph, MA 02368 Occupation

Receipt For s i Primary General___ Ara F] ther (specify), Aggregate earto-Date S I C'ce Name. G. Full Mailing Addrm and ZIP Code Name of Employer Date Imonth, Amount of Each Roy W. -er Lucilic j. Bentley day. year) Receipt this Period 3537 Hunters Pace Dr. 8/14/88 Lithonia, GA 30038 $1,000.00 Occupation Receipt For: Li Primary kJ General [ Other (specify): Occupation 'regate Year-to-Date > S I.r 7 - ..... SUBTOTAL of Receipts This Page (optional) ...... I______

TOTAL This Per iod (last page this line number only) ...... 000030 lefSI5h~dI~5PPAGE O SCHEDULE A RECEIPTS h48tev of the d SummrUy Pop FOR IE

.... M Ainy Information copied from such Report end tatemeonts may not be sold or usmed by any peso for the Purpose of soliciting contributions or for eommyareio 'fisas, other than using the name and *adrmof any political committee to solicit contributions from suech committee. ..AME OP COMMITTEE (in Full) Keep Hope Alive Political Action Committee C00229286 I Date (month, A. Full Name, Mailing Addres and ZIP Ceb Name of Emplover Data (month. Amount of Each day, VW) Receipt this Period Dorothye H. Boswell 2170 W. 27th St. 7/10/88 $200.00 Los Angeles, CA 90018 Occupation Receipt For: U er- La Grlr I ] Other (specify): Aggrew e vee-to.oMte S 3m S. Full Name, Mailing Acdrc nW Zip Code Name of Employer Date (month, Amount of Each Clara L. Brown day,. ver) Receipt this Period 1876 S. Sedalia Circle 7/25/88 $500.00 Aurorae Colo. 80017 Ocpto Receipt For: LJ Fti... lAl General

r 1 Other (specify):- Aggregate Year-to-Date S______C. Full Name, Mailing Address and ZIP Code Name of Employer Date (month, Amount of Each day, year) Receipt this Period -Dr.K. .. .,.i 1 . 287v D&L fle±( Avenue, S.W. "7V4L74,194, 8 _44-nnn$,,I n Occupation Receipt For: [j Primary j,*j General ______'-] Other (specify): Aggregate Year -to-Date $ 0. Full Name. Mailing Address ad ZIP Code Name of Employer Date (month, Amount of Each -Hzlenc, ,. r-- lr.. day. year), Receipt this Priod Vi,, UL R. -4/gA4L. W 3455 Harvey Avv. _-Q; n-..in ,-.l; e, r Occ"1upawtion % Cin- innati 911 45229- Receipt For: U Primary LKIGeneral F].C ther Ispecify).:. Aggregate Yeavrto.Date > $ E. Full Name, Mailing Address and ZIP Code Name of Empioyer Date (month. Amount of Each Rev. Grainger Browning, Jr. day, year) Receipt this Period -Rey. .An a Bronn7/08 $3 .0 7808 Allentown Rd. 7/10/88 $300.00 Ft. Washington. MD 20744 Occupation Receipt For: U Primary LX General Preacher F] Other (specify): Aggregate Year-to-Date F. Full Name, Mailing Address and ZIP Code Name oi Smployer Date (month, Amount of Each James C. Calaway day, year) Receipt this Period 1220 Americana Bldg. 7/21/88 $1,000.00 811 Dallas St. Houston. TX 77002 Occupation Receipt For [ Primary LXj General F]Other (specify): Aggregate Year-to-Date s __

G. Full Name, Mailing Address and ZIP Code Name of Employer Date (month, Amount of Each Joan B. Campbell day. year) Receipt this Period 475 Riverside Drive 7/15/88 New York, NY 10115 $500.00 Occupation Receipt For LJ Primasry LW Gen-ral -F] Other (specify): Aggregate Year-to-Date > S -c SUBTOTAL of Receipts This Page (optional) ...... , c TOTAL This Period (last page this line number only)...... ooo31 ..... SCHEDULE A IT*ED RECEIPTS amIi cteg of 04 nelled Summary Pop IFOR uNE NUMBEi

Any Information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions or forCommercil pi-,oses. other than using the name and address of any political Committee to solic1tcontributions from such commilnt. itE OF COMMITTEE (in Full) Keep Hope Alive Political Action Committee C002292B6 N Date (month. A. Full Name, Mailing Addrs and ZIP Coda Date Imnlth, I Name of Employer I Amount of Each day, yer) Receipt this Period Estella Carrillo 19100 Forst Home Rd. 7/9/88 $200.00 Plymouth, CA 95669 Occupatlon Receipt For: Primay M'- Other (specify): W General Aggresate YVe-to-Date >*" j Full Name, Mailing 8. Address and ZIP Code Name of Employer Date (month. Amount of Each Fannie M. Clayton or day. Vear) Receipt this Period Wil-s R - , .. or7/10/88 $200.00

519, E. Mohawk Blvd., Tulsa, OK Occupation Rleceipt For: _0 Primary LXJ General 741 )6 [7 Other (specifV): Aggregate Year-to-Oaee $_____S C. Full Name. Mailing Address and ZIP Code Name of Employer Date (month, Amount of Each Wayne K. Curry day. year) Feceipt this Period 11400 Earlston Drive 7/22/88 $1,000.00 Mitchellville, MD 20716 Oupation Receipt For: L Primary I General --]Other (specify): Aggregate Year-to-Oate $s ____ D. Full Name. Mailing Address and ZIP Code Name of Employer Date lmonth. Amount of Each Daniel Dennis day. year) Receipt this Period D$nni 7/10/S8 1 9 Huron Ave. 7/10/88 $1,000.00 Danvers, MA 01923 Occupation Receipt For I Primary General Other (specify) Aggregate Year-oDate S E. Full Name. Mailing Address and ZIP Code Name of Employer Date lmonth. Amount of Each Jacoby DickensI day. year) Receipt this Period

7/13/88 $5,000.00

Occupation Receipt For LiPrimary General

F. Full Name, Mailing Address and ZIP Code Name of Employer Date (month, Amount of Each John N. Ford ;day. year) Receipt this Period P.O. Box 9443 7/21/88 $200.00 Memphis, TN 38109 ____7/21/88_$200.00______Receipt For prim ary__ e e a : Occupation Ote sieiv Aggregate Y o.ar, S z

G. Full Name. Mailing Address and ZIP Code Name of Employer Date (month, Amount of Each Brenda Gaines day. year) Receipt this Period 2626 N. Lakeview Chicago, IL. 60614 $500.00 Occupation Receipt For LJPrimary General IOther (specify) Aggregate Yearto.Datej> S 9cc

SUBTOTAL of Receipts This Page (optional) . . . S It C

TOTAL Ths Period (last page this line numer only) .n00032- "* OI tTE9D RECEIPTS h eostqy of I0 SCHEDULE A a"e summary Pep FOR LINE NUMSER

Any information copied from such Reports end Statements may not be sold or used by any person for the purpose of soliciting contributons or for commercial purposes. other then using the name end address of any political committee to solicit contrbutions from such committee. ME OF COMMITTEE (in Full) Keep Hope Alive Political Action Committee Amun o E_ A. Full Name. Mailing Addre end ZiP Name of Employer Date (month. Amount of Each day, year) Receipt this Period

-4..... k rGlzeAga 3--87'74o -,

ttccupota > Receipt For: L Primary UXj General -4 Aggregte Year.,to,,et " Other (specify): S. Full Name. Mailing Address ad ZIP Code Name of Employer Date (month, Amount of Each Rev. Z.L. Grady day, yew) Receipt this Period 2490 Liverpool Drive 7/16/88 $1,000.00 Charleston, SC 29407 Occupaton Receipt For: [JPrimary Generl Preacher fl Other (specify): ,, Yea.to-,,, > st C. Full Name. Mailing Address and ZIP Code Name of Employer Date (month, Amount of Each J-n L. "rcs- day. year) Receipt this Period Earnest A. Green 7/21/88 $2,000.00 5198-27th Street, N.W.

Receipt For- L Primary General

7Other f specify): Aggregate Vear-to-Dote S c ______D. Full Name. Mailing Address nd ZIP Code Name of Employer Date (month, Amount of Each Calvin M. Grimes, Jr. day, year) Receipt this Period 165 Norfolk St. 7/21/88 $5r000.00 Boston, MA 02124-3396 Occupation Receipt For LI Primary Lx]J General , r Cther (specify): Aggregate Year-to-Date SE. cc,

E. Full Name. Mailing Address and ZIP Code Name of Employer Date (month. Amount of Eaci this Period Elliott S. Hall day, year) Receipt Shirley R. Hall 7/21/88 $1,000.00 2770 Unicorn Lane, N.W. D.C. 20015 Occupation ReceiptWashington, For ' _]Primary X General ______R AOther (specify): Aggregate Year-to-Oate> S ci:

F. Full Name. Mailing Address and ZIP Coda Name of Employer Date (month, Ar,'ount of Eacf! Dr. A. Lee Henderson!day. year) Receipt this Perioc 500 Eighth Ave. S. 7 Nashville, TN 37203 Occupation Receipt For L_ Primary I General ___ I ' Other (specify): Aggregate Year-toDate >$ uv% Address and ZIP Code Name of Employer Date (month. Amount of Each G. Full Name. Mailing day, year) Receipt this Perioc C. Garnett Henning 733 Old Bonhomme Rd. 7/10/88 $1 ,000.Or St. Louis, MO 63132 Occupation

Forh Receipt LI_ Primary I General Other (spatifN Aggregate Year-to-Date-> S LC! ,,______, _____, ______,_a-- - |

SUBTOTAL of Receipts This Page (optional) ......

TOTAL This Period (last page this line number only) ...... (1 U U o ...... 99 Occumtionul:klt ion

k category of tow SHEDULE A ITEM* RECEIPTS ed Summary Page FFOR LINE NUMER

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions or for commercial prposes, other On using the name end address of any political committee to solicit contributions from such committee. 41EOF COMMITTEE tin FuN . Keep Hope Alive Political Action Committee C00229286 Date Imonth, Amount of Each A. F Name. Milo, Address and ZIP Cede Name of Employer day. yO) Receipt this Period Hazel Hicks 6510 W. Mercer Way 7/21/88 $1,000.00 Mercer Island, WA 98040 Occupation

Receipt For: U Primary A General ! Ameeste Year.to.Date ~ S aAnn Iw IF.. . . ZIP Code Name of Employer Date (month, Amount of Each B. ChesterFull Name. Mailing A. AddressHiggins, and Jr. day, year) Receipt thisPeriod 7/10/88 $500.00 Occupation Ocpto __L Primary X General iReceipt For:

[] Other (specifyl: Aggregate Year-to-Date > . .. Full Name. Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each C. day. year) Receipt this Period Emogene W. Holt 604 Bessemer Ave. Bessemer, AL 35020 17/22/88 $1,000.00 Occupation Receipt For: L Primary GenerolI --j Other (specify): Aggregate Year-toOaet S I, .., 0. Full Name. Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each day. year) Receipt this Period -virginia B. ute-r .Dvi4 Hcnry Hur---- ~~~~~4tft- ....-Now2- 2 ..... " &, 00 O

Recept For i Primary General 4X7

F Cher (specify): Aggregate Year.to-Date _>_ __. E. Full Name. Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each day. year, Receipt this Period Bishop F.C. James Hamville Estates 7/10/88 $1 000.00 2421 Lang Rd._ -Coui a. SC Occupation Receipt For primary General ,oO,. AEC.. Other (specify)[-O,.er Aggregaie Year-to-Date S of Each F. Full Name. Mailing Address and ZIP Code Name of Employer Date (month. Amount day. year) Receipt this Period Leon N.-or Sandra K6 Jamison P.O. Box 7664 Pine Bluff, AR 71611 7/10/88 $250.00 O Primary x.J General Receipt For Aggregate Year.to.Date $ Otherspelvl: F7~~mon fv ofheEach ZIP Code Name of Employer Date (month, Amount of Each G. Full Name. Mailing Address and day. year) Reeipt this Period Theodore A. Jones 471 E. 31st Street 7/14/88 $500.00 Chicago, IL 60616 Occupation Occ Receipt For W Primary [XJ General [20Oth. 'necfy) AggregateYYearto- Date~> $Sl~ 7 SUBTOTAL of Receipts This Page (optional) .....

TOTAL This Period (last page this line number only) ...... 0 0 0 0 3 4 ...... - -d SCHEDULE A ITE00 RECEIPTS kOtNE NUMIER WLI I purposs, other then using the name end addrm of any political committee to solicit contrbutions from such committee. Any! iiiformtin O eCOMMITTEE copiedp from (In suchFCl.. Reports ard Sttements m ay not be sold or used by any parson for the purpos of solicIng contributions or for commerc !a Keep Hope Alive Pl'0itical Action. Comittee C00229286 Aon fEc

I r A. Full Natme. Mailing Adia and ZIP Code Name of Employer Do (month. Amount of Each Donald H. Jordan, Sr. day. Yew) Receipt this Period 444 Whitestone Ct. Cincinnati, OH 45231 7/10/88 $1,000.00 Oecupsrio

Receipt For: Li Prawy UX General F Other (specify): Aggregate Yser-to-Date > $ I 11. Full Namve. Mailing Address aOd ZIP Code Namne of Employer D*(ot. Aon fEc John H. Jordan, C.P.A. dy.yw Receipt this Period 2030 Peachtree Rd., N.W. No.5-B 7/10/88 $250.00 Atlanta, GA 30309 Occupation Receipt For: Lj Primary LX General C.P.A._ F] Other (spcify): A..reate Year.to.:Oate S ______, C. Full Name, Mailing Address a&d ZIP Code Name of Employer Date (month. Amount of Each - "., ..nniz T. X.ith-, day. yew) Receipt this Ptr.od Mrs. Sherry P. Keith 4970 Dublin Dr., S.W. Atlanta, GA 30331 Occupatin 7/26/88 $1,000.00 Receipt For-, U Primary W Generl

l Other (specify): AgWegte Year-to-Dete > s I, 0. Full Name. Mailing Address end ZIP Code Name of Employer Date (month. Amount of Each 7) Glenn 0. or Ar:-d,- X Lewis day. year) Receipt this Ptriod 6328 Banbury Dr. 7$ Fort Worth, TX 76119 7/10/88 $250.00 C) Occupation Receipt For. Primary General F-] Other (specify): Aggregate Yer-to.Date> S

E. Full Name. Mailing Address and ZiP Code Name of Employer Date (month. Amount of Each Booker T. Lister day. year) Receipt this Period 300 S. Freeway Fort Worth, TX 76104 7/10/88 $200.00 Occupation Receipt For. U Primary L.i General O''other (secf ' 1: AgregateY a.- Date>. S .2c F. Full Name. Mailing Address and ZIP Code Name of Employer Date Imonth, Amount of Eah

Charles N. Mason, Jr. day. yearI Receipt this Period b&. U7/22/88 $1,000.00 ~y.1. Occupation ~ Receipt For: Primary X General At~r( [FlOther (specify): Aggregate Year - o-Date ~>S ic ______

G. Full Name. Mailing Address and ZIP Code Name of Employer Date (month. Amount of Eact, Howland M. Mason day, year) Receipt this Period P.O. Box 108 Washington, D.C. 20044 7/22/88 $1,000.00 Occupation 1 Receipt For: Li Primary .J General F] Other (specify): Aggregate Year.to-Date7 S I.Cr

SUBTOTAL of Receipts This Page (optional) ......

TOTAL This Period (last page this line number only) ...... / SCHEDULE A RECEIPTS FOR LINE NUf~l "-

Any Information copied from such Reports end Setemnts NeY not be sold or used by eny pesn for the purpose of soliciting contributions or for comercial purooses. other then using the name and eddres of any political committee to solicit contrbjtlons from such committee. I OF COMMITTEE (in Full) Keep Hope Alive Political Action Committee C00229286 ... . - i m - - 0 - A. Full Name, Mailing Address and ZIP Cede I Name of Employer I Data (month. Amount of Each Carl Maxey d2y, year) Receipt this Period Attorney at Law 7/26/I West 1303 Broadway 8 $500.00 Wa shiJ.ngton 9920 1 S okane, tccupetone Receipt For: LJ Primary I 10 F1 Other (specify): Aggregate Yeer-to-Daste S f B. Full Name. Mailing Address and ZIP Code Name of Employer Date (month, Amount of Each Martine Maxey day. year) Receipt this Period Bai,,, 3 . MaxeT- E 16 29th 7/26/88 $500.00 Spokane, Washington 99203 Occupation Receipt For: (specify): Primary iaoDGeneralase re $ ______- ______C. Full Name, Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each Enola D. Maxwell day. year) Receipt this Per;od 1559 Jerrold Ave.

San Francisco, CA 94124 Occupation 7/9/88 $250.00 Receipt For: L Primary General Other (specify) : Aggregate Year-to-Date S 0. Full Name, Mailing Address and ZIP Code Name of Employer Date (month, Amount of Each Dr. Joseph McKinney day. veer) Receipt this Period 4633 Blagden Ave., N.W. Washington, D.C. 20011 7/7/88 $1,000.00 Occupation Receipt For L_Primary Lx General [7 Cther (specify): Aggregate Year.to-Date > I Ci_,_,_ E. Full Name, Mailing Address and ZIP Code Name of Employer Date imonth. Amount of Each Ruby B. McZier day, year) Receipt this Period 1420 N Street, N.W. Suite 10 _ 7/21/88/_/_ $5,000.00 Washington, D.C. 20005-2843 Occupa$t,000.00

Receipt For Primarv X General f7 Other (specify) Aggregate Year-to-Date S % Cc F. Full Name. Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each Bishop Donald G. Ming da. year) Reweipt this Period -£dith W. Mi'v: 7100 Grey Oak Dr.7/10/88 $1,000.00 New Orleans. LA 70126 Occupation I Receipt For - _Prmarv Lxi General [7 Other (specify) Aggregate Year-to-Daej.S J i_.

G. Full Name, Mailing Addres and ZIP Code Name of Employer Date imonth. Amount of Each Lucy Montgomery day. year) Reteipt this Period

175 E. Delaware Pl. ______7/25/88 Chicago, IL 60603 $500.00 Occupation Receipt For IjI Primary LX] General 7 Other (specify i Aggregate Year-to-Date > .s ,00.00

TOTAL This Period (last page this line number only) ...... I SUBTOTAL of Receipts This Page (optional) ...... Ii ( 10-- 0L~ 0 ,ategor064atesfhes ! Li Oi SCHEDULE A IT4ED RECEIPTS ftG.O Summary po FO LINE NUMBER

.I& I Anyinformation copied from such RePorts and Statements may net be sold Of use by any person for the purpose of soliciting contributions or for cComeril proe.other than using the name and address of any Political committee to soliit contributions from such commitit. WE OF COMMITTEE (in Full Keep Hope Alive Political Action Committee C00229286 -- Y I A. Full Nom, Mailing Addeem an ZIP I Clef Name of Employer Date (month. Amount of Each Lucy Montgomery day, yew) Receipt this Period 175 E. Delaware P1. Chicago, IL 60603 7/29/88 1 $500.00 Oecupetwn Receipt For: . Primary [J ,General n Other (specify): Agegte YewoDate 1. 000.0 . Full Name. Mailing Addres and ZIP Code Name of Employer Date (month. Amount of Each 4800 S.rCeday. vear) Receipt this Period Chicago, IL 60615 7/12/88 $1,000.00 Receipt For: LJ rim, y LA] Geeral Occupation

[-] Other Ispecify): Aggregat Year-to-Date

C. Full Name. Mailing Addres and ZIP Code Name of Employer Date (month. Amount of Each -.&i Mrs. Ala . Mo .rris-. , . day, year) Feceipt this Period - Mrs. Alma Morris 981 Alaska Street 7/8/88 $250.00 Memphis, TN 3a107 Occupation Receipt For: U Primary Generpl ,'-]Other (specify): Agrgate Year.to.-Ote . D. Full Name. Mailing Address and ZiP Code Name of Employer Date (month. Amount of Each Bishop Henry w. Murph day. yer Receipt this Period 8939 Sepulveda Blvd. Suite 240 Los Angeles, CA 90045 • 7/ /88 $500.00

Receipt For LJ Primary Z C,!neral Preacher F] Other (specify): Aggregate VeartoDate-> s 500. 00

E. Full Name. Mailing Address and ZIP Code Name of Emplover Date (month. Amount of Each Bishop Henry W. Murph day, yeerl Receipt this Period 8939 Sepulveda Blvd. Suite 240 7/10/88 $500.00 Los Angeles, CA 90045 Occupation Receipt For .. Primary I Geeral PracePreacher _ O-1ther (SmCfyl Geea Other specifyl ~Aggregate Year-toDate >S 1 ,000 .00______F. Full Name. Mailing Address and ZIP Cod@ Name of Employer Date (month. Amount of Each Hazel F. Obey day. year) Receipt this Period P.O. Box 6095 Austin, Texas 78762 7/10/88 $250.00

" Occupation Rleceipt For L primary 1 General 7other 'specify) Aggeat,e ar ,to-Date s

G. Full Name. Mai(ing Address and ZIP Code Name of Employer Date (month. Amount of Each Darlene L. Paris day. year) Reteipt this Period 7/13/88 $1,000.00

______Occupation Receipt For _ Primary XTIGeneral m Other (specify) Aggregate Year~to-Date?-'- $ I

000037 . SCHEDULE A ) RECEIPTS

LFO UNI IER Any information copied from such Reports and Statements may not be sold or used by any person for the purpoe of oliciting contributions or for 0ommerc t purposes, other then using the name and address of iny political committee to solicit contributions from such committee. W"E OF COMMITTEE fin Full.

F Keep Hope Alive Political Action Committee C00229286 I , i 111 i, in I of Each NameofEmployer Data (month. Amount A. Pul Name. Mailing Addres and ZIP Coda Date Imonth, Amount of Each I Name of Employer I Mamon Powers day, yewr) Receipt this Period 2077 Harrison Street Gary, Indiana 46407 7/ /88 $1,000.00 Occupation U Receipt For: Primarv A General Awegte Yer-to-Dte >$SIAAA S. Fult Name. Melting iress and ZIP Code Name of Employer Date (month. Amount of Each Vaemvh4+* " q "...day,& year) Receipt this Period 42. _ X4j% _4-O Occupation

F] Other (specify): Aggregte Year-to-ote > S C. Full Name. Mailing Addres and ZIP Code Name of Employer Date (month. Amount of Each Bishop Frank M. Reid, Jr. day. yew) Receipt this Period vr I-cnz . Rcid 1403 Miami Cir. 7/10/88 $1,000.00 Birmingham, &L 35214 Occupation eipt For: - Primary A General Preacher 17 Other Ispecify): Aggregate Yea-oDte0$1.0 0..Q.... D. Full Name, Mailing Address and ZIP Code Name of Employer Date (month, Amount of Each Bishop Frank M. Reid, Jr. day. year) Receipt this Period .16Ircna..q_ B.- Reid 1403 Miami Cir. 7/10/88 $1,000.00 Birmingham. AL 35214 Occupation Receipt For -JPrimary WGeneral Preacher [7 Other (specify): Aggregate Year-to-Date >$ 2,000-.00 E. Full Name. Mailing Address and ZIP Code Name of Employer Date (month, Amount of Each Norma Sandy day, year) Receipt this Period P.O. Box 169 St. Albans, NY 11412 8/30/88 $200.00 Occupation Receipt For L Primary [_X General ..- Other (Specify) Aggregate Year-to-Date> $ .C_'_

F. Full Name. Mailing Address and ZIP Code Name of Employer Date (month, Amount of Each Linda J. Sisk day. year) Receipt this Period 3550 Carter Dr., No. 136 7/9/88 $500.00 So. San Francisco, CA 94080 Occupat ior, Receipt For .Primaryi L.X General A r, Other (specify). AGre -to-Date Dt(mn . Au G. Full Name.Miling Addrs and ZIP Code Name of Employer Date (month. Amount of Each Margaret Smith day, year) Receipt this Period 4949 S. King Dr. 7/13/88 $500.00 Chicago, IL 60615 Occupation Receipt For Li Primary IX General fl; Other (specify) _ egate Yearto-Date'> S sc

TOTAL This Period Oast page thisline number only I...... 00 38 SCHEDULE A ITESD RECEIPTS tIoiled Summary P LINI NUMBER

aLAIt (1~ Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions or forCommercial purposes. other then using the name and address of any political committee to solicit contributions from such committee.

L EOFKeep COMMITTEE Hope tin AliveFull) Political Action Committee C00229286 A. Full Name. Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each day, year) Receipt this Period -Ce,'baa' B. mit rh- Denise Smith 7/11/88 $1,000.00 9914 Litzsinger Road St. LouisMO3124 Occupation Receipt For: U Primary i oneral O=upetkm r-1Other (socify): Aggregate Veer-toDete ' S I t 8. Full Name. Mailing Address and ZIP Cede Name of Employer Date (month. Amount of Each A.M. Stewart day, yea) Receipt this Period 3399 Fannin Dr. 8/4/88 $200.00 Lithonia, GA 30058 Occupation Receipt For: L Primary [X General ... Other (specify): Aggregate Year-to-Date $ c _

C. Full Name. Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each Fred Stuart, Jr. day. year) Feceipt this Period

1234 W. 80th Street _7/10/88 $500.00 Los Angeles, CA 90044 Occupatin Receipt For: Li Primary IXGeneral Other (swify): Aggregate Year-to-Date S £¢c _

0. Full Name. Mailing Address and ZIP Code Name of Employer Date (month, Amount of Each Charles A. Tribbett III dayvea) ReceipthisPeiod i... r .n .bb t t 7/12/88 $200.00 741 Gordon Ter. Chicago, IL 60613 Occupation Receipt For - Primary X General rn Other (specifyi: Aggregate Year-to-Date > s C E. Full Name. Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each Deborah Ann Turner, M.D. day. yearI Receipt this Period Crt. 1244 Guildford $1,000.00 Iowa City, Iowa 52240 7/13/88 Occupation Receipt For- Li Primary I General Doctor Other (specify) - Aggregate Year-to-Date > S I[_ _ _

F. Full Name. Mailing Address and ZIP Code Name of Employer Date (month, Amount of Each Willa M. Vernon dar.year) Receipt this Period 25200 Carlos Bee Blvd. No. 509 7/8/88 $500.00 Hayward, CA 94542 Occupation Receipt For .. Primary [Vj General [7- ther (specify) Aggregate Year-to-Date S Scc G. Full Name, Majing Addres and ZIP Code Name of Employer Date (month, Amount of Each Mcobee W. Waters day. year) Receipt this Period 10125 - 4 Mile Rd. Franksville, Wis. 53126 7/7/88 $250.00 gOccupation Receipt For : Li Primary LxJ General [7 Other (specify) I Aggregate Year-to-Date"7:::. $ 2S BE

F U3TOTAL of Receipts This Page (optional) ...... I STOTAL ThS Period V/astp age this Ine number onlyl......

I OT hiL lnenuh- Prid br 1stpaenll ...... lU04 yU ')i SCHEDULE A ITI 9 D RECEIPTS SummllPgeSlm po,,,,v,p POR LIN E NUMean

Any Information copied from such Reports and Statements may not be sold or used by any person for the urpose of soliciting contrilutions or for commercial purposes, other then using the name and address of eny political committee to solicit contributions from such committee. ME OF COMMITTEE (in Full. Keep Hope Alive Political Action Committee C00229286 I I I II I IDateI (month AmountofEac A. Full Name. Moiling Addr nd ZIP Code Name of Employer Data (month, Amount of Each Royce West c--uul ft. .w.. day, yO) Receipt this Period 1014 Qual Run Duncanville, TX 75115 7/10/88 $500.00 Occupation Receipt For: U Primary J General [n Other (specify): Aggregate Yw-to-Dat> $ S. Full Name, Moiling Address an ZIP Code Name of Employer Date (month. Amount of Each nQui-nyJ. -"*r"day, year) Receipt this Period Aundrey C. Wilkins 2580 Kearney Street,_8/17/88__500.00 Denver, CO 80297 occupation Receipt For: [ Primary General Beauty Consultants [7 Other (specify): Aggregate Year-to-Date > S gee.

C. Full Name. Mailing Addrm%and ZIP Code Name of Employer Date (month, Amount of Each Perod ,,______..._," .. Wilson day. year) Feceipt thii Bennie Wilson 5806 Southlea St. 7/11/88 $250.00 1_n____qfnn_ TX 27033 Occupation Receipt For " L_]rmary W General

[*7 Other (specify): Aggregate Year-to-Date S _ _......

D. Full Name, Mailing Address and ZIP Code Name of Employer Date (month, Amount of Each Paterson Wiman day, year) Receipt this Period 343 Keller St. Petaluma, CA 94952 7/22/88 $250.00 Occupation Receipt For O'Primary X General [7Cther (specify) Aggregat Year-to-Date Ss ______

E. Full Name. Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each day, year) Receipt this Period

Occupation Receipt For LI Primarv Li General [7 Other Ispecify). Aggregate Year-to-Date S

F. Full Name. Mailing Address and ZIP Code Name of Employer Date (month, Amount of Each day. year) Receipt this Period

Occupation Receipt For L Primary General [ Other (specify). Aggregate Year-to-Date> S

G. Full Name, Mailing Address and ZIP Code Name of Employer Date (nonth. Amount of Each day, year) Receipt this Period

Occupation

Receipt For: H Primary H General F[Other fspecify). __ Aggregate Year-to-Date s ,

SUBTOTAL of Receipts This Page (optional) ...... ->C

TOTAL This Period (last page this line number only) ...... , --,,11111911&4 CA SCHEDULE A ITElO REcEIPTS FOR LINEN NUMBERk w Any Information copied from such Reports and Smant may not be sold or ued by any parson for the puneg of solicitlng contributions or for commercial purpree. other than using the name and addrew of any poltklal ommit to 0olc 00otrbutloN from Such committee. "OF COMMITTEE ( Full) 6? Par kvt 1blikal &6-h Cotrakt ta"Z14 I I S I Date (month. I Amount of Each A. Full Name. Mailing Address and Zip Ceab Name of Emnover Dow l onth, Amount of Each day, yeW) Receipt this Period 4( 1 4%I-wics~h4JF. /Ce ,o Occupation 7/,o/ft Receipt For: U Prkm W General F] te spcf) Auragate Yearto.Date > $ ~ B. Full Name. Mailing Address and ZiP coo Name of Employer Date (month. Amount of Each 4 M day, year) Receipt this Period

(b J .______

[--o the r (spe ify: Agg.gat Year.o.Date > S C. Full Name. Miling Addressand " ZiP Cds-"WX61WOccupation Name of Employer Date month. Amount of Eah k .J.day, year) Receipt thi, Period Receipt For:Gera

day. year) Receipt this Period 1- Other (specify).Alu utt Aggregate Year-to-Oate $ D. Full Name, Mailing Address and ZiP Code Name of Employer Date (month. Amount of Each ,,,,o. n6wP?,.ra_ . ,) b.;w Occupation V.-,t- Receipt For: HiPrimary J General

[17Other (specify): Aggregate Year-to-Date,> S

E. Full Name. Mailing Address and ZiP Code Name of Employer Dote (month. Amount of Each day, year) Receipt this Period Receipt For: L_ PrimaryfK iltkOccupation __'Generalrhot

[7 Other specifV:) Aggregate Year-to-Date S _

F. Full Name. Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each day, year) Receipt this Period

F. Fllad ame.MaiingAddruZP Coe OccupationNme f Emloyr Dte (ont. AoA~n ofEec Receipt For j Primary Li General F Other fspecify). Aggregate year-to.Date S ,,_,

G. Full Name. Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each day. year) Receipt this Period

occupation Receipt For ! j Primary Li General r7'Other (specify) Aggregate Year-to-Date '> S

SUSTOTAL of Receipts This .. Page (optional) .44. . t.C

TOTAL This Period (last page. this .... line number only) ...... ,a ,1 4 /C. ;ke SCHEDULE A ITEMS~p RECEIPTS I Summar fPg lPOR 1oe NUMB~e (Contributions fom Political Committees)I I N I II AyInformation copied from such Reports and Statements may not be slold Or use by anY peron for the purpose of soliciting contributions or for comnmercia purposes. other than using the name and address of any Political committee to solIcit contributions from such committee. NA I OF COMMITTEE (in Fun). ..eep Hope Alive Political Action Committee

A. Full Name, Mailing Address and Zip Co1 ! - . 1 ., • re~my• e'fVg~ff Amnount of Each Friends of Jesse Jackson day. year) Receipt this Period

Washington, D.C. 7/13/88 Occupation $5,000.00 Receipt For: U Primary Uj General r Other Ispecify): W B. Full Name, Mailing Address &ndZIP Cede Name of Employer Date (month, Amount of Each Congressman Major Owens da, yrea Receipt this Period In '88 Committee P.O. Box 2265_ 8/29/88 $ 100.00 Brooklyn, NY 11202-2265 ocupation Receipt For: 1Primary X General - P. Other (specify): Aggregate Vear-toat S C. Full Name. Mailing Address ad ZIP Code Name of Employer Date (month. Amount of Each Mid Brooklyn Political Assn. day, vw) Receipt this Period 9/15/88 $ 100.00

______Occupation Receipt For U Prinary X General [-J Other (specify): Aggregate Year-to-Oete" s it D. Full Nare, Mailing Addr s nd ZIP Code Name of Employer Date (month, Amount of Each ommiltej T$daect dy. year) Receipt this Period (Sec./reas. of Extension) 500.00 R overBechwoo/88 Rouge , N 1 48 218 Occuption $ 50.00 Receit For Li Prmary J Geer al T ett. spcfv:Ageae er -toO ,

E. Full Name. Mailin Addres and ZIP Code Name of Employer Date (month, Amount of Each 406 E. 5th PriceSt. 943-8114 Campaign day. yer) Receipt this Period Dallas,John Wiley TX 75203 .7/9/88 $ 250.00 Rxei, V,:I e, , _ ,,, Occupation

F] Other (specify): Aggregae Yer-to-Date" $ 2,q F. Full Name. Mailing Addrs and ZI P Code Name of Employer ats (month, Amount of Each day. year) Receipt this Period

Ote (pciy: greaeYear -to-Dote S "

•~ ~ ~ ~ " tlfr IW a, 3q &Wmm rI %OQK~e Name Of Employer Date (month, Amount of Each day, veer) Receipt this Period

Occupation Receipt For: U Primary L General Occupation Other (specify): Agtidote yeamr.t.n-to AI rot ~r~nf..N SUBTOTAL of Receipts This Page (optional) ......

TOTAL This Period (last page this line number only) ...... (00042 SCHEDULE B ITEMIZEO BURSEMENT8 F U at*schedu,(s) PAGE OF fw caW'tegory of the IN NUMBER Detailed Summary POP FOR LINE NUMBER I I' Any Information copied from such Repots and Statements my not be sold or used by any person for the purpose of soliciting contributions or for commercial !Purooses. other than using the name and address of any political committee to solicit contributions from such committee. -ME OF COMMITTEE (in Full) kep Pote i . . . •I A6 Tati6t I- Al-ft &W 1Dat (month A. Full Name. Mailing Addres and ZIP Ced Purpose of Disbursement Date Imonth Amount of Each tline+f day. year) Disbursement This Period Z3 E. It. 1t1iltWllr Disbursement for: U Primary jGenerl 7/i1tt (wo . ~0 &thAm. Ift-itt Lthij iOttw(spcify) a. Full Name. Mailing Addres end ZIP Code Purpose of Disbursement Oats (month. Amount of Each I.a iday. year) Disbursement This Period )4.4 ltiisdisww.WDisbursement for: U Primary [jGenel 6i/4. 00 " W , rwr" -uu i--Iother (specify)

C. Full Name. Mailing Addrsu and ZIP Code Purpose of Disbursement Date (month. Amount of Each

4,'L I C , day. eer, Disbursement This Period

qt!.bQ . A4#*IftVD -~ Disbursementfor: [jPrimarv 0WGeneral 7/it/t "" " Other (specify) 0. Full Name. Mailing Addes and ZIP Code Purpose of Disbursement Date (month. Amount of Each LixLday. year) Disbursement This Period

tM;16& i). Disbursement for: [JPrimary Woeneral ' " " f " ULM Other (specify) E. Full Name. Mailing Address and ZIP Code Purpose of Disbursement Date (month. Amount of Each ~ ~ ~iIday. year) Disbursement This Period

1 j Disbursement for: JPrimary L/ General 9 It / CC -I Other (specify)

F. Full Name. Mailing Address and ZIP Code Purpose of Disbursement DOate (month Amount of Each

. -, ~day. year) Disbursement This Period

TZT / F--- -i"-L rt . : , Disbursement for: _Primary LJGeneral ra {4D ~ Z ~ t\ ~ C~Other speify) jGe G. Full Name, Mailing Address and ZIP Coda Purpose of Disbursement Date (month, Amount of Each day, year) Disbursement This Period Disbursement for: U Primary [JGeneral i73?/ tb f1)-C. - 1) *1 Other (spec if y)______

H. Full Name. Mailing Address and ZIP Code Purpose of Disbursement Date (month. Amount of Each Y~day. yea r) Disbursement This Period ~ ?I)~X~~ed ~' ~*Disburementfor: Primary v~ General SQ/ 1 t ~'' 'n''Other (specify) I. Full Name. Mailing Address and ZIP Code Purpose of Disbursement Date (month. Amount of Each day. year) Disbursement This Period .... M isbursement for: Li Primary General 1 i N-0 c -]Other (specifv I

SUB3TOTAL ol Disbursements This Page (optional) ...... ,4IC

T OTAL This Period (lost page this line num ber onlV ......

000043 CHEDULE S JRSEMENTS

FOR NE NUMHR 1 1

Any Infornilon copied from such Reports eW Statements may not be sold or used by eny person for the purpose of Sollkitlng contributlone or for commercial Purpoe. other then using the name end addres of any political commltte to solicit contributions from such commIt., f AME OF COMMITTEE (in Full

_ V uooet W Coit*. ______i_ A. FuNt Name, Mailing Adurm a d ZIP Code Purpoae of Disbursement Date Inmonth, Amount of Each 01.Vi 4v day. year) Osbursement This Period Disbursemeant for: U Primar 1j Genera tfZsk$ 1Otlw (specify) B. Full Nam, Mailing Addma on ZIP Code Purpose of Disbursement Date (month, Amount of Each day. year) Disbursement This Period

Disbursement for: U Primary U Generol , _ _,,,_ _ _ _I Other (splcify) C. Full Name. Mailing Addres alnd ZIP Cede Purpose of Oisbursement Dote (month, Amount of Each day, Year) Disbursement This Period

Disbursement for: U Primary U General Other (specify) 0. Full Name, Mailing Addres and ZIP Code Purpose of Disbursement Date (month, Amount of Each day. year) Disbursement This Perioc'

Disbursement for: Primary General 3 Other (specify)

E. Full Name. Mailing Addres and ZIP Code Purpose of Disbursement Data (month, Amount of Each day. year) Disbursement This Period

Disbursement for: U Primary U General Other (specify)

F. Full Name. Mailing Address and ZIP Code Purpose of Disbursement Oats (month, Amount of Each

This Period Disbursement day, year) Other (specify) Disbursement G. Full Name. Mailing Address and ZIP Code Purpose of Disbursementfor: LiPiay L eea Date (month. Amount of Each day. year) Disbursement This Period

Disbursement for L Primary Generl Oter(secify)

H. Full Name. Mailing Addres and ZIP Code Purpose of Disbursement Date (month. Amount of Each

Disbursement for:L Prmy f oI Other (specify) day. year) Disbursement This Period

SUBTOTAL of Dfsbursements This Page (optional) ...... o...... )' 4,493 it

i OTAL This Period (last page this line number only) ...... o...... I "',-S,*)~* i -C 000044 * IN.

.~~~ go.d .1II:

06 4 *W

r . .. 0 .J.

N"1 " tI f"" me so"" at " " ;% *" '" rgy @V14f 00he ft p~etwA.- I th CV rt(). JL N mbe ONnif~~~ Aft ge" ,..s,-.• .. ,ai,

enter "oif a~ itto@ ~ e 69

pet solioitatisme either 1 a wilts. 5U"u* bi On V ~ oral. reymeet dooumted -1a vittim to_ Weahi ""tra the ntr t, o . yew N. s....., eerecised 'best *1900AIDS ftz U @3 .71(b). 00 ~each of fort hall omelet 09 a Clear repeft .1w the Information (I...@ . ,.ag edftWW tie sat a& of * bs Afors - prwsim prow ide a G of yo•t ,- iitat. m o nr. " ""um of the me the(a) used to obtaim Odugh -un Information* ,t £• "fatm regard i, %et Of bts' should be disclosed dgo ah Kseuj a boginning with thole re t kttII &,Uef e le tIon Fear. 11 C3 "04.3(.~i7 ") -Tout report discloses linited paymue for administratie. expenes. oimisttativome are payments md tt the purpose of ageating politieal (100045 5' L"* " I.-' b 16 i. A

-,~. I.-'.

I~ ftdk=a ILA"'! ., = 4 - "€ . p rib .4 -, it Iwo*

4 -. 8433 tb) (2). 4

mM 40 otei io -o o gatioss. Mlarlf 'a) @bov 3hin11 be dl (8) b"Ifti t then V

4cebeftle A ofg yur Wroc tn tiasat portiom(s) attached) dislom a treima) from ft organization(s) which is N a polituiel mitts registered with the omssio.ftea 11 Oft lfloS(b)v orlaiatias wbich are not politicel ooittees une" the Act mat elther. 1) establi a -erateoafat which contains only those fUnds peaittd "Nr the Act, or 2) deomstrate tbrmgh a rasonblooceatieg metbod that the organiatim has reoeived sufficient funds subject to the limitations and prohibitios in order to sake the contribution. It your cinittee does not finanoo so-fedocal activity* the receipt of the referenmd contrUtice(s) may violate the limitations and obhibitimns of the Act. (2 U.S.C. JS44la(f) and 44bi If yer eamitto engages in both federal and non-fedecal ativity, either through a separate mm-federal. aooont, or me account that finances activity in ontomI with both (00046 .it '10

*e• liat.lits. . o MAO' Ifouly in wt t 'Mis d::loc the f- r lm 3 , dolt I" whiclo tb"e

I . . , r i, a (Pmole,. 1 ij ,I.

...... the 00f " eso ' take ftft ez le al . wwewagv the ooeptae of pIobibited ocutlbut = t act to&by ra -oomtte In retudive lit & O-MeclL-Vat tn "&sauts Wii be taken I"* c4silerat ion. A vritten tespobe or an a idmeot to COcollnel repoct(s) correcting the above problem() abouald bC filed with the VFeGdrl ilection Ciion within fifteen (15) da S of the date Of this letter. If you need aOsistanCe plese fteel tre to contact so on our toll-Itre number. (800) 42 4-9530. *t 1W0oe3 number to (202) 376-2480. Sincerely,

0(0047 IEM EUCT*"eCMgSIWi' WAMW4vo 0C m

Keep ope AliveJoati"t Action Conittoo 4 1074 Thoms jeftft.m Washington, De -sweet Identifioation Mulbect 'JOa Re*erence, otobc GfAte9y RepeOt 17/1/fw/3g/g) Dear *r. ""*usn8 1OnDs*9ber 7. 198 ou Weco notified that a lgv of the above-referonced report (a) raised cooributions tI e and/or expendit sro a t rpot g of information soitalm required by the Federal le sti..Capaig &aot. tour December IS, 1966 response is imoapote have not provided all the requested infOUM4tl. b s in response to be b ea hi considered adequat the fallering infrtion is rk still required. -Your report discloses adainistrative expensos. limited pemfs for Payments Administrative Ns fe made for the purpose of oerrting oel ouMmittes, icludingt but not uiies limited to, resto salarose telephone quipsent and supplies. servioe, office aggregating Any such payments to a person in exces of $200 in a calendr year be disclosed on Schedule must Detailed ir supporting Line 19 ofthe Summary page* (2 addition, if expenses U.oC. 1434(b)(5)) In in have bee Incurred but a reporting period, the activity not paid as a debt on Schedule should be dil4se D. if the obligation is sore, or outstanding for sixty (60) days or tore.$500 or11 CFR 104.11. If these expenses orgAnIsation, are beir paid by a connected your Statement o2 Organisatio amended to reflect mus be this relationship. 2 3433(b) (2). U.s.c. Any goods or services provided person, except volunteer to your Comitto by a time), Would activity (i.e., ppersone be considered an in-kind contribution that person, and would be from (0i subject to the disclosure () 0 7. a . -, , 21. W~bi1~UP 5.'" -- 4'

requirements of 2 U.s.C. 10~4(b)(3) MO It MV M4445. and the limitations atd prhibti of 2 U.S.C. 11441A and 441b. Please provide olacitiofstsos regarding ad isietreve expenses incurred by or nmittee and/or oeed react to disclose dob W 0ooc1 to rrCenOei provisionsim o 7t -ot and %X.2 regulations. Clatifittt r Uding admi expese should be diI Saot met oneYtro *eot-t

4obedule A of your report (pertiftat portion(e) attached) discloses a contribution(s) from am organizationts) whioh Is not a politial oomittee registered with the Comissiom. U er t M 12e2.5(b), organizations which are not politioas osmittees mer the Act must aitbers 1) establish a searate account which contains only t boo funds permitted under the aot, or 2) demonstrate tbtogb a reasonable aoounti method that the organination has reeived suffiolem? funds subject to the limitations and prohibitions in order to make the contribution. If your oomsittee does not finance non-federal activity, the receipt of the referenoed contribution(e) may violate the limitatioms and prohibitions of th Act. (2 U.S.C. S44la(f) and 441b) If your comittee engages in both federal and non-federal activity, either through a separate non-federal account, or ons account that finances activity in connection with both fe.deral and non-federal elections, your committee may be in violation of 11 CYR 102.5(a). ?lease clarify whether the contribution(s) received from the referenced organixation(s) is permissible. To the extent that your comittee has received funds whish are )ot permissible, the Comission ro o ends that you refund the impermissible amount(s) to the donor(s) In accordance with 11 CPR 103.3(b). Alternatively, if you choose to transfer the funds to an account not used to influence federal elections, the Commission advises that you inform the contributor in writing and provide the contributor with the option of receiving a refund. You may -.ish to seek a written authorination (either before or after the transfer-out) from the donor for any transfer-out to protect the donor's interests. 000040 youhud- amens your origiua,

report wtlt tho larifying inforation. AJthougb the Coissio@ Mir take further leg1 s O~mrsg the aoCOeptsa. Of Prohibited prompt &atla by your OOftrslbAtI.,ts, OMnittee in refuntng 0 transLerrlog-out the amount consideration. viii be takes ino It this Lnformation fifteen is not received by the (15) days from the date of Comisslon vithin CDe may choose to initiate this notice, the oeisslom audit or legal enforoement ction. If you should have please any questions relsted to this .ontact Anthony Raymond on mtter, C) our toil-free nuber (M) 424- C) 9530 or our local number (202) 376-2480. " . inoerely,

"ohn D. Gibson Assistant Staff Director Reports Anolysis Divisio

0000050

I I eep mope Alive 3mitiea, Ae m ommstteo t JAN So 73) '931115e 20"o lo~*ngtno15th t. D.. 8491g aomi~ NOW #700 Jamnsryf 1). 1909 John D, Gibson Assistant Staff Director Reports aalis Division Federal Bleaton Comisseon 999 a t., N.V. Washington, D.Co 20463 Dear Mr. Gibsons In response to your letter of December the Reep Mope Alive 30o Ilo, to Political Action Omwittee, I would LO like to report the followings --You noted that during the through September period July 1, Iglo, 30# 19S, the PAC had very low expenses for adinistrative functions. That happens, is correct. As it the Keep lo0pe Alive PAC raised Its early mOWe ,Th at gatherings during the Atlanta Convention* and* from one direct mail at so cost p for which the consultant effort after the contVenion,, expenses were detailed In the disbursement section of the report. The PAC had no staff until oD It had after October 15, l68. no office space until December 1, friends 1963 (al&tough of the PAC did agree to collect mail at our old Thomas for the PAC Jefferson ft. address). The PAC had no phone until December 21, 1963. - .O no administrative Thus, we had almost expenses during not only the quarter reporting third period, but also for the post-election reporting period. We now have an executive director, 737-4673; a telephone (202) and a new office, at the address abodes Vcosts viii These be reported in our next report, and in all subsequent reports. --The other question you the PAC had involved a contribution received from a committee which was with the FEC. not registered Since that time, this $5,000 contribution, along with another $1,975 in contributions which we could not quickly verify as qualified for have been transferred our federal account, to our non-federal account. (The deposit/transfer slip is attached for verification.) .-*Sl "u4. I trust these responses will answer your If you have any questions. further questions, please contact me through the PAC office in Washington--Steve 737-4673. Thank you. Cobble,/ So00051

Sretar/L Beep opeGURCamittas Alve olital 733 15th St., .W. ftm 07T00 Waston, D.C. 20005 January 24, 19 r. Anthony D. Raymond Senior Analyst Federal 3lection Comission 999 a Street, N. Washington, D.o 20463 Dear IKr. tRaymond, This letter updates our donors 0 occupation employer and Information, which was not included on our original third-quarter 1960 that we sent report. The letter to our donors, requesting this required information, is attached. Our information Is still not complete, feel that we have but we - made our best effort to meet the requirements of Cip 104.3 (a)(4) (). The ~ we now data did receLve from our donors is also attached. o Please call me if there are any questions, .. (202) 737-4673, at

Sincerely,

Steven B. Cobble - Executive Director

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(00057 rtotlS~ AND DISOURMENTS For Ohw Than An Authorized Committee (Summary Page) . _ _ III M 1. ADRSS(ume_NAME OF COMMITTEE (in full)

I ADDRESS (n~ nd stree L C if diffeirent tan previously reported ,.. 1',, 2. FEC IDENTIFICA rION NUMB-ER 17,. - -s 7o3 -I CITY, STATE and ZIP CODE I 3. 0 This committee qualified as a multicandidate ~ 9. C.locos I committee DURING THIS Reporting Period on(dat). 4. TYPE OF REPORT

(a) April IS Quarterly Report Monthly Report Due On: July 1S Quarterly Report 0 February 20 C June 20 C October 20 O March 20 D July 20 C November 20 October 15 Quarterly Report o April 20 C August 20 C December 20 I] May 20 C September 20 C January 31 January 31 Year End Report []Twelfth day report preceding (Type of Election) July 31 Mid Year Report (Non-election Yeair Only) election on in the State of

Thirtieth day report following the General Election on Termination Report in the State of

(b) Is this Report an Amendment? 7 YES E] NO S U M M A R Y- S M - -- - COLUMN A 5 Corn! o ' :through V J" COLUMN 1 This Period Calendar Year-to-Date

6. (a) Cash on Hand January 1. 193 ...... T&

(b) Cash on Hand at Beginning of Reporting Period...... $

(C) Total Receipts (from Line 18)..$. .k .... $ .J ".- ,' (d) Subtotal (add Lines 6(b) and 6(c) for Column A and ...... Lines 6(a) and 6(c) for Column B) $ l 17 4"1,t' $ r 7. Total Disbursements (from Line 28) ..$ ., . .... $

8. Cash on Hand at Close of Reporting Period (subtract Line 7 from Line 6(d)) . $ , I s$ 4 9. Debts and Obligations Owed TO the Committee For further information (Itemize all on Schedule C and/or Schedule D) ...... $ contact: 10. Debts and Obligations Owed BY the Committee (Itemize all on Schedule C and/or Schedule D) Federal Election Commission $ C. Washington, DC 20463 I certify that / have examined this Report and to the best of my knowledge and belief it is true, correct Toll Free 800-424-9530 i and complete. Type or Pnnt Local 202-376-3120 Name of Treasurer Local 202-376.3120 Signature of Treasurer . Date

NOTE. Submission of false, erroneous, or incomplete information may subject the person signing this Report to the penalties of 2 U.S.C. §437g. O Ji8 FORMvsFEC 3X I (revised C/87) DETAILED SUMMARY PAGE* 1 of R" t and Disbursements V000059 (Page 2. FEC FORM 3X) Na m e o f Co mm ,tte (in full) m.,..

~ J,1 .. 4i,~,;~.k.~ ' W .... 1.RECEIPTSCo 'i 11. CONTRIBUTIONS (other than loans) FROM: ...... (a) Individual/Person Other Than Political Commillees .... (i) Itemized (use Schedule A) ...... (ii) Unitemnized ...... (iii) Total of contributions from individual ...... (b) Political Party Committees ...... (c) Other Political Committees (such as PAC)...... (d) TOTAL CONTRIBUTIONS (add 11 (a)(iii), (b). and (%:)). . 12. TRANSFERS FROM AFFILIATED/OTHER PARTY COMMITTEES .

13. ALL LOANS RECEIVED ......

14. LOAN REPAYMENTS RECEIVED......

15. OFFSETS TO OPERATING EXPENDITURES (Refunds.Rebates. etc.)

16. REFUNDS OF CONTRIBUTIONS MADE TO FEDERAL CANDIDATES - . AND OTHER POLITICAL COMMITTEES ._._._._...... 17. OTHER RECEIPTS (Dividends.Interest. etc.) ......

18. TOTAL RECEIPTS (add 11(d), 12.13.14,15.16 and 17) .. :

II. DISBURSEMENTS - 19. OPERATING EXPENDITURES ......

20. TRANSFERS TO AFFILIATED/OTHER PARTY COMMITTEES 21. CONTRIBUTIONS TO FEDERAL CANDIDATES AND OTHER . -" POLITICAL COMMITTEES

22. INDEPENDENT EXPENDITURES (use Schedule E) ...... 23 COORDINATED EXPENDITURES MADE BY PARTY COMMITTEES (2 U.S.C. 441a(d)) (use Schedule F) ...... _ _ 24. LOAN REPAYMENTS MADE ......

25. LOANS MADE ......

99 9UHP'nJt1Ir-r)KTQI. Q9 "T. (a) Individuals/Persons Other Than Political Committees .. . (b) Political Party Committees ...... (c) Other Political Committees (such as PACs). (d) TOTAL CONTRIBUTION REFUNDS (add 26(a), (b), and (c))

27. OTHER DISBURSEMENTS . . .. 0 :,).1. .. 28. TOTAL DISBURSEMENTS (add 19. 20. 21. 22. 23. 24. 25. 26(d) and 27) ...... III. NET CONTRIBUTIONS/OPERATING EXPENDIT 29. TOTAL CONTRIBUTIONS (other than loans)( from Line 1 (d)). 30. TOTAL CONTRIBUTION REFUNDS (from Line 26(d)) ..... 31. NET CONTRIBUTIONS (other than Ioans)(subtract Line 30 from 29).

32. TOTAL OPERATING EXPENDITURES (from Line 19) . 33. OFFSETS TO OPERATING EXPENDITURES (from Line 15) . 34. NET OPERATING EXPENDITURES (subtract Line 33 from 32) ion

p~i "erate schadwlets) SCHEDULE A ITWIZED RECEIPTS fle each category of the Detailed Summary PwP FOR INE NUMBER

Any-,rposa., information other than copied using from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions or for commercial the name and addm of any political committee to so.ct contribution from such commitee. lAME OF COMMITTEE (in Ful.l

U> A. FulN M p klll c 1P Addm% & wd . L.. ( C A" X'f" 46 nt IA. Pull Namet Mallne Addreg and 21P End I - moame Of Eployer Date (month, Amount of Each day, vor) Receipt this Period

Occupation Receipt For: Li Primaery U General M Other (specify): A--- V i R ...... nEn fa, s -. a .... -- Iff . . " m---:u wne - --.... m----- 1r " .... Name of Employer Date (month. Amount of Each day, year) Receipt this Period

Occupation Receipt For: Li Primary LJ General rl Other (specify): ,Ag~aate Year.tonist. 0 C. Full Name. Mailing Addre and ZIP Code Name of Employer Date (month, A day.Date(onth. Year I ReceiptAmount this of PerOdEach

Receipt For: k- Primary L General SOther (seif) Y,,.,o .,,I j-~ the (seciy):Aggregate Year-to-Dat, 5$ 0. Full Name. Mailing Addres and ZIP Code Name of Employer Date (month, Amount of Each day, year) Receipt this Period

'Receipt For.I Primary General Ocpto

J7 ,-hr(pcf) Aggregate Year-to.DtO " E. Full Name, Mailing Address and ZIP Code Name of Employer Date (month. Amount of Each day, year) Receipt this Period

Occupation IReceipt For: Lj Primary U General _]]Other Ispecifv): Aggregate Year-to-,e' s-

[g V 1 W.ll SmA it.| Aad :. -- Vin I_.__ . a fl and*Eww V %#0 Name of Employer Date (month. Amount of Each day. year) Receipt this Period

Occupation Receipt For: U Primary [. General 7 Other (specify): .. ll ~~ ]II ~ ~ ~ ~ AniOccuPat .2---- Va-i*-- * r%-- . ul iame, madiiirg A@res anaZ Ir Loae Name of Employer Date (month, Amount of Each day, year) Receipt this Period

Occupation Receipt For: L_ Primary Li General F1 Other (specify): -1 ,w - V- IV -t J U a.W SUBTOTAL of Receipts This Page (optional)...... -

TOTAL This Period (last page this line number only)...... ft*iii '

I • I I or ITEMIZED DISBURSEMENTS Use separate scheduk(s) PAGE SCHEDULE B for each category of the Detailed Summary Page FOR LINE NUMBER

1 A Iknyinformation copied from such Reports anW Statements may not be sold or used by any person for the purpose of soliciting contributions or for commerci, purposes. other than using the name and addres of any political committee to solicit contributions from such committee. NAME OF COMMITTEE (in Full) Air ._c -, I A. Full Name, Mailing Address and ZIP Cod. Purpose of Disbursement Daeo (month Amount of Each day, year) Disbursement This Peric ILI , "4. -'. ft "0 " 5 - A,:. .-'C. Disbursement for: E Primary U General -1 Other (specifyI 9. Full Name. Mailing Address and ZIP Code Purpose of Disbursement Date (month, Amount of Each ~ ~ 1cck~,4 ~day. year) Disbursement This Peric

, • ,76o A t Disbursementfor: LPrimary U Gen. "A' co 1 40~;,, . 2 r Other (specify)- C. Full Name, Mailing Address and ZIP Code Purpose of Disbursement Date (month, Amount of Each •. i" Jt ~ d 7 T day, year) Disbursement This Peri,

Disbursement for: Primary General A, f.. i Other (specify)

0. Full Name, Mailing Address and ZIP Code Purpose of Disbursement - Date (month, Amount of Each -,1 '" day, year) Disbursement ThisPer .. . .. L .... . :,-,--.-This Per ~." ' . o ", ', "cc Disbursement for: [Primary LJGeneral . j' ,. "

,,... ;.. ... -. ,~ - ', < .... . Other (specify)

E. Full Name, Mailing Address and ZIP Code Purpose of Disbursement Date (month, Amount of Each

. I day. Year) Disbursement This Pe,

'isbursement for: Li Primary H General Other (speciflV

F. Full Name. Mailing Address and ZIP Code ;Purpose of Disbursement Date (month, Amount of Each Disbursement This Per f - day. year)

Disbursement for: .1 Primary H General ' '.' Other specify G. Full Name, Mailing Address and ZIP Code Purpose of Disbursement Date (month. Amount of Each clay, year) Disbursement This Per

'Disbursement for: Primar ,General

~ -~'KOther(seiy I

H. Full Name, Mailing Address'and ZIP Code Purpose of Disbursement Date (month, Amount of Each A . n , day, year) Disbursement This Per

. , . t -Disbursement for: * Primary General .

" , ' - I " "- Other (specify) 1. Full Name, Mailing Address and ZIP Code Purpose of Disbursement Date (month, Amount of Each jlj' / 1 day, year) Disbursement This Pe'

Disbursement for: Primary U General P 'ir . ."

C, -, Other (specify)

SUBTOTAL of Dtsbursements This Page (optional) ......

TO TA L This Period (4ass page th;S fine numb~er only) ......

0 0o0 0 / eparate schedule(s) PAGE Of ITEM , DISBURSEMENTS I of the .7 SCHEDULE B for each category Detailed Summary Page FOR LINE NUMBER

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions or for commerc;a r0P01Se1.other then using the name and address of eny political committee to solicit contributions from such committee. NAME OF COMMITTEE fin Full)

COMMTT.1' it , ~ ,. ~T ...... ,.."

A. Full Name, Mailing Address and ZIP Code Purpose of Disbursement Date (month. Amount of Each day, Ver) Disbursement This Peri , , _ _ ,,,, . _

for: J Primary it Disbursement U General I Other (specify) . Fuff Naeo Mailingl Address ad ZiP Code .'= "Purpose of Disbursement Date (month, Amount of Each *day. Year) Disbursement This Peric, 8. Full Nonte, Mailing Addrm and ZIP Code PupsafLsusettOt mnh Amount of Each 3C *S t',4 UT Disbursement for: Primary LJ General 1°,). " .. ., ~ ~ IO~!Other (speicifyV) C. Full Name. Mailing Address and ZIP Code Purpose of Disbursement Date (month, Amount of Each i r .'day, year) Disbursement This Pert

Disbursement for: [J Primary L General A A 7

_,' *Other. (specify) . D. Full Name. Mailing Address and ZIP Code Purpose of Disbursement Date (month. Amount of Each dlay. year) Disbursement This Per,

SZf ' Disbursement for: I 1 Primary Lj General x J

~~ s.-,~~~~~0 ~~Other (specify) ______E. Full Name. Mailing Addres and ZIP Code Purpose of Disbursement Date (month. Amount of Each day. veer) Disbursement This Per.-

- I"% Disbursement for Li Prmry General Other (specify) F. Full Name, Mailing Address and ZIP Code Purpose of Disbursement Date (month, Amount of Eaci, day. year) Disbursement This Pe,

G. Full Name. Mailing Address and ZIP Code Purpose of Disbursement

H. Full Name. Mailing Address and ZIP Code

I. Full Name. Mailing Address and ZIP Code

ISS;UBTOTAL ofo Dtsb~rse~en~ts This Page (optional)......

TOTA L This Period (last page this line num ber onl) ...... -.

i i 1000062 N• - ,7 IT .-. .T, *, " ;. , ...-. ,.. Senor f.l, . . , Anthn D .a I~or IAn&yet 999 a 8to nIow* IfehIA"t Doe* 1%7 4-y . 3.3, •3 . . ... i " ,,,

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N.I. oir whi Ch VO bad -s ~ r as1WJmee W for-$500 and, inolud4ed in oaur'•-~ L our calendar ye.r o. ". The sond tran ser'1 *, IAt-•,, CD sincme it va" * acOC"ad~amgXAJMI- have received a neirox orp o had Previously requ~e Vbt MJb ft 'Friends of cei This $6 Jackson* be aoow t * *975 transfer lovsr. ggaole' aor Party Comitte bqts by 46,150 to .: conjunction with a $50 additut away from the individual aror. -it.*not 125 lowering Unit1.t the total by $75 to $135,031.54. 1cotributions Thus, our calendar year dropped dovn to $214,557.61. Total cntributionS . or if you have any qraestlms comnts, please give 2e a call at 737-4673. Thanks.

Sincerely.

Stcven B. Cobble Executive Director

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FEDERAL ELECTION COMMISSION WASHINCTO4 DC SMS

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Cirilo A. McSween, Treasurer Keep Hope Alive Political *UU Action Committee 1074 Thomas Jefferson Street Washington, DC 20007 Identification Numbers C00229286 Reference: Year 8nd Report (11/29/88-12/31/88) Dear Mr. McSween: C% This letter is prompted by the review of Commission's preliminary the report(s) referenced above. The questions concerning certain review raised Information contained In the report(s). An itemization followss r'' -Although you have reduced receipts from Line Il(a)(1) and 11(b) of the Detailed Summary Page through a transfer-out to your non-federal account* you (D not adjust the Column should Please amend your reporta calendar year-to-dati figures. into your to disclose total receipts account for the calendar year. In addition, your beginning cash-on-hand figure on Line ") ~Summary 6(b) of the Page should equal the cash-on-hand at the close of your 1988 30 Day Post-General Report. -The Commission notes your transfers to your non- feJeral account of possible Although impermissible funds. the Commission may take further legal concerning the steps acceptance of impermissible funds, your prompt action will be taken into consideration. A written response or an amendment to your original report(s) c:rrecting the above tl-e FeJeral problem(s) should be filed with Election Commission with.n fifteen (IS) date of tnis letter. If you days of the need assistance, please feel free to coritact me on our toll-free number, (800) 424-9530. My local :njmber is (202) 376-2480.

Sincerely,

An~ny 000066

Senior Reports Analyst ______Reports Analysis Division ID Is C00229286 733 15th St.. N.V. Room #700 Washington. D.C. 20005 rN1' March 27. 1989

Anthony D. Raymond Senior Reports Analyst Reports Analysis Division Federal Election Commission Washington# D.C. 20463

Dear Mr. Raymond:

On March 8, 1989. you wrote to the Keep Hope mmj. Alive PAC requesting a written response regarding certain information from our Year End Report. I r. should note here that we have responded in as timely a fashion as we could, including walking our response over to the FEC personally. Unfortunately, your letter was mailed to our old address (1074 Thomas Jefferson St.) instead of our new one (733 15th St.. N.W.; Room #700; Washington, D.C.; 20005), thus delaying our receipt of the letter.

(We have previously filed an amendment of our address with the FEC. If we need to do so again, please let me know.)

As you noted in your March 8th letter, we had incorrectly adjusted our calendar-year-to-date figures when we transferred certain monies from our Federal account to our Non-Federal account. Upon review, this was due to several factors, but mainly due to our assumption that monies that should have originally been placed in our Non-Federal account should not be counted as having been received and then disbursed from our Federal a-count. Now that you havL corrected this mistaken assumption on our part, we will not make this mistake aqain. (Also. of coarse, oar intent from now on i to make sure that money which belongs in our Non-i'ederal account is correctly placed there in the I ir.t placel)

(100067 2 The attached copies of our Year End Report now show the following Asianges: *The correction of a $50 addition error 11/28/88 report. in our *The transfer of to our $6,975 from our Federal account Non-Federal account, which includes the $S,000 donation which the FEC first questioned. *The transfer of another account $2,000 from our Federal to our Non-Federal account, which we had incorrectly deducted from our Year This amount End Report figures. covered three checks for which we had been able to find no additional information early on these three donors (Paris-$1,O00; Compton-$500; Higgins-$S00). Our figures have been adjusted as shown on the attached copies of our Year End figures Report. These new will be reflected in all subseqtent reports. Please contact me if there are any further M) questions on this matter.

Sincerely, C)

Steven B. Cobble Executive Director

Zcc: Cirilo A. McSween Secretar y/Trcasjrer

000068 MR&,g i 'M• iON . 1.01 MAMOal E v eUPo taU _ It I t Keep Hope Alive Political lion Committee a. February 27, 1989

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d3430 1 BEFORE THE FEDERAL ELECTION COlRl wl PH 4:08 In the Matter of ) Keep Hope Alive Political ) MUR 2939 SENSITIVE Action Committee and Dr. Mary Berry, treasurer as )

GENERAL COUNSEL'S REPORT I. BACKGROUND

This matter was initiated by a referral from the Reports Analysis Division ("RAD"). On August 8, 1989, the Commission found reason to believe Keep Hope Alive Political Action Committee ("the Committee") and its treasurer' had violated 2 U.S.C. $ 441b and 11 C.F.R. S 102.5(a). These findings related to the Committee's receipt of $5,850 in funds from four unregistered organizations as follows:

Organization Date Amount Friends of Jesse Jackson 7-13-88 $5,000.00 Washington, D.C. 0 John Wiley Price Campaign 7-9-88 250.00 Dallas, Texas C) Committee to Elect Rev. 7-10-88 500.00 A.R. Polk River Rouge, Michigan

Mid-Brooklyn Political 9-15-88 100.00 Association

The Commission also approved interrogatories and a request for

1. The referral and First General Counsel's Report identified Cirilio A. McSween, as treasurer. This Office has learned that on June 27, 1989, the Committee filed a new Statement of Organization identifying Dr. Mary Berry as the treasurer. The letter accompanying the statement stated that her term began with the filing of the statement, although the statement itself is dated February 27, 1989. -23

documents with respect to these receipts. Counsel for the Committee filed the response on October 17, 1989. Attachment 1. Keep Hope Alive Political Action Committee was organized in June 1988 and filed its original Statement of Organization with the Commission on June 30, 1989, listing Alvin J. Boutte of Chicago, Illinois, as treasurer and custodian of records and the Independence Bank of Chicago as the campaign depository and with the Committee located in Chicago. The Committee described itself as a committee that supports or opposes more than one federal candidate and is not a separate segregated fund or a party

011 committee. On October 27, 1988, the Committee filed a new Statement of Organization identifying Cirilio A. McSween of Chicago as treasurer and Steven B. Cobble of Washington, D.C., as custodian of records and added the National Bank of Washington as a depository and indicated a change of location to Washington, D.C. For 1988, the Committee reported total receipts of $223,481 and

D7 total disbursements of $77,486. - On January 30, 1989, the Committee again amended its Statement of Organization to show a new address in the District. The Committee further amended its statement on June 27, 1989, to show Dr. Mary Berry of Washington as the new treasurer and added the Adams National Bank of Washington as a depository. Through the 1989 Mid-Year Report, the Committee disclosed total receipts of $138,394 and total disbursements of $190,777 with cash on hand of $93,663.42 and debts owed by the Committee of $7,633.93. From its inception, the Committee's counsel has been the same as * -3- counsel designated to represent the Committee in this matter. I11. FACTUAL AND LEGAL ANALYSIS

The Commission's regulations provide that organizations, which qualify as a political committee under the Act must register with the Commission. 11 C.F.R. S 100.5. organizations qualifying as political committees must establish a separate account for federal activity which includes only funds subject to the limitations and prohibitions of the Act. 11 C.F.R. 5 102.5(a). organizations that are not political committees must either establish a separate account for federal activity or demonstrate that contributions made to federal committees did not include any funds prohibited under the Act. 11 C.F.R. S 102.5(b). The Act prohibits corporate and labor union contributions. 2 u.s.C. s 441b. With respect to the $250 contribution from the John Wiley Price Campaign, counsel states that Mr. Price, a county commissioner in Dallas, wrote the check from his campaign fund. Counsel further states that "[wle have spoken with Mr. Price, and he has stated that there was at that time no corporate or labor money in his campaign account, nor did his campaign receive any personal contributions greater than $5000." we note that Texas law prohibits corporate and labor union contributions. Regarding the $100 contribution from Mid-Brooklyn Political Association, counsel states that James Connally, district leader of the 42nd State Assembly District in New York, signed a check for $100 from the Mid-Brooklyn Political Association, which is described as "an account opened for the purpose of impacting -4-

local races in Brooklyn." Counsel further states that "Mr. Connolly has informed us that the account contained no corporate or union money and no individual contributions of more than $5000." We note that Now York law permits limited corporate contributions and unlimited union contributions. Counsel states that the Committee to Elect Rev. A.R. Polk has been written at its last known address but that a reply is still awaited. Accordingly, this Office contacted the office of the Secretary of State, where campaign reports are filed, to ascertain if this committee had been registered during 1988 and, if so, if copies of its reports could be obtained. No such committee had been registered with the state for 1988. This Office then contacted the Wayne County Clerks office to ascertain if such a committee was a local committee registered with that office and again learned that no such committee had been registered with Wayne County. Finally, staff of this office called Rev. A.R. Polk on November 1. Rev. Polk stated that the committee was formed for an election within the church, not a political office. Although he said he did not recall making a contribution to Keep Hope Alive PAC, he did acknowledge that such a contribution may have been made during a meeting in Texas. He further stated that the funds in the committee's accounts did not come from corporations or unions but from members of the church. Finally, counsel has clarified the circumstances regarding the $5000 reported as received from Friends of Jesse Jackson. Counsel states:

On June 20, 1988, a twenty-five dollar plate ($25) per dinner was held at the Shiloh Baptist Church -5- located at 9th and P Streets, N.W., Washington, D.C. The dinner was advertised throughout the community, via flyers and invitations, as a dinner featuring the Reverend Jesse Jackson. Reverend Jackson had planned to attend, but could not due to a scheduling conflict. The guest speakers who did attend included Mayor Marion Berry and Congressman Walter Fauntroy. Approximately three hundred (300) people were at the dinner. The organizers of the dinner opened an account at the Industrial Bank of Washington specifically for this event. The account was opened in the name "Friends of Jesse Jackson." The profits from the dinner- five thousand dollars ($5000) -- were placed into this account. Shortly after the dinner, according to one of the organizers of the event, Mr. Joseph Beavers, the organizers consulted with Jesse Jackson who suggested that the proceeds of the dinner be contributed to the Keep Hope Alive PAC. on July 13, 1988, a five thousand dollar check representing all of the profits from the dinner was written to the Keep Hope Alive PAC. The "Friends of Jesse Jackson" bank account was thereupon closed out. As discussed above, "Friends of Jesse Jackson" is not a formal organization. This was merely the name given to the bank account opened for the purpose of receiving and transferring the proceeds of a dinner held in Washington, D.C. at the Shiloh Baptist Church. The head organizer for this event was Mr. Joseph Beavers. Mr. Beavers is a clerk and a trustee of the Shiloh Baptist Church. Mr. Beavers can be reached at (202) 654-6391, and correspondence may be sent care of the Shiloh Baptist Church. Later in the response, counsel contends that the receipt of the $5000 in funds from the Shiloh Baptist Church event was proper. Counsel states:

... Furthermore, we believe that the $5000 representing the profits of the dinner at the Shiloh Baptist Church was properly transferred to the Keep Hope Alive PAC under 11 C.F.R. S 102.6. We do acknowledge, however, that this receipt originally was not properly reported. By virtue of 11 C.F.R. SS 102.6(c)(5),(7), and S 104.3(a), the Keep Hope Alive PAC was not obligated to report the names of the individual attendees at the dinner, but it should have reported the aggregate $5000 amount as a memo entry of unitemized contributions. Instead, the amount was reported as a receipt from a committee. This $5000 and the other three contributions have since been transferred out of the Keep Hope Alive PAC's federal account and into its non-federal account, -6- and the PAC's reports have been amended to reflect this transfer. Therefore# we do not presently see a need to amend further the initial reports listing these contributions. Counsel has not requested preprobable cause conciliation, but instead concluded her letter by stating that the Committee would "be happy to provide any further assistance needed by the Commission in order to close this matter without further action." in the view of this Office, counsel's reliance on 11 C.F.R. S 102.6, particularly subsections (c)(5) and (7), is misplaced. Those provision deal with collecting agents for separate segregated funds. When Keep Hope Alive PAC registered with the Commission, it indicated on its Statement of Organization that it was not a separate segregated fund. Moreover, there are no apparent facts which would suggest that it is a separate segregated fund. Nevertheless, counsel by citing to these regulations does represent and assert that Friends of Jesse Jackson was a fundraising agent for Keep Hope Alive PAC. She states that Friends of Jesse Jackson was not a formal organization but merely the name used to open a bank account into which the proceeds of the Shiloh Baptist Church dinner were deposited. All of the funds deposited into this account were apparently transferred to Keep Hope Alive PAC and the account closed. Accepting these representations as valid, the forwarding provisions of the Act and regulations at 2 U.S.C. S 432(b)(2) and 11 C.F.R. S 102.8(b) are the initial reference point. Because the amount of the individual contributions was only $25 per -7- person, these provisions required that the person receiving these contributions forward them to the committee within 30 days. See 11 C.F.R. 5 102.8(b)(l). The event was held on June 20, 1988, and the funds disbursed to Keep Hope Alive PAC on July 13, 1988, or 23 days later. Thus, to the extent they may be applicable, the forwarding provisions of the Act and regulations were complied with.

Counsel has stated that the Committee should have reported these funds as unitemized contributions from individuals rather than a contribution from a political committee. We note that if counsel's contention that Friends of Jesse Jackson were merely a fundraising agent for the Committee and not itself a political N committee were accepted, then the Committee should have reported gross (not net) proceeds and the expenses of the dinner as disbursements. 2

The facts as presently known, however, suggest that Friends

of Jesse Jackson may have functioned as a political committee. A

,7) '1committee" is defined to include "any... group of persons" who

- receive more than $1,000 in contributions or make more than

2. The regulations do not speak specifically to situations where a fundraising agent pays expenses of the fundraising activity from the fundraising proceeds themselves. where that occurs, however, the recipient committee should report the gross proceeds and the expenses paid. If a separate bank account is used to make the initial deposit of the proceeds and from which expenses are paid, the account should be listed as a campaign depository. If that is done, the forwarding provisions are met with the deposit into this account. See, Advisory Opinion 1980-42 and MUR 2808. If, instead, the fundraising agent pays expenses from its own resources, not from the proceeds, such payments are advances and should be reported by the recipient committee as in-kind contributions unless they are reimbursed on a timely basis. $1,000 in expenditures during any calendar year. 2 U.S.C. 5 4 3 1(4)(A). Friends of Jesse Jackson is a name used by a group of persons who held a fundraising event. The group charged persons attending the event $25 per person. rt paid the expenses of the event and deposited the proceeds into a separate bank account. From this account, it made a $5,000 contribution to Keep Hope Alive. Thus, it appears that Friends of Jesse Jackson qualified as a political committee under the Act and should have registered and reported, even though it may have also been able to terminate. Accordingly, we recommend that the Commission find LO reason to believe Friends of Jesse Jackson and Joseph Beavers, in) acting as treasurer, violated 2 U.S.C. 55 433 and 434. PN, Furthermore, we do not know what the fliers and invitations to I-) dinner said or the circumstances relating to the request or suggestion by Reverend Jackson or his representative that the funds be contributed to Keep Hope Alive PAC . As noted earlier, the information received from counsel indicates that it does not appear the contributions received from

- the John Wiley Price Campaign and the Mid-Brooklyn Political Association, were made from accounts containing funds prohibited under the Act or in excess of the Act's limitations. Rev. A.R. Polk told staff of this office that funds in the account of the

3. If an investigation shows that these funds were behalf of solicited on Reverend Jackson's candidacy or earmarked by the contributors to his candidacy, a further question whether would arise Reverend Jackson has effectively directed or controlled the making of this contribution so that it should also have been attributed to him or his principal campaign committee Friends of as well as Jesse Jackson and so reported by his committee and Keep Hope Alive PAC. See 11 C.F.R. 5 110.6. -9-

Committee to Elect Rev. A.R. Polk came from members of his church. Furthermore, counsel has clarified that the funds initially reported as received from Friends of Jesse Jackson consisted of individual contributions of $25 and did not come from an account that included any corporate or union funds. Thus, it does not appear that these funds included prohibited funds under 2 U.S.C. 5 441b or that their deposit violated 11 C.F.R. S 102.5(a). Because of the need to further investigate whether Friends of Jesse Jackson was a political committee and the possible impact of the resolution of this issue on Keep Hope 110 Alive, we do not at this time make any recommendations with

respect 4 to Keep Hope Alive. Once the investigation is complete, N- the Section 441b and 102.5(a) issues can be addressed in a brief.

III. RECOMMENDATIONS

1. Find reason to believe Friends of Jesse Jackson and Joseph Beavers, acting as treasurer, violated 2 U.S.C. SS 433 and 434. a

4. If it is determined that Friends of Jesse Jackson was a political committee, then its $5,000 contribution to Keep Alive would Hope be within the contribution limitation of 2 U.S.C. S 441a(a)(1)(C) for contributions to unauthorized committees. noted in the report, As if it is determined that Friends of Jesse Jackson were merely a fundraising agent and not a political committee, then Keep Hope Alive PAC should have reported the gross receipts as well as the expenses and would have violated 2 U.S.C. S 434(b) by failing to do so. Whether further findings with respect to Keep Hope Alive PAC are necessary will depend on the resolution of the issue regarding the status of Friends of Jesse Jackson. See also, Footnotes 2 and 3. -10- 2. Approve the attached letter, factual and legal analysis, and interrogatories and request for documents.

Lawrence M. Noble General Counsel

BY: Date Lois G. ferner Associate General Counsel Attachments 1. Response 2. Proposed letter, factual and legal analysis, and interrogatories and request for documents

Staff persons: Jeffrey D. Long George F. Rishel FEDERAL ELECTION COMMISSION WASHINGTON. 0 C 20461

MEMORANDUM

TO: LAWRENCE M. NOBLE GENERAL COUNSEL

FROM: MARJORIE W. EMMONS/DELORES HARRIS&" COMMISSION SECRETARY

DATE: NOVEMBER 17, 1989

SUBJECT: MUR 2939 - GENERAL COUNSEL t REPORT DATED NOVEMBER 13, 1989

The above-captioned document was circulated to the Commission on Wednesday, November 15, 1989 at 11:00 a.m.

Objection(s) have been received from the Commissioner(s) as indicated by the name(s) checked below:

Commissioner Aikens

Commissioner Elliott

Commissioner Josef iak xxxx

Commissioner McDonald

Commissioner McGarry

Commissioner Thomas xxxx

This matter will be placed on the meeting agenda for Tuesday, November 28, 1989 at 10:00 a.m.

Please notify us who will represent your Division before the Commission on this matter. BEFORE THE FEDERAL ELECTION CONNISSION

In the Matter of ) MUR 2939 Keep Hope Alive Political Action ) Committee and Dr. Mary Berry, as ) treasurer )

CERTIFICATION

I, Marjorie W. Emmons, recording secretary for the Federal Election Commission executive session on

November 28, 1989, do hereby certify that the Commission decided by a vote of 5-0 to take the following actions in MUR 2939:

1. Find reason to believe Friends of Jesse Jackson and Joseph Beavers, acting as treasurer, violated 2 U.S.C. SS 433 and 434. 2. Approve the letter, factual and legal analysis, and interrogatories and request for documents as recommended in the General Counsel's report dated November 13, 1989.

Commissioners Aikens, Elliott, Josefiak, McDonald, and Thomas voted affirmatively for the decision;

Commissioner NcGarry was not present.

Attest:

Date of E tW e os Secretary of the Commission FEDERAL ELECTION COMMISSION WASHINGTON. OC 2043

December 7, 1989

CERTIFIED MIUL

Joseph Beavers, Acting Treasurer Friends of Jesse Jackson c/o Shiloh Baptist Church 1500 9th Street, N.V. Washington, D.C. 20001

RZ: NUR 2939 Friends of Jesse Jackson and Joseph Beavers, acting as treasurer Dear Mr. Beavers:

On November 28, 1989, the Federal Election Commission found that there is reason to believe Friends of Jesse Jackson (*the Committee") and you, as treasurer, violated 2 U.S.C. 55 433 and 434, provisions of the Federal Election Campaign Act of 1971, as amended ("the Act"). The Factual and Legal Analysis, which formed a basis for the Commission's finding, is attached for your information.

Under the Act, you have an opportunity to demonstrate that no action should be taken against the Committee and you, as treasurer. You may submit any factual or legal materials that you believe are relevant to the Commission's consideration of this matter. Please submit such materials to the General Counsel's Office along with answers to the enclosed questions within 15 days of your receipt of this letter. Where appropriate, statements should be submitted under oath.

In the absence of any additional information demonstrating that no further action should be taken against the Committee and you, as treasurer, the Commission may find probable cause to believe that a violation has occurred and proceed with conciliation.

If you are interested in pursuing pre-probable cause conciliation, you should so request in writing. See 11 C.F.R. S 111.18(d). Upon receipt of the request, the OfTTe of the General Cour-el will make recommendations to the Commission either propo~ing an agreement in settlement of the matter or Joseph Beavers Page 2 recommending declining that pre-probable cause conciliation be pursued. The Office of the General Counsel pro-probable may recommend that cause conciliation not be entered into at this time so that it may complete its investigation of the matter. Further, the Commission will not entertain requests for pre-probable cause conciliation after briefs on probable cause have been mailed to the respondent. Requests for extensions of time will not be routinely granted. Requests must be made in writing at least five days prior to the due date of the response and specific good cause must be demonstrated. in addition, the Office of the General Counsel ordinarily will not give extensions beyond 20 days. If you intend to be represented by counsel please in this matters advise the Commission by completing the enclosed form stating the name, address, and telephone number and authorizing of such counsel, such counsel to receive any notifications and other communications from the Commission.

This matter will remain confidential in accordance with 2 U.S.C. 55 437g(a)(4)(8) and 437g(a)(12)(A), the Commission unless you notify in writing that you wish the investigation to made public. be

For your information, we have attached a brief description of the Commissionf's procedures for handling possible of the Act. violations If you have any questions, please contact Jeffrey D. Long, the staff member assigned to this matter, at (202) 376-5690.

DAnny Li McDonald Chairman Enclosures Factual and Legal Analysis Procedures Designation of Counsel Form Questions FEODUAL ELECTIOU COMM ISSIOU

FACTUAL AND LEGL ANALYSIS

RESaOUD3TS: friends of Jesse Jackson MIUhR 2939 and Joseph Beavers, acting as treasurer 1. GEUE3ATwI OF rTTEM

This matter was generated based on information ascertained by the Federal Election Commission (*the Commission0) in the normal course of carrying out its supervisory responsibilities. 2 U.S.C. S 4379(a)(2).

11. FACTUAL AND LEGAL ANALYSIS

Under the Federal Election Campaign Act of 1971, as amended ("the Act"), a 'committee" is defined to include "any...group of persons" who receive more than $1,000 in contributions or make more than $1,000 in expenditures during any calendar year. 2 U.S.C. S 431(4)(A). Such political committees are required to file a Statement of Organization with the Commission within 10 days of becoming a political committee and to file periodic reports of its receipts and disbursements. 2 U.S.C. SS 433 and 434.

Keep Hope Alive Political Action Committee reported the receipt of a $5,000 from Friends of Jesse Jackson on July 13, 1988 as the receipt of a contribution from a political committee. Friends of Jesse Jackson apparently is a name used by a group of persons who held a fundraising event at the Shiloh Baptist Church on June 20, 1988. The event was advertised by fliers and invitations distributed in the community. The group charged persons attending the event $25 per person. It apparently paid -2- the expenses of the event and deposited the proceeds Into a separate bank account at the Industrial Bank of Washington. from this account, it made a $5,000 contribution to Keep NOV* Alive after consulting vith the Reverend Jesse Jackson or his representatives. Thus, it appears that Friends of Jesse Jackson qualified as a political committee under the A~ct and should have filed a Statement of organization and a July and October Quarterly Report for 18. Accordingly, there Is reason to believe Friends of Jesse Jackson and Joseph Beavers, acting as treasurer, violated 2 U.S.c. 5S 433 and 434.

1. if this activity were the only federal election activity by Friends of Jesse Jackson, it could also have terminated after filing the July and October Quarterly reports. w...... r

BEFORE T FEDER" E CTION COIN ISSIOK In the Matter of )

) lU 2939 )

13YUo001TIzes AND EQoEST

TO: Joseph Beavers, Acting Treasurer Friends of Jesse Jackson c/o Shiloh Baptist Church 1500 9th Street, NW.. Washington, D.C. 20001 in furtherance of its investigation in the above-captioned matter, the Federal Election Commission hereby requests that you submit answers in writing and under oath to the questions set forth below within 15 days of your receipt of this request. In addition, the Commission hereby requests that you produce the documents specified below, in their entirety, for inspection and copying at the Office of the General Counsel, Federal Election Commission, Room 659, 999 E Street, N.W., Washington, D.C. 20463, on or before the same deadline, and continue to produce those documents each day thereafter as may be necessary for counsel for the Commission to complete their examination and reproduction of those documents. Clear and legible copies or duplicates of the documents which, where applicable, show both sides of the documents may be submitted in lieu of the production of the originals. MUR 2939 Joseph Beavers Page 2 INSTRUCTIONS

In answering these interrogatories and request for production of documents, furnish all documents and other informationt however obtained, including hearsayr that is in possession of, known by or otherwise available to you, including documents and information appearing in your records. Each answer is to be given separately and independently, and unions specifically stated in the particular discovery request, no answer shall be given solely by reference tither to another answer or to an exhibit attached to your response* The response to each interrogatory propounded herein shall set forth separately the identification of each person capable of furnishing testimony concerning the response given, denoting separately those individuals who provided informational, documentary or other input, and thost who assisted in drafting the interrogatory response. If you cannot answer the following interrogatories in full after exercising due diligence to secure the full information to do so, answer to the extent possible and indicate your inability to answer the remainder, stating whatever information or knowledge you have concerning the unanswered portion and detailing what you did in attempting to secure the unknown information. Should you claim a privilege with respect to any documents, communications, or other items about which information is requested by any of the following interrogatories and requests for production of documents, describe such items in sufficient detail to provide justification for the claim. Each claim of privilege must specify in detail all the grounds on which it rests. Unless otherwise indicated, the discovery request shall refer to the time period from January 1. 1988 to the present. - The following interrogatories and requests for production of documents are continuing in nature so as to require you to file supplementary responses or amendments during the course of this investigation if you obtain further or different information prior to or during the pendency of this matter. include in any supplemental answers the date upon which and the manner in which such further or different information came to your attention. HUR 2939 Joseph Beavers Page 3 DZFINITIONS For the purpose of these discovery requestse including the instructions thereto, the terms listed below are defined as follows:

"You" shall mean the named respondent in this action to whom these discovery requests are addressed, including all officers, employees, agents or attorneys thereof. "Persons* shall be deemed to include both singular and plural, and shall mean any natural person, partnership, committee, association, corporation, or any other type of organization or entity.

"Document* shall mean the original and all non-identical copies, including drafts, of all papers and records of every type in your possession, custodyt or control, or known by you to exist. The term document includes, but is not limited to books,, letters, contracts, notes, diaries, log sheets, records of telephone communications, transcripts, vouchers, accounting statements, ledgers, checks, money orders or other commercial paper, telegrams, telexes, pamphlets, circulars, leaflets, reports, memoranda, correspondence, surveys, tabulations, audio and video recordings, drawings, photographs, graphs, charts, diagrams, lists, computer print-outs, and all other writings and other data compilations from which information can be obtained. "Identify" with respect to a document shall mean state the nature or type of document (e.g., letter, memorandum), the date, if any, appearing thereon, the date on which the document was prepared, the title of the document, the general subject matter of the document, the location of the document, the number of pages comprising the document.

"Identify" with respect to a person shall mean state the full name, the most recent business and residence addresses and the telephone numbers, the present occupation or position of such person, the nature of the connection or association that person has to any party in this proceeding. If the person to be identified is not a natural person, provide the legal and trade names, the address and telephone number, and the full names of both the chief executive officer and the agent designated to receive service of process for such person.

"And" as well as "or" shall be construed disjunctively or conjunctively as necessary to bring within the scope of these interrogatories and requests for the production of documents any documents and materials which may otherwise be construed to be out of their scope. MUR 2939 Joseph Beavers Page 4 These questions relate to the event hold an June 20, 1988t at the Shiloh Baptist Church which resulted in funds being raised that were eventually contributed to the Keep Hope Alive Political Action Committee.

I. Describe in detail this event Includiqg the identity of the organizers and who spoke at the event.

2. State whether the cost for attending this event vas solicited on behalf of Reverend Jesse Jackson or his principal campaign committee. State further whether personW who attended the event earmarked or designatede In any manner, his or her payment as made on behalf of, or directed to, Reverend Jackson or his principal campaign committee. State whether persons making payments to attend this event were told their contributions go would to Reverend Jackson, his principal campaign committee, or Keep Hope Alive Political Action Committee. Provide copies of each type of flier and invitation used to advertise this event or solicit persons to purchase ticker or make contributions with respect to this event.

3. State the amount of total (gross) proceeds realized this event from and itemize all expenses for this event to include the payee, the amount, and the purpose of the payment. State all whether expenses were paid for from the proceeds and whether payments were made from the bank account at the Industrial Bank Washington. of If not, identify each expense that was paid for from other sources and identify the source who paid for each expense. such identify all goods or services provided without charge with respect to this event.

4. Identify the account number and the person(s) who the opened account at the industrial Bank of Washington into which the proceeds were deposited and who had authority to sign checks drawn on this account. Provide copies of the bank statements for this account for the period covering June and July 1988. whether State payments to attend this event were made in cash or by check and, if both, give the approximate percentage of each. State whether all checks were deposited into the account at the industrial Bank of Washington.

5. Identify the person(s) who suggested or requested that the proceeds from this event be contributed to the Keep Alive Hope Political Action Committee. State the date and place where this request or suggestion was made and who was present time. at the f *0 't 6 ~ January 26, 1990

Federal Election Commission Danny L. McDonald, Chairman 999 E Street, NW Washington, DC 20463 CA)

Re: MUR 2939 Dear Sir:

This correspondence is in reply to your letter dated ( December 7, 1989, and received by me January 7, 1990. I contacted Mr. Jeffrey D. Long, the staff member assigned to this case by telephone, who advised that I within 20 days answer the questions on MUR 2939 page 4, which are as follows:

. Question Number 1. Answer -- In the early spring of 1988 Pastor Henry C. Gregory, III of Shiloh Baptist Church and I was discuss- %J. ing the candidacy of Jesse Jackson for President of the U.S.A. who had a strong message but a shoe string budget and he asked me about putting on a fundraiser for Rev. Jackson because he would need a lot of money if he was going to do well in the primaries and win the Democratic Party candidacy for President c or Vice President at the Democratic National Convention in Atlanta, Georgia. I agreed. and contacted Mrs. Mattie Robinsoc.4 a very active member of Shiloh and head of the Missionary De- 0Z partmnent and Mr. Horace Roberts, one of the Senior Deacons an C) a very active community worker.

We three agreed to Chair and Co-Chair a Fundraiser for REM..- Jackson, the proceeds after expenses to help him win at the Democratic National Convention in Atlanta, GA. Our first job was to organize a committee, which we agreed to name"Friends of Jesse Jackson". We also agreed on Honorary Chairpersons, see Letterhead attached. We agreed on D.C. City Council Supporters, see Letterhead attached.

We got friends to join our committee, see Letterhead attached.

We were able to get as our guest speaker, Marion S. Barry, the Major of the District of Columbia.

Question Number 2. Answer -- The cost for attending this event was solicited on behalf of Rev. Jesse Jackson, see Invitation and return card. Committee Letterhead and Flier attached. All persons attending the affair was told that after expenses, all proceeds would be given to Rev. Jackson to help him win in Atlanta, GA.

Question Number 3. Answer -- The total receipts were $10,466.44 2

with Disbursements of $5,314.00 expenses and $5,152.44 to be given to Rev. Jesse Jackson. See attached itemized list. All disbursements for expenses was paid from the Industrial Bank of Washington by check.

Question Number 4. Answer -- The account was set up at the Industrial Bank of Washington. Checking Account Number 035-091-5 in the name of Friends of Jesse Jackson Banquet Fund Raiser with three people authorized to sign checks, Joseph A. Beavers, Mattie Robinson and Horace Roberts. Payments to attend the banquet was made both in cash and checks and were deposited in the Industrial Bank of Washington. I can't remember the percentage of each deposit but they were mostly checks. All checks and cash was deposited in this account. There was no* other account. Question Number 5. Answer -- Rev. Jesse Jackson was speaking at the National Association for the Advancement of Colored People's Convention held at the Sheraton Park Hotel, Washington, DC. The committee arranged to make the contribution to him personally on the night he spoke. The check was made out to Rev. Jesse NO Jackson in the amount of $5,152,44. After the check was presented to him in the Grand Ballroom where he spoke, later that night at the reception, Rev. Jackson came to me and asked me to change the check, and make the check out to Keep Hope Alive for $5,000.00 and give the $152.44 to yourself for part of your expenses to come down to Atlanta, GA to work for my candidacy at the Democratic National Convention. Present was Horace Roberts, Co-Chair and other members of the "Friends of Jesse Jackson Committee".

11qrSincereY _3 Jo eph A. Beavers

-p.s. Your other communication was sent to Shiloh Baptist Church. My address is 3215 Park View Road, Chevy Chase, MD 20815

Enclosures: Invitation & Return Card I- L- Financial Report of 6/20/88 - - Jesse Jackson Letterhead - Fundraiser Flier - S-- Bank Statements, June & July 1988-. -7-- PNORARY CHAIRPERSONS The Hon. Mario S. Bry, Jr. The Hon. Walter E. Fauntroy Mayor of 9k D.C. Delegae to Rev. Henry-.1mOgy, mI District of Colwimbia U.S. Congress Shiloh Baptist Church D.C. CITY COUNCIL SUPPORTERS Hon. Dave Co o Hon. H. R. Crawford * Hon. Wilhelmina Rolark o Hon. Frank Snith Ham Nadine Winters - Hon. Harry L Thomas o Hon. John Ray DINNER COMMITTEE Joseph A. Beavers o Chairperson Mattie Rdbmm * Co-Chairperson Horace Roberts • Co-Chakpown Licia Gren Ella 1. Pitts Jeame Bms Marion 0. Greene, Jr. Ronald Richenbo Robert Bas John Howard Calvin Rolark G. F. Bmgha Monteria Ivey Delores Sawyer Minor Chriadm Bary Jerrels Barbara Leas Siamno Christine COk Shari Jerrels Mrs. Joseph D. Spei. BemnuDemcl James Johnson Cirie Mae Turne Rev. David Bmm Donna Jones Mary Bates Wubinpau Willie Fordhu Carl W. Lee Richard Whisesum Lavonia P. Fairfax Gloria E. Miller John Williams Rev4,Ernme IL Gibson Mildred Moseley Stanley Williams

3'-- I FUNDRAISLJII k OR JESSE JACKSON

MONDAY * JUNE 20, 1988 SHILOH FAMILY LIFE CENTER NINTH AND P STREETS, N.W. WASHINGTON, D.C. 20001 JESSE JACKSON FOR PRESIDENT THE MAN WITH VISION

rw #f". A " A

The Hon. John Ray col Ccuwffmembw DOC

* PLEASE JOIN FRIENDS OF JESSE JACKSON ATA RECEPTION AND DINNER Fundraiserto Help Jesse Win at the DEMOCRATIC NATIONAL CONVENTION IN ATLANTA, GA Monday evening, the Twentieth of June Nineteen Hundredand Eighty-eight Guest Speaker the HonorableMarion S. Barry, Jr. Mayor of the Districtof Columbia Shiloh Family Life Center Ninth and "P"Streets, N.W., Washington, D.C. 20001

Hospitality Hour: 6:30 p.m. Dress Optional Dinner 7.00 pm. R.S.V.P. Card Enclosed (202) 2324200 THE ATLANTA DEMOCRATIC CONVENTION A CRITICAL CROSSROAD IN OUR NATION'S HISTORY JESSE JACKSON-88-FOR PRESIDENT RECEPTION & DINNER FUNDRAISER Family Life Center Monday, June 20, 1988 0 Shilob subsaptim($35.00 - tax deductible) $50.00 per person - sb ($35. - tax deductible) $500.00 for table of en of $ for %ti"]yes, I will attend and enclosed is my contribution person(s) @$50.00 or -a table(s) @ ______is my contribution of $ I No, I cannot attend, but enclosed Make checks payable to: Banquet Fundraiser Friends of Jesse Jackson Name ______

Hone Address

on reverse side. SPlease print name(s) and addmss(es) of Guest(s) MA.... ALYF LIEIJUWC CS"I 1510 9TH STREET, N. W. WASHINGTON, D. C. 20001

HONORARY U ON Mal r demllgaFcII~b FINANCIAL REPORT OF THE JUNE 20TH FUNDRAISER TO HELP Is IMDelWh ILho" JESSE JACKSON WIN AT THE DEMOCRATIC NATIONAL CONVENTION ite. HIw C. 0qW"I IN ATLANTA, GEORGIA a. C. M cotcu..uwuMm lm De Cor Receipts------lm IL L Cnaufad $ 10,466.44 KmL Fsk Soflh DISBURSEMENTS O NLoine Wadm 1: 3. MMwL hme h a. -da ay Printing ------$ 857.65 DIER COMMTIT U Postage, Posters, Office Supplies, J910 A. Dewm,%Chalepamm Mania. sEabIm *CChuPw= E.T.C. 589.19 H*mp Reber%,C*CbrPerMs Champagne, Wine & Snacks 410.88 for Reception Flowers for Head Table------52.50 C. F. 3o LS se ridmm Dinner, E.T.C. 2,833.78

Annette Anderson, Soloist - - Betrdj-i,- sawe DewnAu - - 50.00 RIN7D-avi FateS %11ikFordham Judy Williams,.Soloist 50.00 b" Cberbd mt Everett Williams, Organist - - - - 150.00 Ucla G.ace GMbaa 0. Grese, Jr. Delores Sawyer, Secty. Work - - -- 150.00 John Hoeward Returned Checks %Iarjlot) Hatcher, Whitson & Fields BarryJL" - - - 170.00 sun73 Joelrl Jam. Johmo. r $5,314.00

Carl W. Lee Gkoria LMNkh Balance to Mildred MrnalY give Rev. Jesse Jackson - - - $ 5,152.44 Ch-e M-nT Rold Rtichardso Calva loiark Barbara LAS hes Mrs.Jone*& D. Spallr Cirtle Mae Tinies %larySagan Wahiqon Richar WhIlAbara Joseph A. Beavers, Chairman ja wme Mattie Robinson, Co-Chair Horace Roberts, Co-Chair WASHINGTON, D. C. 20001

HONORARY C AIUPUISONS The llo. Marke. awy, Jr. Mayor dw D* 41t'MECsuft T -ei.Watw L Few" D.C. Deloga i U. & asmw Rev. Hray C. Go y, m Pa"r,SlDk a*" Cbwk

D. C. CITY COUN L SU?11R3tS Ho. Dave Clark Ha. IL R. Crawfwd Ho. WlIblaa IRlark Hon. Frmak Smft Hon. NadlmeWhir Ha. Hany L TIu Hon. John Ray

QQER COMMITEE Ja A. Isas,eh Chairperson Mattli Roblmm, C.Cbairpern fr.lce Roberta, Co-Chafrpem

Mielkorville Jeatle Bat"s It-ert Baia G. F. SagM "or Chriuilan Crdne Clark Bernard Demank f. David Eaton Willie Fordham gnaii P. Faiths I e. Ernest Lr Gibson ucia Green ,trion 0.Greene, Jr. John Howard ,"nteria Ivey Mar) Ivey Barry Jerreb Mari Jerreb James Job"" boamnrJones Carl W. Lee Gloria L Miller Mildred Moseley EllaJ. Pit Ronald Richardsnm Calvin Rolrk Barbara Lea Sbmom Mrs. Joseo D. Speller CirtieMae Turner Mary Bates Washington Richard Wlltehurst John Wulalam Ac

FUNDRAISER TO HELP JESSE WIN AT THE DSMOCRATIC NATIONAL CONVENTION IN ATLANTA, GA.

FRIENDS OF JESSE JACKSON INVITE YOU TO ATTEND A RECEPTION AND DINNER Guest Speaker the Honorable Marion S. Barry, Jr. Mayor of the District of Columbia

Monday, June 20,1988 Hospitality Hour: 6:30 p.m. Dinner: 7:00 p.m.

Shiloh Family Life Center 9th and P Streets, N.W. Washington, D.C. 20001

THE ATLANTA DEMOCRATIC CONVENTION A CRITICAL CROSSROADS IN OUR NATION'S HISTORY TICKETS $50.00 DRESS OPTIONAL ($35.00 tax deductible)

For further Information call The Family Life Center at (202) 232-4200 35-04 02 INDUSTRIAL SANK OF V IN6TON 4812 GEORGIA AVENUE WASHINGTON DC 20011 PHOhE&22-722-2G33

FRIkNqS OF JESSE JACKSON BANQUET FUND RAISER SENO STNr TO MINICIPAL CTR C/O LIZ CHECKING ACCOUNT: 353915 06/31/88 THRU 0712918B

PAGE 1 OJR CUSTOMER SERVICE LINE 722-2031 IS OPEN FROM V AN rO 3 PN MONDAY - FRIDAY FOR ANY INQUIRIES REGARDING YOUR CNECKING OR SAVINGS ACCOUNTS.

CHECKINfi ACCOUNT 350915 *ql3333333g5&33333 33333333333333* 333333333333333333333U3333U33nu33333U33333ana*n DESCRIPTION DEBITS CREDITS DATE BALANCE

BALAkCE LAST STATEMENT 36130168 6,946.00 310.00 47101/88 7,256323 CHECKcilck &0 9394 857.65 37/CSSB 6,59So35 159.28 07/06188 6,239.0? 175.00 718/88 CHI CK 0P 9b 6,414.0? 3,. 88 7/11/88 6,113.19 ChECK 9 97 J7/1 5/88 6,353.19 su.a.,LO bExOSI T 5w.L.C. 25.oC 37/28/88 6,D3R.19 cU1 c 96 5,Ull.cO J7128/88 6,o038.19 CHECK 37/28/88 1,038.19 8iLANCE THIS STATEMENT 07/29/88 1,D38.19

rOTAL CRE)LTS (3) 510.O( MINIMUM BALA4CE 1,038.19 --TOTAL DEaITS (6) 6,417.61 AVERAGE 8ALA4CE 5,393.19 tAX ID NUMibf 253-18-3619

YOUR CHECKS SEQUENCED

DAT#..LeHECK /...,...AMOUNT DATE..CHECK I...... AMOUNT DATEe.CHECK #...... AMOUNT

* 5,t.C. , 07/06 94* 159.28 07/15 97 50.00 357.65 07128 53.30 07111 98 33.89 ~1

0-04 L I14o0SrqIA. BANAK OF W SNINGTON 431 GEORUA AVENUE WAShINGTOt. Dc 20011 P140%E :202- 722- 2033

FRIENDS Of JESbE JACKSON 30 £Ahtl"UJ FUND RAISER 5 C/O SHLLO FAPALY LIFE CENTER S 1SIC 9Th STREET NW WA$hI-vTOt4 Dc 20001 CHECKING ACCOUNT: 35U915

06115/3b THOU 0613(/83

PAGE I OUR CJbT(#MER SERVICE LINE 722-2031 IS OPEN FROP Am To 5 PR PONDAY - FRIDAY FOR ANY INQUIRIES REGARDING YOUR CHECKING OR SAVINGS ACCOUNTS.

CHECKING ACCOUNT 350015

OESCLI PT.Oa DEBITS CREDITS DATE BALANCE

S9LANC& LAST STATEAEtT 06/1 5/R8 *)O SIT 4o875.OO U6115/8 *s"osi T 2.,800.00 JE 11I1$8 5,675.JO DEPOSI T Zo405.O(& J6129188 D osI I 1,360.OL J6/24/S3 9.94 j '. DEPOSI T 500.00 061?718 06/288 NfCELLANEOL DE;I) 20.00 90 92 .. 06 RACELLAN:tJ ,$ c'II 53.00 06130/ '4a 14 CE.LLAhEOLI., D).EA I ICC.Oc J6I3-j/P'4 9v 7?,). ;.' C*CK a 1 50.C 36131'&53 9,62 ,j.O CHECK b 2,674.00 U6/3I /s &MACt:. T I STATEf*E4T 6,94..U

-'IOTAL CED 1S (5) 9,940.00 r.TOTA. D-JlTj (5) 2,994.O0u TAX 10 4iJf't', 253-18-381y

YOUR CHECKS SEQUENCED

DATE..LNECK io..o...vtoT DATE..CHECK #...... APOUNT DATE.CeCHECK *.....ooAvOUNT

06/30 oI ,:,i?4.)J 06/3 0 97_ 1 50, L *' .~ 1 V

JESSE JACKSON-.88-.FOR PRESIDENT RECEPTION AND DINNER FU RAISER To help him wis the Democraic NationalConvuengi VIM BOLD LEADERSHIP - NEW DUiCN 0 Guest Speaker: Honorable ,la-on Barry, Jr. fayor, Wasbington, D.C MONDAY. JUNE 20. 1911 Recertif-,n - 6:30 p m. Dinner - 7:0 p.m. SILlOH rAMILY LIFE CENTEiR N'nth nJ "'P" Streets. NW. Washiuon. D.C. DON X, IO\ - $500.00 r4-f'rrpAL FLECTOp COfS~ t,,

BEFORE THE FEDERAL ELECTION CONPRIX 211I:3

In the Matter of ) Friends of Jesse Jackson ) Beavers, acting )SENSITIVE asand treasurer)Joseph ) MUR 2939 Keep Hope Alive Political ) Action Committee and ) Dr. Mary Berry, as ) treasurer ) CORPREBHESIVE INVESTIG&TIVE REPORT I. BACKGROUND This matter was initiated by a referral from the Reports Analysis Division ("RAD"). On August 22, 1989, the Commission found reason to believe Keep Hope Alive Political Action Committee ("the Committee") and its treasurer had violated related 2 U.S.C. S 441b and 11 C.F.R. S 102.5(a). These findings to the Committee's receipt of $5,850 in funds from four unregistered organizations. The Commission also approved interrogatories and a request for documents with respect to these receipts. Counsel for the Committee filed the response on the October 17, 1989. The response was previously discussed in General Counsel's Report, signed November 13, 1989. On November 28, 1989, the Commission further found reason to believe Friends of Jesse Jackson and Joseph Beavers, acting as treasurer, and violated 2 U.S.C. §433 and 434 and approved interrogatories his a request for documents to Mr. Beavers. Mr. Beavers filed response on January 30, 1990. This reports reviews the earlier response from Keep Hope Alive with respect to Friends of Jesse of Jackson and the latest response from Joseph Beavers on behalf -2-

Friends of Jesse Jackson.

Keep Hope Alive Political Action Committee was organized in

June 1988 and filed its original Statement of Organization with

the Commission on June 30, 1989, listing Alvin J. Boutte of

Chicago, Illinois, as treasurer and custodian of records, the

Independence Bank of Chicago as the campaign depository, and the

Committee's address as Chicago. The Committee described itself

as a committee that supports or opposes more than one federal

candidate and not a separate segregated fund or a party

committee. For 1988, the Committee reported total receipts of

C:) $223,481 and total disbursements of $77,486. Through the 1989 1r) Mid-Year Report, the Committee disclosed total receipts of

N $138,394 and total disbursements of $190,777 with cash on hand of

$93,663.42 and debts owed by the Committee of $7,633.93.

II. FACTUAL ANALYSIS

C:) The Commission's regulations provide that organizations, Vwhich qualify as a political committee under the Act must

C- register with the Commission. 11 C.F.R. 5 100.5. Organizations

qualifying as political committees must establish a separate

account for federal activity which includes only funds subject to

the limitations and prohibitions of the Act. 11 C.F.R.

S 102.5(a). Organizations that are not political committees must

either establish a separate account for federal activity or

demonstrate that contributions made to federal committees did not

include any funds prohibited under the Act. 11 C.F.R.

5 102.5(b). The Act prohibits corporate and labor union

contributions. 2 U.S.C. S 441b. -3- A. Review of Earlier Response from Keep Hope Alive in the earlier response, counsel stated with respect to Friends of Jesse Jackson: on June 20, 1988, a twenty-five dollar ($25) per plate dinner was held at the Shiloh Baptist Church located at 9th and P Streets, N.W., Washington, D.C. The dinner was advertised throughout the community, via flyers and invitations, as a dinner featuring the Reverend Jesse Jackson. Reverend Jackson had planned to attend, but could not due to a scheduling conflict. The guest speakers who did attend included Mayor Marion Barry and Congressman Walter Fauntroy. Approximately three hundred (300) people were at the dinner. The organizers of the dinner opened an account at the Industrial Bank of Washington specifically for this event. The account was opened in the name "Friends of Jesse Jackson." The profits from the dinner-- five thousand dollars ($5000) -- were placed into this account. Shortly after the dinner, according to one of the organizers of the event, Mr. Joseph Beavers, the organizers consulted with Jesse Jackson who suggested that the proceeds of the dinner be contributed to the Keep Hope Alive PAC. on July 13, 1988, a five thousand dollar check representing all of the profits from the dinner was written to the Keep Hope Alive PAC. The "Friends of Jesse Jackson" bank account was thereupon closed out. o: As discussed above, "Friends of Jesse Jackson" is not a formal organization. This was merely the name given to the bank account opened for the purpose of receiving and transferring the proceeds of a dinner held in Washington, D.C. at the Shiloh Baptist Church. The head organizer for this event was Mr. Joseph Beavers. Mr. Beavers is a clerk and a trustee of the Shiloh Baptist Church. Mr. Beavers can be reached at (202) 654-6391, and correspondence may be sent care of the Shiloh Baptist Church. Later in the response, counsel contends that the receipt of the $5000 in funds from the Shiloh Baptist Church event was proper. Counsel states: ..Furthermore, we believe that the $5000 representing the profits of the dinner at the Shiloh Baptist Church was properly transferred to the Keep Hope Alive PAC under 11 C.F.R. S 102.6. We do acknowledge, however, that this receipt originally was not properly reported. By virtue of 11 C.F.R. S 102.6(c)(5),(7), and -4- S 104.3(a), the Keep Hope Alive PAC was not obligated to report the names of the individual attendees at the dinner, but it should have reported the aggregate $5000 amount as a memo entry of unitemized contributions. Instead, the amount was reported as a receipt from a committee. This $5000 and the other three contributions have since been transferred out of the Keep Hope Alive PAC's federal account and into its non-federal account, and the PAC's reports have been amended to reflect this transfer. Therefore, we do not presently see a need to amend further the initial reports listing these contributions.

B. Review of Response from Friends of Jesse Jackson Joseph Beavers states in his response that, at the suggestion of Pastor Henry C. Gregory of the Shiloh Baptist Church, he organized a fundraiser on behalf of the Rev. Jesse Jackson's candidacy for the Democratic Party's presidential nomination at the convention in Atlanta. He agreed to chair the fundraiser and enlisted the assistance of Mattie Robinson and Horace Roberts, active members of the church. The proceeds after expenses from the fundraiser were to help Rev. Jackson win the nomination. The group first organized a committee known as the "Friends of Jesse Jackson." Its honorary chairpersons were Mayor Marion S. Barry, the Honorable Walter E. Fauntroy, and Rev. Henry C. Gregory. Its also enlisted several District of Columbia city council members as supporters and a number of others as friends. The group advertised the fundraiser with flyers and invitations. This material described the event as a "Fundraiser for Jesse Jackson" or as "Jesse Jackson--88--For President." It was described to participants as a fundraiser to help Rev. Jackson win the nomination. Mayor Barry was the guest speaker. The fundraiser took place on June 20, 1988, at the Shiloh Family Life Center at 9th and P Streets, N.W-# in the District. The cost of

the event was $50 per person.

An account was opened at the Industrial Sank of Washington on

June 15, 1988, in the name of Friends of Jesse Jackson Banquet

Fund Raiser with Joseph Beavers, Nattie Robinson, and Horace

Roberts on the signature card. Beavers states that tickets were paid for in cash and in checks, although mostly in checks. He adds that all receipts were deposited into the bank account and that this account was the only one used for the event. He provided a financial report that showed total receipts of

$10,466.44, expenses of $5,314.00 with the balance of $5,152.44 to be given to Rev. Jackson. The bank statements he provided cover the period from June 15 to July 31. It shows total deposits of $10,450 and total debits of $9,411.81 with an ending balance of $1,038.19.

Beavers states that when Rev. Jackson was speaking to the

NAACP convention at the Sheraton Park Hotel, Friends of Jesse

Jackson arranged to make the contribution to him personally on the night he spoke. A check was made out to Rev. Jackson in the amount of $5,152.44. Beavers states that after the check was presented, Rev. Jackson came to Beavers and asked that the check be changed to be made out to Keep Hope Alive for $5,000. He said that Rev. Jackson further suggested that Beavers keep the $152.44 balance and come to Atlanta to help him win the nomination. The reports filed by Keep Hope Alive show the receipt of the $5,000 contribution on July 13, 1988. The bank statements show it cleared the account of Friends of Jesse Jackson on July 28, 1988. mm-- -6-

C. Conclusion

Neither Keep Hope Alive nor Friends of Jesse Jackson has requested preprobable cause conciliation. The responses from both Keep Hope Alive and Friends of Jesse Jackson provide sufficient information regarding the subject transaction to prepare briefs on the issues raised. Therefore, this Office will proceed to the next stage of the enforcement process.

Lawrence N. Noble General Counsel

______BY: ______Date Lois-G. 1krner Associate General Counsel Attachment

Staff persons: George F. Rishel -Jeffrey D. Long FEDERAL ELECTION COMMISSION WASHINGION, 0 C. 20463

TO: LAWRENCE NOBLE, GENERAL COUNSEL (4/ FROM: ARJORIE W. EMMONS /DELORES HARRIS 4 SECRETARY OF THE COMMISSION DATE: FEBRUARY 22, 1990

SUBJECT: MUR 2939 - COMPREHENSIVE INVESTIGATIVE REPORT DATED FEBRUARY 20, 1990.

The above-captioned matter was received in the

Commission Secretariat at 11 :3 3 a.m. on February 21, 1990 and circulated on a 24-hour no-objection basis at 4:00 p.m. on Wednesday, February 21, 1990

There were no objections to the above-captioned matter. )W

FEDERAL ELECTION COMMISSION WASHrINCTON, D C 20463

March 15, 1990

Joseph A. Beavers 3215 Park View Road Chevy Chase, Maryland 20815

Dear Mr. Beavers: The Commission received your response dated January 26, 1990, on January 30, 1990. After reviewing your response, one point has arisen which needs further clarification. You state in the response that payments to attend the banquet were made in both cash and checks and that all were deposited into the account at the Industrial Bank of Washington. This Office needs to know whether any of the payments to Friends of Jesse Jackson were made with corporate or union checks. Please call Jeffrey Long at (202) 376-5690 with your response, or you may respond by letter.

Sincerely,

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'A 90ANl I I P1W k it BEFORE THE FEDERAL ELECTION COlNISSION In the Matter of) SENSTIV Keep Hope Alive Political Action Committee and Dr. Mary Berry, as treasurer MUR 2939 Friends of Jesse Jackson and Joseph Beavers, acting as treasurer

GENERAL COUNSELS REPORT

The Office of the General Counsel is prepared to close the investigation in this matter as to Keep Hope Alive Political Action Committee and Dr. Mary Berry, as treasurer, and Friends of

Jesse Jackson and Joseph Beavers, acting as treasurer, based on the assessment of the information presently a ilable

I //0Aner_ ounse DateLarne.-ol General Counsel 'ml t Iwa BEFORE THE FEDERAL ELECTION CONNISSIOK mTVE in the Matter of Sl

Friends of Jesse Jackson MUR 2939 and Joseph Beavers, acting as treasurer Keep Hope Alive Political Action Committee and Dr. Mary Berry, as treasurer

COMPREHE NSIV INVESTIGATIVE REPORT #2

This Office circulated Comprehensive Investigative Report #1 to the Commission on February 21, 1990, that included the response from Joseph Beavers on behalf of the Friends of Jesse Jackson. The attached response has been received from Mr. Beavers and provides additional information for the preparation of briefs.

Lawrence M. Noble General Counsel

Date BY: L0-78-0. 1erner Associate General Counsel

Attachment

Staff assigned: Jeffrey Long FEDERAL ELECTION COMMISSION WASHINGTON, D C 20463

MMONANDUR

TO: LARRY NOBLE GENERAL COUNSEL \ FROM: JORI E W. EMMONS /DELORES HARRIS SECRETARY OF THE COMMISSION DATE: APRIL 19, 1990

SUBJECT: MUR 2939 - COMPREHENSIVE INVESTIGATIVE REPORT #2 DATED APRIL 16, 1990

The above-captioned matter was received in the Commission

Secretariat at 11:00 a.m. on Tuesday, April 17, 1990 and circulated on a 24-hour no-objection basis at 4:00 o.m, on Tuesday, April 17, 1990

There were no objections to the above-captioned matter. FEDERAL ELECTION A M $ 0 WASHINGTON, D.C. 20463 SERSI1I f

ApiI 24v 199-0

TO: The Commission

FROM: Lawrence M. Noble General Counsel

SUBJECT: MUR 2939

Attached for the Commission's review is a brief stating the position of the General Counsel on the legal and factual issues of the above-captioned matter. A copy of the brief and letter notifying the respondents of the General Counsel's intent to recommend to the Commission a finding of probable cause to believe with respect to Friends of Jesse Jackson and Joseph Beavers, acting as treasurer, was mailed on April 24 , 1990. Following receipt of the respondents' reply to this notice, this Office will make a further report to the Commission. O Attachments 1. Brief 2. Letter to respondent

Staff persons: Jeffrey D. Long George F. Rishel FEDERAL ELECTION COMMISSION WASHINGTON, D.C 20463. A r l 2 , 1 9

Joseph A. Beavers, Acting Treasurer Friends of Jesse Jackson 3215 Park View Road Chevy Chase, RD 20815

RE: MUR 2939 Friends of Jesse Jackson and Joseph Beavers, acting as LO treasurer r K Dear Mr. Beavers: N. Based on information ascertained in the normal course of carrying out its supervisory responsibilities, on November 28, 1989, the Federal Election Commission found reason to believe that Friends of Jesse Jackson ("Committee") and you, acting as treasurer, violated 2 U.S.C. SS 433 and 434, and instituted an investigation in this matter. CD After considering all the evidence available to the Commission, the Office of the General Counsel is prepared to recommend that the Commission find probable cause to believe that these violations have occurred.

The-Commission may or may not approve the General Counsel's recommendation. Submitted for your review is a brief stating the position of the General Counsel on the legal and factual issues of the case. Within 15 days of your receipt of this notice, you may file with the Secretary of the Commission a brief (ten copies if possible) stating your position on the issues and replying to the brief of the General Counsel. (Three copies of such brief should also be forwarded to the Office of the General Counsel, if possible.) The General Counsel's brief and any brief which you may submit will be considered by the Commission before proceeding to a vote of whether there is probable cause to believe a violation has occurred.

If you are unable to file a responsive brief within 15 days, you may submit a written request for an extension of time. All requests for extensions of time must be submitted in writing five days prior to the due date, and good cause must be demonstrated. In addition, the office of the General Counsel ordinarily will not give extensions beyond 20 days. Joseph A. Beavers Page 2

A finding of probable cause to believe requires that the Office of the General Counsel attempt for a period of not less than 30, but not more than 90 days, to settle this matter through a conciliation agreement.

Should you have any questions, please contact Jeffrey D. Long, the staff member assigned to this matter, at (202) 376-5690.

Lawrence M. Noble General Counsel Enclosure Brief BEFORE THE FEDERAL ELECTION COMMISSION In the Matter of) Friends of Jesse Jackson ) MUR 2939 and Joseph Beavers, acting ) as treasurer) GENERAL COUNSELUS BRIEF

1. STATEM OF THE CASE on November 28, 1989, the Commission found reason to believe Friends of Jesse Jackson and Joseph Beavers, acting as treasurer, violated 2 U.s.c. 5 433 and 434. These findings related to the $5,000 contribution Keep Hope Alive Political Action Committee reported receiving from Friends of Jesse Jackson on July 13, 1988. Keep Hope Alive Political Action Committee was organized in June 1988 and filed its original Statement of Organization with the Commission on June 30, 1988. The Committee described itself as a committee that supports or opposes more than one federal candidate and not a separate segregated fund or a party committee. According to press reports, Keep Hope Alive was formed by the Rev. Jesse Jackson as a political action committee to form "the basis for his activities beyond the 1988 elections and to assist local, state, and national candidates." Keep Hope Alive has not been designated by Rev. Jackson as an authorized committee. II. LEGAL AND FACTUAL ANALYSIS Under the Federal Election Campaign Act of 1971, as amended ("the Act"), a "committee" is defined to include "any...group of -2- persons" who receive more than $1,000 in contributions or make more than $1,000 in expenditures during any calendar year. 2 U.S.C. 5 431(4)(A). Such political committees are required to file a Statement of Organization with the Commission within 10 days of becoming a political committee and to file periodic reports of their receipts and disbursements. 2 U.S.C. 55 433 and 434. The Act also prohibits corporations and labor unions from making contributions and expenditures in connection with federal elections and prohibits political committees from knowingly accepting such contributions or expenditures. 2 U.S.C. 5 441b. The Commission's regulations provide that organizations, which qualify as a political committee under the Act, must register with the Commission. 11 C.F.R. Part 102. Organizations qualifying as political committees must establish a campaign depository into which, with limited exceptions, all receipts are deposited and from which all disbursements are made. 2 U.S.C. S 432(h). This depository may be a separate account for federal activity into which are deposited only funds subject to the limitations and prohibitions of the Act. 11 C.F.R. S 102.5(a). In the early spring of 1988 Pastor Henry C. Gregory of the Shiloh Baptist Church and Joseph Beavers, a member of the church, discussed the desirability of holding a fundraiser on behalf of the candidacy of Rev. Jackson for the Democratic Party's presidential nomination. At the suggestion of Rev. Gregory, Joseph Beavers along with two other members of the church, Mattie Robinson and Horace Roberts, began organizing a fundraiser on behalf of the Rev. Jesse Jackson's candidacy. Beavers became the *3 chairman of the fundraiser, and Hattie Robinson and Horace Roberts became co-chairs. The proceeds after expenses from the fundraiser were intended to help Rev. Jackson win the nomination. The group first organized a committee with the name of "Friends of Jesse Jackson." Its honorary chairpersons were Mayor Marion S. Barry, Jr., the Honorable Walter z. Fauntroy, and Rev. Henry C. Gregory. Several District of Columbia city council members were enlisted as supporters and a number of other persons as friends. The group advertised the fundraiser with flyers and invitations. According to Beavers, a mailing was made to members of the Shiloh Baptist Church. One flyer listed the honorary chairpersons, the council supporters, and the dinner committee and described the event as a "Fundraiser for Jesse Jackson" to be held at the Shiloh Family Life Center on Monday, June 20, 1988. The contributor information card described the event as "Jesse Jackson--88--For President." It noted a ticket cost of $50 per person or $500 for a table of ten. Checks were to be made payable to "Friends of Jesse Jackson Banquet Fundraiser." The group also prepared letterhead stationery that listed the honorary chairpersons, council supporters, and dinner committee. Another flyer advertised the event as a "Fundraiser to Help Jesse Win at the Democratic National Convention in Atlanta, GA." It stated that the "Friends of Jesse Jackson Invite You to Attend a Reception and Dinner." Mayor Marion S. Barry, Jr., was listed as the guest speaker. The flyer also stated "The Atlanta Democratic Convention A Critical Crossroads in Our Nation's History." -4-

on An account was opened at the industrial sank of Washington Banquet June 15, 1988, in the name of Friends of Jesse Jackson Fund Raiser with Joseph Beavers, Hattie Robinson# and Horace in cash and Roberts on the signature card. Tickets were paid for in checks, although mostly in checks. A financial report a total of prepared by the chairman and co-chairs indicates that Jesse $10,466.44 was received as receipts by the Friends of these Jackson for this fundraiser event. The report indicated disbursements :1 Printing $857.65 Postage, Posters, etc. 589.19 Champagne, etc. 410.88 Flowers 52.50 Dinner, etc. 2,833.78 Soloists and Organist 250.00, Secretary 150.00 Returned checks 170.00 Total $5o.140 Jackson or This left a balance of $5,152.44 to be given to Rev. the his presidential campaign. The bank statements covering of $10,675 period from June 15 to November 30 show total deposits of and total debits of $10,532.71 with an ending balance

mailing to 1. The payment for postage apparently relates to the of the church. The Act provides that any the members the communication, which solicits funds or expressly advocates or defeat of a clearly identified candidate for federal election other type office and which is distributed by direct mail or any public political advertising, shall carry a disclaimer of general was stating who paid for the communication and whether it authorized by any candidate. 2 U.S.C. 5 441d. The financial does not indicate any payments to commercial report, however, for a vendors regarding the distribution of flyers or payments mailing list. According to Beavers, a mailing was commercial to church made to members of the church. Thus, such a mailing would not appear to be direct mail for purposes of the members is made with disclaimer provision. Therefore, no recommendation regard to 2 U.S.C. 5 441d. -5-

$142.29.2 Thus, all of the receipts were apparently deposited into the bank account at the Industrial Bank of Washington. Friends of Jesse Jackson established no other bank account. Beavers states that it has since been closed out. Arrangements were made to present the contribution check to Rev. Jackson personally on the night he spoke to the NAACP convention at the Sheraton Park Hotel in July 1988. A check was made out to Rev. Jackson or his campaign in the amount of $5,152.44.3 After the check was presented, Rev. Jackson reportedly came to Beavers and asked that the check be changed to $5,000.4 The reports filed by -be made out to Keep Hope Alive for

2. The differences between the financial report and the bank statements are relatively minor and appear to be related to the late payments for a few tickets or returns of deposits. 3. At the time this check was drafted, Friends of Jesse Jackson had not qualified as a multicandidate political committee as defined at 2 U.S.C. S 441a(a)(4). Therefore, it could have O legally contributed only $1,000 to the Jackson campaign unless it was another authorized committee raising funds for the Jackson campaign. As previously noted, Rev. Jackson never designated Friends of Jesse Jackson as an authorized committee, nor is there any evidence his campaign was involved in the Friends of Jesse of Jesse Jackson could, - Jackson fundraising event. Friends however, contribute up to $5,000 per calendar year to Keep Hope Alive pursuant to 2 U.S.C. 5 441a(a)(1)(C), because Keep Hope Alive was not an authorized committee.

4. Rev. Jackson also apparently suggested to Joseph Beavers that he keep the $152.44 balance and use it to come to Atlanta and help Rev. Jackson win the nomination. Although that is how the $152.44 balance was apparently used, it would not have necessarily resulted in any violation of the Act. There is no provision that precludes this balance from being paid to Beavers personally. Section 439a limits the conversion to personal use of the funds of only a principal campaign committee. Friends of Jesse Jackson is not a principal campaign committee of any candidate and was not an authorized committee of Rev. Jackson. Furthermore, Rev. Jackson's prompt return of the contribution from Friends of Jesse Jackson demonstrates that it was never accepted by Rev. Jackson's principal campaign committee. -6-

Keep Hope Alive reported the receipt of the $5,000 contribution on July 13, 1988, as from a political committee. The bank statements show it cleared the account of Friends of Jesse Jackson on July 28, 1988. These facts demonstrate that Friends of Jesse Jackson was a group of persons who received an aggregate of more than $1,000 in contributions in calendar year 1988 and made an aggregate of more than $1,000 in expenditures in calendar year 1988 for the purpose of influencing a federal election. In fact, Friends of Jesse Jackson received more than $10,000 in contributions for the purpose of influencing the nomination of Rev. Jesse Jackson as the Democratic Party's candidate for President of the United States and expended $5,314 in raising these funds. When its contribution check to Rev. Jackson was returned, Friends of Jesse Jackson then contributed $5,000 to Keep Hope Alive Political Action Committee, a federal political committee registered with the Commission. Thus, Friends of Jesse Jackson became a political committee under the Act. 5 See 2 U.S.C. S 431(4)(A). As such, it was required to register with the Commission and file

(Footnote 4 continued from previous page) Moreover, pursuant to 2 U.S.C. 5 431(8)(B)(iv), Beavers' use of the $152.44 balance as his personal funds would not have been a contribution to Rev. Jackson's campaign. 5. The Act also provides that an unauthorized committee may not include the name of any candidate in the name of the committee. 2 U.S.C. S 432(e)(4). Friends of Jesse Jackson was not designated by Rev. Jackson as an authorized committee. Thus, it would have been precluded from using Rev. Jackson's name in its name. Nevertheless, because it had not registered and reported as a political committee at that time, it does not appear that this section has been implicated. Therefore, no recommendation is made with respect to 2 U.S.C. S 432(e)(4). -7- reports of its receipts and disbursements in accordance with the Act and regulations pursuant to 2 U.S.C. 55 433 and 434. moreover, the facts demonstrate that Friends of Jesse Jackson, as an unauthorized political committee, was not a designated fundraising agent for either Keep Hope Alive or the Jackson campaign. The District of Columbia prohibits corporate, but not union, contributions. Beavers has stated in a conversation with the General Counsel's staff that solicitations were sent to two unions that he previously belonged to: the Hotel and Restaurant Employees Local 25 and the Greater Washington Central Labor Council. He indicated these two unions usually purchase two tickets each. The costs of two tickets each for both unions would have totaled $200. Thus, it remains possible that the $10,466.44 in funds received by Friends of Jesse Jackson included up to $200 in union treasury funds. Beavers did not retain copies of the checks received to verify whether or not union funds had been received. In light of the amount possibly involved and the absence of readily available records to check whether union funds were received, no recommendation is made with respect to 2 u.s.C. s 441b(a). Accordingly, the General Counsel recommends that the Commission find probable cause to believe Friends of Jesse Jackson and Joseph Beavers, acting as treasurer, violated 2 U.S.C. SS 433 and 434 for failure to register and report as a political committee. III. GUWENRAL COUN'SEL'S RECONNlNDATIOllS

Find probable cause to believe that Friends of Jesse Jackson-and Joseph Beavers, acting as treasurer, Ar 9g A12 nA A2A Vi~l1ad.t 2 u ww0

116 /f 1) Date General Counsel BEFORE THE FEDERAL ELECTION CONII 55 AF303AN AN II:41 In the Matter of )

Keep Hope Alive Political ) XUR 2939 SENSITIVE Action Committee and Dr. Mary Berry, as ) treasurer )

GENERAL COUNSEL'S REPORT

I. BACKGROUND On August 22, 1989, the Commission found reason to believe

Keep Hope Alive Political Action Committee ("the Committee") and

its treasurer1 ("the Respondents") had violated 2 U.S.C. 5 441b Ln and 11 C.F.R. 1102.5(a). These findings related to the r Committee's receipt of $5,850 in funds from four unregistered organizations. Keep Hope Alive Political Action Committee was organized in June 1988 and filed its original Statement of Organization with the Commission on June 30, 1988. The Committee described itself (7) as a committee that supports or opposes more than one federal candidate and not a separate segregated fund or a party

- committee. According to press reports, Keep Hope Alive was formed by the Rev. Jesse Jackson as a political action committee to form "the basis for his activities beyond the 1988 elections and to assist local, state, and national candidates." Keep Hope

1. The initial findings in this matter identified Cirilio A. McSween, as treasurer. The General Counsel later discovered that on June 27, 1989, the Committee had filed a new Statement of Organization identifying Dr. Mary Berry as the treasurer. In accordance with Commission policy, Dr. Mary Berry has been substituted as treasurer in this matter. Alvin J. Boutte of Chicago was the original treasurer and the treasurer of record at the time of the events in question in this matter. -2- Alive has not been designated by Rev. Jackson as an authorized committee. At the time of the events that are the subject of this matter, Keep Hope Alive had not yet qualified as a multicandidate political committee as defined at 2 U.S.C.

S 441a(a)(4). For 1988, the Committee reported total receipts of $223,481 and total disbursements of $77,486. Through 1989, the Committee disclosed total receipts of $337,775 and total disbursements of $436,587 with cash on hand of $47,234 and debts owed by the Committee of $9,031. It was originally located in Chicago, but later moved to Washington, D.C.

II. LEGAL AND FACTUAL ANALYSIS The Federal Election Campaign Act of 1971, as amended ("the Act"), prohibits corporations and labor unions from making contributions and expenditures in connection with federal elections and prohibits political committees from knowingly accepting such contributions or expenditures. 2 U.S.C. S 441b. Organizations qualifying as political committees may establish a separate account for federal activity into which are deposited only funds subject to the limitations and prohibitions of the Act. 11 C.F.R. S 102.5(a). Commission regulations further provide that the treasurer of a political committee shall be responsible for ascertaining the legality of all contributions. 11 C.F.R. S 103.3(b). As noted, the findings in this matter relate to the Committee's receipt of $5,850 in funds from four unregistered -3- organizations as follows: 2

Organization Date Amount Friends of Jesse Jackson 7-13-88 $5,000.00 Washington, D.C. John Wiley Price Campaign 7-9-88 250.00 Dallas, Texas Committee to Elect Rev. 7-10-88 500.00 A.R. Polk River Rouge, Michigan Kid-Brooklyn Political 9-15-88 100.00 Association With respect to the $250 contribution from the John Wiley Price Campaign, counsel for the Respondent states that Mr. Price, a county commissioner in Dallas, wrote the check from his campaign fund. Counsel further states that "(wie have spoken with Mr. Price, and he has stated that there was at that time no corporate or labor money in his campaign account, nor did his campaign receive any personal contributions greater than $5000." Texas law prohibits corporate and labor union contributions. Regarding the $100 contribution from Mid-Brooklyn Political Association, counsel states that James Connolly, district leader of the 42nd State Assembly District in New York, signed a check for $100 from the Mid-Brooklyn Political Association, which is described as "an account opened for the purpose of impacting local races in Brooklyn." Counsel further states that "Mr. Connolly has informed us that the account contained no corporate or union money and no individual contributions of more than

2. The amounts of these contributions are within the contribution limitations of 2 U.S.C. S 441a(a). -4- $5000." New York law permits limited corporate contributions and unlimited union contributions. Counsel was not able to provide information relating to the Committee to Elect Rev. A.R. Polk. Instead, the General Counsel contacted Rev. A.R. Polk, who stated that the committee was formed for an election within the church, not a political office. Although he said he did not recall making a contribution to Keep Hope Alive PAC, he did acknowledge that such a contribution may have been made during a meeting in Texas. He further stated that the funds in the committee's accounts did not come from corporations or unions but from members of the church. with regard to the $5,000 contribution from Friends of Jesse Jackson, the General Counsel has learned that in the early spring of 1988 Pastor Henry C. Gregory of the Shiloh Baptist Church and Joseph Beavers, a member of the church, discussed the desirability of holding a fundraiser on behalf of the candidacy of Rev. Jackson for the Democratic Party's presidential nomination. At the suggestion of Rev. Gregory, Joseph Beavers along with two other members of the church, Mattie Robinson and Horace Roberts, began organizing a fundraiser on behalf of Rev. Jesse Jackson's candidacy. Beavers became the chairman of the fundraiser, and Mattie Robinson and Horace Roberts became co-chairs. The proceeds after expenses from the fundraiser were intended to help Rev. Jackson win the nomination. The group first organized a committee with the name of "Friends of Jesse Jackson." Its honorary chairpersons were Mayor Marion S. Barry, Jr., the Honorable Walter E. Fauntroy, and Rev. -5- Henry C. Gregory. Several District of Columbia city council members were enlisted as supporters and a number of other persons as friends. The group advertised the fundraiser with flyers and invitations. According to Beavers, a mailing was made to members of the Shiloh Baptist Church. one flyer listed the honorary chairpersons, the council supporters, and the dinner committee and described the event as a "Fundraiser for Jesse Jackson" to be held at the Shiloh Family

Life Center on Monday, June 20, 1988. The contributor information card described the event as "Jesse Jackson--88--For President." It noted a ticket cost of $50 per person or $500 for a table of ten. Checks were to be made payable to "Friends of Jesse Jackson Banquet Fundraiser." The group also prepared

letterhead stationery that listed the honorary chairpersons, council supporters, and dinner committee. Another flyer advertised the event as a "Fundraiser to Help Jesse Win at the Democratic National Convention in Atlanta, GA." It stated that the "Friends of Jesse Jackson Invite You to Attend a Reception

- and Dinner." mayor Marion S. Barry, Jr., was listed as the guest speaker. The flyer also stated "The Atlanta Democratic Convention A Critical Crossroads in Our Nation's History." An account was opened at the Industrial Bank of Washington on June 15, 1988, in the name of Friends of Jesse Jackson Banquet Fund Raiser with Joseph Beavers, Mattie Robinson, and Horace Roberts on the signature card. Tickets were paid for in cash and in checks, although mostly in checks. A financial report prepared by the chairman and co-chairs indicates that a total of $10,466.44 was received as receipts by the Friends of Jesse Jackson for this fundraiser event. The report indicated these disbursements:

Printing $857.65 Postage, Posters, etc. 589.19 Champagne, etc. 410.88 Flowers 52.50 Dinner, etc. 2,833.78 Soloists and organist 250.00 Secretary 150.00 Returned checks 170.00 Total $5,314.00 This left a balance of $5,152.44 to be given to Rev. Jackson or his presidential campaign. The bank statements covering the period from June 15 to November 30 show total deposits of $10,675 and total debits of $10,532.71 with an ending balance of $142.29.3 Thus, all of the receipts were apparently deposited into the bank account at the Industrial Bank of Washington. Friends of Jesse Jackson established no other bank account. Beavers states that it has since been closed out. Arrangements were made to present the contribution check to Rev. Jackson personally on the night he spoke to the NAACP convention at the Sheraton Park Hotel in July 1988. A check was made out to Rev. Jackson in the amount of $5,152.44.4 After the

3. The differences between the financial report and the bank statements are relatively minor and appear to be related to the late payments for a few tickets or returns of deposits. 4. At the time this check was drafted, Friends of Jesse Jackson had not qualified as a multicandidate political committee as defined at 2 U.s.c. S 441a(a)(4). Therefore, it could have legally contributed only $1,000 to the Jackson campaign unless it was another authorized committee raising funds for the Jackson campaign. As previously noted, Rev. Jackson never designated Friends of Jesse Jackson as an authorized committee, nor is there any evidence his campaign was involved in the Friends of Jesse -7- check was presented, Rev. Jackson reportedly came to Beavers and asked that the check be changed to be made out to Keep Hope Alive

for $5,000. 5 The reports filed by Keep Hope Alive reported the receipt of the $5,000 contribution on July 13, 1988, as from a political committee. The bank statements show it cleared the account of Friends of Jesse Jackson on July 28, 1988. These facts demonstrate that Friends of Jesse Jackson was organized and operating as an unauthorized political committee and not as a designated fundraising agent for Keep Hope Alive or the Jackson campaign. Thus, Keep Hope Alive's reporting of this contribution as from a political committee was correct. The District of Columbia prohibits corporate, but not union, contributions. Beavers has stated in a conversation with the

(Footnote 4 continued from previous page) Jackson fundraising event. Friends of Jesse Jackson could, however, contribute up to $5,000 per calendar year to Keep Hope C) Alive pursuant to 2 U.S.C. S 441a(a)(1)(C). 5. These facts demonstrate that the contribution from Friends of Jesse Jackson, a political committee, to Keep Hope Alive should not also be attributed to Rev. Jackson's presidential campaign - committee. Under the Act, Rev. Jackson is deemed an agent of his committee for the purpose, among others, of receiving contributions. 2 U.S.C. S 432(e)(2). Commission regulations also provide that a contribution that is "returned" to the contributor within 10 days of its receipt is not deemed to have been accepted by the committee for the purposes of the Act. 11 C.F.R. S 103.3(b)(1). Rev. Jackson returned the check for the Friends of Jesse Jackson contribution on the same day he received it. Thus, although the funds making up the contribution were raised for the purpose of furthering Rev. Jackson's presidential campaign, his actions in returning the contributions demonstrate, pursuant to 11 C.F.R. S 103.3(b)(1), that this contribution was not accepted by Rev. Jackson's committee. Instead, apparently at Rev. Jackson's suggestion, a new check was written and made payable to Keep Hope Alive. At that point, with the check being returned, Friends of Jesse Jackson was free to follow Rev. Jackson's suggestion and make a contribution to Keep Hope Alive without any consequences to Rev. Jackson's campaign. General Counsel's staff that solicitations were sent to two unions that he previously belonged to: the Hotel and Restaurant Employees Local 25 and the Greater Washington Central Labor Council. He indicated these two unions usually purchase two tickets each. The costs of two tickets each for both unions would have totaled $200. Thus, it remains possible that the $10,466.44 in funds received by Friends of Jesse Jackson included up to $200 in union treasury funds. Beavers did not retain copies of the checks received to verify whether or not union funds had been received. In light of the amount possibly

'N involved and the absence of readily available records to check

- whether union funds were received, this office recommends that no further action be taken regarding the receipt and deposit of this contribution as well as the others. 6

Accordingly, the General Counsel recommends that the Commission take no further action with respect to Keep Hope Alive 0- Political Action Committee and Dr. Mary Berry, as treasurer, regarding the alleged violations of 2 U.S.C. S 441b and 11 C.F.R. S 102.5(a). III. RECOMMENDATIONS

1. Take no further action against Keep Hope Alive Political Action Committee and Dr. Mary Berry, as treasurer, with respect to 2 U.S.C. S 441b and 11 C.F.R. 5 102.5(a).

2. Close the file as it pertains to these respondents.

6. A brief recommending a finding of probable cause to believe Friends of Jesse Jackson and Joseph Beavers, acting as treasurer, failed to register and report as a political committee is being sent to these respondents. _9-.

3. Approve the attached letter. Lawrence 1. Noble General Counsel

BY: c, Dat Lois G Lbrnir Associate General Counsel

Attachment 1. Letter to respondents BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of ) ) Keep Hope Alive Political Action) MUR 2939 Committee and Dr. Mary Berry, ) as treasurer )

CERTIFICATION

I, Marjorie W. Emmons, Secretary of the Federal Election Commission, do herby certify that on May 2, 1990, the Commission decided by a vote of 4-0 to take the following actions in MUR 2939:

1. Take no further action against Keep Hope Alive Political Action Committee and Dr. Mary Berry, as treasurer, with respect to 2 U.S.C. 5 441b and 11 C.F.R. S 102.5(a), as recommended in the General Counsel's Report dated April 27, 1990. 2. Close the file as it pertains to these respondents.

Commissioners Aikens, Elliott, Josefiak and McGarry voted affirmatively for the decision; Commissioners McDonald and Thomas did not cast votes.

Attest:

-? 9 DateI arjorie W. Emmons Sec vary of the Commission

Received in the Secretariat: Mon., April 30, 1990 11:41 a.m. Circulated to the Commission: Mon., April 30, 1990 4:00 p.m. Deadline for vote: Wed., May 2, 1990 4:00 p.m. FEDERAL ELECTION COMMISSION WASHINGTON, D C. 20463

May 4, 1990

Katharine R. Boyce, Esquire Patton, Bogga & Blow 2550 1 Street, N.W. Washington, D.C. 20037-1350 RE: MUR 2939 Keep Hope Alive and Dr. Mary Berry, as treasurer !f) Dear Ms. Boyce:

On September 12, 1989, your clients, were notified that the Federal Election Commission found reason to believe that they had violated 2 U.S.C. S 441b and 11 C.F.R. S 102.5(a). On October 17, 1989, you submitted a response to the Commission's reason to believe findings. After considering the circumstances of the matter, the Commission determined on May 3 , 1990, to take no further : action against your clients, and closed the file as it pertains to them. 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 factual or legal materials to appear on the public record, please do so within ten days of your receipt of this letter. Such materials should be sent to the Office of the General Counsel. The confidentiality provisions of 2 U.S.C. S 437g(a)(4)(B) and 5 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. In the event you wish to waive confidentiality under 2 U.S.C. S 437g(a)(12)(A), written notice of the waiver must be submitted to the Commission. Receipt of the waiver will be acknowledged in writing by the Commission. The Commission reminds you that accepting contributions from unregistered organizations appears to be a violation of 2 U.S.C. S 441b and 11 C.F.R. S 102.5(a). Your clients should take immediate steps to insure that accepting such contributions do not result in the acceptance of prohibited funds in the future. Katharine R. Boyce Page 2 if you have any questions, please contact Jeffrey D. Long, the staff member assigned to this matter, at (202) 376-5690. Sincerely, Lawrence M. Noble General Counsel

BY: Lois G. Lirner Associate General Counsel FEDERAL ELECTION COMMISSION WASHINGTON, D C. 20463 June 11, 1990

CERTIFIED NAIL TURN RECEIf UESTED Joseph A. Beavers, Acting Treasurer Friends of Jesse Jackson 3215 Park View Road Chevy Chase, Maryland 20815 RE: MUR 2939 Friends of Jesse Jackson and Joseph Beavers, as acting treasurer Dear Mr. Beavers: On April 24, 1990, you were mailed a brief stating the position of the General Counsel on the legal and factual issues in this matter under review. This brief and accompanying letter notified you of the General Counsel's intent to recommend to the Commission a finding of probable cause to believe Friends of Jesse Jackson, and you as acting treasurer violated 2 U.S.C. 55 433 and 434. C) To date, you have not responded to the General Counsel's brief. Unless we receive a response from you within 15 days of your receipt of this letter, this Office will circulate a report to the Commission recommending a finding of probable cause. You should submit 10 copies of your response to the Secretary of the Commission, and forward 3 copies to the Office of the General Counsel. Should you have any questions, please contact Jeffrey Long, the staff member assigned to this matter, at (202) 376-5690. Sincerely, Lawrence M. Noble General Counsel

BY: Lois G. Lerner Associate General Counsel 90AUG22 AM 11:I42 SENSITIVE BEFORE THE FEDERAL ELECTION COMMISSION In the Matter of AD I awe99 ) MUR 2939 Friends of Jesse Jackson ) EXEIAVE ESSSMM and Joseph Beavers, acting ) as treasurer ) GENERAL COUNSEL'S IRPORT

I. BACKGROUND

This matter was initiated by a referral on April 26, 1989, from the Reports Analysis Division involving a multicandidate political committee, Keep Hope Alive. On August 22, 1989, the Commission found reason to believe Keep Hope Alive and its treasurer had violated 2 U.S.C. S 441b and 11 C.F.R. 5 102.5(a)(1) and initiated an investigation. On the basis of information obtained in response to the investigation, the Commission on November 28, 1989, found reason to believe Friends of Jesse Jackson and Joseph Beavers, acting as treasurer, violated 2 U.S.C. 55 433 and 434. On May 2, 1990, the Commission decided to take no further action with respect to Keep Hope Alive and its treasurer and close the file as it pertains to that respondent.

II. ANALYSIS

This Office incorporates the General Counsel's Brief, signed April 23, 1990, into this report as the factual and legal -2- analysis of the issues in this matter. As noted, the brief was sent to Mr. Beavers on April 24, 1990. When no response had been received, this Office sent a reminder letter to him on June 11, 1990. According to the return receipt, he received this letter on June 20, 1990. Mr. Beavers then contacted this Office and informed us that he had not received the brief. The earlier package was a sizable one in that we had included a copy of the campaign guide for nonconnected committees and blank forms so that the committee could file a Statement of Organization and the necessary

- reporting forms. We then prepared a package with a copy of the Sbrief and notification letter along with the campaign guide and reporting forms. Mr. Beavers came to this Office and picked up this package on June 22, 1990. When no further response was forthcoming, this Office contacted Mr. Beavers by telephone on or about July 10, 1990. Mr. Beavers represented to staff from this Office that he had no dispute with the facts in -- the General Counsel's Brief, and asked if his previous submissions sufficed as a response brief. After the staff member explained the Commission's procedures, Mr. Beavers agreed to prepare and send his response. Therefore, this Office recommends that the Commission find probable cause to believe Friends of Jesse Jackson and Joseph Beavers, acting as treasurer, violated 2 U.S.C. 55 433 and 434. -3-

III. DISCUBSION Or CONCILIATION AND CIVIL PENALTY

IV. RECOMMENDATIONS

1. Find probable cause to believe that Friends of Jesse Jackson and Joseph Beavers, acting as treasurer, violated 2 U.S.C. 55 433 and.434.

2. Approve the attached conciliation 9*reement and appropriate letter.

Date -Lawrence M. Nob.e I) General Counsel Attachment Conciliation Agreement Staff assigned: George F. Rishel Jeffrey D. Long BEFORE TiE FEDERAL ELECTION COMMIUSSION

In the Matter of HUR 2939 Friends of Jesse Jackson and Joseph Beavers, acting as treasurer.

CERTIFICATION

I, Marjorie W. Emmons, recording secretary of the

Federal Election Commission executive session on

September 20, 1990, do hereby certify that the Commission decided by a vote of 4-0 to take the following actions in

NUR 2939:

1. Find probable cause to believe that Friends of Jesse Jackson and Joseph Beavers, acting as treasurer, violated 2 U.S.C. 5S 433 and 434.

2. Approve the conciliation agreement attached to the General Counsel's report dated August 21, 1990, and an appropriate letter as recommended in the General Counsel's report.

Commissioners Elliott, Josefiak, McGarry, and Thomas voted affirmatively for the decision; Commissioners Aikens and McDonald were not present. Attest:

10hDDate -at S retary of the Commission FEDERAL ELECTION COMMISSION WASHINC10%. DC 20463

is September 27, 1990 Joseph A. Beavers Friends of Jesse Jackson 3215 Park View Road Chevy Chase, Maryland 20815 RE: MUR 2939 Friends of Jesse Jackson and Joseph Beavers, acting as treasurer

Dear Mr. Beavers: on September 20, 1990, the Federal Election Commission found that there is probable cause to believe Friends of Jesse Jackson and you, acting as treasurer, violated 2 U.S.C. SS 433 and 434, provisions of the Federal Election Campaign Act of 1971, as amended. The Commission has a duty to attempt to correct such violations for a period of 30 to 90 days by informal methods of conference, conciliation, and persuasion, and by entering into a conciliation agreement with a respondent. If we are unable to reach an agreement during that period, the Commission may institute a civil suit in United States District Court and seek payment of a civil penalty. Enclosed is a conciliation agreement that the Commission has approved in settlement of this matter. If you agree with the provisions of the enclosed agreement, please sign and return it, along with the civil penalty, to the Commission within ten days. I will then recommend that the Commission accept the agreement. Please make your check for the civil penalty payable to the Federal Election Commission. If you have any questions or suggestions for changes in the enclosed conciliation agreement, or if you wish to arrange a meeting in connection with a mutually satisfactory conciliation agreement, please contact Jeffrey Long, the staff member assigned to this matter, at (202) 376-5690. S inc erel1y,Il

-- 6;Zc M. Noble General Counsel

Enclosure Conciliation Agreement qu)EPAL FLECTION CO"MI5Sj),j 91 JAN 24 AM I0: 94

BEFORE THE FEDERAL ELECTION COMMISSION In the Matter of SENSITIVE )MUR 2939 Friends of Jesse Jackson S and Joseph Beavers, acting ) as treasurer )

GENERAL COUNSEL'S REPORT I. BACKGROUND

This matter was initiated by a referral on April 26, 1989, from the Reports Analysis Division involving a multicandidate

political committee, Keep Hope Alive. On August 22, 1989, the Commission found reason to believe Keep Hope Alive and its treasurer had violated 2 U.S.C. 5 441b and 11 C.F.R. 5 102.5(a)(1) and initiated an investigation. The findings were based on the reported receipt of a $5,000 contribution from an unregistered organization called Friends of Jesse Jackson. On the basis of information obtained in response to the CD investigation, the Commission on November 28, 1989, found reason

to believe Friends of Jesse Jackson and Joseph Beavers, acting as treasurer, violated 2 U.S.C. 55 433 and 434. The response from Keep Hope Alive had identified Joseph Beavers as the person who had knowledge of the Friends of Jesse Jackson activity. On May 2, 1990, the Commission decided to take no further action with respect to Keep Hope Alive and its treasurer and to close the file as it pertains to that respondent.

On April 24, 1990, this Office sent the General Counsel's Brief to Joseph Beavers, recommending that the Commission find probable cause to believe Friends of Jesse Jackson and Joseph Beavers, acting as treasurer, violated 2 U.S.C. 55 433 and 434. -2- No response was received, on September 20, 1990, the Commission found probable cause to believe the Friends of Jesse Jackson and Joseph Beavers, acting as treasurer, violated 2 U.S.C. 55 433 and 434.

11. DISCUSSION After repeated attempts by telephone and letter to elicit a response from Mr. Beavers, he sent a letter that was received on January 16, 1991. (Attachment 1). In telephone conversations he had indicated that he would contact Keep Hope Alive and ask it to handle this matter. Keep Hope Alive has not contacted this Office with regard to Mr. Beavers' request. In his letter Mr. Beavers notes that he was startled that Keep Hope Alive personnel had not contacted us and resolved this matter. He says that he feels that Reverend Jackson was wrong in asking them to make the check payable to Keep Hope Alive and that Keep Hope Alive should take responsibility for any violations. He denies that he ever acted as treasurer of Friends of Jesse Jackson or that it had a treasurer. He says he was one of three co-chairmen of the event along with the late Rev. Henry C. Gregory, III. All four of them authorized the bills to be paid and made joint decisions on all matters pertaining to the fundraiser. He notes that he has cooperated with the Commission in its investigation in this matter and has supplied us with copies of all bank statements and other pertinent information which enabled -3- us to "make the Cage." He says he in *very sorry" and apologizes to the Commission on behalf of the late Rev. Gregory and the three co-chairs. He further notes that the group was not an active political campaign committee but sponsored a one time event for which they believed a formal political committee structure would not be necessary.

Taking into account the facts and circumstances of this matter and the points raised in Mr. Beaversf letter, this office does not believe that filing a civil suit would be advisable in

this matter. Mr. Beavers, points about the treasurer question and his voluntarily providing full information to the Commission as part of its investigation are well taken. Furthermore, considering his current situation, we do not feel holding him financially responsible is warranted.

Therefore, we recommend that the Commission take no further action with respect to Friends of Jesse Jackson and Joseph

Beavers, acting as treasurer, and to close the file in this matter. The attached letter contains admonitory language.

Although the file has previously been closed with respect to Keep

Hope Alive, we recommend that the Commission send the attached letter to it. The letter notes that the file has been closed but also includes admonitory language. This language points out that when the committee accepts contributions from unregistered groups or from fundraising events such as the one involved here, such -4- contributions may result in imposing the requirements of the Federal Election Campaign Act of 1971, as amended ("the Act"), on such groups, requiring them to register and report and abide by the other requirements of the Act. The letter then points out that in such circumstances, Keep Hope Alive should deposit such contributions in a nonfederal account or designate the group as a fundraising agent of Keep Hope Alive, in which case it must report and itemize the group's receipts and disbursements as its own and amend its Statement of Organization to add any bank accounts used by the fundraising group as an additional campaign depository.

III. RECOMMENDATIONS

1. Take no further action with respect to Friends of Jesse Jackson and Joseph Beavers, acting as treasurer. 2. Close the file. C:) 3. Approve the attached letters.

Lawrence M. Noble General Counsel

Date Lois G'_ _ _ __rner__ __ _ Associate General Counsel Attachments 1. Beavers letter 2. Proposed letters

Staff Persons: George F. Rishel Jeffrey D. Long FEDERAL ELECTION COMMISSION WASINCI O O C 1)4hi

MMOAN DUM

TO: LAWRENCE M. NOBLE GENERAL COUNSEL

FROM: MARJORIE W. EMMONS/DELORES HARRISO COMMISSION SECRETARY DATE: JANUARY 29, 1991 SUBJECT: MUR 2939 - GENERAL COUNSELPS REPORT DATED JANUARY 23, 1991

The above-captioned document was circulated to the Commission on Thursday, January 24, 1991 at 4:00 p.m.

Objection(s) have been received from the Commissioner(s) as indicated by the name(s) checked below:

Commissioner Aikens xxx Commissioner Elliott

Commissioner Josefiak xxx Commissioner McDonald Commissioner McGarry Commissioner Thomas

This matter will be placed on the meeting agenda for TUESDAY, FEBRUARY 5, 1991

Please notify us who will represent your Division before the Commission on this matter. BEFORE THE FEDERAL ELECTION COMMISSION

In the Mattr of MUR 2939 Friends of Jesse Jackson ) and Joseph Beavers, acting ) as treasurer )

CERTIFICATION

I, Hilda Arnold, recording secretary for the Federal Election Commission executive session on February 5, 1991, do hereby certify that the Commission decided by a vote of 6-0 to take the following actions with respect to MUR 2939:

1. Take no further action with respect to Friends of Jesse Jackson and Joseph Beavers, acting as treasurer. 0 2. Close the file as recommended in the January 23, 1991 General Counsel's Report. 3. Approve the letters, subject to the amendment of the letter to Katherine R. Boyce, Esquire, as discussed at the meeting.

Commissioners Aikens, Elliott, Josefiak, McDonald, McGarry and Thomas voted affirmatively for the decision. Attest:

Admiisa Arna A s a- Administrative Assistn FEDERAL ELECTION COMMISSION WASHINGTON, D.C. 2043 February 12, 1991 qu

Katherine R. Boyce, Esquire Patton, Boggs a slow 2550 ItStreet, N.W. Washington, D.C. 20037-1350

RE: MUR 2939 Keep Hope Alive and Dr. Mary Berry, as treasurer Dear Ms. Boyce:

This is to advise you that the entire file in this matter has now been closed and will become part of the public record within 30 days. Should you wish to submit any legal or factual materials to be placed on the public record in connection this with matter, please do so within ten days. Such materials should be sent to the office of the General Counsel. You are reminded that when Keep Hope Alive accepts contributions from unregistered organizations or fundraising groups, obligations may be imposed on the groups contributing such funds to register and report as political committees under the Federal Election campaign Act of 1971, as amended, ("the Act") if the contributions exceed an aggregate of more than $1,000 in any calendar year. To avoid imposing such obligations on grolips that are not on-going political organizations or do not intend to become federal political committees, Keep Hope Alive should either (1) deposit such contributions in a nonfederal account, to be used solely for nonfederal activity, or (2) designate the group as a fundraising agent of Keep Hope Alive. if the group is designated as a fundraising agent, Keep Hope Alive is responsible for reporting all receipts and disbursements by the fundraising group as its own financial activity and for amending its Statement of Organization to list all bank accounts used by the fundraising group as additional campaign depositories of Keep Hope Alive. Such designation and reporting should occur in the same reporting period as the fundraising event activity.. or Keep Hope Alive should take steps to insure that the problems that arose with regard to the contribution from Friends of Jesse Jackson do not occur in the future. Katherine a. Boyce, Esquire Page 2 Should You have any questions, contact Jeffrey D. Long, the staff neab*er assigned to this matter, at (202) 376-5690. Sincerely, Lawrence M. Noble General Counsel

BY: Lois G. erner Associate General Counsel

0 FEDERAL ELECTION COMMISSION WASHINGTON, OX, 2043 1991 11s; February 19,P

CORRECTED COPY Joseph A. Beavers, Acting Treasurer Friends of Jesse Jackson 3215 Parkview Road Chevy Chase, Maryland 20815 RE: MUR 2939 Friends of Jesse Jackson and Joseph Beavers, acting as treasurer Dear Mr. Beavers:

-~ On September 20, 1990, you were notified that the Federal Election Commission found probable cause to believe that Friends of Jesse Jackson and you, acting as treasurer, violated 2 U.S.C. 55 433 and 434. on January 16, 1991, you submitted a response to the Commission's probable cause to believe findings. After considering the circumstances of the matter, the O: Commission determined on February 5, 1991, to take no further action against Friends of Jesse Jackson and you, acting as treasurer, and closed the file in this matter. The file will be made part of the public record within 30 days. Should you wish to submit any factual or legal materials to appear on the public

- record, please do so within ten days of your receipt of this letter. Such materials should be sent to the Office of the General Counsel. The Commission reminds you that raising more than $1,000 for purposes of influencing a federal election in any calendar year or making expenditures, including contributions to federal political committees, of more than $1,000 in any calendar year for the purpose of influencing any federal election qualifies any group of persons as a political committee under the Federal Election Campaign Act of 1971, as amended ("the Act"). For such a group to fail to register and report with the Commission as a political committee is a violation of 2 U.S.C. 55 433 and 434. You should take immediate steps to insure that this activity does not occur in the future. Joseph beavers. Page 2

If you have any questions, please contact Jeffrey D. Long, the staff member assigned to this matter, at (202) 376-5690. Sincerely,

Lawrence M. Noble General Counsel

BY: Lois G. Lerner Associate General Counsel FEDERAL ELECTION COMMIS5!CPN WASNIWTON. DC. n30

THIS ISlE ENFMFI#

WIE FILMED CAMERA ND.i :r CAMEAMA