Tills IS the END of Riur N

iLDERAI. ELECi ION COMMiSSION 132% I~ SIRII I NW '~ASI IING1ON.I).(. 2O4(~ I

0 TillS IS THE END OF rIUR N

Date Filmed .4 ~L~~

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6* .4 FEDERAL ELECTION CO~ISSION -- S

C~ /,Am J ~58 ~jUUt A. a I)- -I .~. ~A - I

The above-described material was removed from Ihis file pursuant to the following exemption provided in the Freedom of Information Act~ 5 V.S.C. Section 552(b):,

(1) Classified Information (6) Personal privacy

~< Internal rules and * (7) Investigatory practices files (3) Exempted by other (8) Banking statute Information

(4) Trade secrets and ____ (9) Well Informajion commercial or (geographic or financial information geophysical) Internal Documents

.55.

* '~ II~

Signed ~i~il I~4Y L/C/. *~.* ~

date ~-Y S. eel FEC 9-21-77 K' :.

*6.

-a' P'~IWRA 93103

AssociateKenneth A. General Gross, CounselEsq. Federal Election Commission 1325 K Street, N.W. Washington, D.C. 20463 Attention: Deborah Curry 0 * ~ 4i~CLIv~rj THE FEC c~e~f#d SEDAM & HERGE ~4AUQ8 ~ A PUOWOWAL O0~SATJOW ATWORWUTS A? LAW SUITS 1100 5300 QRw6SSORO DRIVU MoLSAN. VIRGINIA sues

GLENN 5. EDAM. JR. (70310111000 TELEX: 7tOSSt0506 5. CURTIS HURON CAULE: SEOAMNER RODURT 3. SPARKS JR. August 3, 1984 A. MARE VHRISTOPIIUR SEDAM, NEHRU A RUED CHRISTOPHER K MOPDWR' SUITE 1000 PNILW IL DANE isis u~a STREET, N.W. DONNA K~.MULER NASEDISTON. DC. 00006 6~S - OP COUNSEL RESIDENT PARTNER; CHARLES 0. REED THOMAS 5. V&DOUL. SR.

Kenneth A. Gross, Esq. Associate General Counsel Federal ~lection Commission 1325 K Street, N.W. Washington, D.C. 20463 Attention: Deborah Curry

Re: MUR 1578 Dear Mr. Gross: With reference to your letter, dated July 12, 1964, arId to the Conciliation Agreement which was accepted in settlement of this matter, we are sending to you herewith the check of Friends 0 of Ron Packard, drawn to the order of the Treasurer of the United States in the amount of $250.00, in payment of the civil penalty.

C, With reference to the public record on this matter, we request that the Commission approve including in the public 9. record a copy of my letter to you dated November 23, 1983. Sincerjjy yours,/

Enclosure MEMORANDUM

TO: CHERYL THOMAS TO: JOAN HARRIS FROM: JOAN HARRIS FROM: CHERYL THOMAS

CHECK NO. ~5~3 (a copy of which is attached) RELATING ~TO MUR /5') AND NAME ~ 4 ~DI~1 4c4C~c4t

~WA~ RECEIVED ON 8' . PLEASE INDICATE THE ACCOUNT 114' N *WHICH IT SHOE ILD BE DEPOSITED:

/ / BUDGET CLEARING ACCOUNT (#95F3875. 16) / E'7 CIVIL PENALTIES ACCOUNT (#95-1099 .160)

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a . . - **~' lAg BEFORE THE FEDERAL ELECTION COMMISS ION

* In the Matter of ) Friends of Ron Packard )ItJR 1578 William L. Hardy, Treasurer)

CERTIFICATION ~

~.~1~'*'

I, Marjorie W. Emmons, Secretary of the Federal Election Commission, do hereby certify that on July 9, 1984, the Commission decided by a vote of 6-0 to take the following actions in MUR 1578: S

r) 2. Approve the proposed conciliation 9 agreement, attached to the General Counsel's Report signed July 3, 1984,

3. Approve the letters attached to the General Counsel's Report 0 signed July 3, 1984. 4. Close the file.

Commissioners Aikens, Elliott, Harris, McDonald, McGarry and Reiche voted affirmatively in this matter.

Attest:

Date A * Marjorie W. Ezmuons Secretary of the Commission a,

Received in Office of. Commission Secretary: 7-3-84, 3:43 Circulated on 48 hour tally basis: 7-5-84, 11:00 ~

* .7.-*;%.~~ ~"'rb S

FEDERAL ELECTION COMMISSION * WASHINGTON. D.C. 20*3

July 12, 1984

Mrs. Andrew Crean 109 Monarch Bay South Laguna, Calfornia 92677 Re: MUR 1587 Dear Mrs. Crean: This is in reference to the complaint you filed with the Commission on September 19, 1983, concerning possible violations by Ronald C. Packard and Friends of Ron Packard. The Commission determined there was reason to believe that Friends of Ron Packard and William L. Hardy, as treasurer, violated 2 U.S.C. S 438(a) (4), a provision of the Federal Election Campaign Act of 1971, as amended and conducted an investigation in this matter. On July ~, 1984, a conciliation agreement signed by the respondent was accepted by the N Commission, thereby concluding the matter. A copy of this agreement is enclosed for your information. o The new file number in this matter is MUR 1578. If you have any questions, please contact Deborah Curry, the attorney assigned to this matter, at (202) 523-4000. C Sincerely,

~qrn 0

asociate Genera Counsel Enclosure Conciliation Agreement FEDERAL ELECTION COMMISSION WASHINGTON. D.C 20*3 July, 12, 1984

Hale Dougherty, M.D. 9431 Hhliview Road Anaheim, California 92804 Re: MUR 1590 Dear Mr. Dougherty: This is in reference to the complaint you filed with the Commission on September 26, 1983, concerning possible violations by Ronald C. Packard and Friends of Ron Packard. The Commission determined there was reason to believe that Friends of Ron Packard and William L. Hardy, as treasurer, o Electionviolated Campaign2 U.S.C. ActS 438(a) of 1971, (4), asa provisionamended andof conductedthe Federal an investigation in this matter. On July 9, 1984, a conciliation agreement signed by the respondent was accepted by the Commission, thereby concluding the matter. A copy of this agreement is enclosed for your information. o The new file number in this matter is MUR 1578. If you have any questions, please contact Deborah Curry, the attorney assigned to this matter, at (202) 523-4000. C Sincerely,

BY: nneth * Gros ssociate Gener 1 Counsel Enclosure Conciliation Agreement FEDERAL ELECTION COMMISSION * WASHINGTON. D.C. 20463 July 12, 1984

Mrs. John C. Crean 617 North Canon Drive Beverly Hills, California 90210 Re: MUR 1578 Dear Mrs. Crean: This is in reference to the complaint you filed with the Commission on September 12, 1983, concerning possible violations by Ronald C. Packard and Friends of Ron Packard. 0 The Commission determined there was reason to believe that Friends of Ron Packard and William L. Hardy, as treasurer, * violated 2 U.S.C. S 438(a) (4), a provision of the Federal Election Campaign Act of 1971, as amended and conducted an investigation in this matter. On July 9, 1984, a conciliation agreement signed by the respondent was accepted by the Commission, thereby concluding the matter. A copy of this agreement is enclosed for your information. o The file number in this matter is MUR 1578. If you have any questions, please contact Deborah Curry, the attorney assigned to this matter, at (202) 523-4000. o Sincerely,

ssociate Gener Counsel Enclosure Conciliation Agreement FEDERAL ELECTION COMMISSION * WASHINGTON. D.C. 20*3 July 12, 1984

Mrs. Judith Caruthers 2701 Ebbtide Corona del Mar, California 92625 Re: MUR 1591 Dear Mrs. Caruthers: This is in reference to the complaint you filed with the Commission on September 30, 1983, concerning possible violations by Ronald C. Packard and Friends of Ron Packard. The Commission determined there was reason to believe that I') Friends of Ron Packard and William L. Hardy, as treasurer, violated 2 U.S.C. S 438(a) (4), a provision of the Federal Election Campaign Act of 1971, as amended and conducted an investigation in this matter. On July 9, 1984, a conciliation agreement signed by the respondent was accepted by the Commission, thereby concluding the matter. A copy of this agreement is enclosed for your information. o The new file number in this matter is MUR 1578. If you have any questions, please contact Deborah Curry, the attorney assigned to this matter, at (202) 523-4000. 0 Sincerely,

Associate G eral Counsel Enclosure Conciliation Agreement FEDERAL ELECTION COMMISSION WASHINCTON. D.C. 20463 July 12, 1984

7. Curtis Herge Sedam and Herge 8300 Greensboro Drive McLean, Virginia 22102 RE: !4UR 1578 Friends of Ron Packard and William L. Hardy, as treasurer Dear Mr. Herge: o On July 9, 1914, the Commission accepted the conciliation agreement signed by your clients and a civil penalty in settlement ofa violation of 2 U.S.C. S 438(a) (4), a provision of * the Federal Election Campaign Act of 1971, as amended. Accordingly, the file has been closed in this matter, and it will become a part of the public record within thirty days. However, 2 U.S.C. S 437g(a) (4)(3) prohibits any information derived in connection with any conciliation attempt from becoming public without the written consent of the respondent and the Commission. Should you wish any such information to become part of the public o record, please advise us in writing. Enclosed you will find a fully executed copy of the final conciliation agreement for your files. V Sincerely, Charles N. Steele

Associate Gen al Counsel Enclosure Conciliation Agreement 3W03 TEl FAL ELUCTICE OWEESSIGE

Zn the Matter of ) Friends of Ron Packard and ) MUR 1578 William L. Hardy, treasurer ) COUCILI&TTG AG~ This matter vas initiated by a signed, sworn, and notarized complaint by Mrs. John Crean, Mrs. Andrew Crean, Dr. Hale Dougherty and Mrs. Judith Caruthers. The Commission found reason to believe that Friends of Ron Packard (Respondent) violated 2 U.S.C. S 438(a) (4)by copying the names and addresses of contributors from Commission files for the purpose of soliciting contributions, and an investigation was conducted. NOW THEREFORE, the Commission and Respondent, having qr( participated in informal methods of conciliation, prior to a finding of probable cause to believe, do hereby agree as follows: I. The Commission has jurisdiction over Respondent, and the 0 subject matter of this proceeding, and this agreement has the V effect of an agreement entered pursuant to 2 U.S.C. C S 437g(a)(4) (A)Ci). cr II. Respondent has had a reasonable opportunity to demonstrate that no action should be taken in this matter. III. Respondent enters voluntarily into this agreement with the Commission. IV. The pertinent facts in this matter are as follows: 1. Respondent, Friends of Ron Packard, is the principal campaign committee for Ronald Packard. 2. Dr. Hale Dougherty and Mrs. Judith Caruthers9 were -2-'

sent invitations to attend a fundraising dinner sponsored by

Friends of Ron Packard9 which was to be held on September 17, 1983. 3. Mrs. Bruce D. Buckner was a member of the Dinner Committee which organized the fundraising dinner. 4. Ms. Betty Buckner was responsible for preparation of the invitation list.. 5. Ms. Betty Buckner reviewed the disclosure statements filed by various candidates, including the reports filed by Crean for Congress. 6. The names and addresses of Dr. Hale Dougherty and of Mrs. Judith Caruthers were copied from the reports filed by Crean for Congress. 7. A total of 6,300 invitations were mailed. Of that total, 47 invitations were to individuals whose names and addresses were copied from reports filed with Crean for o Congress. 8. 2 U.S.C. S 438(a) (4)prohibits the copying of information in Commission reports for the purpose of soliciting contributions or for any commercial purpose. 9. .11, C.F.R. S 104.15(b) defines soliciting contributions" to include soliciting any type of contribution or donation, such as political or charitable contributions." V. Respondent violated 2 U.S.C. S 438(a) (4)by c9pying the names and addresses of contributors from Commission files for the m~a~ I U

purpose of soliciting contributions. TI. Respondent sill pay a civil penalty to the treasurer of the United States in the amount of two hundied ti~fty. (*250.00) dollars, pursuant to 2 U.S.C. 3.437g(a) (5) (A). VEX. Respondent agrees that he shall not undertake any activity which is in violation of the Vederal 3leotion Ca~aign Act of 1971, as mended, 2 U.S.C. S 431, gj gg. TXU. The Commission, on request of anyone filing a complaint under 2 U.S.C. S 437g(a) (1)concerning the matters at issue herein or on its own motion, nay review complianoe with "a this agreement. If the Commission believes that this agreement or any requirement thereof has been violated, it may institute a N civil action for relief in the United States District Court for the District of Columbia. 0 XX. This agreement shall become effective as of the date ~I. that all parties hereto have ezecuted the same and the Commission C has approved the entire agreement.

1. Respondent shall have no more than thirty (30) days from *the date this agreement becomes effective to comply with and implement the requirements contained in this agreement and to so notify the Coamission.

f .44.

XI. Thi5 Conciliation Agreement constitutes the entire agreement between the parties on the matters raised herein, and no other statement, promise, or agreement, either written or oral, made by either party or by agents of either party, that is not contained in this written agreement shall be valid. FOR UN COKI4ISSIOtI: Charles U. Steele General Counsel

Associate Gener Counsel

J, Cur a Hercre. C nsel to Date 0 Friends of Ron ftc ard Committee

C a, ( FEDERAL ELECTION COMMISSION ~ WASHINGTON. D.C. 20463

Mrs. Andrew Crean 109 Monarch Bay South Laguna, Calfornia 92677

~ ~, Re: MLJR 1587 Dear Mrs. Crean: This is in reference to the complaint you filed with the Commission on September 19, 1983, concerning possible violations by Ronald C. Packard and Friends of Ron Packard. The Commission determined there was reason to believe that Friends of Ron Packard and William L. Hardy, as treasurer, violated 2 U.S.C. S 438(a) (4), a provision of the Federal Election Campaign Act of 1971, as amended and conducted an investigation in this matter. On July , 1984, a conciliation agreement signed by the respondent was accepted by the Commission, thereby concluding the matter. A copy of this agreement is enclosed for your information. o The new file number in this matter is MUR 1578. If you have any questions, please contact Deborah Curry, the attorney assigned to this matter, at (202) 523-4000. C Sincerely, t~. Charles N. Steele CO General Counsel

BY: Kenneth A. Gross Associate General Counsel Enclosure Conciliation Agreement 0 0

FEDERAL ELECTION COMMISSION WASHINCTON. D.C. 2O4~3

Hale Dougherty, M.D. 9431 Huliview Road - Anaheim, California 92804 Re: MUR 1590 Dear Mr. Dougherty: This is in reference to the complaint you filed with the Commission on September 26, 1983, concerning possible violations by Ronald C. Packard and Friends of Ron Packard. The Commission determined there was reason to believe that Friends of Ron Packard and William L. Hardy, as treasurer, violated 2 U.S.C. S 438(a) (4), a provision of the Federal Election Campaign Act of 1971, as amended and conducted an investigation in this matter. On July , 1984, a conciliation N agreement signed by the respondent was accepted by the Commission, thereby concluding the matter. A copy of this agreement is enclosed for your information. o The new file number in this matter is MUR 1578. If you have any questions, please contact Deborah Curry, the attorney assigned to this matter, at (202) 523-4000. C, Sincerely, 0 GeneralCharles CounselN. Steele

BY: Kenneth A. Gross Associate General Counsel Enclosure Conciliation Agreement FEDERAL ELECTION COMMISSION U, WASHINCTON. D.C. 20463

14r5. John C. Crean 617 North Canon Drive Beverly Hills, California 90210 MUR 1578 Dear Mrs. Crean: This is in reference to the complaint you filed with the Commission on September 12, 1983, concerning possible violations by Ronald C. Packard and Friends of Ron Packard. N The Commission determined there was reason to believe that Friends of Ron Packard and William L. Hardy, as treasurer, violated 2 U.S.C. S 438(a) (4), a provision of the Federal Election Campaign Act of 1971, as amended and conducted an investigation in this matter. On July , 1984, a conciliation agreement signed by the respondent was accepted by the N Commission, thereby concluding the matter. A copy of this agreement is enclosed for your information. o The file number in this matter is MUR 1578. If you have any questions, please contact Deborah Curry, the attorney assigned to this matter, at (202) 523-4000. Sincerely, Charles N. Steele General Counsel

BY: Kenneth A. Gross Associate General Counsel Enclosure Conciliation Agreement FEDERAL ELECTION COMMISSION ~j7jUJ.) WASHINGTON, DC. 20463

Mrs. Judith Caruthers 2701 Ebbtide Corona del Mar, California 92625 Re: MUR 1591

Dear Mrs. Caruthers:~ This is in reference to the complaint you filed with the Commission on September 30, 1983, concerning possible violations by Ronald C. Packard and Friends of Ron Packard. The Commission determined there was reason to believe that Friends of Ron Packard and William L. Hardy, as treasurer, violated 2 U.S.C. S 438(a) (4), a provision of the Federal Election Campaign Act of 1971, as amended and conducted an investigation in this matter. On July , 1984, a conciliation agreement signed by the respondent was accepted by the N Commission, thereby concluding the matter. A copy of this agreement is enclosed for your information. o The new file number in this matter is MUR 1578. If you have any questions, please contact Deborah Curry, the attorney assigned to this matter, at (202) 523-4000. Sincerely, Charles N. Steele Co General Counsel

BY: Kenneth A. Gross Associate General Counsel Enclosure Conciliation Agreement 0*

FEDERAL ELECTION COMMISSION * WASHINGTON, D.C. 20463

3. Curtis Herge Soda. and Herge 8300 Greensboro Drive McLean, Virginia 22102 RE: MUR 1578 Friends of Ron Packard and * William L. Hardy, as treasurer

Dear Mr. Herg~:

On July , 1984, the Commission accepted the conciliation agreement signed by your clients and a civil penalty in settlement of a violation of 2 U.s.c. S 438(a) (4), a provision of the Federal Election Campaign Act of 1971, as amended. Accordingly,become a part theof thefile publichas been record closed within in thisthirty matter, days. andHowever, it will N 2 U.S.C. S 437g(a) (4)(3) prohibits any information derived in connection with any conciliation attempt from becoming public without the written consent of the respondent and the Commission. Should you wish any such information to become part of the public o record, please advise us in writing. Enclosed you will find a fully executed copy of the final conciliation agreement for your files. Sincerely, CO Charles N. Steele General Counsel

By: Kenneth A. Gross Associate General Counsel Enclosure Conciliation Agreement B~V~E ~ fl~AL ZEECI'IQ~ C~SSI~I

In the Matter of ) ) ZIJE 1578 ~nald Packard and Friend5) of ~ Packard )

I, Marjorie W. flmr~ns, recording secretary for the Federal Election C~miission exectitive ses~ion on April 24, 1984, d6 hereby C, certify that the Caurnission took The followin~ acticns in IVR 1578:

9' N

- ~ ~~71 Page 2 Cmrt±fict.iCfl for k't3R 1378 ~g 24, 1984

2. OecidedbYavotS0f4 in2~

file with regard d. Take ~ farther action and close t1~ to I~na1d Packard. to Ponald Packard as recctrnerx!ed Li) e. ~proVe t1* letter 1984. in ti~ General Couns~l'5 report dated April 12,' Elliott, 1tGarry, and Peiche voted C~xunissiCmr5 Aikens, C~fffl55ODer5 Harris and affir!atiVelY for the decision; McDonald dissented. N Attest:

Date /Secretary Marjorie of W.the i~uiCn5 ~iu~55Ofl ~bz~-~ ~L~g

(3A~A4LA~ 04 FEB * A~1OmRuUTSATLAW DRIVU MoLUAN. vmouILL 36106

(703) 621.1000 GLENN 5. SEDAM. JR. TELEX: 7106910666 5. CUETIS mOD CAELE~b~DAMHER6, DODEET 3. SPARKS 53. February 17, 1984 A. MARK OHUZWI'011133 SUDAN. inin* ENUD inwwowm U.xowrzT lUflaW 3. BAND 1350 3~UWWD NW DONNA L MULUR WASUDIGTOII. D~ 60066 OP COUNSEL THOMASI. PADOUL JR. ESWENT PARTN 6Z~MARLES D. USED S.

The Honorable Lee Ann Elliott Chairman Federal Election Commission 1325 K Street, LW. Washington, D.C. Attention: Deborah Curry, Esq. Office of General Counsel Re: MUR 1578, 1587, 1590 and 1591 Dear Madam Chairman: This responds to your letter of February 15, 1984, in 0 which you reported that the Federal Election Commission has found reason to believe that our clients, Representative Ronald Packard V and Friends of Ron Packard, have violated 2 U.S.C. 438(a) (4). C Pursuant to the provisions of 11 CFR 111.18(d), our clients hereby express a desire to enter into immediate negotiations directed toward entering into a mutually acceptable conciliation agreement. We trust that you will be getting in touch with us for that purpose in the near future.

'mm- J. Curtis He ge SUDAx A HERGE ATTORNEYS AT LAW OPESSIONAL CORPORATION SUITE 1100 ,un~ LB@o ORUUNUDORO DRIVE

~ / ~cLUAN, VIRGINIA 33163

Ms. Deborah Curry o Office of General Counsel Federal Election Commission 1325 K Street, N.W. Washington, D.C. 20463 0

FEDERAL ELECTION COMMISSION WASHINGTON. D.C. 20463

February 15, 1984

3. Curtis Herge Sedam £ Herge 8300 Greensboro Drive, Suite 1100 McLean, Virginia 22102 Re: MUR 1578 Dear Mr. Herge: The Federal Election Commission notified you on September 27, 1983, of complaints which alleged that your clients Representative Ronald Packard and Friends of Ron Packard, violated certain sections of the Federal Election Campaign Act of an 1971, as amended ("the Act"). A copy of the complaint was forwarded to you at that time. We acknowledge receipt of your explanation of this matter which was dated November 29, 1983 and December 5, 1983.

Upon further review of the allegations contained in the complaint and information supplied by you, the Commission, on February 14, 1984, determined that there is reason to believe that your clients have violated 2 U.S.C. S 438(a) (4), a provision 0 of the Act. You may submit any factual or legal materials which you believe are relevant to the Commission's analysis of this matter. Please submit any such response within ten days of your o receipt of this letter. In the absence of any information which demonstrates that no further action should be taken against your clients, the Commission may find probable cause to believe that a violation has occurred and proceed with conciliation, Of course, this does not preclude the settlement of this matter through conciliation prior to a finding of probable cause to believe if you so desire and if the Commission has concluded its investigation. Any request to initiate such conciliation should be in writing. See 11 CFR S 111.18(d). 3. Curtis Herge Page 2

This matter will remain confider~tial in accordance with 2 U.S.C. SS 437g (a)(4) (B) and 437g(a) (12) (A) unless you notify the Commission in writing that you wish the matter to be made public. If you have any questions, please contact Deborah Curry, the attorney assigned to this matter, at (202) 523-4000. Sincerely,

Elliott, Chairman Enclosure Procedures

*V) Lfl 0

~qb

~qrn 00 FEDERAL ELECTION COMMISSION U. WASHINCTON. D.C. 20463

J. Curtis Herge Sedam &.Herge 8300 Greensboro Drive, Suite 1100 McLean, Virginia 22102 Re: MUR 1578 Dear Mr. Herge: The Federal Election Commission notified you on September 27, 1983, of complaints which alleged that your clients Representative Ronald Packard and Friends of Ron Packard, '~ violated certain sections of the Federal Election Campaign Act of In 1971, as amended ("the Act"). A copy of the complaint was forwarded to you at that time. We acknowledge receipt of your * explanation of this matter which was dated November 29, 1983 and December 5, 1983. Upon further review of the allegations contained in the complaint and information supplied by you, the Commission, on q' February 14, 1984, determined that there is reason to believe that your clients-have violated 2 U.S.C. S 438(a) (4), a provision o of the Act. You may submit any factual or legal materials which you believe are relevant to the Commission's analysis of this matter. Please submit any such response within ten days of your C, receipt of this letter. In the absence of any information which demonstrates that no further action should be taken against your clients, the ~ Commission may find probable cause to believe that a violation has occurred and proceed with conciliation, Of course, this does not preclude the settlement of this matter through conciliation prior to a finding of probable cause to believe if you so desire and if the Commission has concluded its investigation. Any 3 request to initiate such conciliation should be in writing. See 11 CFR S 111.18(d). 3. Curtis Merge Page 2

This matter will remain confidential in ac~ordance with 2 U.S.C. SS 437q (a)(4)(B) and 437g(a)(12) (A) unless you notify the Commission in writing that you wish the matter to be made public. If you have any questions, please contact Deborah Curry, th. attorney assigned to this matter, at (202) 523-4000. Sincerely,

Enclosure Procedures

Lfl

0 In the Matter of )

ftx~a1d Packard and MJR 1578 of ftm Packard )

~2rWICATICtI

I, Marjorie W. Dmws, Reoording Secretary for the Federal Election Ccxuuission Lcecutive Session on February 14, 1984, ~ 0 hereby certify that the Ccxmiission decided by a vote of 6-0 to

take the foll~Jing actions in ?41R 1578: 1. Find reason to believe that Representative ~nald Packard and friends of I~n Packard violated 2 U.S.C. S 438(a) (4). 2. Approve and autt~rize the sending of the letters attached to the General Cotmsel's o report dated February 2, 1984. Ccmiuissioners Aikens, Elliott, Harris, ?~Donald, !4Garry, and Reiche C voted affirmatively for- the decision.

~qrn Attest: CO

[~te Secretary of the Qmxuission * SUEIIVE * 3W033 T FEDERAL ELUCUCE ~ ~ut~ In the Matter of ) ) Ronald Packard and Friends ) MUR 1578 8~FE82 P2: 01 of Ron Packard ) GENERAL COUNSEL'S REPOM I. MCKGROUHD/PREVIOuS CONIUSSIOW ACIION During the month of September 1983, the Commission received complaints from Mrs. John C. Crean, Mrs. Andrew Crean, Dr. Hale Dougherty and Mrs. Judith Caruthers alleging violations of the Federal Election Campaign Act of 1971, as amended by Representative Ronald Packard and Friends of Ron Packard (hereinafter "Respondents"). The above mentioned complaints were numbered MUR 1578, 1587, 1590 and 1591 respectively. Each complaint alleges that the complainant was sent a direct mail solicitation by Respondents. Each complaint alleges that the N complainant actively supported and contributed to the campaign of

Johnnie Crean, the Republican opponent of Ronald Packard in the 1982 Congressional election. Each complainant contends that O there is no other way for respondent to have gotten his/her name, except through Commission files, since complainants had engaged in no other activity other than support of Mr. Crean. Therefore, complainants allege that Respondents violated 2 U.S.C. S 438(a) (4), which makes unlawful the copying of Commission reports for the purpose of soliciting contributions. On October 31, 1983, the Commission determined to merge MURs 1587, 1590 and 1591 into MUR 1578. The Commission also approved a letter to Respondents granting them an extension of time in which to respond. Respondents submitted one response which addressed all of the complaints. 0 -2-

II. LEGAL ANALYSIS 2 U.S.C. S 438(a) (4) prohibits the copying of information in Commission reports for the purpose of soliciting contributions or for any commercial purpose. 11 CFR S 104.15(b) defines

U contributions to include soliciting any type of contribution or donation, such as political or charitable contributions. Respondents made a consolidated response to the four complaints. (See Attachment 1 pages 1-18 of attachments). Among other things, the response contained two affidavits, one from James M. Gaiser, Chairman of the Dinner Committee and one from Mrs. Bruce D. (Betty H.) Buckner, a member of the committee and compiler of the invitation list. (See Attachment 1 pages 8-10 and 16-18 of attachments.) Respondents concede that the mailing of invitations was for the purpose of attending a fundraising dinner sponsored by 0 Friends of Ron Packard on September 17, 1983. (See Attachment 1 c pages 2, 8, and 16 of attachments) Respondents also concede that these invitations were to solicit contributions to Friends of Ron Packard. (See Attachment 1 page 2 of attachments). According to Respondents answer and the attached affidavits, Mrs. Betty Buckner used disclosure statements filed by various candidates, including the reports filed by Crean for Congress, in compiling the invitation list. Mrs. Buckner also obtained names from other sources including a professional mailing list service, local directories and the campaign files of Ron Packard. (See Attachment 1 pages 2, 8 and 16 of attachments). -3-

Respondents state that the names and addresses of Dr. Hale Dougherty, Mrs. Judith Caruthers and 47 other individuals were copied from reports filed by Crean for Congress. (See Attachment 1 pages 2, 8 and 17 of attachment). With regard to Mrs. John Crean and Mrs. Andrew Crean, the two other complainants, Respondents state that these names were obtained from the files of Friends of Ron Packard. (See Attachment 1 pages 2 and 9 of attachment). Respondents submit two letters, one letter with a return address from John and Donna Crean to Representative Packard, dated September 29, 1982 and August 9, 1983. (See Attachment 1 pages 9, 11-13 and 14-15 of attachments). This correspondence from John Crean to Representative Packard is part of the internal files of Friends of Ron Packard. Mrs. Betty Buckner states that

the names and address of Mrs. Andrew Crean was obtained from Mr. Charles E. McClung, a campaign volunteer who is a neighbor of C Mrs. Crean. (See Attachments 1 page 10 of attachments and Attachment 2 pages 19-20 of attachments). Both Mr. Gaiser and Mrs. Buckner states under oath that they had no previous knowledge of the provision of 2 U.S.C. S 438(a)(4). Respondents state that the laws of California with which they are familiar, do not prohibit the use of disclosure reports of state and local candidates. (See Attachment 1 pages 3, 9 and 16 of attachments). According to the affidavits of Mr. Gaiser and Mrs. Buckner a total of 6,300 invitations were mailed. Of that number 47 -4-

invitations were to individuals whose names and addresses were copied from reports filed by Crean for Congress. According to Hr. Gaiser, none of those 47 individuals responded by making a contribution to Friends of Ron Packard. (See Attachment 1 pages 3, 9 and 17 of attactments). The names and addresses have been purged from the files and records of Friends of Ron Packard. (See Attachment 1 pages 3 and 10 of attachments). Respondents admit copying the names and addresses of contributors from Commission files for the purpose of soliciting contributions. Accordingly, the Office of General Counsel '0 recommends that the Commission find reason to believe that Ronald Packard and Friends of Ron Packard violated 2 U.S.C. S 438(a) (4). 1% 1110 RECOHMEUDATIOIIS 1. Find reason to believe that Representative

V Ronald Packard and Friends of Ron Packard violated 2 U.S.C. C S 438(a) (4) 2. Approve and authorize the sending of the attached letter to the respondents.

0 '~!~~>' GeneralCharles N. Steele

By:______Kenneth A. Gross 1' Associate General Counsel Attachments 1. Respondents Response (pages 1-18) 2. Letter from Respondents (pages 19-20) 3. Letter to Respondents (pages 21-22) SEDAM. & HEDGE 83NDV?~PL2~ A PR@P55S@NAL mPgAY,@W AIV@RNSYS AY ~AW suuia saoo GLENN S SEDAND ~ 6300 @REENSS@R@ RSVE .wv~ see .e.CURTIS MERGE MCLZA)I, VRDODIRA ~1O3 1709 PENNSYLVANIA AVENU~ N. w. ROE ER? R. SPARKS. JR. WASNING?014. c. so@oe A. MARK CHRISTORMER * 793) S3*1090 ~

JOHN POSER? CLARK NOvember 23, 1983 TELEX S. ERIC SIVERYSEN CASLE' SEDAMNERE SHARON L. POWERS orc~ a SEA. CLAIRE N. SOCCELLA I JAIr4ESEOJ)I& DASLARO THOMAS J.~O@UL,*JR.~

I%~ ~'* -. Kenneth A. Gross, Esquire Associate General Counsel Federal Election Commission 1325 K Street, N.W. Washington, D.C. 20463 Attention: Deborah Curry, Esquire Re: MCJR 1578, 1587, 1590 AND 1591 ~0 Dear Mr. Gross: On behalf of our clients, Rep. Ron Packard and Friends of Ron Packard, we are writing in substantive response to the N. complaints filed with the Federal Election Commission by Mrs. John Crean, Mrs. Andrew Crean, Dr. Hale Dougherty and Mrs. Judith Caruthers, which have been numbered Z4UR 1578, 1587, 1590 and 1591, respectively. By letter dated November 3, 1983, a copy of which is enclosed for your convenience, I advised you that I had been engaged to represent our clients in connection with these matters, I enclosed a statement of designation of counsel and I requested additional time to submit this letter in order to gather and analyze the relevant facts. On behalf of Rep. Packard, we wish to note that we are pleased to have this opportunity to respond anil that we intend to be as forthcoming and cooperative as possible. Rep. Packard and the managers of his principal campaign committee, Friends of Ron Packard, have consistently made every reasonable and good faith effort to comply with the provisions of the Federal Election Campaign Act of 1971, as amended, and the regulations and directives of the Federal Election Commission. Now, upon investigation, it does appear that two of the complaints at hand do have merit. As a consequence, and even though the apparent violations were innocent and inadvertent, it is our intent to disclose the facts in full and to suggest that immediate steps be taken to reconcile the issue to the satisfaction of all concerned. Kenneth A. Gross, Esquire November 23, 1983 Page Two

An analysis of the four complaints reveals that they all relate to a single event: the mailing of invitations to attend a fund-raising dinner sponsored .by Friends of Ron Packard, which was held on September 17, 1983. Each complainant asserts that he or she received an invitation to attend that dinner and suggests that his or her name and address were copied from reports filed by Crean for Congress, the principal campaign committee of Mr. Johnnie Crean. As Mr. Crean was a candidate for election to the United States House of Representatives, the reports of Crean for Congress were filed in accordance with and subject to the pr'~visions of the Federal Election Campaign Act of 1971, as amended. 2 U.S.C. 431, et. seq. Section 438(a) (4) of Title 2 of the United States Code provides, in relevant part, "that any information copied from such reports...may not be...used by any person for the purpose of soliciting cOntributions...." We stipulate that the copies of the invitations attached to the subject complaints are copies of the invitations N mailed by Friends of Ron Packard for the September 17, 1983 dinner; and, we stipulate that the invitations solicit contribu- V tions to Friends of Ron Packard. Thus, the sole issue is whether or not the names and addresses of the four complainants were 0 copied from the reports filed by Crean for Congress. We submit V that it appears that the names and addresses of two of the four complainants were, in fact, copied from reports filed by Crean C for Congress while the names and addresses of the other two complainants were secured from other, non-restricted sources. Enclosed herewith and made a part of this response is the affidavit of Mrs. Bruce D. (Betty H.) Buckner, who, it will be noted with reference to the invitations, was a member of the Dinner Committee which organized the fund-raising dinner in question. Mrs. Buckner, who was an enthusiastic, hard working volunteer, explains in her affidavit that she was the individual responsible for the preparation of the invitation list. She also explains that, in compiling the invitation list, she did review disclosure statements filed by various candidates, including the reports filed by Crean for Congress; and, that the names and addresses of Dr. Hale Dougherty, the complainant in MUR 1590, and of Mrs. Judith Caruthers, the complainant in MUR 1591, were copied from the reports filed by Crean for Congress. Mrs. I

Kenneth A. Gross, Esquire November 23, 1983 Page Three

Buckner also states, under oath, however, that she had no previous knowledge whatsoever of the provisions of 2 U.S.C. 438(a) (4). Also enclosed herewith and made a part of this response is the affidavit of Mr. James N. Gaiser, who served as Chairman of the Dinner Committee and who supervised the work done by Mrs. Buckner. Mr. Gaiser explains that Mrs. Buckner did tell him of her plans to review disclosure statements filed by various candidates, including the reports filed by Crean for Cbngress. He did not object, because it is a recognized and common practice in California to compile names and addresses of contributors to state and local candidates from disclosure reports filed by those candidates. That practice is not prohibited by the laws of the State of California. Mr. Gaiser also states, under oath, that he too had no previous knowledge of the provisions of 2 U.S.C. 438(a)(4). With respect to the source of the names and addresses N of Mrs. John C. (Donna) Crean, the complainant in MtYR 1578, and of Mrs. Andrew (Charlene) Crean, the complainant in MUR 1587, Mrs. Buckner explains in self-explanatory detail, in paragraph o (7), (8)and (9) of her affidavit, that they were secured from the files of Friends of Ron Packard and not from the reports '~r filed by Crean for Congress. C As a consequence of the foregoing, it appears that

.~ Friends of Ron Packard may be held responsible for having violated the provisions of 2 U.S.C. 438.(a) (4) by reason of ~ soliciting contributions from Dr. Hale Dougherty and Mrs. Judith Caruthers, whose names and addresses were copied from reports filed by Crean for Congress. As stated in the affidavit of Mr. Gaiser, a total of 6,300 invitations were mailed. Of that total, only 47 invitations were to individuals whose names and addresses were copied from the reports filed by Crean for Congress, but, as Mr. Gaiser states, none of those 47 individuals responded by making a contribution to Friends of Ron Packard. Furthermore, as stated by Mrs. Buckner in her affidavit, the names and addresses of the 47 individuals copied from reports filed by Crean for Congress have been purged from the files and records of Friends of Ron Packard. Thus, a mistake was made. It was an innocent and inadvertent mistake, however, and one which resulted in no profit or benefit whatsoever to Friends of Ron Packard. 0 Kenneth A. Gross, Esquire November 23, 1983 Page Four

For the reasons stated, and in the interest of resolving this matter, it is recommended that the Federal Election Commission find reason to believe that Friends of Ron Packard may have violated the provisions of 2 U.S.C. 438(a) (4) by copying the names and addresses of Dr. Bale Dougherty and Mrs. Judith Caruthers from reports filed by Crean for Congress and then by soliciting contributions from those two individuals. Furthermore, it is recommended that the Federal Election Commission take no further action on the complaints filed by Mrs. John Crean and Mr4. Andrew Crean for the reasons set forth in the affidavit of Mrs. Buckner. Thereupon, and in accordance with the provisions of 11 CFR 111.18(d), we express the desire of Friends ~) of Ron Packard to enter into immediate negotiations directed towards reaching a conciliation agreement in settlement of this matter. It is also the wish of Friends of Ron Packard that this letter, together with its enclosures, be made a part of the 6( public file after this matter is concluded. Sincer your,'

C, J. Curtis Herge Enclosures id**' 7~... ~. .~6. .'. .i~1

~. ;>~.'

~*~a~:4; 2~ November 3, 2983

Kenneth A. Gross, Zsq. Associate General Counsel Federal Election Comission 1325 K Street, W.V. Washington, D.C. 20515 Attentions Deborah Curry, sq. Re: MUR 1578, 1587. 1590 and 1591 Dear Mr. Gross: N and On November 2. 1983, I was engaged by Rep. Ron Packard Friends of Ron Packard, respondents in complaints filed by Mrs John Crean, Mrs. Andrew Crean, Dr. Kale Dougberty and Mrs. Judith Carutbers, which have been numbered KUR 1578, 1587, 1590 and 159~, respectively. Enclosed, for your records, is a statement of designation of counsel, signed Friends by the Treasurer of of Ron Packard, which was delivered to me on November 2, q~. 1983.

Consistent vith Rep. Packard's letter to you of October 4, 1983, it is our intention to coopez~ate fully in resolving these matters and to do so as expeditiously as possible. An analysis of the complaints leads to the conclusion that they relate to a single incident, the issuance of solicitations for a fund-raising function held on September 17, 1983, which were processed by an individual vbo just recently returned from an extended vacation abroad. As a result, it is ~ 'our intention to respond to the four complaints in a consolidated Naftlker.

V Zn response to my request, certain informationp. and facts relevant to the matter at hand are being accumklsted should be and available to me by the end of next week. E~ is my plan then to prepare a substantive response, which will include a K:. Kenneth A. Gross Sovember 3, 1983 Page ?vo

~zoitation of tbe relevant facts untier oath. Because that will *','~.quire documents to be mailed to and returned from California, It is :y expectation that my submission to you should be completed by November 18, 1983. In the Interim, you may be assured that, without admitting or denying the allegations contained in the complaints. individuals associated with Friends of Ron Packard have now been adviced of the prohibitions of 2 U.S.C. 438(a)(4). Thus, all reasonable preca)4tionc have been taken* Lo assure that the provisions of that section sha2l not be violated in the futuz:e.

Sincerely yours, (5j~J 1. Oiwtia hr. o .7.Curtis Serge Counsel to Rep. Ron Packard and Friends of Ron Packard bcc: Mr. Clyde A. Romney

C9 ( 4h.. .9 SATNENT OF DESIGNATION OF COUNSEL

~WU OF COUNSEL: 3. Curtis Berg., Esq.. Sedam & Merge

Suite 1100, .8300 Greensboro ~r4ve, ?lcLean, Vixginia 22102

TELEPHONE: (703) 82±-bOO

Re: MUR 1578, 1597, 1590, 1591

The above-named individual is hereby designated as my counsel and is authorized to receive any notifications and 'hO other communications from the Conmnission and to act on my behalf before the Commission. Friends of Ron Packard By: Q~ 6 /Y&J Date -, S~.gnature Treasurer

NAME: William L. Hardy

ADDRESS: 550 W. Vista Way, Suite 402

Vista, CA 92083 HOME PHONE:

BUSINESS PHONE: (619) 758-7505 ThE iz~n&z

STATE OF CALIFORNIA ) COUNTY OF SAN DIEGO ) to-wit:

BETTY M. BUCKNER, being duly sworn, deposes and says: (1) That she served as a member of the Dinner Committee for a fund-raising function sponsored and held under the auspices of Friends of Ron Packardon September 17, 1983, the invitations to which were reproduced and attached as exhibits to the complaints filed with the Federal Election Commission 1587,' numbered MUR 1578, 1590 and 1591; (2) Th'at your deponent was the individual responsible o for the preparation of the list of individuals to whom invitations to the above-referenced function were to be mailed; that in the course of compiling the list of invitees I discussed with James M. Gaiser, Chairman of the Dinner Committee, my proposed sources of information and he did not object to my o proposal; (3) That, in the course of compiling the list of invitees, your deponent secured a mailing list of names from a professional mailing list service, utilized numerous local a, directories and reviewed copies of financial reports filed by various candidates for elective office in the State of California, including the reports filed by Crean for Congress. (4) Included in the list of invitees were the names and addresses of Hale Dougherty, M.D., 9431 Hillview Road, Anaheim, California 92804 and of Mrs. Judith Caruthers, 2701 Ebbtide, Corona del Mar, California 92625, complainants in MUR 1590 and MUR 1591. Said names were on the report filed by Crean for Congress. However1 it is possible that said names were also listed in other sources. (5) That a total of approximately 6,300 invitations were mailed to individuals. Of this amount 47 names, constituting less than one per cent (1%) of the invitations mailed (.7469%), were mailed to individuals whose names and addresses appeared on the reports filed by Crean for Congress; (6) That at the time the list of invitees was compiled and the invitations were mailed, your deponent had no.knowledge of the fact that section 438(a) (4) of Title 2 of the United States Code provides that the names and addresses of contributors to Federal .candidates contained in reports filed as required by the Federal Election Campaign Act of 1971, as amended, may not be used by any person for the purpose of soliciting contributions; (7) That the name and address of Mrs. John C. (Donna) 0 Crean, 617 North Cannon Drive, Beverly Hills, California 90210, V complainant in MUR 1578, was obtained from the files of Friends V of Ron Packard, particularly from the return address on a letter from John C. Crean to Mr. Packard, dated September 29, 1982, a copy of which is attached as Exhibit "A". The subject invitation was mailed to Mr. and Mrs. John C. Crean as a courtesy because, as evidenced by the attached letter from Mr. Crean to Rep. Packard dated August 9, 1983, which is attached hereto as Exhibit "B", Mr. Crean has invited Rep. Packard to various functions in the past year. (8) That the name and address of Mrs. Andrew (Charlene) Crean, 109 Monarch Bay, South Laguna, California

-2- 92677, complainant in MUR 1587, was obtained from Mr. Charles Z. J4cClung, a campaign volunteer who is a neighbor of Mrs. Crean. A copy of a letter from the campaign files dated October 22, 1982 which is addressed to Mr. McClung is attached hereto as. Exhibit "C". (9) Since the date of Mr. Packard's letter to Mr. McClung, Johnnie R. Crean moved from the Monarch Bay address to a home in the 43rd Congressional District. In keeping with my decision to mail courtesy inhritations to Mr. and Mrs. Johnnie R. Crean (the candidate and h~s wife) and Mr. and Mrs. John C. Crean CM (parents of the candidate), I sent the subject invitation to Mr. and Mrs. Andrew Crean (his brother and sister-in-law). (10) Upon learning of the unusability of names derived rb from the reports of Mr. Crean, I immediately removed said names from the computer files and records of Friends of Ron Packard on 0 or about November 12, 1983.

~qrn IN WITNESS WHEREOF, your deponent has executed this affidavit this 18th day of November, 1983. cn

SWORN to before me this 18th day of November, 1983. OFFICIAL SFAJE W JOSEPH PA~ISt

* * ~OTA~ PUBLIC - CAL!~ORNA P.~ b2ZCarIsbad, ~ I2Ooi DIECOexpires courm'FEB 21, 1986 Notary b 1

-3- 6)~iI'n and ~Done~a Car'on 617 LAbat~ Cai~o~ CD~iw C~0 ~ 3 '~3JiQ&L &z(~r~~nia '10210

September 29, 1982

Dear Hr. Packard, This letter is an attempt to clear a personal resentment that I have against you. It really has nothing to do with the current political events in the 43rd distrIct, nor do I hope to bring about any changes in your opinions or actions.

My father was an Irish Nationalist, he could not fe~gn alligiance to R9me. nor to £ngland. So at the turn of the century when he was nineteen years old he made the decision to come to this country to seek the kind of religeous, ~pol4ticald....eco.~omjc. Ireedom4.bate.Axeam~d...Qf....

He found the realization of that dream on these shores and was grateful for it til the day he died. He passed this love of freedom along to me and I have attempted to carry on the traditon and pass it along to my children. I seem to be plagued with the opinion that the political ~ process took its course on June 8. This process was an extreme demonstration of competitive endeavor and in his 0 zeal to win my son was responsible for some regretable ~qs actions. This often happens to' the best ofus in times of passion. Ours and many other great nations regret many of the acts committed in the heat of battle. I saw the Japanese u~ ..Arneric.ans.1 many of- tbem..my good friends, treated like, cattle shortly after December 7, 1941. At the time~I agreed with the government's actions as. there was a great fear and mueh anger upon the land and I was no less affected than most. * We who condoned this unjustice later regretted it and sought the forgivness of those injured.

The unmerciful pounding that the city of Le Mans in France recieved shortly after the Normandy invasion because it was believed to be a German stronghold that killed and maimed ~thousands of innocent French-civilians was an act that- those responsiblelived to regret. 'These regretful actions do occur with frightful frequency during times of conflict and struggle. 3

Page 2. War is possibly the ultimate form politics of competition, and probably come second. And most important mind is that to keep in war is the result of the failure of politics. This is getting close to the basis of my anger toward you. Competition is a remarkable dynamic. The blessings that we have recieved as a result of it are countless. However when a competition is concluded and the refuses vanquished to concede defeat the results can be quite disasterous. Hitler brought on millions and untold of needless deaths dist~uction to his country by not conceding for almost a year defeat after it was a reality. The Japanese from Guadalcanal to Iwo Jima and Okinawa and could not concede defeat a terrible price was paid in lives on both inability sides for this to recognize the conclusion of a contest. N When the checkered flag falls, the gun sounds the end game, the photo of the shows the winner by a nose or the votes are counted and the winner declared defeat then the vanquished accepts and congratulates the winner. When he N the very essence of doesn't, then this marvelous dynamic of competition has been violated. o These people are usually referred to as sore losers, bad sports or crybabies. You are most certainly But in the grand all of these. scheme of things it is my Opinion that you are guilty of much more than that.

When the smoke clears from battle and people rational state return to a more then the salvation of mankind has been his Cod-given ability to forgive, in victory inability to or defeat. Your respond to this basic truth is ~he true guage your shallowness. of

In my rather stormy life it has been my observation measure of our that the character is in direct proportion to our ability to forgive. The judgemental and viscious attitude that you are displaying in the face of defeat is in my opinion caused forces that by the same brought on the spiritual smugness that snade neccessary the crucifixtion of our Lord. The November election will soon come and go. it will be of very The results of little interest to anyone after the first of the year. 'U 0

Page 3. As a loving father Z feel that the Outcome will only be another turning point in my son's life. He has given me great joy in the past and I am grateful and proud to be his father. He is a young man of great depth, compassion, wisdom, honesty and courage. He will either go to Washington and do a fine job or stay home and continue to do productive and meaningful service. In my opinion, he wins either way. In the meantime I will accept your visciousness towards my soh as a flame and fire that willonly temper him into a stronger man. You have thrown dQwn the gauntlet and another competition seems to be on. I shall replace the anger I have towards you with activity in the contest. I will be in the district shortly and I will be attacking your viciousness, deceptivenesS, deviseivness, smugness and your blatent and chronic dishonesty for precisely what they are. My son can't and won't. And I'm proud of him for that. But as for me, all the stops are out and I intend to let the good people of the 43rd district know the essence of your character. May God protect you and your family as you go on your misguided way. Sincerely yours,

roan . ' 4 ( Nolional ~nsm~m forth. Md and Talented cZ2~ 19), Peimau$vanla 4wnue~ N. W.. Suite 301 Washlngto'e, D.C 2~tA6 (202)2934194 Wewrn Regienal Office 2040 Santa Craz, Sta Jis August 9, 1993 OCTg ~ (%V 4 Aahebn. Cal jfornIa ~iaos The Honorable Ron Packard (714) 975.0936 1207 Elm Avenue C4,mh Chbmm Carlsbad, California 92008 JA C Cm CA.buuu VahulwE FbAA~5uwp.im Dear Congressman Packard: FumkJkau~ huM... A..m.7& F.emwP~uW.m& As our State's newly appointed Am.~e.u PemImmJaaIa.u. chairman for the Business Consortium for Gifted and Talented Children, I would like to cordially invite you to be my Amusma P.w~Jeym Iauahuu. guest at a cocktail reception at the Balboa Bay Club (Quarter Deck Room) on la.'t1eq~m IwAugeviw Thursday, August 25, 1983 from 5:30 P.M. to 7:30 P.M. Also during the event will Co.drwa :81 Iili.Mu PJeAeAmeJ leak be a Bay cruise aboard "Prowler 76". J.ArZD.... Cvu., This event is the kickoff for the C~wp.r~i.n Business Consortium for the Gifted and W1~M~N. D.aa.rFeuadeAa Talented Children in California. The guest speaker will be a board member of L.A j~.rpewiem the National Business Consortium in Fiw C..pwuie. Washington. Our audience will consist of

C."',-, giants of industry, political and educational leaders, as well as Hollywood o.4~bu c..p.u.y celebrities. Iac~ Hos~I Ce~vuai.n qfimuac. Today we are surrounded, world-wide by growing industrial excellence and Xm.MG.e Feaamdeder~ Ia& achievement. Other countries are moving FM~i*pF.wad~~Ie'i Ja& faster and in many areas we are actually M.L~smehd Ceaqpwt. I.e. suffering declines. For over a decade educat~onal quality at the secondary level Milk, T.chae)egyd Cemmanui..deau Ce.pe~ueien has been deteriorating, particularly in Mobil Feiaadaui.r~ i.e. science and math, and especially for top NabLice lrwmda, I.e. students. This must be reversed but it cannot be NOMAW C.upemaie. unless the American Business Community joins Pew,-Lwi, Cewusti." with educators, parents, governors and local governments all over the country in a PhilI4pa P.w.l.um Coup.., coordinated effort. h.emrd GoubkFuud Ra~h... C.a~p.wy Ri. R.,.oM.Induwiea~ Ian. &waet Maaq.wuaai C. w"'ion Tunwrlan.da.ariq Uaia.d Teehanlegin Cuporsuien The Wazhiesgwa 7~asn AL W.V. Eawpna.a of California (*. I

August 5, 1983 Page Two (~)

President Ronald Reagan plans to have the business sector, rather than government, assume the role that it. should have in the future direction of education. Vice-President George Bush feels so strongly in what the Consortium hopes to accomplish that he held the "National Kickoff" reception at his home in Washington, D.C. We are organizing a private sector effort in California that will engage industrial and commercial America directly with education. The reception highlights our purpose...to place California business in the forefront of the rapidly developing national consensus that quality education is essential for our country in an ever more competitive world. This is not a fund raising event! Ultimately, when N the membership is expanded, revenues will be sufficient to cover on-going costs. Today, however, we face immediate N start up costs which must be met if we are to develop a business network all over California. To make this a reality we have established a "Committee of 100" each of whom would be asked to donate $1,000 to become a member. This would provide the "seed money" to operate for 18 months. These N monies are important but the main thrust is your personal involvement and help in our work at the local, state or. federal level. 0 I cannot over-emphasize that we are now enjoying a "window of opportunity" because of the several reports that have recently criticized and recommended drastic changes in our educational system. We feel that now is the time to V move boldly and decisively in a way that will benefit business as well as education. Your attendance will only emphasize the vital role California will play in the success of the battle for better educat ion. Sincerely,

John Crean California Chairman TUE FEDEML

STATE OF CALIFO~MIA COUIITY OF SAN DIEGO ) to-wit:

JAMES N. GAISER, being duly sworn, depose. and says: (1) That he served as Chairman of the Dinner Committee for a fund-raising function sponsored and held under the auspices of Friends of Ron Packard on September 17, 1983, the invitations to which were reproduced and attached as exhibits to the complaints filed with the Federal Election Commission numbered 1587, MUR 1578, 1590 and 1591; (2) TlZat Mrs. Betty N. Buckner, ~ member of the Dinner

0 Committee, was the individual responsible for the preparation of the list of individuals to whom invitations to the above- referenced function were to be mailed; (3) That Mrs. Buckner, in the course of compiling the N list of invitees, advised your deponent that she proposed to

secure a mailing list of names from a professional mailing list service, utilize numerous local directories and review copies of O financial reports filed by various candidates for elective office * in the State of California, including the reports filed by Crean for Congress; (4) That your deponent is aware, of his own knowledge and experience (having served as treasurer for a state assemblyman), that it is a recognized and common practice in the State of California for candidates and campaigns to secure from reports filed by candidates for state and local elective offices in accordance with the laws of the State of California, the names and addresses of contributors to such candidates and to use those C .4

names and addresses for the purpose of soliciting contributions, such practice not being prohibited by the laws of the State of California; (5) That, by reason of the foregoing, your deponent did not object to the proposal of Mrs. Buckner that she proceed as described in paragraph (3) hereof; (6) That, upon information and belief, Mrs. Buckner did gather selected names and addresses from the various sources previously stated. Such list of names an'! addresses did include the names and addresses of Hale Dougherty, M.D., 9431 Hillview

Road, Anaheim, California 92804 and of Mrs. Judith Caruthers, 2701 Ebbtide, Corona del Mar, California 92625, complainants in MUR 1590 and MUR 1591. Said names were on the report filed by Crean for Congress. However, I do not have the information o available to state whether said names were also listed in other sources used by Mrs. Buckner. C, (7) That a total of approximately 6,300 invitations were mailed to individuals. Of this amount 47 names, constituting less than one per cent (1%) of the invitations mailed (.7469%) were mailed to individuals whose names and addresses appeared on the reports filed by Crean for Congress. None of the said 47 individuals responded by making a contribution to Friends of Ron Packard. (8) That at the time the list of invitees was compiled and the invitations were mailed, your deponent had no knowledge of

-2- Sc.

~ James H. Gaiser V CO SWORN to before me this 19th day of November, 1983. OF?'1C1h~LS! 5AL W JOSEPH PARISI N tJOTARY FUBLIC - CALFO~MA

Box 92, CarI~bad, CA 92008 SAN DIrGO COUNTY P.O My wmm. inxpires FEB 21, 1996 Notary 1

0 -V.

-3- -. p~ ,

SEDA.~ & U2RGE 830Ec$ ASflJj A PR09ESSS@NA~ S@RRGAI@N ATTORNEYS A? LAW surruseso 6300 @REENSS@R@ GLENN J. SWAM, JR. Sew, 'WOO ~. CURISS MERGE NOLZA2I. 'Y1301XZ& 35103 PENNSYLVArnb AVENUE. N. W. mOSER? N. SPARKS, JR. WASMON?0~, D.c. 8000. A. MARK CMRSSTOPMER (109k SIIm*@@@ 703)631-1000 .10MW ROBERT CLARK I ELK [email protected] S. ERIC SIVERISEN November 30, 1983 CASLEa SAWNERGE SMAROM L. POWERS CLAIRE N. SOCCELLA OF COuwSEI. JAMES COWARD ASLARD ThOMAS ~rUA0@UL. .DR.

C, Kenneth A. Gross, Esquire Associate General Counsel Federal Election Commission -o 1325 K Street, N.W. Washington, D.C. 20463 a I ATTN: Deborah Curry, Esquire

Re: )IUR 1578, 1587, 1590 and 1591 a) Dear Mr. Gross: This letter is written with reference to my letter to you, dated November 23, 1983, with respect to the above-captioned ~ matters. Enclosed with my letter was-the affidavit of BettyM. Buckner, which, in paragraph (8), referred to a letter addressed to Mr. Charles E. McClung dated October 22, 1982. Enclosed ~ herewith is a copy of that referenced letter, which was inadver- tently omitted from my original submission~.

J. Curtis Herge Enclosure -*0~ * r~.

October 22, 1982

-. j. *6 C)' ~

Mr. Charles E. McClung Fleming, Anderson, McClung £ Finch 24012 Calle de la Plata,. Suite 330 Laguna Hills, CA 92653 Dear Mr. McClung: I really appreciated hearing from you with regard to your experience' with Johnnie Crean as a neighbor. yousre not the first neighbor of his that has made contact with me. As you are no doubt aware, Mr. Crean has done an excellent job of creating a bad image of himself. Rather than add fuel to that fire, I would be most appreciative of a~ efforts you could make inmy behalf with your friends and associates that reside within the 'Urd Congressional District. I hope that you would encourage them to vote for me and to multiply their efforts by talking to their friends and neighbors. 0 Should you or your partners wish to make a monetary contribution to uur campaign to assist us in getting our o message to the voters, that too would be most A contribution envelope is enclosed for your convenience.appreciated.

~m.. Thank you again for writing, en

RON PACKARD 0* 9

FEDERAL ELECTION COMMISSION * WASHINGTON. D.C. 20463

44~ctlL~d.&.3

J. Curtis lierge Sedam & Herge 8300 Greensboro Drive, Suite 1100 McLean, Virginia 22102 Re: MUR 1578 Dear Mr. Herge: The Feder:aJ. Election Commission notified you on September 27, 1983, of complaints which alleged that your clients Representative Ronald Packard and Friends of Ron Packard, violated certain sections of the Federal Election Campaign Act of 0 1971, as amended ("the Act"). A copy of the complaint was forwarded to you at that time. We acknowledge receipt of your explanation of this matter which was dated November 29, 1983 and December 5, 1983. Upon further review of the allegations contained in the complaint and information supplied by you, the Commission, on SI' January , 1984, determined that there is reason to believe that your clients have violated 2 U.S.C. S 438(a) (4), a provision of 0 the Act. You may submit any factual or legal materials which you believe are relevant to the Commission's analysis of this matter. Please submit any such response within ten days of your receipt of this letter. In the absence of any information which demonstrates that no further action should be taken against your clients, the Commission may find probable cause to believe that a violation has occurred and proceed with conciliation, Of course, this does not preclude the settlement of this matter through conciliation prior to a finding of probable cause to believe if you so desire and if the Commission has concluded its investigation. Any request to initiate such conciliation should be in writing. See 11 CFR S 111.18(d). J. Curtis Herge Page 2

This matter viLl remain confidential in accordance vith 2 U.S.C. SS 437g (a)(4)(B) and 437g(a)(12)(A) unless you notify the Commission in vriting that you vish the matter to be made public. It you have any questions, please contact Deborah Curry, the attorney assigned to this matter, at (202) 523-4000. Sincerely,

Enclosure Procedures

C IHENGE ~ORPORATION A~TLAW

'0 DRIVE 14 *A 82109 2 flu: 5 P2: 58

Kenneth A. Gross, Esquire Associate General Counsel Federal Election Commission 1325 K Street, N.W. Washington, D.C. 20463 4 AIYN: Deborah Curry, Esquire 0 ~U~IVEL) A~ THE FEC

SEDAX & IKEnGE 833EC5 *t: ~ A PROPESSIOWAI. CORPQRAb@N AYY@RNEYS A? LAW (~bt~ / 67~ SunS 1100 0300 @REENSUORO DRIVE GLENN .5. SEDAM, JR. J. CURTIS MERGE XCLA3I, VIUGINRA 103 1700 PENNSVIVANIA AVENUE N. W, ROSERT R. SPARKS, JR. WAS~IWGON. D.C. 20000 A. MARK CHRISTOPHER (703)081-1000 (703) gal-lOOC VELEN 710-03l-OSSO JOHN ROUCRY CLARK DI S. ERIC SIVERYSEN November 30, 1983 CASLE SEDAMMERGE SHARON L. POWERS OP COUNSEL CLAIRE 14. SOCCELLA JAMES E~WARD AS LARD TMOMAS J. PACOUL, JR.

Kenneth A. Gross, Esquire Associate General Counsel Federal Election Commission 1325 K Street, N.W. Washington, D.C. 20463 ATTN: Deborah Curry, Esquire Re: DEl 1578, 1587. 1590 and 1591 Dear Mr. Gross: 0 This letter is written with reference to my letter to you, dated November 23, 1983, with respect to the above-captioned N matters. Enclosed with my letter was the affidavit of Betty M. Buckner, which, in paragraph (8), referred to a letter addressed to Mr. Charles E. McClung dated October 22, 1982. Enclosed herewith is a copy of that referenced letter, which was inadver- tently omitted from my original submissio9.

J. Curtis Herge Enclosure ~1~ -

October 22, 1982

e~n

Mr. Charles E. McClung Fleming, Anderson, McClung & Finch 24012 Calle de la Plata, Suite 330 Laguna Hills, CA 92653 Dear Mr. McClung: I really appreciated hearing from you with regard to your experienct? with Johnnie Crean as a neighbor. N first neighbor of his that has made contact withYo&re me. not the

As you are no doubt aware, Mr. Crean has done an excellent job of creating a bad image of himself. Rather than add fuel to that fire, I would be most appreciative of any efforts you could make inmy behalf with your friends and N associates that reside within the 43rd Congressional District. I hope that you would encourage them to vote for me and to multiply their efforts by talking to their friends and neighbors. 0 Should you or your partri~~rs wish to make a monetary contribution to uur campaign to assist us in getting our o message to the voters, that too would be most appreciated. A contribution envelope is enclosed for your convenience. Thank you again for writing,

RON PACKARD * SEDAM & HEDGE 83N2V28 PIZ: 43 A PROFESSIONAL CORPORATION ATTORNEYS AT LAW SUITE 1100

GLENN J. SEDAM, JR. 5300 GREENSEORO DRIVE sug~g oao .3. CURTIS MERGE MOLNAN, VIRGINIA 89100 1700 PENNSYLVANIA AVENUE, N. W. ROBERT R. SPARKSJR. WASNINGT0N~. C. 50004 A. MARK CHRISTOPHER (703) 6311000 (7031 S5*~0OO * TELEX' 7131-0555 JOHN ROBERT CLARK in November 23, 1983 CASLEsSEDAMI4ERGE B. ERIC SIVERTSEN 3 SHARON L. POWERS OP C tSEL CLAIRE M. BOCCELLA JAMES E0~AO ASLARD THOMAS J.F~0OUL, JR.

Kenneth A. Gross, Esquire Associate General Counsel Federal Election commission 1325 K Street, N.W. Washington, D.C. 20463 Attention: Deborah Curry, Esquire Re: xuR 1578. 1587, 1590 AND 1591 Dear Mr. Gross: On behalf of our clients, Rep. Ron Packard and Friends of Ron Packard, we are writing in substantive response to the complaints filed with the Federal Election Commission by Mrs. John Crean, Mrs. Andrew Crean, Dr. Hale Dougherty and Mrs. Judith Caruthers, which have been numbered RUE 1578, 1587, 1590 and 1591, respectively. By letter dated November 3, 1983, a copy of which is enclosed for your convenience, I advised you that I had been engaged to represent our clients in connection with these matters, I enclosed a statement of designation of counsel and I requested additional time to submit this letter in order to gather and analyze the relevant facts. On behalf of Rep. Packard, we wish to note that we are pleased to have this opportunity to respond and that we intend to be as forthcoming and cooperative as possible. Rep. Packard and the maragers of his principal campaign committee, Friends of Ron Packard, have consistently made every reasonable and good faith effort to comply with the provisions of the Federal Election Campaign Act of 1971, as mended, and the regulations and directives of the Federal Election Commission. Now, upon investigation, it does appear that two of the complaints at hand do have merit. As a consequence, and even though the apparent violations were innocent and inadvertent, it is our intent to disclose the facts in full and to suggest that immediate steps be taken to reconcile the issue to the satisfaction of all concerned. S w

Kenneth A. Gross, Esquire November 23, 1983 Page Two

An analysis of the four complaints reveals that they all relate to a single event: the mailing of invitations to attend a fund-raising dinner sponsored by Friends of Ron Packard, which was held on September 17, 1983. Each complainant asserts that he or she received an invitation to attend that dinner and suggests that his or her name and address were copied from reports filed by Crean for Congress, the principal campaign committee of Mr. Johnnie Crean. As Mr. Crean was a candidate for election to the United States House of Representatives, the reports of Crean for Congress were filed in accordance with and subject to the provisions of the Federal Election Campaign Act of 1971, as amended. 2 U.S.C. 431, et. seq. Section 438(a) (4) of Title 2 of the United States Code provides, in relevant part, that any information copied from such reports...may not cr~ be...used by any person for the purpose of soliciting contributions... We stipulate that the copies of the invitations attached to the subject complaints are copies of the invitations mailed by Friends of Ron Packard for the September 17, 1983 dinner; and, we stipulate that the invitations solicit contributions to Friends of Ron Packard. Thus, the sole issue is whether or not the names and addresses of the four complainants were copied from the reports filed by Crean for Congress. We submit that it appears that the names and addresses of two of the four complainants were, in fact, copied from reports filed by Crean for Congress while the names and addresses of the other two complainants were secured from other, non-restricted sources. Enclosed herewith and made a part of this response is the affidavit of Mrs. Bruce D. (Betty H.) Buckner, who, it will be noted with reference to the invitations, was a member of the Dinner Committee which organized the fund-raising dinner in question. Mrs. Buckner, who was an enthusiastic, hard working volunteer, explains in her affidavit that she was the individual responsible for the preparation of the invitation list. She also explains that, in compiling the invitation list, she did review disclosure statements filed by various candidates, including the reports filed by Crean for Congress; and, that the names and addresses of Dr. Hale Dougherty, the complainant in MUR 1590, and of Mrs. Judith Caruthers, the complainant in MUR 1591, were copied from the reports filed by Crean for Congress. Mrs. Kenneth A. Gross, Esquire November 23, 1983 Page Three

Buckner also states, under oath, however, that she had no previous knowledge whatsoever of the provisions of 2 U.s.c. 438(a) (4). Also enclosed herewith and made a part of this response is the affidavit of Mr. James M. Gaiser, who served as Chairman of the Dinner Committee and who supervised the work done by Mrs. Buckner. Mr. Gaiser explains that Mrs. Buckner did tell him of her plans to review disclosure statements filed by various candidates, including the reports filed by Crean for Congress. He did not object, because it is a recognized and common practice in California to compile names and addresses of contributors to state and local candidates from disclosure reports filed by those candidates. That practice is not prohibited by the laws of the State of California. Mr. Gaiser also states, under oath, that he too had no previous knowledge of the provisions of 2 U.S.C. 438(a) (4). With respect to the source of the names and addresses of Mrs. John C. (Donna) Crean, the complainant in HUE 1578, and of Mrs. Andrew (Charlene) Crean, the complainant in HUE 1587, Mrs. Buckner explains in self-explanatory detail, in paragraph (7), (8) and (9) of her affidavit, that they were secured from the files of Friends of Ron Packard and not from the reports filed by Crean for Congress. As a consequence of the foregoing, it appears that Friends of Ron Packard may be held responsible for having violated the provisions of 2 U.S.C. 438(a) (4) by reason of soliciting contributions from Dr. Hale Dougherty and Mrs. Judith Caruthers, whose names and addresses were copied from reports filed by Crean for Congress. As stated in the affidavit of Mr. Gaiser, a total of 6,300 invitations were mailed. Of that total, only 47 invitations were to individuals whose names and addresses were copied from the reports filed by Crean for Congress, but, as Mr. Gaiser states, none of those 47 individuals responded by making a contribution to Friends of Ron Packard. Furthermore, as stated by Mrs. Buckner in her affidavit, the names and addresses of the 47 individuals copied from reports filed by Crean for Congress have been purged from the files and records of Friends of Ron Packard. Thus, a mistake was made. It was an innocent and inadvertent mistake, however, and one which resulted in no profit or benefit whatsoever to Friends of Ron Packard. Kenneth A. Gross, Esquire November 23, 1983 Page Four

For the reasons stated, and in the interest of resolving this matter, it is recommended that the Federal Election Commission find reason to believe that Friends of Ron Packard may have violated the provisions of 2 U.S.C. 438(a)(4) by copying the names and addresses of Dr. Hale Dougherty and Mrs. Judith Caruthers from reports filed by Crean for Congress and then by soliciting contributions from those two individuals. Furthermore, it is recommended that the Federal Election Commission take no further action on the complaints filed by Mrs. John Crean and Mrs. Andrew Crean for the reasons set forth in the affidavit of Mrs. Buckner. Thereupon, and in accordance with the provisions of 11 CFR 111.18(d), we express the desire of Friends of Ron Packard to enter into immediate negotiations directed towards reaching a conciliation agreement in settlement of this ~natter. It is also the wish of Friends of Ron Packard that this letter, together with its enclosures, be made a part of the public file after this matter is concluded. Sincer your ~

C) it. L... J. Curtis Herge Enclosures 9

* November 3, 1983

Kenneth A. Gross Ksq. Associate General Counsel Federal Ilection Commission 2325 K Street, W.V. Washington, D.C. 20515 Attention, Deborah Curry, Zuq. Re, RUR 1578. 1587. 1590 and 1591 Dear Mr. Gross: N On November 2, 1983, K was engaged by Rep. Ron Packard and Friends of Ron Packard. respondents in complaints filed by Mrs John Crean, Mrs. Andrew Crean, Dr. Nale Dougherty and Mrs. Judith Caruthers, which have been numbered NUK 1578, 1587, 1590 and 159), respectively. Inclosed, for your records, is a statement of designation of counsel, signed by the treasurer of Friend, of Ron Packard, which was delivered to me on November 1983. 2,

Consistent with Rep. Packard's letter to you of October 4, 1983, it is our intention to cooperate fully in resolving these matters and to do so as ezpedlti.ously as possible. An analysis of the complaints leads to the conclusion that they relate to a single incident, the issuance of solicitations for a fund-raising function held on September 17, 1983, vhich were processed by an individual who just recently zeturned from an extended vacation abroad. As a result, it is ~ Our intention to respond to the four complaints in a consolidated mammer. Zn response to my request, certain information and facts relevant to the matter at hand are being acoin~1sted and should be available to me by the end of next week. ft is my plan then to prepare a substantive response, which will include a I.

Mc. Kenneth A. Gross November 3, 1983 Wage Two

I, ~toitation of the relevant facts under oath. Decaus. that will gequire documents to be mailed to and returned from California, It Is my expectation that my submission to you should be completed by November 18, 1983. In the interim, you may be assured that, without admitting or denying the allegations contained in the complaints9 individuals associated with Friends of Ron Packard have now been advicqid of the prohibitions of 2 U.S.C. 438(a)(4). Thus, all reasonable precautionc have been taken*to assure that the provisions of that section shall not be violated ira the future. Sincerely yours, (II~d) 1. Otittia hiss 0 3. Curtis Merge Counsel to Rep. Ron Packard and Friends of Ron Packard N bcc: Mr. Clyde A. Romney

0 9~ 9. .3

'I STATENEtT OF DESIGNATION OF COUNSEL

NAME OF COUNSEL: J. Curtis Merge, *Esq.. Sedam & Merge

ADDRESS: Suite 1100, 8300 Greensboro DrLv., ?lcLean, Virginia 22102

TELEPHONE: (703) 821-1000 Re: MUR 1578, 1587, 1590, 1591

The above-named individual is hereby designated as my counsel and is authorized to receive any notifications and other communications from the Commission and to act on my 9' behalf before the Commission. Friends of Ron Packard By:

Date ' Signature Treasurer

NAME: William L. Hardy

ADDRESS: 550 V. Vista Way, Suite 402 Vista, CA 92083

HOME PHONE: BUSINESS PHONE: (619) 758-7505 8S30N . ORE THE FEDERAL ELECTIOW

STATE OF CALIFORNIA ) COUNTY OF SAN DIEGO ) to-wit:

BETTY M. BUCKNER, being duly sworn, deposes and says: (1) That she served as a member of the Dinner

committee for a fund-raising function sponsored and held under the auspices of Friends of Ron Packard on September 17, 1983, the invitations to which were reproduced and attached as exhibits to the complaints filed with the Federal Election Commission 1587, numbered MUR 1578, 1590 and 1591; (2) That your deponent was the individual responsible for the preparation of the list of individuals to whom invitations to the above-referenced function were to be mailed; that in the course of compiling the list of invitees I discussed with James M. Gaiser, Chairman of the Dinner Committee, my N proposed sources of information and he did not object to my

proposal; (3) That, in the course of compiling the list of C invitees, your deponent secured a mailing list of names from a professional mailing list service, utilized numerous local directories and reviewed copies of financial reports filed by various candidates for elective office in the State of

California, including the reports filed by Crean for Congress. (4) Included in the list of invitees were the names and addresses of Hale Dougherty, M.D., 9431 Hillview Road, Anaheim, California 92804 and of Mrs. Judith Caruthers, 2701 Ebbtide, Corona del Mar, California 92625, complainants in MUR 1590 and MUR 1591. Said names were on the report filed by Crean for Congress. However, it is possible that said names were also listed in other sources. (5) That a total of approximately 6,300 invitations

were mailed to individuals. Of this amount 47 names, constituting less than one per cent (1%) of the invitations mailed (.7469%), were mailed to individuals whose names and addresses appeared on the reports filed by Crean for Congressi (6) That at the time the list of invitees was compiled and the invitations were mailed, your deponent had no knowledge of the fact that section 438(a) (4) of Title 2 of the United ~0 States Code provides that the names and addresses of contributors C,, to Federal candidates contained in reports filed as required by

the Federal Election Campaign Act of 1971, as amended, may not be used by any person for the purpose of soliciting contributions~ (7) That the name and address of Mrs. John C. (Donna) 0 Crean, 617 North Cannon Drive, Beverly Hills, California 90210,

complainant in MUR 1578, was obtained from the files of Friends C of Ron Packard, particularly from the return address on a letter a, from John C. Crean to Mr. Packard, dated September 29, 1982, a copy of which is attached as Exhibit "A'. The subject invitation was mailed to Mr. and Mrs. John C. Crean as a courtesy because, as evidenced by the attached letter from Mr. Crean to Rep. Packard dated August 9, 1983, which is attached hereto as

Exhibit 'B", Mr. Crean has invited Rep. Packard to various functions in the past year. (8) That the name and address of Mrs. Andrew (Charlene) Crean, 109 Monarch Bay, South Laguna, California

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92677, complainant in MUR 1587, was obtained from Mr. Charles K. McClung, a campaign volunteer who is a neighbor of Mrs. Crean. A copy of a letter from the campaign files dated October 22, 1982 which is addressed to Mr. McClung is attached hereto as Exhibit "C". (9) Since the date of Mr. Packard's letter to Mr. McClung, Johnnie R. Crean moved from the Monarch Bay address to a home in the 43rd Congressional District. In keeping with my decision to mail courtesy invitations to Mr. and Mrs. Johnnie R. Crean (the candidate and his wife) and Mr. and Mrs. John C. Crean N (parents of the candidate), I sent the subject invitation to Mr. and Mrs. Andrew Crean (his brother and sister-in-law). (10) Upon learning of the unusability of names derived N from the reports of Mr. Crean, I immediately removed said names from the computer files and records of Friends of Ron Packard on 0 or about November 12, 1983.

IN WITNESS WHEREOF, your deponent has executed this affidavit this 18th day of November, 1983. a,

SWORN to before me this 18th day of November, 1983. O~TTf~Y4~ SF2A!J VJ .JOSEPH PAR~SI I~IOTA~y PUBLIC - CAUFOPNIA

P. ~ ki 2,Carls?:d, DIeGO CA COUNTY::ooa

-3- ~9oIin and 'Thmna C~oi 617 LA~1ALI~ C(ii~On ~O~iLQ ~Qeue*~J WiQ&~. i~6r~iuri 'x~io

September 29, 1982

Dear Mr. Packard,

This letter is an attempt to clear a personal resentment that I have against you. It really has nothing to do with the current political events in the 43rd district, nor do I hope to bring about any changes in your opinions or actions.

My father was an Irish Nationalist, he could not feign alligiance to Rme nor to England. So at the turn of the century when he was nineteen years old he made the decision to come to this country to seek the kind of religeous, -political,.an&econ~omjc Ireedom.thatdw. d.r.earned..Qf...

Ours and many other great nations regret many of the acts committed in the heat of battle. I saw the Japanese ...Americans, many of- them my good friends, treated like cattle shortly after December 7, 1941. At the time I agreed with the government's actions as there was a great fear and much anger upon the land and I was no less affected than most. We who condoned this unjustice later regretted it and sought the forgivness of those injured.

The unmerciful pounding that the city of Le Mans in France recieved shortly after the Normandy invasion because it was believed to be a German stronghold that killed and maimed thousands of innocent French civilians was an act that those responsible lived to regret. -These regretful actions do occur with frightful frequency during times of conflict and struggle. 0

Page 2.

War is possibly the ultimate form of competition, politics probably and come second. And most important to keep in mind is that war is the result of the failure of politics. This is getting close to the basis of my anger toward you. Competition is a remarkable dynamic. The blessings that we have recieved as a result of it are countless.

However when a competition is concluded and the vanquished refuses to concede defeat the results disasterous. can be quite Hitler brought on millions of needless deaths and untold distruction to his country by not conceding for almost defeat a year after it was a reality. The Japanese from Guadalcanal to Iwo Jima and Okinawa could not concede and a terrible defeat price was paid in lives on both sides for this inability to recognize the conclusion of a contest. When the checkered flag falls, the gun sounds the game, end of the the photo shows the winner by a nose or the votes are counted and the winner declared then the vanquished accepts defeat and congratulates the winner. When he doesn't, then the very essence of this marvelous dynamic of competition has been violated. These o people are usually referred to as sore losers, bad sports or crybabies. You are most certainly all But in the of these. grand scheme of things it is my opinion that you are guilty of much more than that. When the smoke clears from battle and people return to a more rational state then the salvation of mankind has been his God-given ability to forgive, in victory or defeat. inability to Your respond to this basic truth is the true guage of your shallowness.

In my rather stormy life it has been my observation measure that the of our character is in direct proportion to our ability to forgive. The judgemental and viscious attitude that you are displaying in the face of defeat is in my opinion caused forces by the same that brought on the spiritual smugness that made neccessary the crucifixtion of our Lord.

The November election will soon come and go. The it will results of be of very little interest to anyone after the first of the year. Page 3. As a loving father I feel that the outcome will only be another turning point in my son's life. He has given me great joy in the past and I am grateful and proud to be his father. He is a young man of great depth, compassion, wisdom, honesty and courage. He will either go to Washington and do a fine job or stay home and continue to do productive and meaningful service. In my opinion, he wins either way. In the meantime I will accept your visciousness towards my son as a flame and fire that will only temper him into a stronger man. You have thrown down the gauntlet and another competition seems to be on. I shall replace the anger I have towards you with activity in the contest. o I will be in the district shortly and I will be attacking your viciousness, deceptiveness, deviseivness, smugness and your blatent and chronic dishonesty for precisely what they are. My son can't and won't. And I'm proud of him for that. But as for me, all the stops are out and I intend to let the r~. good people of the 43rd district know the essence of your character. May God protect you and your family as you go on your 0 misguided way. Sincerely yours,

hn C. Crean 0 ~bi~WCuweium terMs *US. ~0~UWSd

1919 huuna7lvni Awuue~ N. ;i':, Suite 30i WahWP~C2~X~

Western Reukuel Office August 9, 1983 4 2040 Santa Crux. Sit 115 OCr~ 1~q3 ~ Anaheim. CaILferu.la 92505 The Honorable Ron Packard (714) 975.0936 1207 Elm Avenue Clifernla Chabuan Carlsbad, California 92008 JeAn C. Cre~n CA.lu.m, Vuhe Beard Fleeuweedlnteeprlses Dear Congressman Packard: Frank lher~ PPwldeni Anenmeyd FenmerAvsddem& As our State's newly appointed Ames*en html... luatlaute chairman for the Business Consortium for Gifted and Talented Children, I would AEGlndAiuuties like to cordially invite you to be my ~4ineHcan Petroleum hnetleute guest at a cocktail reception at the Balboa Bay Club (Quarter Deck Room) on Budinguen InduuuiV.. Thursday, August 25, 1983 from 5:30 P.M. LAP Telephene Company to 7:30 P.M. Also during the event will C~Sn tlneuteilllhuelsNahienal5ank be a Bay cruise aboard "Prowler 76". JeAn 4 Deane Crean This event is the kickoff for the '%xcmperagren Business Consortium for the Gifted and ~4l lam H.Denier Feundeglen Talented Children in California. The guest speaker will be a board member of Ceperetlen the National Business Consortium in Flue, Ceuperatlen Washington. Our audience will consist of '~neralEleetufr giants of industry, political and Company educational leaders, as well as Hollywood ~ Oil Company celebrities. rd4umahlein. lie. HospkalCeaperaalon finwica Today we are surrounded, world-wide by growing industrial excellence and Kerr-McGee Feundatlen~ lne~ achievement. Other countries are moving Kirby Feundatien, Inc. faster and in many areas we are actually ft4~,will Lynch 4 Cempany. Ine~ suffering declines. For over a decade educati~onal quality at the secondary level Miller Teehuelegyd Communication, Corporation has been deteriorating, particularly in Mobil Foundatier~ Inc~ science and math, and especially for top Nabisco Druid,, Inc. students. Nestle This must be reversed but it cannot be Norrhrop Corporation unless the American Business Community joins PetroLewiu Cerperation with educators, parents, governors and local governments all over the country in a Phill4ps Petroleum Company coordinated effort. A'oeierd Gamble Fund Raytheon Cempany RJ. Reynolds IndusarVes. Inc. Science Manegement Corporation Turner Broadcasting United Technologies Corporation The Washington Times AA~ WoLfe Enterprgses .1 California 0 August 5, 1983 Page Two

President Ronald Reagan plans to have the business sector, rather than government, assume the role that it should have in the future direction of education. Vice-President George Bush feels so strongly in what the Consortium hopes to accomplish that he held the "National Kickoff" reception at his home in Washington, D.C. We are organizing a private sector effort in California that will engage industrial and commercial America directly with education. The reception highlights our purpose...to place California business in the forefront of the rapidly developing national consensus that quality education is essential for our country in an ever more competitive world. This is not a fund raising event! Ultimately, when the membership is expanded, revenues will be sufficient to cover on-going costs. Today, however, we face immediate start up costs which must be met if we are to develop a business network all over California. To make this a reality we have established a "Committee of 100" each of whom would be asked to donate $1,000 to become a member. This would provide the "seed money" to operate for 18 months. These monies are important but the main thrust is your personal involvement and help in our work at the local, state or federal level. 0 I cannot over-emphasize that we are now enjoying a "window of opportunity" because of the several reports that have recently criticized and recommended drastic changes in our educational system. We feel that now is the time to V move boldly and decisively in a way that will benefit business as well as education. Your attendance will only emphasize the vital role California will play in the success of the battle for better education. Sincerely,

John Crean California Chairman .0 RE THE FEDERAL ELECTION 18510K

STATE OF CALIFORNIA ) COUNTY OF SAN DIEGO ) to-wit:

JAMES 14. GAISER, being duly sworn, deposes and says: (1) That he served as Chairman of the Dinner Committee

for a fund-raising function sponsored and held under the auspices of Friends of Ron Packard on September 17, 1983, the invitations to which were reproduced and attached as exhibits to the complaints filed with the Federal Election Commission numbered 1587, MUR 1578, 1590 and 1591; (2) That Mrs. Betty 14. Buckner, a member of the Dinner Committee, was the individual responsible for the preparation of 0 the list of individuals to whom invitations to the above-

referenced function were to be mailed; (3) That Mrs. Buckner, in the course of compiling the N list of invitees, advised your deponent that she proposed to secure a mailing list of names from a professional mailing list service, utilize numerous local directories and review copies of financial reports filed by various candidates for elective office in the State of California, including the reports filed by Crean for Congress; (4) That your deponent is aware, of his own knowledge and experience (having served as treasurer for a state assemblyman), that it is a recognized and common practice in the

State of California for candidates and campaigns to secure from reports filed by candidates for state and local elective offices in accordance with the laws of the State of California, the names and addresses of contributors to such candidates and to use those V 0 0

names and addresses for the purpose of soliciting contributions, such practice not being prohibited by the laws of the State of California; (5) That, by reason of the foregoing, your deponent did

not object to the proposal of Mrs. Buckner that she proceed as described in paragraph (3) hereof; (6) That, upon information and belief, Mrs. Buckner did

gather selected names and addresses from the various sources previously stated. Such list of names and addresses did include

the names and addresses of Hale Dougherty, M.D., 9431 Hillview 0 Road, Anaheim, California 92804 and of Mrs. Judith Caruthers, 2701 Ebbtide, Corona del Mar, California 92625, complainants in MUR 1590 and MUR 1591. Said names were on the report filed by Crean for Congress. However, I do not have the information available to state whether said names were also listed in other q~. sources used by Mrs. Buckner. (7) That a total of approximately 6,300 invitations were mailed to individuals. Of this amount 47 names, constituting less than one per cent (1%) of the invitations mailed (.7469%) were mailed to individuals whose names and addresses appeared on the reports filed by Crean for Congress. None of the said 47 individuals responded by making a contribution to Friends of Ron Packard.

(8) That at the time the list of invitees was compiled and the invitations were mailed, your deponent had no knowledge of

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the fact that section 438(a) (4) of Title 2 of the United States Code provides that the names and addresses of contributors to Federal candidates contained in reports filed as required by the Federal Election Campaign Act of 1971, as amended, may not be used by any person for the purpose of soliciting contributions. IN WITNESS WHEREOF, your deponent has executed this affidavit this 18th day of November, 1983. ~ ~t' James 14. Gaiser 0 ci SWORN to before me this 18th day of November, 1983. OPPYC~AL SEAL W JOSEPH PARISI NOTARY PUBLIC - CALIFOPNIA SAN DIEGO COUNTY comm. expires FEB 21, 1986 Notary O P.0 Box 92, Carlsbad, CA 92008

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0 0 U ±F FEC

CONGRESS 07 THE UNITED STATES HOUSE OP REPRESENTATtVES WASHINGTON, D. C. 30515

RON PACKARD 43mo D.smaei~ CALSPO~NIA October 4, 1983

-4

Federal Election Commission 1325 K Street, NW -or Washington, DC 20463 @0

Attn: Kenneth A. Gross Associate General Counsel RE: IdUR 1578, 1587, 1590, etc. N Dear Mr. Gross: I have received your transmittals of September 27 and September 29 pertaining to the above referenced matters, and I have reviewed the complaints contained therein with great care. Since all arrangements concerning the mailing of invitations to N the September 17 testimonial dinner in question were handled by a committee of campaign volunteers, I have absolutely no personal knowledge of the sources of information used for the creation of o their mailing lists. I am very anxious to look into this situation and find out whether there was any inadvertent misuse of FEC reports. Please o permit me to extend an offer of full cooperation on the part of me, my staff and my campaign organization in this matter. I personally will be happy to respond to any requests for information or assistance which you or the other members of the FEC may make. The person who handled all of the list accumulation and mailing work for the September 17 event left the country for an extended vacation in Europe with her husband last week. It is my under- standing that she will return to her home in Carlsbad, California during the last week in October. While Mrs. Buckner is out of the country, I know of no way that I can gain access to the computer files which she used in setting up her mailing lists. Since the complaints referred to in your conversation with my Administrative Assistant, Clyde Romney, have not all been received, I would respectfully ask that my campaign committee be afforded the opportunity to consolidate all such complaints and make a single response thereto, and that the time for such response be Mr. Kenneth A. Gross OotQber 4, 1983 Page 2

extended until Friday, November 4, 1983, which should be approximately one week following Mrs. Buckner's return, based upon information vhich I have been able to obtain from her husband' a office. I hope that these requests present no problems. I thank you in advance for your courtesy and cooperation.

RON PACKARD Member of Congress

0 RP/cp 0

0 RON PACKARD C0NU~ESS OF THE UNITED STATES ~ USE OP REPRESENTATIVES 30Cr? PJL~jj WASHINGTON, D. C. 20515

Federal Election Commission 1325 K Street, NW Washington, DC 20463 Attn: Kenneth A. Gross Associate General Counsel

m 0.

FEDERAL ELECTION COMMISSION WASHINGTON. D.C. 20463

November 14, 1983

William L. Hardy, Treasurer Friends of Ron Packard Committee P.O. Box 1549 Carlsbad, California 92008 Re: MURs 1578, 1587, 1590 and 1591 Dear Mr. Hardy:

The Commission has merged MUR 1587, HUE 1590 and HUE 1591 0 with MUR 1578. Therefore, you may file a single response to all of the complaints filed in MURs 1578, 1587, .1590 and 1591. In the future this matter will be referred to only as MUR 1578. If you have any questions, please call Deborah Curry, the attorney assigned to this matter at (202) 523-4000. Sincerely, FEDERAL ELECTION COMMISSION WASHINGTON. D.C. 20463

November 14, 1983

The Honorable Ronald C. Packard U.S House of Representatives Washington, D.C. 20515 Re: MURs 1578, 1587, 1590 and 1591 Dear Mr. Packard: The Commission has merged k4UR 1587, MUR 1590 and MUR 1591 with MUR 1578. Therefore, you may file a single response to all of the complaints filed in MURs 1578, 1587, 1590 and 1591. In the future this matter will be referred to only as MUR 1578. If you have any questions, please call Deborah Curry, the attorney assigned to this matter at (202) 523-4000. Sincerely, Ch les N. Steele

0 Associate Gene al Counsel BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of MUR 1578 Ronald C. Packard

CERTIFICATION

I, Marjorie W. Enuons, Secretary of the Federal Election Commission, do hereby certify that on October 31, 1983, the Commission decided by a vote of 6-0 to take the following actions in MUR 1578:

1. Merge HUES 1587, 1590 and 1591 into MUR 1578.

2. Approve the letter to the respondent. as attached to the First General Counsel's Report dated October 27, 1983.

Aikens, Elliott, Harris, McDonald, McGarry ~q. Commissioners 0 and Reiche voted affirmatively in this matter.

Attest:

JLzLz&~ W. Emmons Date Marjorie Secretary of the Commission

l0-2783, 9:29 Received in Office of CommisSiOn Secretary: 10-2783, 4:00 Circulated on 48 hour tally basis: rRECEIIvED ~2C~ < ~ ~ ~ FEDERAL ELECTION COMMISSION c~ 1325 K Street, NW Washington, D.C. 20463

FIRST GENERAL COUNSEL' S REPORT 83 OCT27 A9: 29

DATE AND TIME OF TRANSMITTAL MUR ~j7~ BY OGC TO THE COMMISSION: DATE COMPLAINT RECEIVED BY Ib/.~1/P2~9:3c DATE ~+ IO~TO RESPONDENT September 27 1983 STAFF MEMBER: Deborah &rrv

COMPLAINT'S NAME: Mrs. Donna S. Crean RESPONDENT'S NAME: Ronald C. Packard RELEVANT STATUTE: 2 U.S.C. S 438(a) (4) 11 C.F.R. S 104.15 INTERNAL REPORTS CHECKED: None in' FEDERAL AGENCIES CHECKED: None SUDISARY OF ALLEGATICUS On September 12, 1983, the Office of General Counsel 0 received a signed, sworn and notarized complaint (Attachment 1 page 1-4 of attachments) from Mrs. Donna S. Crean ("hereinafter "Complainant"). Complainant alleges that Representative Ronald C. Packard (hereafter "Respondent") violated 2 U.S.C. S 438(a) (4) by copying from Commission files her name and address for the purpose of solicitation. Complainant alleges that she does not live in responent's congressional district. Complainant states that she was sent a direct mail solicitation. Complainant alleges that she actively supported and contributed to the campaign of Johnnie Crean, the republican opponent of Respondent in the 1982 Congressional election. Since Complainant has engaged in no other activity other than support of Mr. Crean, she -2-

contends that there is no other way for Respondent to have gotten her name, except through copying of Commission files. This complaint is identical to three other complaints recently filed with the Commission. (See MURs 1587, 1590 and 1591). FACTUAL AND LUBAL ANALYSIS 2 U.S.C. S 438(a) (4) makes unlawful the copying of Commission reports for the purpose of soliciting contributions or for any commercial purpose. On October 7, 1983, the Office of General Counsel received a letter from Respondent requesting an extension of time in which to answer the notification of complaint. (Attachment 2 pages 5-6 of attachments.) Respondent requests an extension of time until Friday, November 4, 1983, since the person responsible for the mailing in question is out of the country at the moment. 0 Respondent requests, in addition to an extension of time, that all complaints be consolidated so that a single response can be made. An extension of time to respond has been granted to the C!) Respondent in this matter. The Office of General Counsel will send a report to the Commission after a response to the notification of complaint has been made by Respondent. At this time, the Office of General Counsel recommends that MURs 1587, 1590 and 1591 be merged into MUR 1578. -3-

£UCOND&TICU 1. Merge MURs 1587, 1590 and 1591 into MUR 1578. 2. Approve attached letter to Respondent.

Charles N. Steele General Counsel

BY: ______Date Kenneth A. Gross Associate General Counsel Attachments 1. Complaint (pages 1-4) 2. Respondents Response (pages 5-6) 3. Letter to Respondent (page 7)

N * Ke ArrAc~N+~J: AIO: 3?

617 North Canon Drive Beverly Hills, CA 90210

Federal Elections Commission 1325 K Street NorthweSt Washington, D.C. 20463 Dear Commissioners: I would like to make a formal complaint and request for an investigation into the fund raising practices of Congressman tO Ron Packard of the 43rd Congressional District.

- I have attached a copy of a direct mail solicitation recently *sent to me at my address listed above. Although I do not reside in this congressional district, I actively supported and contributed to the campaign of Johnnie Crean, the Republican opponent of Mr. Packard in the 1982 congressional election. I understand Mr. Crean was obliced to report my name and contribution in reports filed with the House of Representatives and the Secretary of State of o California. I swear that I have engaged in no political activity, support of M. Crean, through which C Mr.other Packard than mycould reported reasonably obtain my name as a prospect for such a solicitation. I have no residence or business listing within the 43rd Congressional District. Therefore, it seems Mr. Packard's activity is in violation of Public Law 95-521, Title I, Section 104(e)(l)(D) which states, "It shall be unlawful for any person to obtain or use a report for use, directly or indirectly, in the solicitation of money for any political, charitable, or other purpose." I would appreciate your ir~xnediate attention to this K4Q

Federal Elections Commission Page Two matter. Please feel free to contact me if you need any further information. Sincerely,

Attachment cc: Mr. Johnnie R. Crean

STATE OF CALIFORNIA ) ss. COUNTY OF 4 ~ *~.J~:- )

N DONNA S. CREAN , being duly sworn, deposes and __ declares under penalty of perjury under the laws of the State of California: That ~w/she is over the age of 18 and is a resident of the State of California. That the above statements were made of ku/her own free will, without cooercion or payment of any nature or kind and that the N above statements are true and correct.

Subscribed and sworn to before me on ______, 1983.

*..~ ALAN NOKAIN j (~JA~.Z. ~ NOTARY PUBLIC - CAUFORNIA ______My ORANGE co~i~ Pub~i~ con~m. expires FED 24, 1CS

One N.A~ P'-~ 1I~h ~., I4ev~M B~h, ~. !2~6O (SEAL)

STATE OF CALIFORNIA ) ) ss. COUNTY OF

On Z4~ , l9~ before me, the undersigned, a Notary Pubfic in and for said State, personally appeared DONNA S. CREAN , personally known to me (or proved to me on the basis of satisfactory evidence) to be the person whose name is subscribed to the within instrument and acknow- ledged that he/she executed the same. WITNESS my hand and official OrPICIAL SEAL ALAN N OKAtN NOTARY PUPLIC - CALIFORNIA a ORANGE COUNTY My comm. expires FEB 24, ICSB Notary Public

SEAL) ~qpPh PA .0 . ( w - U

4% 'S U~C6 ~ I ~p~'1 XOE 0d GVI~'Y~Vd tJOU WVWSSJMOWO3 hi' j i~ I Ii's.~1j ~ iIl~I iii 1h'-4 Ii A *1

I (we) will attend the dinner with Convrwman Ron Peckerd and Ed Mew of the Sen Dieg.o Hilton Hotel on Mwion Bay on September 17.1983. D Eneiosedavu'CheCkfOt~~..~~dinflC? tickets a: £250 per couple (5125 per pmon). 0~ 0 1 we) cannot attend fAr reception, baa hew enclosed my (our) contribution of S______

P .wke ebe~ pi~vub'eeO Freads of ion Packvd ~p~ind e*tounu. pffII~0IAI~ o, si As, bugen~ sbseAs eaty. 1* eospreae eA.e*1 p4. Minwn' gouwgbwiea n ZJ.~O ~' ~a, P.000 air mined inapt,.

I m*atu ~tI be nwued .1 ----.----- ~ -

S I I 44 '~ i14~:: 4*: jj~.p~1~ i~ 2 fiji I Sr a a'- 4 I~ 4 .a a, .i '~ .1' * ~i ~ .:*I~ - - 4a S * 4 4 4 4 C,,- iit ~." ~ 4'.,. .3 * .1 ~ .4 ;ij~i:~ 4 4 .1

'U 1s 4 3 4 .etzt I (

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Thank you for s'uppl.vang us with the following anforreeteen as required for campaign reporvin, in ccordance with election jaw.

Name Spouse Residential Address 3.

Employer ______Check if seIf4mploye~.

Business AOdresi

C... Zn Occupation or Title

If seIf.emplove~. Place of Business

Pa~ to' 0' PtwnUaof R~ Par*wd. * FECI D ~WtU P0. 1.' 154C.Cav~,ba. CA9UW

- * -~-' ~ 030cr? ~I:g0

CONGRESS OP THE UNITED STATES AT 1 AC N/1i~~T HOUSE OP REPRESENTATIVES WASHINGTON, 0. C. 20515

Row PACKAnD isms Desimici. Ca.~..,.ewsA October 4, 1983 cm~

Federal Election Commission 1325 K Street, NW Washington, DC 20463 Attn: Kenneth A. Gross Associate General Counsel RE: MUR 1578, 1587, 1590, etc. Dear M. Gross: CM I have received your transmittals of September 27 and % September 29 pertaining to the above referenced matters, and i have reviewed the complaints contained therein with great care. Since all arrangements concerning the mailing of invitations to j*.. the September 17 testimonial dinner in question were handled by a committee of campaign volunteers, I have absolutely no personal ~ knowledge of the sources of information used for the creation of their mailing lists. I am very anxious to look into this situation and find out whether there was any inadvertent misuse of FEC reports. Please ~ permit me to extend an offer of full cooperation on the part of ~. me, my staff and my campaign organization in this matter. I personally will be happy to respond to any requests for information cv or assistance which you or the other members of the FEC may make. The person who handled all of the list accumulation and mailing work for the September 17 event left the country for an extended vacatiQl'1 in Europe with her husband last week. It is my under- standing that she will return to her home in Carlsbad, California during the last week in October. While Mrs. Buckner is out of the country, I know of no way that I can gain access to the computer files which she used in setting up her mailing lists. Since the complaints referred to in your conversation with my Administrative Assistant, Clyde Romney, have not all been received, I would respectfully ask that my campaign committee be afforded the opportunity to consolidate all such complaints and make a single response thereto, and that the time for such response be

- ~uI. aw~ Hr. Kenneth A. Gross October 4, 1983 Page 2

extended until Friday, November 4, 1983, which should be approximately one week following Mrs. Euckner's return, based upon information which I have been able to obtain from her husband's office. I hope that these requests present no problems. I thanic you in advance for your courtesy and cooperation.

RON PACKARD Member of Congress PP/cp

U' r~.

0 * ATTAffift1ENT2EC FEDERAL ELECTION COMMISSION WASHINGTON. D.C. 2~3

The Honorable Ronald C. Packard U.S House of Representatives Washington, D.C. 20515 Re: MURs 1578, 1587, 1590 and 1591 Dear Mr. Packard: The Commission has merged MUR 1587, MUR 1590 and MUR 1591 with MUR 1578. Therefore, you may file a single response to all CYJ of the complaints filed in HURl 1578, 1587, 1590 and 1591. In the future this matter will be referred to only as MUR 1578. Your response to the notification of complaints is due to the Federal Election Commission by November 4, 1983. If you have any questions, please call Deborah Curry, the attorney assigned to this matter at (202) 523-4000. w~. Sincerely,

Charles N. Steele o General Counsel w~4.

C., By: Kenneth A. Gross Associate General Counsel .9

FEDERAL ELECTION COMMISSION 6 WASHINGTON. D.C 20463 September 29, 1983

Hale Dougherty, M.D. 9431 Hiliview Road Anaheim, CA 92804

Dear Doctor Dougherty: This letter is to acknowledge receipt of your complaint which we received on September 26, 1983, against Congressman Ronald C. Packard and the Friends of Ron Packard Committee which alleges violations of the Federal Election Campaign laws. A staff member has been assigned to analyze your allegations. The respondents will be notified of this complaint within five days. You will be notified as soon as the Commission takes final action on your complaint. Should you have or receive any 1%. additional information in this matter, please forward office. We suggest that this information be sworn to init theto thissame manner as your original complaint. For your information, we have attached a brief description of the Commission's procedure for 0 handling complaints. If you have any questions, please contact Cheryl Thomas at (202) 523-4073. c Sincerely,

~qrn

Kenneth A. Gross" Associate. General Counsel

Enclosure j ELECTION COMMISSION ~HINCT0N, D.C. 20463 FEDERAL

September 29, 1983

CERTIFIED MAIL RETURN RECEIPT REQUESTED Mr. William L. Hardy Treasurer Friends of Ron Packard Committee P. 0. Box 1549 Carlsbad, CA 92008 Re: MUR 1590

Dear Mr. Hardy: This letter is to notify you that on September 26, 1983, the Federal Election Commission received a complaint which alleges that your committee may have violated certain sections of the N Federal Election Campaign Act of 1971, as amended ("the Act"). A copy of the complaint is enclosed. We have numbered this matter MUR 1590. Please refer to this number in all future correspondence. Under the Act, you have the opportunity to demonstrate, in writing, that no action should be taken against your committee in connection with this matter. Your response must be submitted within 15 days of receipt of this letter. If no response is received within 15 days, the Commission may take further action based on the available information. Please submit any factual or legal materials which you believe are relevant to the Commission's analysis of this matter. £~here appropriate, statements should be submitted under oath. This matter will remain confidential in accordance with 2 U.S.C. S 437g(a) (4) (B) and S 437g(a) (12) (A) unless you notify the Commission in writing that you wish the matter to be made public. 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 a statement authorizing such counsel to receive any -2-

If you have any questions, please contact Deborah Curry the attorney assigned to this matter at (202) 523-4000. For your information, we have attached a brief description of the Commission's procedure for handling complaints. Sincerely,

Charles N. Steele

cc: The Honorable Ronald C. Packard

Enclosures 1. Complaint 2. Procedures

3. Designation of Counsel Statement ~, ( FEDERAL ELECTION COMMISSION WASHINCTON. DC 20463

September 29, 1983

CERTIFIED NAIL RETURN RECEIPT REQUESTED The Honorable Ronald C. Packard U. S. House of Representatives Washington, D. C. 20515

Re: MUR 1590 Dear Congressman Packard: CM This letter is to notify you that on September 26, 1983, the Federal Election Commission received a complaint which alleges that you may have violated certain sections of the Federal Election Campaign Act of 1971, as amended ("the Act"). A copy of N the complaint is enclosed. We have numbered this matter MUR 1590. Please refer to this number in all future correspondence. Under the Act, you have the opportunity to demonstrate, in 0 writing, that no action should be taken against you in connection with this matter. Your response must be submitted within 15 days of receipt of this letter. If no response is received within 15 days, the Commission may take further action based on the available information. Please submit any factual or legal materials which you believe are relevant to the Commission's analysis of this matter. Where appropriate, statements should be submitted under oath. This matter will remain confidential in accordance with 2 U.S.C. S 437g(a) (4)(B) and S 437g(a) (12) (A) unless you notify the Commission in writing that you wish the matter to be made public. 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 a statement authorizing such counsel to receive any notifications and other communications from the Commission. 4-..'

-2-

Charles N. Steele

By Kenneth A. G6oss Associate General Counsel

r%. cc: William L. Hardy, Treasurer

Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement S SEDAX A HERez 84 MAR PIZ: ~ A pUOOKALO~EA~IaK ATYORNUTS AT LAW UUZTU fl sass omm Dmvm

S M.L3AX. VmDUA SnOB

x~m a~mAx. 53. (7033 631.1000 a. ~wnsino3 UIZX: 710421.0W6 303T2 SPARIW. 13. CAULK: um~ A. MARK oumropm March 8, 1984 zwzowmm. MOFvI~~r AM.s3A 3m. iI~W a RAIIN 91~U~' DONNA L =L~ zmuu~.~ww. * WAIUMK. Do lOgOS OP COf.R4SE~ mm- TEOXAS a. PADOIJI. JR. mcssum ~~wwam aeAmzs D. mu

Ms. Deborah Curry Office of General Counsel Federal Election Commission 1325 K Street, LV. Washington, D.C. 20463

Re: MUR~57S, -1587, 1590 and

Dear Ms. Curry: With reference to the above-captioned matters, I am sending to you herewith the affidavit of Congressman Packard, dated February 22, 1984, in which he disclaims having had any knowledge about the activities which are the subject of these 0 matters.

Enclosure 7;

FEDERAL ELECTION COMMISSION

Affidavit of Ronald Packard

DISTRICT OF COLUMBIA ) to-wit: RONALD PACKARD, being duly sworn, deposes and says: (1) That he and his principal campaign committee, Friends of Ron Packard, have been designated by the Federal Election Commission as respondents relative to certain complaints filed with the Commission on September 12, 1983, September 19, 1983, September 26, 1983 and September 30, 1983, numbered MUR 1578, MUR 1587, MUR 1590 and ?4UR 1591, respectively, bll of which relate to the solicitation of contributions in connection with a 1% fund-raising dinner sponsored by Friends of Ron Packard which was held on September 17, 1983. 0 (2) That the subject complaints allege that certain invitations to attend the fund-raising dinner sponsored by Friends of Ron Packard,~hich invitations solicited contributions to Friends of Ron Packard, were mailed to individuals whose names and addresses were copied from Federal Election Commission reports filed by Crean for Congress, the principal campaign committee of Johnnie Crean. (3) That he had no knowledge whatsoever that, for the purpose of soliciting contributions to Friends of Ron Packard, names and addresses of contributors to Crean for Congress were to

-1- be copied from Federal Election Commission reports filed b~ Crean for Congress. (4) That upon learning that the subject complaints had been filed, he immediately instructed those associated with Friends of Ron Packard, particularly those associated with the orgwnization and administration of the dinner sponsored by Friends of Ron Packard, to cooperate fully with the Federal Election Commission in resolving the issue. IN WITNESS WHEROF, your deponent has executed this

affidavit this ~ day of February, 1984. .~41~26 RONALD PACKARD N SWORN to before me this c~~- day of February, 1984. o x~.

My commission expires:' 2*i.>' '~zr

-2- FEDERAL ELECTION COMMISSION WASHI\CTONDC 20463

October 4, 1983

CERTIFIED MAIL RETURN RECEIPT REQUESTED The Honorable Ronald C. Packard U. S. House of Representatives Washington, D. C. 20515

Re: MUR 1591 Dear Congressman Packard: This letter is to notify you that on September 30, 1983, the Federal Election Commission received a complaint which alleges that you may have violated certain sections of the Federal Election Campaign Act of 1971, as amended ("the Act"). A copy of the complaint is enclosed, we have numbered this matter MUR 1591. N Please refer to this number in all future correspondence. Under the Act, you have the opportunity to demonstrate, in writing, that no action should be taken against you in connection with this matter. Your response must be submitted within 15 days of receipt of this letter. If no response is received within 15 days, the Commission may take further action based on the available information. Please submit any factual or legal materials which you tir~ believe are relevant to the Commission's analysis of this matter. Where appropriate, statements should be submitted under oath. This matter will remain confidential in accordance with 2 U.S.C. ~ 437g(a) (4)(B) and S 437g(a) (12) (A) unless you notify the Commission in writing that you wish the matter to be made public. 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 a statement authorizing such counsel to receive any notifications and other communications from the Commission. -2-

Associate General Counsel cc: William L. Hardy, Treasurer

Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of HUE 1591 Ronald C. Packard

CERTIFICATION

I, Marjorie W. Enuuons, Secretary of the Federal

Election Commission, do hereby certify that on October 31, 1983, the Commission decided by a vote of 6-0 to merge HUEs 1587, 1590 and 1591 into MUR 1578. Commissioners Aikens, Elliott, Harris, McDonald, McGarry and Reiche voted affirmatively in this matter.

Attest:

J1d~ Date ecretary of the Commission

~q. C, V

Received in Office of Commission Secretary: 10-27-83, 9:28 10-27-83, 4:00 Circulated on 48 hour tally basis: ,< .- I:t.

FEDERAL ELECTION COMMISSIONk ~ '"''~' 1325 K Street, NW Washington, D.C. 20463 ~ A9: 28

FIRST GENERAL COUNSEL'S REPORT gI 1mpJ~

DATE AND TIME OF TRANSMITTAL MUR 1591 BY OGC TO THE COMMISSION: DATE COMPLAINT RECEIVED BY /o/~7/r&.- ~ OGC September 3~ l~83 DATE OF NOTIFICkI~ION TO RESPONDENT October 4. 1983 STAFF MEMBER: Deborah Curry

COMPLAINT'S NAME: Mrs. Judith Caruthers RESPONDENT'S NAME: Ronald C. Packard RELEVANT STATUTE: 2 U.S.C. S 438(a) (4) 11 C.F.R. S 104.15 INTERNAL REPORTS CHECKED: None FEDERAL AGENCIES CHECKED: None BUDEARY OF ALLUG&TIOIIS V On September 12, 1983, the Office of General Counsel 0 V received a signed, sworn and notarized complaint (Attachment 1 page 1-4 of attachments) from Mrs. Judith Caruthers ("hereinafter V "Complainant"). Complainant alleges that Representative Ronald C. Packard (hereafter "Respondent") violated 2 U.S.C. S 438(a) (4) by copying from Commission files her name and address for the purpose of solicitation. Complainant alleges that she does not live in responent's congressional district. Complainant states that she was sent a direct mail solicitation. Complainant alleges that she actively supported and contributed to the campaign of Johnnie Crean, the republican opponent of Respondent in the 1982 Congressional election. Since Complainant has engaged in no other activity other than support of Mr. Crean, she -2-

N Friday, November 4, 1983, since the person responsible for the mailing in question is out of the country at the moment. 0 Respondent requests, in addition to an extension of time, that

all complaints be consolidated so that a single response can be C, made. An extension of time to respond has been granted to the 4v~ Respondent in this matter. The Office of General Counsel will send a report to the Commission after a response to the notification of complaint has been made by Respondent. At this time, the Office of General Counsel recommends that MURs 1587, 1590 and 1591 be merged into MUR 1578. -3-

RUCWUND&TIOU 1. Merge MURI 1587, 1590 and 1591 into MUR 1578.

Charles N. Steele General Counsel

BY: ~ Date io/;~ lo/93 Kenneth A. Gross Associate General Counsel Attachments 1. Complaint (pages 1-4) 2. Respondents Response (pages 5-6) * e ~ r~9:

Mrs. Judith Caruthers ~ a I 2701 Ebbtide Corona del lIar, CA. 92625

Federal Elections Commission 1325 K Street Northwe*t ~0 Washington, D.C. 20463 LZ Dear Commissioners: ~ would like to make a formal complaint and request for an invest.~ation into the fund raising practices of Congressman Ron Packard o~ the 43rd Congressional District. I have attached a copy of a direct mail solicitation recently sent to me at my address listed above. Although I do not reside in this congressional district, I actively supported and contributed to the campaign of Johnnie Crean, the Republican opponent of Mr. Packard in the 1982 congressional election. .1 understand Mr. Crean was obliged to N report my name and contribution in reports filed with the House of Representatives and the Secretary of State of California. 0 I swear that I have engaged in no political activity, V other than my reported support of Mr. Crean, through which Mr. Packard could reasonably obtain my name as a prospect 0 for such a solicitation. I have no residence or business V listing within the 43rd Congressional District. Therefore, it seems Mr. Packard's activity is in violation of Public Law 95-521, Title I, Section 104(e)(l)(D) which states, "It shall be unlawful for any person to obtain or use a report for use, directly or ind.irec'ty, in the solibitation of money for any political, charitc~ble, or other purpose. I would appreciate your immediate attention to this Federal Elections Commission Page Two matter. Please feel free to contact me if you need any further information. Sincerely,

Attachment cc: Mr. Johnnie R. Crean

STATE OF CALIFORNIA ) ss. COUNTY OF

JUDITH CAI~UTHERS , being d\aly sworn, deposes and declares under penalty of perjury under the laws of the State of California: That )S~/she is cver the age of 18 and is a resident of the State of California. That the above statements were made of ~K/her own free will, without cooercion or payment of any nature or kind and that the above statements are true and correct.

Subscribed and sworn to before me on $epr&'78~ G,~'7 1983.

0 * C.. L'FO~NIA

?.'y c:~.e~p~::~ JUL 23, 1925 C (SEAL)

STATE OF CALIFORNIA ) 55.

COCNTY OF ______

On gEpr~,'~eC, ~27 , l9~3, before me, the undersigned, a Notary Public in and for said State, personally appeared

JUDITH CARUTHERS , ~crcc~ll~' ~r.~:n to ~ (or proved to me on the basis of satisfactory evidence) to be the person whose name is subscribed to the within instr~xnent and acknow- ledged that he/she executed the same.

WITNESS my hand and official seal.

AL(~'AY ~ My c~. c~p~;cs JUL 23. 1935 1:CTAR( ~ CALI~OR~4IA Not - / C?:~E CVZTY (SEAL) Maclee of Cevencooka llaeee'eaAir Ilair N'. a..ra3r 4~ Oe~3L17J%~t3.9

l)lnnee (onmIlSre Air. end Airs. Janet, At. Gaiter. (:Am. IberArwe Ate. and Airs. Unite P. Cengtesmem endyou Me's. teen Roes ewuesg ~.~Aerd ~V Air. areAAirs. Suit-fl flu.t& cit cordially invite Air. and Airs flel'vl 5mg goodleod. goodfrien'L; end good eiuiertemnn.ent with lien, speriel guest linen, ary Co-Cha4emen Mr. Idrln Aleese E.mdd Reagan M..b..F M.dA.S Sr.s~en Mawr (ft&bwftw C..rrr.,..w. ire.. Serr (anusriew it' i'Arsi&wi Ce.g'r-sw-.'r Ie.eree.e..e lAd Ca..... Srnyr.w ii.ee.rd BeAr' (r.rg'rsuanq lbs I ang.w. iie..w.ADr FAeA.J. Cr.. 195) ri...i is. era en Semi-day. Septenihee 17. Srveiery 5e..rrer Ebr.s 0. lArvA E.'irr~an~ ~ ee.rb S. AACAh Anrur4lpw.w'en lien.. hra.e .5e.ereurF~..b lie..AAsg (..greanrm. JeAn at the Aeeeerhiis.w. BiN is.~ a.~ uu,.Arr.ra Ca.reuusee Al AirCeueMrsr lb. AAAm.e. Ce.ggeaneu Ii...'.. DA.Eer DUe..areiir CAuse. Sen Diego II ilton lintel Se..r.w WEt.. A. Cr.'.. (mgrnieuin. Steer, I. Di~e re.grru-.. leArn Ii A&.A, Cer'aree.nw' WIt.... F. Ube.r..rvrr Air. Jeans F. helm, Ane.rftirrrarr.. Swim, AAVm~Ar The Intevoetlenel Nflreem Cra,.reev ~.vgi ibulmrJIu.e caearr..eme JerAF Fe.up r....r~.-e. CwA..l AAwAe.d fuiIWE Uir .Iiu.... EVA. .Ijni.w 177! East Rhjislon Bury Drive 5e..' -geen-ac a.,l.en I. I ege.ewnaea lAd, Se.arew ides S.."I.V Fred t.*eeA A.,rmu'i~.ncs I we- S*U.r~g Fdr'.b..... San Diego (-..irtieem. JeAn (eeerrn-.a ieerp i.eei, I e.vrsuuu C.i- S'e.uA.rl.~i Ce.g'.u.nuuee 8.441 ,iearr Srrrelerv kenya 0. Ware Aneesbirm.. Male'S C F)were Swimw Nrr U'iiim Su.ea. SeAr Ewus MhostcorktailsE:Jllp.iii.7:Np.nu. ReptyR.WI' card enclosed Dinseer Special EmleulaucmeU

~Sing foe Aacerira A musical review produced and dieccied by Midwiil/Knolis tneedalnmenl. gee- - .~ie 4ee~~ ~

Fl 0 0 ~ Crsepeille 5*. iaeriiit' ~ ... a wj4p~~leiiWd.wJ 0- I haieererlwiJDtel ut Unreel Aiairree ~ ~m. ~ 'urgent i'er*g.Iirrfiiiet AlasA. lIarreirr' 3 ~ r~ *.-ne9 IleAtti 0 AAAAAAAAAAAAAAAAA.AAAAAAA %.~* 'On EEC DIE1555 bq I, *~ Ai. iriuilAjit. E..er.AUElYEt 3 rs it- Air e..lAi'. Se.er.leeseir o~ '3 Al' e..lAlr' Werner I fftdIi* *1l.J. lb ..e.rlAir. ie.A.rlie'.rneAe Air aedAirs iI d.DB Ii. .4.UAe.r U 3- .~. 39. .lS..iurer 5~ 4' .5 Air eee.uiAir. irae.S Air en.iAUr' NiA.eg.wA Ai..4rdir e Air eeeuiAir. lieuineei ,teeeirr~0U Sir fleer 15.5 lair 0 I fl.eeeeAr zj~ Air .rerSlie' AleA.rSaeE Air arwlAl*t. ienrAi.EUrM.a' Age Au .4rrheee fleeS, Air medAl.' EJvjr.eAi.E.u~n 0 Ar, Al' Ureeesd..eIih.ie Air. aewlAigS tIeS ASv.r..Aeeg I 9- .9 il-li~ 30 Air Mr.. Ireneher Air. amwiASe'. AeEAe..r Ate'.'.. a 3 MeAareiA Merit 0- 3 Air .eeeeiAlrs Air enellir' (ueab.,e9Ai.WI*' en I t 4' '5 Air ann Airi liereridi aegisehir SIne lieS Aie.qeA. - 9 a Air igredAir' MnAarJE Arsi fir e.elAUr.t IegIAE.eeg'Ar 6 Mi .eneiAir' J..Ael Irene', Me...rNr'i.enrie lie... ~ ~-~ 03 Air .rreiAir~ lrrErer'r' Air reef Alit Ejee~fIet.N 3 11 Air eee..iAiri feel. I ibreirr Sir an.lAir' IA*r.iie'hird Air ee.illre Arese'rUAjfr5~*~~~ ii Sege 5~ee1.r,.i 0 Sir aee.iAirt '3 Air ee.,eiAi' ..lrerlir.Se.eui. I' Air ,rgeilirt i..rrvf i~.g.r a lb Ie.u.eIeerEiei AS, ee.dSIrt i.r.S im.vli 3', AS. ..eelAl" ii 5 e.slteeeeenlh..r ii.'". ei'.i Air' Seem' Meal, Air l..l,..Il l.rA- ii.... reel Ai.t. iAu.e.ee'i Melt Air mini Air' i'.e..i i-Sr. Jr. Air a'eiAi" (Spelt M..e....-r AS' .eeeiAlr, I. Firer ieigi.erginM AS' eeeeiASr' i.erE. 5.Ameelf gg '0 Air u.nrfAir~ SArmee.cC. iMaS Air Dl.errr~eegh. I. Air (harm A lineAr, Air ..n.iAFr. ~e~.'.e.eiA Air aeeiiiri Arm live. hi-' AS' .eg.iAD:,. SeerSI- Seeuil Dine. M.gger .'.ieeuieeee WMr.re. I hareS, Air arid Air, Air aimSAD's lsew.rlr.%Sree.ivu Air aerrlAS~' I & il.eiiur.rg Iiee~ SeE burmA ,.ee.. Air AWaA.r fir, mewSAle.. Army WareAe Air anuti Airi bar, FigureS Air. eee.iAir' SuspAreNAe'r&5 Si J.erugrh Air .eeeiAir' SerwiA Air eereiAirt. Fuee'r efilAe.er' AIr. aeefAir'. Aemleen Ndwei Air. a.eelAi's MuggerS gg'e.esMs? iede'rg Air erwiAirc MerfrrrrE AU'. geereiAir.tAAreu raurAe.eAl Air erewiAi" I ii i.ae.rree.V 5' g.ee'.eSbe~ /

(32

Thank you for s*pplwng MSwith the following infomouOiI as required for campaign reporting aneccordonce with ejection ie".

Name Spouse

~.CS)OCflh3SJAOCress

C... Li Che~ if self4fllOiO',e ~iovet ______

Business Ad~TeSs

Li .uimI~

Occuoauoti or Tule

I! seif.empl0ve~. Place o~ Business

Pa~Cto' 0' ~'een0 e~ Po~Perim' * FUR D ~0 So' ~. CaflisaC.CA 9~W w

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I U_ 83Oc~1~#j!3~

CONGRESS OP IHE UNITED STATES MOUSE OP REPRESENTATIVES WASHINGTON, 0. C. 30515

4m*Da5Yft.C~CAuP~MSA October 4, 1983

--- C Federal Election Commission 1325 K Street, NW -o Washington, DC 20463 *1~ Attn: Kenneth A. Gross Associate General Counsel RE: MUR 1578, 1587, 1590, etc. Dear Mr. Gross: I have received your transmittals of September 27 and % September 29 pertaining to the above referenced matters, and I have reviewed the complaints contained therein with great care. Since all arrangements concerning the mailing of invitations to N the September 17 testimonial dinner in question were handled by a committee of campaign volunteers, I have absolutely no personal ~ knowledge of the sources of information used for the creation of their mailing lists. C, I am very anxious to look into this situation and find out whether there was any inadvertent misuse of FEC reports. Please C permit me to extend an offer of full cooperation on the part of me, my staff and my campaign organization in this matter. I personally will be happy to respond to any requests for information or assistance which you or the other members of the FEC may make. The person who handled all of the list accumulation and mailing work for the September 17 event left the country for an extended vacatiQn in Europe with her husband last week. It is my under- standing that she will return to her home in Carlsbad, California during the last week in October. While Mrs. Buckner is out of the country, I know of no way that I can gain access to the computer files which she used in setting up her mailing lists. Since the complaints referred to in your conversation with my Administrative Assistant, Clyde Romney, have not all been received, I would respectfully ask that my campaign committee be afforded the opportunity to consolidate all such complaints and make a single response thereto, and that the time for such response be

- mum a eev~, suin~ Mr. Kenneth A. Gross October 4, 1983 Page 2

extended until Friday, November 4, 1983, which should be approximately one week following Mrs. Euckner' s return, based upon information which I have been able to obtain from her husband' S office. I hope that these requests present no problems. I thank you in advance for your courtesy:~x, and cooperation. >~<

RON PACKARD Member of Congress RP/cp

~qrn 0

~qrn FEDERAL ELECTION COMMISSION WASHINGTON, D.C 20463

October 4, 1983

CERTIFIED MAIL RETURN RECEIPT REQUESTED Mr. William L. Hardy Treasurer Friends of Ron Packard Committee P. 0. Box 1549 Carlsbad, CA 92008 Re: MUR 1591 Dear Mr. Hardy: This letter is to notify you that on September 30, 1983, the Federal Election Commission received a complaint which alleges that your committee may have violated certain sections of the Federal Election Campaign Act of 1971, as amended ("the Act"). A r~. copy of the complaint is enclosed. We have numbered this matter MUR 1591. Please refer to this number in all future correspondence.

Under the Act, you have the opportunity to demonstrate, in writing, that no action should be taken against your committee in connection with this matter. Your response must be submitted within 15 days of receipt of this letter. If no response is received within 15 days, the Commission may take further action based on the available information. Please submit any factual or legal materials which you believe are relevant to the Commission's analysis of this matter. Where appropriate, statements should be submitted under oath. This matter will remain confidential in accordance with 2 U.S.C. S 437g(a)(4)(B) and S 437g(a)(12)(A) unless you notify the Commission in writing that you wish the matter to be made public. 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 a statement authorizing such counsel to receive any notifications and other communications from the Commission. -2-

Sincerely,

By Kenneth A. Grosf Associate General Counsel cc: The Honorable Ronald C. Packard

Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement I FEDERAL ELECTION COMMISSION WASHINCTON, DC. 20463

October 4, 1983

Mrs. Judith Caruthers 2701 Ebbtide Corona del Mar, CA 92625 Dear Mrs. Caruthers: This letter is to acknowledge receipt of your complaint which we received on September 30, 1983, against Congressman Ronald C. Packard and the Friends of Ron Packard Committee which alleges violations of the Federal Election Campaign laws. A staff member has been assigned to analyze your allegations. The respondents will be notified of this complaint within five days. You will be notified as soon as the Commission takes final action on your complaint. Should you have or receive any additional information in this matter, please forward it to this office. We suggest that this information be sworn to in the same N manner as your original complaint. For your information, we have attached a brief description of the Commission's procedure for handling complaints. If you have any questions, please contact o Cheryl Thomas at (202) 523-4073. Sincerely, C, Charles N. Steele Gen Counsel EY~

By Kenneth A. Associate General Counsel

Enclosure . t~EE FEC ~3SEP3O A9:52

Mrs. Judith Caruthers 2701 Ebbtide Corona del Mar, CA. 92625

-o Federal Elections Commission 41325 K Street Northwe*t Weshington, D.C. 20463 Dear Commissioners: I would like to make a formal complaint and request for

- a~ investigation into the fund raising practices of Congressman Ro~ Packard of the 43rd Congressional District. ~0 I have attached a copy of a direct mail solicitation recently sent to me at my address listed above. Although I do not reside in this congressional district, I actively supported and contributed to the campaign of Johnnie Crean, the Republican opponent of Mr. Packard in the 1982 congressional election. I understand Mr. Crean was obliged to report my name and contribution in reports filed with the House of Representatives and the Secretary of State of California. 0 I swear that I have engaged in no political activity, other than my reported support of Mr. Crean, through which Mr. Packard could reasonably obtain my name as a prospect for such a solicitation. I have no residence or business listing within the 43rd Congressional District. ~herefore, it seems Mr. Packard's activity is in violation of Public Law 95-521, Title I, Section 104(e) (1)(D) which states, "It shall be unlawful for any person to obtain or use a report for use, directly or indirectly, in the solicitation of money for any political, charitable, or other p~urpose." I would appreciate your immediate attention to this Federal Elections Commission Page Two matter. Please feel free to contact me if you need any further information.

Attachment cc: Mr. Johnnie R. Crean

STATE OF CALIFORNIA ) ss. COUNTY OF

N JUDITH CARUTHERS , being duly sworn, deposes and declares under penalty of perjury under the laws of the State of California: That Ks/she is over the age of 18 and is a resident of the State of California. That the above statements were made of ~5/her own free will, without pd~ cooercion or payment of any nature or kind and that the above statements are true and correct. N Subscribed and sworn to before me on .SEp7vj.,a~,e .~'7 1983.

C, ~ GPAYSEAL NOTARI' ~UDtjC - CALIFORNIA ~ O2'~GE cc~u;iiy ~ My comm. expires JUL 23, 1985 C, (SEAL)

STATE OF CALIFORNIA ) ss. COUNTY OF O~AA/Q.~? )

On $7epre,&~aeA ..~7 , 19f3, before me, the undersigned, a Notary Public in and for said ~Eate, personally appeared JUDITH CARUTHERS , ycrccr~lly known to me (or proved to me on the basis of satisfactory evidence) to be the person whose name is subscribed to the within instrument and acknow- ledged that he/she executed the same.

WITNESS my hand and official seal.

~'T' \1, rr~Ay - CALIRORNIA 49Not y Pu ic

~ My Comm. e~pies JUL 23, 1985 (SEAL) Master ol ~erensonies3 I Itanarable Clue W. Uurgener r Dinner Conuniliec Mr. and Mrs. James M. Ga~ser~Chin. Mr. and Mrs. Bruce D. Buckner Cengressnuan and Mrs~ Rem Packard Mr. and Mrs. Russell BarkeR cordially invite you to an evening of Mr. and Mrs. DeIjel Kunz good food. good friends. and good enierlaannrent their spedei guest Honorary CoChairmnen with Mr. Edwin Meeu Req.. Coqraumn SaheCE. Uwihus', Sturiar Bony Gssidseoue Caqresssm.iCas'sgrussw anFrau Lasusry Lots Cssunsetar to President Ro.meM Doter Can.restm.u Phil Grit., SenatorHoward J. Gray Co.arnsaus Lb. Lursareu Tweetit. Intl Howoisie Edmeiu Saturday. September 17. 1983 Secretary Snutor Con, G. lietch Cav4resswin Carat. Marl on AsSnmblyuOnieAMarlin Dwgeuui knusar hut. liowhiu* Ceqrmss'sm JohnS. hieCuAs at the Mumh~sasuaBIB Dra*y £i.,or Regar ik*rcarh Caqrinma At A*CummEus Saws.' Wilt... C.mheM Duiirin HUNt., iiouonohk cwo. lb. Atrkmo. San Diego Hilton Hotel A. Craw. Co.gnassuso. SenatorWililiss, Cangeenue.. tinuy I Hy~ Cas'r nakrt H. Aekhd CaaaeesssrsauWi~ 5. lb.onmeswe E. Jeabus Anamhiywasvua S..., Ms'sia..ier The Internetiond Baflrooni lbuAsuejiit Mr. luau Gore'..' George Caqrwum ~* F.keu~ Cauar.. ConiesJ. Mawbud Bay Drive Seratar Raket Oat. Cangr.uss~ Rakes J. Lqmmwuu. Strat.' ~varmw 177S East Minion SenatorJon Elts Saws.' hid Le.t* San Diego CossgrauuwAjohn Ednborsm Csusaerssm..JErry Lewis C.qressmmwGuy Ibs~~t coaarm~ Botot Sawtony Mum G. Writ Assesnblyim Debars C Frawe Sm...' PeteWits.. Senator lit. Con. RSVP No host co*taib6:Np.m. 0 card enclosed Dinner 7:M Special Entertaiumenl Reply Singfor Anaeulca~ A musical review produced and directed by MIcheill/Knolls Enieutalnmeal.

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.1441 o 0 0 (oqualle Si. Jacques Salade Waldorf ii ~ (hairasebridnd tie Boris! Mactitle ~1 Sauce Perigourdmne I Ii th Baked ,lla;ka Flinsale - o hAll *1*1 ** (I) hOStS Air. and Mrs. bordsin lure K Air usiit Airs. IamnrAsone Airt H amer I usards II I Mr and asisiAirs bun Atisasiilar a Its' Air end Airs. i)onssid N. hA Arthur and Airs. grant .Iteshurr At, tie and Air' Wuii.issiiN. Mi Anie II At. asialAirs itssisertI ,Inslreson lie. Nay Mi Claw C aba At. ansi Airs. No AssIsts Mr and At's lone AisCieiistui At. .4rtIiar u.n. hr. Air. and Mrs Glenn hisS ssesssss ii .ilr Itrantisen tisrti her Air. andAirs. (AsiA Airnsshasg At' Rassihisrieher Air, and Airs Anthons Aissaso Ii 2 S hard A Burt ~ ansiAirs Ru .1 Air Air and Airs. (orison Moms II Air isgisiAirs. itarsilsit ar~sintCr ltsin. lack Aiuniihr 13 (hisS Air ansiAirs Roharal hr asid A5rs. lass Aturphy it0 'I Airs hAn I (osnin 'sir ansi thin. itrus eNestande ~ Psi~ ansiAirs lens Cusrtss At, ansIAirs Cusstissen Mn and Airs John I. ihailer anilhir llssrdi'stihO'd lie. ~ Air ansiAirs Aenneth L%(;rsssat tie unit isle' ii. Ian l'ssskarsi At, and Airs .lrsr iseissna.Jr Air and Airs louses i~. Pipe lie isssssSunsin r Air. and Airs hi A Psieett At' and Airs ii. S eashnianlisw lion. saulAirs lan~s Rude I I Air loAn W Earle lion and Airs. ihisnias I Rile, Jr Air asisi Airs. Paul lake. Air and At,' St jde Riisnney Mr and Airs 1. l.arrr Eddiasploas Air ansiAirs. losseest. 'a hniidt Ut A I At, ansiMrs lhonsoi C Ellis Air. harry 5mph. Jr ~. a Air (liartes K. Fletcher Mr. ansiAirs. tory Saisath Mrs Kssnhlets her U Air aissl Air and A9;s. Josh F. Smith At, ansiAts Robert G. 11.11 m ham. RsszrrStanton itsihsassnI ilarsty Air and Airs Air ansiAir.s lsssssthr 'strasler Air and Airs S F. iiedbssrse hiss' 1.1 'driishsnw tSr.usssh Airs I ,eskna A iluisar Air hashHailer R huff At. and Airs hansel lie ansiAirs. ReuseSlarsiess Air a.isl Airs Gary hunt Air, and Airs .Sar,,hrn SIAreler At, and Air.s JasseishIt. jassuds Mr. and Airs. Knee tt'ihliams At Asahi Air issnalsi Air and At,.. Andrew Wilson lie. i)oi, llssieseAuss Air. and Aims.Ruger .5. St'sssslley (~. I asisuip Air. and Mrs. Rsshert Air, and Air.s Alien yosuisssshi florence Air. and Airs S. It I 5 55 r'sis5sshut I. em

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2lanA you ~or suppiving us with the following information as required or cam pauRn reporting in accordance with election law

\ame Spouse

kesidential Address -

:nn~oser ______Check if self.eIUpIOYC(±.

~5u'iflCS *5~ddress

)~cUPdtIOfl or title

cit cmpiosed. Place ot Business ______

'220 FrienaZ if RUr Packard' * FEC I D ~I93?4.5 P) 805 if 4~. Carlsbad. CA 92008

U_ 4~ 'V .4 If~ ~u '~

Fedex~a1 Elections Commission 0 1325 K Street Northwest Washington, DC. 20463 C, 'q. SEDAAM a HERGE ~4MAR P~:~ APOWUOKALCO.ATUO., ATT~mquys AT LLW - aim sass xuinmouo DRRY3 M~L3AX. V~UgI& 33163 -C

oz~uw 5. AM. 53. (705) .31.1000 5. OUUT 33~3 TELEX: 71@451Om OS? 3. WAR, 53. A. MARX oinm~Pm March 8, 1984 inro~uin a MOWITI mAMmo3b~ P~W 3. 3AN3 y~u isa.' DONWA L uzm urn uy~rm.ui~ WA@TUI. D4 NEws OP COUNSEl. THOMAS 5. FADOUI~ JR. mgsm~t PARTNER: CHARLES D. NEW

Ms. Deborah Curry Office of General Counsel Federal Election Commission 1325 K Street, LW. Washington, D.C. 20463

Re: MUR 1578, 1587, 1590 and 1591 Dear Ms. Curry: With reference to the above-captioned matters, I am N sending to you herewith the affidavit of Congressman Packard, dated February 22, 1984, in which he disclaims having had any knowledge about the activities which are the subject of these 0 matters.

Enclosure *

FEDERAL ELECTION COIO(ISSION

Affidavit of Ronald Packard

DISTRICT OF COLUMBIA ) to-wit:

- RONALD PACKARD, being duly sworn, deposes and says: (1) That he and his principal campaign committee, Friends of Ron Packard, have been designated by the Federal Election Commission as respondents relative to certain complaints filed with the Commission on September 12, 1983, September 19, CA 1983, September 26, 1983 and September 30, 1983, nwubered MUR 1578, MUR 1587, MUR 1590 and MUR 1591, respectively, ~all of which relate to the solicitation of contributions in connection with a fund-raising dinner sponsored by Friends of Ron Packard which was held on September 17, 1983. C, (2) That the subject complaints allege that certain invitations to attend the fund-raising dinner sponsored by Friends of Ron Packard,~,hich invitations solicited contributions to Friends of Ron Packard, were mailed to individuals whose names and addresses were copied from Federal Election Commission reports filed by Crean for Congress, the principal campaign committee of Johnnie Crean. (3) That he had no knowledge whatsoever that, for the purpose of soliciting contributions to Friends of Ron Packard, names and addresses of contributors to Crean for Congress were to

-1- 0

be copied from Federal Election Commission reports filed b~y Crean for Congress. (4) That upon learning that the subject complaints had been filed, he immediately instructed those associated with Friends of Ron Packard, particularly those associated with the organization and administration of the dinner sponsored by Friends of Ron Packard, to cooperate fully with the federal Election Commission in resolving the issue. IN WITNESS WHEROF, your deponent has executed this

affidavit this ~ day of February, 1984. I,

RONALD PACKARD

SWORN to before me this c~- day of February, 1984.

0 ~1A~

My commission expires: 3o# j~9'

-2- U TI.~Er~r~ w S3OCTI ~I: 10

CONGRESS 07 THE UNITED STATES HOUSE OP REPRESENTATIVES WASHINGTON, 0. C. 30515

RON PACKARD 43mm Destm.cY~ CAUPOUNSA October 4, 1983 Ch)~

-6

Federal Election Commission .0 1325 K Street, NW Washington, DC 20463 Attn: Kenneth A. Gross Associate General Counsel

RE: MUR 1578, 1587, 1590, etc. q~. Dear Mr. Gross: In I have received your transmittals of September 27 and September 29 pertaining to the above referenced matters, and I have reviewed the complaints contained therein with great care. Since all arrangements concerning the mailing of invitations to N the September 17 testimonial dinner in question were handled by a cQmmittee of campaign volunteers, I have absolutely no personal knowledge of the sources of information used for the creation of their mailing lists. I am very anxious to look into this situation and find out whether there was any inadvertent misuse of FEC reports. Please permit me to extend an offer of full cooperation on the part of me, my staff and my campaign organization in this matter. I personally will be happy to respond to any requests for information rn or assistance which you or the other members of the FEC may make. The person who handled all of the list accumulation and mailing work for the September 17 event left the country for an extended vacation in Europe with her husband last week. It is my under- standing that she will return to her home in Carlsbad, California during the last week in October. While Mrs. Buckner is out of the country, I know of no way that I can gain access to the computer files which she used in setting up her mailing lists. Since the complaints referred to in your conversation with my Administrative Assistant, Clyde Romney, have not all been received, I would respectfully ask that my campaign committee be afforded the opportunity to consolidate all such complaints and make a single response thereto, and that the time for such response be Mr. I~enneth A. Gross October 4, 1983 Page 2

extended until Friday, November 4, 1983 which should be approximately one week following Mrs. Buckner s return, based upon information which I have been able to obtain from her husband's office. I hope that these requests present no problems. I thank you in advance for your courtesy and cooperation. ~;)~< :~,RON PACKARD Member of Congress EP/cp

Lfl

0 q BEFORE THE FEDERAL ELECTION COMMISS 1011

In the Matter of MUR 1590 Ronald C. Packard

CERTIFICATION

I, Marjorie W. Emmons, Secretary of the Federal Election Commission, do hereby certify that on October 31, 1983, the Commission decided by a vote of 6-0 to merge MURs 1587, 1590 and 1591 into MUR 1578. Commissioners Aikens, Elliott, Harris, McDonald, McGarry and Reiche voted affirmatively in this matter. V)

Attest:

~LLzL~- Date ecretary of the Commission

Received in Office of Commission Secretary: 10-27-83, 9:28 Circulated on 48 hour tally basis: 10-27-83, 4:00 0 ~,I.

FEDERAL ELECTION COMMISSION r ~ ~i ~«TARY 1325 K Street, NW Washington, D.C. 20463 fl30C12? AS: Z8

FIRST GENERAL COUNSEL'S REPORT

DATE AND TIME OF TRANSMITTAL MUR j~j~ BY OGC TO THE COZ5MISS ION: DATE LAINT RECEIVED BY

p11/ - ~ FICA*IO~ TO RESPONDENT !~ffi~gr29l8 STAFF MEMBEftii~~u~~j

COMPLAINT'S NAME: Mr. Hale Dougherty RESPONDENT'S NAME: Ronald C. Packard RELEVANT STATUTE: 2 U.S.C. S 438(a) (4) fV) 11 C.F.R. S 104.15 INTERNAL REPORTS CHECKED: None FEDERAL AGENCIES CHECKED: None SUDISARY OF ALLUGATIOUS

On September 12, 1983, the Office of General Counsel received a signed, sworn and notarized complaint (Attachment 1

page 1-4 of attachments) from Mr. Hale Dougherty ("hereinafter "Complainant"). Complainant alleges that Representative Ronald C. Packard (hereafter "Respondent") violated 2 U.S.C.

S 438(a) (4) by copying from Commission files his name and address for the purpose of solicitation. Complainant alleges that he does not live in responent's congressional district. Complainant states that he was sent a direct mail solicitation. Complainant alleges that he actively supported and contributed to the campaign of Johnnie Crean, the republican opponent of Respondent in the 1982 Congressional election. Since Complainant has engaged in no other activity other than support of Mr. Crean, he 0 0

-2-

contends that there is no other way for Respondent to have gotten his name, except through copying of Commission files. This complaint is identical to three other complaints recently filed with the Commission. (See MURs 1578, 1587 and 1591). FACTUAL AND LUGAL ANALYSIS 2 U.S.C. S 438(a) (4) makes unlawful the copying of Commission reports for the purpose of soliciting contributions or for any commercial purpose. On October 7, 1983, the Office of General Counsel received a letter from Respondent requesting an extension of time in which

IrE, 'N to answer the notification of complaint. (Attachment 2 pages 5-6 of attachments.) Respondent requests an extension of time until N Friday, November 4, 1983, since the person responsible for the mailing in question is out of the country at the moment. 0 Respondent requests, in addition to an extension of time, that

all complaints be consolidated so that a single response can be C, made. An extension of time to respond has been granted to the Respondent in this matter. The Office of General Counsel will send a report to the Commission after a response to the notification of complaint has been made by Respondent. At this time, the Office of General Counsel recommends that MURs 1587, 1590 and 1591 be merged into MUR 1578. -3-

RUCOIUUND&TIOU 1. Merge blURs 1587, 1590 and 1591 into MUR 1578.

Charles N. Steele General Counsel

/o(~/ ~3 BY: 4~tOL. jJAjs~O Date Kenneth A. Gross Associate General Counsel Attachments 1. Complaint (pages 1-4) 2. Respondents Response (pages 5-6)

N * .k.

Hale Dougherty, 1.1* D. 0' 9431 Huliview Road Anaheim, CA 92804 1

Federal Elections Commission 1325 I~ Street Northwest Washington1 D.C. 20463 Dear Commissioners: I would like to make a formal complaint and request ~pr an investigation into the fund raising practices of Cong~sman Ron Packard of the 43rd Congressional District. I have attached a copy of a direct mail solicitation recently sent to me at my address listed above. Although I do not reside ~n :n~s congressional district, I active> supported and contributed to the campaign of Johnnie Crean, t~e Republican opponent of Mr. Pac.~arc ~n the 1982 congres- N sional election. I understand Mr. Crean was obliced to re~or:my name and contribution in re~cr:s filed with the *.ouse of Representatives and the Secre:ar~ of State of 0 California. I swear tnat I have engaged in no political activity, other than my reported support of Mr. Crean, through which Mr. Packard could reasonably obtain my name as a prospect for ~ch a SO~iOitdL.L~)L1. I h~v~ ~io o~. ~ listing within the 43rd Congressional District. Therefore, it seems Mr. Packard's activity is in violation of Public Law 95-521, Title I, Section 104(e)(l)(D) which states, "It shall be unlawful for any per son to obtain or use a report for use, directly or ~.ncirect1y, in the solicitation of money for any political, charitable, or other purpose." I would appreciate your immediate attention to this Federal Elections Commission Page Two matter. Please feel free to contact me if you need any further information. ~

Attachment cc: Mr. Johnnie R. Crean

STATE OF CALIFORNIA ) ss. COUNTY OF

HALE DOUGHERTY, M.D. , being duly sworn, deposes and declares under penalty of perjury under the laws of the State of California: That he/V~W is over the age of 18 and is a resident of the State of California. That the above statements were made of his/har own free will., without cooercion or payment of any nature or kind and that the above statements are true and correct.

Subscribed and sworn to before me on ______, 1983. 0 ~~~1C1AL SEAL *IA?!'~ LYNNE KRIEGER ~ ~ota~y Public *' t~c'~'~ ~" . C&UFORNIA I

My c-"n'. exp Cs1.AY 24, 1~Z3 -- -. - .

STATE OF CALIFORNIA ) )

COUNTY OF ~

On ~ , l9~. before me, the undersigned, a Notary Public in and for said State, personally appeared HALE DOUGHERTY, M.D. , personally known to me (or provec to ~ie on the basis of satisfactory evidence) to be the person whose name is subscribed to the within instrument and acknow- ledged that he/she executed the same. WITNESS my hand and official seal.

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- - ~.~y-9'~ ~ 1:10 CONGRESS OF THE UNITED STATES c~iiII~tc. MOUSE OF REPRESENTATIVES WASHINGTON 0 C. 20515

RON PACKARb ~/4Ic~4.c4i4...4~..o*{5f c~- ibm. DtUYSeCY. CAUP.RWSA October 4, 1983 0

- Federal Election Commission 3.325 K Street, NW

Washington, DC 20463 ::~*. ~'.

Attn: Kenneth A. Gross -~ r Associate General Counsel RE: MUR 1578, 1587, 1590, etc. Dear Mr. Gross: I have received your transmittals of September 27 and September 29 pertaining to the above referenced matters, and I have reviewed the complaints contained therein with great care. Since all arrangements concerning the mailing of invitations to N the September 17 testimonial dinner in question were handled by a committee of campaign volunteers, I have absolutely no personal ~ knowledge of the sources of information used for the creation of o their mailing lists. I am very anxious to look into this situation and find out whether there was any inadvertent misuse of FEC reports. Please ~ permit me to extend an offer of full cooperation on the part of ~. me, my staff and my campaign organization in this matter. I personally will be happy to respond to any requests for information ~ or assistance which you or the other members of the FEC may make. The person who handled all of the list accumulation and mailing work for the September 17 event left the country for an extended vacatiQn in Europe with her husband last week. It is my under- * standing that she will return to her home in Carlsbad, California during the last week in October. While Mrs. Buckner is out * of the country, I know of no way that I can gain access to the computer files which she used in setting up her mailing lists. Since the complaints referred to in your conversation with my Administrative Assistant, Clyde Romney, have not all been received, I would respectfully ask that my campaign committee be afforded the opportunity to consolidate all such complaints and make a single response thereto, and that the time for such response be

p., p.AU aw~ .9. Mr. Kenneth A. Gross October 4, 1983 Page 2

extended until Friday, November 4, 1983, which should be approximately one week following Mrs. 3uckner' a return, based upon information which I have been able to obtain from her husband's office.

I hope that these requests present no problems. I thank you in advance for your courtesy and cooperation.

RON PACKARD Member of Congress EP/cp .1#)

N * 6:' k1# EFEC

Hale Dougiierty, I1.D. 9431 Huliview Road Anaheim, CA 92804

Federal Elections Commission m 1325 K Street Northwest Washington, D.C. 20463 Dear Commissioners:

I would like to make a formal complaint and request~~r an investigation into the fund raising practices of Cong~ssma~n Ron Packard of the 43rd Congressional District.

I have attached a copy of a direct mail solicitation recently sent to me at my address listed above. Although I do not reside in this congressional district, I actively supported and contributed to the campaign of Johnnie Crean, the Republican opponent of Mr. Packard in the 1982 congres- N sional election. I understand Mr. Crean was obliged to report my name and contribution in reports filed with the House of Representatives and the Secretary of State of California. I swear that I have engaged in no political activity, other than my reported support of Mr. Crean, through which Mr. Packard could reasonably obtain my name as a prospect fuL bLLCh a SOljCiLdLLUII. I h~v~ dO L~ Ut~ii~ oi. listing within the 43rd Congressional District. Therefore, it seems Mr. Packard's activity is in violation of Public Law 95-521, Title I, Section 104(e) (1)CD) which states, "It shall be unlawful for any person to obtain or use a report for use, directly or indirectly, in the solicitation of money for any political, charitable, or other purpose."

I would appreciate your immediate attention to this Federal Elections Commission Page Two matter. Please feel free to contact me if you need any further information.

DOU~E~Yj M.D.

Attachment cc: Mr. Johnnie R. Crean

STATE OF CALIFORNIA ) ss. COUNTY OF

HALE DOUGHERTY, M.D. , being duly sworn, deposes and declares under penalty of perjury under the laws of the State of California: That he/~W is over the age of 18 and is a resident of the State of California. That the above statements were made of his/bar own free will, without cooercion or payment of any nature or kind and that the above statements are true and correct. N

Subscribed and sworn to before me on ~ , 1983. U- 7~r~id1AL SEAL JAN'S I.YNNE KRIEGER ~uri'C - CALIFORNIA ota Pu ic O'~ANG COUNTY My c:n~m. exp:es MAY 24, 198~j

STATE OF CALIFORNIA ) ss. COUNTY OF ~

On % ~ 2a. , l9~, before me, the undersigned, a Notary Pu~blic in and for said State, personally appeared HALE DOUGHERTY, M.D. , personally known to me (or proved to me on the basis of satisfactory evidence) to be the person whose name is subscribed to the within instrument and acknow- ledged that he/she executed the same.

WITNESS my hand and official seal.

2~ JA~~flS LYNN~ KPIEGE!~ Ct ~ ~1AALcA~~ NO'h4~ Pur C - CrIiFOi~NA ORANC~ COIJTI'y My c~r"rn ~ ~ 24. 19~5

- Master of CeremnoasiesJ A143 7~./ Itanarable ClaIr W. Bargener Dinner Committee Mr. and Mrs. James U. Gaiw. CAns. Mr. and Mrs. Bruce D. Buckner Congressman and Mrs~ Ron Packard Mr. and Mrs. Russell Burkeil cordially invite you to an evening of Mr. and Mrs. DeViri kunz good food, good friends, and good entertainment Honorary Co-Chairmen with their special guest Mr. Edwin P.fene CangressnuenAdmirE C DadA". Senator8w, Gaidwaler CongressmanTrial Lell Senalorliaword Baker CangressaanPhIl Grimm Congrmsm., eel Louvey Couriselar Ia PiesWeal Rsmaid Reqaiu Sera'eteryTwit It &a lianarebJe EdwinI. Grey Coagressm.i DenLeaqren Germ0. ilelcIc ConnieMark Auembiywamen *~uen Beqesan Senator Congeassanen on Saturday, Septenuber 17, 1983 Senatorhad. H.wkms Congressmanlola S MrC.1, Assemhlynw.sDiM badey at the SeniOr WIDIm.cenqpl.1 Mayer Rogeriledgecork cengomnen Al A*C~ SenatorWiMim. A. crave, Canaresam Dime., Hunlie lmonerektr~tan ~ AleKlein San Diego Hilton Hotel Cangrtum.i Wilt.. E. Deenenuesvr CongressmenHenry I Hyde congresmin ReSeatH. MA*II Governor GeorgeDeulmuim herleases E Jenkins Assenbiymmcin ~y Moj.mstn' The Internetlorid Baiboon, Senelar RaIny Dole Cer4rwmea Jerk F Een~ Congreumen CinieeI. Ato.r~ SenatorJim Ellis CangresmmsRaIny I. Lqaawsmo Senatorline - 1775 East Mission Bay Drive cangressan.enlaIn &lrnbmm Senatorhad IAmb - Lwy Sdehg Cangreuwomen hilt F~ Ca.gresseniaJerry Lenin CongressmenGuyVenderJql San Diego AssemblymenRobert C. Pewe SeesatoryAmes G. Wen Smiler Jul. Gun, Stager PeteWMum RSVP No hast cocktails 6:30 p.nu. Spedal Entertainment Reply card enclosed Dinner ?:30p.m. ~Sing for Anseric." A musical review produced and directed by Mlchetel/Knos Enaertalameut.

Ni pi.ui - .dIatC tb.e,~ ue

0 0 (oqelille SI. Jacques Salade Waldorf (haieaubriafld de Born! Matinee Id Sauce I'erugourdine IlL Baked Alaska 1:lanhre' I -. 2 hA ***AA* 0**~ -4 3, S Ii Air, and Airs. Gordon haag Air aradAirs. lonrAsone usarde * I s-I. lit arid Airs bun ,tirsandrr Air and Airs. Ii'arnrr I I a Air anti Airs, trunk .4ir'durr Air. end Airs. i)sanaid R. At. Arthur a 0 Millie.. A. kicAreile Air cecilAirs. Rohert I ,tnderson Air andAirs I Ray AIlf.laee Air aeri~hAirs. Na. AaiasC. Banehe ik. Ii Air ,trtiaearBerg. her Mr and Airs. lever Ak('frllan ii Air. and Airs. Glean Aua'Ctueaas Air lirandcen Bert. her Mr. and ('hick Liensching 0 Air RecriBartahe' Airs * ui~ a Air and Airs Rn hard A. Burl Air. and Mrs. Anlhan, Ainaso end Airs. (boison Morris a Air and Airs Ilareeld I 'arpenler Air, 0* Murihr Air and Airs Rah.ard ('link lion Dick ii lie', and Airs EastAlcerphy tie and Airs John I (100.0 ii0 Air analAirs I'ern ('urlas lIon. Brute Nrstandr Air end Airs GusOwen Air analAirs John 1 (leader lard Air and Airs Arnnrlh lieGrenel lie'. and Airs. lt,,vai Pan Ii anti Airs Are. Irriant. Jr it, unit Airs ii *~en i'ankaeei iii Air and Airs. mines I i'icpr I lie I circaI careen Air Airs len APowell a Ij Airs Ii. C caslirnan O.c.r Air and Air cnn lion, and Airs JaneesReds' I. Air ledin It' Earle 3 hang,and Airs lhaineasl Ail~s' 3 Air cecil Airs Paul t. Ar. Jr Air, and Airs ('bite Rienaney Air and Airs 1'. i arre Eddan~laiii ii Air, and Airs. Jurors C Achneidi Air urcd Airs Thomas C. Ella. k Air. harry .5engh.Jr. Air Charies A'. Flriahrr Saulh Air aearlAirs Ku. hielaher Mr and Airs. Gory and Airs. Jerk F Smith Air ann Airs Raa.'iret G. lieu Air Ata cmi Airs 0,11mm I. liaraic' lion. Ro~rr ratanlon Airs lunecthr .%iraulrr Air and Airs I F. lirsIhucra Air and Siruik sane tie. aendAirs. lreitrra.k flume lion. Ed Air. cajatiAirs. itanarik. huff Air. Boic Hhkr Air arid Airs Gary IlunI lIe and Airs Bruce Warden Ate,and Airs SteehenStArrier Air anal Airs Jaisepli II Iceecale Air and Airs KnowWdiaumns Air Itoneald At. A'eeli I*ihsc.ra 1k lheelliereekaio Air. andAirs. Aadrrsr Air. end Airs. Augar S M'oealhey Air and Airs Racherlt. laedra'ep Airs. Allen Vasukoshi Air ann Airs C II l.acrrrna'e Air and

1waiculkay F- -

ThanA vvzj for eupplving us with the following information as required

r campoien reportine in accordance with eleciton law

\,srne Spouse

Residential Address ~

2.1*

- -______Check if self.emploved.

husines~ Address -

c~.ition c~r Title ______

c' ernt'i'sed, Place ot Business ______

Ron PacAa~d" a FECI D R5Q37~ P (1 Ban 549.Carlsbad. CA 92008 ~ PtA *19\~ z

Feder~1 Elections ConmLission 1325 K 8t~eet No~thwest Washington, D.C. 20463 V a, .AfVr~s SEDAJ~ a HuaGE 84t4ARtt PIZ:~Z A PUUU.aLcomrn*IIpK ATYO3XUTs AT LAW UZTU nO. SSOO BRUUIISDOUODKYU McLEAN. VWGauZA iOS

oimsKE 5. UDAM. 53. ThWX: ?t043146 5. CUETIB ma. NODEET ~ SPAUNN 53. CAU~HU~I A. MARK oinwrovm March 8, 1984 mwz'opi a.xowiwr inAW.. a a*mu WE-,' DONNA L m lmEvwrmwI.aw. WATOK.D~ 50065 OF COUNSEL mm- FEOMAS 5. VADUIJL 53. NESIOINT PARIN cMAZS D. mm

Ms. Deborah Curry Office of General Counsel Federal Election Commission 1325 K Street, N.W. Washington, D.C. 20463 / Re: MUR 1578, 1587, 1590 and 1591 Dear Ms. Curry: 9' With reference to the above-captioned matters, I am sending to you herewith the affidavit of Congressman Packard, dated February 22, 1984, in which he disclaims having had any knowledge about the activities which are the subject of these 0 matters. SincJhI/

Curtis Her Enclosure FEDERAL ELECTION CONKISS ION

Affidavit of Ronald Packard

DISTRICT OF COLUMBIA ) to-wit: RONALD PACKARD, being duly sworn, deposes and says: (1) That he and his principal campaign cojimittee, Friends of Ron Packard, have been designated by the Federal Election Commission as respondents relative to certain complaints filed with the Commission on September 12, 1983, September 19, 1983, September 26, 1983 and September 30, 1983, numbered MUR 1578, MUR 1587, MUR 1590 and MUR 1591, respectively, ill of which relate to the solicitation of contributions in connection with a fund-raising dinner sponsored by Friends of Ron Packard which was held on September 17, 1983. C, (2) That the subject complaints allege that certain invitations to attend the fund-raising dinner sponsored by Friends of Ron Packard, ~ihich invitations solicited contributions to Friends of Ron Packard, were mailed to individuals whose names and addresses were copied from Federal Election Commission reports filed by Crean for Congress, the principal campaign committee of Johnnie Crean. (3) That he had no knowledge whatsoever that, for the purpose of soliciting contributions to Friends Qf Ron Packard, names and addresses of contributors to Crean for Congress were to

-1- be copied from Federal Election Commission reports filed by Crean for Congress. (4) That upon learning that the subject complaints bad been filed, he immediately instructed those associated with Friends of Ron Packard, particularly those associated with the orga~nization and administration of the dinner sponsored by Friends of Ron Packard, to cooperate fully with the Federal Election Commission in resolving the issue. IN WITNESS WHEROF, your deponent has executed this affidavit this ~ day of February, 1984. N

RONALD PACKARD N SWORN to before me this ~- day of February, 1984.

My commission expires: *~

-2- BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of MUR 1587 Ronald C. Packard

CERTIFICATION

I, Marjorie W. Emmons, Secretary of the Federal Election Commission, do hereby certify that on October 31, 1983, the Commission decided by a vote of 6-0 to merge MrJRs 1587, 1590 and 1591 into MUR 1578. Commissioners Aikens, Elliott, Harris, McDonald, McGarry and Reiche voted affirmatively in this matter.

Attest:

I' dI~ ~i Date ( Marjorie W. Emmons 0 Secretary of the Commission

of Commission Secretary: 10-27-83, 9:28 Received in Office 4:00 Circulated on 48 hour tally basis: 10-27-83, 0

FEDERAL ELECTION coiuiissidii"''~'~ 1325 K Street, NW Washington, D.C. 20463~'~Oc1Z7 A9: ZB FIRST GENERAL COUNSEL'S REPORT SOIItTIVE

DATE AND TINE OF TRANSMITTAL MUR 1587 BY OGC TO THE COMMISSION: DATE~~RPLAINT RECEIVED BY OGC September 19, 1983 ~o/.~7/8'3 DATE OF NOTIFICATION TO RESPONDENT September 27. 1983 STAFF MEMBER: Deborah Curry

COMPLAINT'S NAME: Mrs. Andrew Crean RESPONDENT'S NAME: Ronald C. Packard RELEVANT STATUTE: 2 U.S.C. S 438(a) (4) 11 C.F.R. S 104.15

INTERNAL REPORTS CHECKED: None '( FEDERAL AGENCIES CHECKED: None N SUIESARY OF AUUG&TIOUS On September 12, 1983, the Office of General Counsel 0 received a signed, sworn and notarized complaint (Attachment 1 page 1-4 of attachments) from Mrs. Andrew Crean ("hereinafter "Complainant"). Complainant alleges that Representative Ronald C. Packard (hereafter "Respondent") violated 2 U.S.C. S 438(a) (4) by copying from Commission files her name and address for the purpose of solicitation. Complainant alleges that she does not live in responent's congressional district. Complainant states that she was sent a direct mail solicitation. Complainant alleges that she actively supported and contributed to the campaign of Johnnie Crean, the republican opponent of Respondent in the 1982 Congressional election. Since Complainant has engaged in no other activity other than support of Mr. Crean, she -2-

contends that there is no other vay for Respondent to have gotten her name, except through copying of Commission files. This complaint is identical to three other complaints recently filed with the Commission. (See I4URs 1578, 1590 and 1591). FACTUAL AND LUGAL ANALYSIS 2 U.S.C. S 438(a) (4) makes unlawful the copying of Commission reports for the purpose of soliciting contributions or for any commercial purpose. On October 7, 1983, the Office of General Counsel received a letter from Respondent requesting an extension of time in which N to answer the notification of complaint. (Attachment 2 pages 5-6 of attachments.) Respondent requests an extension of time until

N Friday, November 4, 1983, since the person responsible for the mailing in question is out of the country at the moment. 0 Respondent requests, in addition to an extension of time, that all complaints be consolidated so that a single response can be C made. An extension of time to respond has been granted to the Respondent in this matter. The Office of General Counsel will send a report to the Commission after a response to the notification of complaint has been made by Respondent. At this time, the Office of General Counsel recommends that MURs 1587, 1590 and 1591 be merged into MUR 1578. -3-

RBCOUUDATIO 1. Merge I4URs 1587, 1590 and 1591 into MUR 1578.

Charles N. Steele General Counsel

IoJadn/ ?3 BY: KI~CJA~d~J Date Kenneth A. Gross Associate General Counsel 1/ Attachments 1. Complaint (pages 1-4) N 2. Respondents Response (pages 5-6) N

0 A4ACHtvThNT 2F~ ~3SEP~ P4: 34 Mrs. Andrew Crean3 109 1'aonarch Bay South Laguna, CA.~2677

Federal Elections Commission 1325 K Street Northwe~t Washington, D.C. 20463 Dear Commissioners: I would like to make a formal complaint and request for an investigation into the fund raising practices of Congressman Ron Packard of the 43rd Congressional District. I have attached a copy of a direct mail solicitation recently sent to me at my address listed above. Although I do not reside in this congressional district, I actively supported and contributed to the campaign of Johnnie Crean, the Republican opponent of Mr. Packard in the 1982 congressional election. I understand Mr. Crean was obliged to report my name and contribution in reports filed with the House of Representatives and the Secretary of State of California. 0 I swear that I have engaged in no political activity, other than my reported support of Mr. Crean, through which Mr. Packard could reasonably obtain my name as a prospect o for such a solicitation. I have no residence or business listing within the 43rd Congressional District.

Therefore, it seems Mr. Packard's activity is in violation of Public Law 95-521, Tit~.e I, Section 104(e) (1)(D) which states, "It shall be unlawful for any person to obtain or use a report for use, directly or indirectly, in the solicitation of money for any political, charitable, or other purpose." I would appreciate your immediate attention to this ~ rl Elect~.ons Commission (~) Page Two matter. Please feel free to contact me if you need any further information. Sincerely,

(A/ CH~LENE CI~E~ Attachment cc: Mr. Johnnie R. Crean

STATE OF CALIFORNIA ) 55. COUNTY OF

CHARLENE CREAN , being duly sworn, deposes and declares under penalty of perjury under the laws of the State of California: That ,b/she is over the age of 18 and -s a resident of the State of California. That the above statements were made of bbs/her own free will, without cooercion or pa~ent of any nature or kind and that the 9' above statements are true and correct.

Subscribed and sworn to before me on . /3 , ~983. L4~. OFFICIAL SEAL ALAN N OKAIN 0 rJO7A~Y FUE.L!C - CAUFO~NIA ______(MA~G CC'JNTY My comm. ex~ras ~EB 24 ~ Notary P One Newport PIa~, 10th FIr., hewFort Beach, CA92660 (SEAL) en STATE OF CALIFORNIA ) ss. COUNTY OF

On ~ /.~ , l~, before me, the undersigned, a Notary Pu~ic ~n and for said State, personally appeared CI-IARLENE CREAN , personally known to me (or proved to me on the basis of satisfactory evidence) to be the person whose name is subscribed to the within instrument and acknow- ledged that he/she e

WITNESS my hand and official O OFFICIAL SEAL ALAN N OKAIN II OTA~Y PUBLIC - CALiFORNIA ______

*~' My comm. ex~ira: FIB 24, 1986 y Pu.o

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for compasgn reporung anaccor~ana with election .0w.

Name Spouse

Resadentss.l AdCress

Er~iover ______Check if salf4milo'tC.

~usaraess ACOreIS 1*w*

Occu~azaOn or Title

jf seif.e~npho~e~. Place of Business ______

P.o fo' o~ F'RAI e' Ae'~P.r.a'd * FECI D 09P~~ P o ba i~ Canssac. CA 92009

I U CONGRESS OP THE UNITED STATES H~::~;:::N;~I~ES ATTACMME iVT )j

Row PACKAmO ~3.S DesYmeer. Cauuomwsa October 4, 1983 o

Federal Election Commission 1325 K Street, NW W~shington, DC 20463

Attn: Kenneth A. Gross .~-. I-- -. Associate General Counsel RE: MUR 1578, 1587, 1590, etc. Dear Mr. Gross: 00 I have received your transmittals of September 27 and ~ September 29 pertaining to the above referenced matters, and I have rev~.ewed the complaints contained therein with great care. Since all arrangements concerning the mailing of invitations to [% the September 17 testimonial dinner in question were handled by a committee of campaign volunteers, I have absolutely no personal ~ knowledge of the sources of information used for the creation of their mailing lists. I am very anxious to look into this situation and find out whether there was any inadvertent misuse of FEC reports. Please ~ permit me to extend an offer of full cooperation on the part of ~. me, my staff and my campaign organization in this matter. I personally will be happy to respond to any requests for information CO or assistance which you or the other members of the FEC may make. The person who handled all of the list accumulation and mailing work for the September 17 event left the country for an extended vacation in Europe with her husband last week. It is my under- standing that she will return to her home in Carlsbad, California during the last week in October. While Mrs. Buckner is cut of the country, I know of no way that I can gain access to the computer files which she used in setting up her mailing lists. Since the complaints referred to in your conversation with my Administrative Assistant, Clyde Romney, have not all been received, I would respectfully ask that my campaign committee be afforded the opportunity to consolidate all such complaints and make a single response thereto, and that the time for such response be

- ~.m a, ~ aa~ Hr. A. Gross October 4, 1983 Page 2

extended until Friday, November 4, 1983, which should be approximately one week following Mrs. Buckner's return, based upon information which I have been able to obtain from her husband' 5 office.

I hope that these requests present no problems. I thank you in advance for you.r courtesy and cooperation.

RON PACKARD Member of Congress

EP/cP 0

~qrn FEDERAL ELECTION COMMISSION WASHINCTON.D.C. 20463

October 5, 1983

The Honorable Ronald C. Packard 4001 Sunnyhill Street Carlsbad, CA 92008 Attn: Clyde Roinney Re: MUR 1587 Complaint of Mrs. Andrew Crean Dear Mr. Romney:

In our telephone conversation of October 4, you indicated that the enclosures in the above referenced matter were not ~ included with the notification sent to your office. Enclosed please find a copy of the Complaint with attachments. Sincerely,

0 Associate General Counsel C:,

Enclosures cc, ~> C ( .0 .9 * ~.3SEP~ P4:34 Mrs. Andrew Crean3 109 Monarch Bay South Laguna, CA.~2677S. c.0

Federal Elections Commission 1325 K Street Northwe*t Washington, D.C. 20463 Dear Commissioners: I would like to make a formal complaint and requelt for an investigation into the fund raising practices of Congressman Ron Packard of the 43rd Congressional District. I have attached a copy of a direct mail solicitation recently sent to me at my address listed above. Although I do not reside in this congressional district, I actively supported and contributed to the campaign of Johnnie Crean, the Republican opponent of Mr. Packard in the 1982 congressional election. I understand Mr. Crean was obliged to N Housereport ofmy Representativesname and contribution and the inSecretary reports offiled State with of the California. 0 I swear that I have engaged in no political activity, other than my reported support of Mr. Crean, through which Mr. Packard could reasonably obtain my name as a prospect C for such a solicitation. I have no residence or business listing within the 43rd Congressional District. Therefore, it seems Mr. Packard's activity is in violation of Public Law 95-521, Title I, Section 104(e) (1)CD) which states, "It shall b~ unlawful for any person to obtain or use a report for use, directly or indirectly, in the solicitation of money for any political, charitable, or other purpose. I would appreciate your immediate attention to this Federal Elections Commission Page Two matter. Please feel free to contact me if you need any further information. Sincerely,

CRE~14~

Attachment CC: :4:. Johnnie R. Crean

STATE OF CALIFORNIA ) as. COUNTY OF

CHARLENE CREAN , being duly sworn, deposes and declares under penalty of perjury under the laws of the State of California: That ,b/she is over the age of 18 and ~s a resident of the State of California. That the above statements were made of~bs/her own free will, without czcerzion or payment of any nature or kind and that the abcve statements are tr'~e and correct.

N Subscribed and sworn to before me o6 , 1993. ALAN N OKAIN

SEAL ~O~A~YOFFiCIAL PUEL' CALiFORNIA1 ______My ~ CC~NTY NotarvPx~2.2.c 'v/comffl&x..fIsrEB24Iru~5. One Newport Plain, 10th flr., Newport Beach, CA92660 (SEAL)

STA'E OF CALIFORNIA sa. COb~TY OF

On ~ l~, before me, the undersigned, * a Notarv~~ ~c ~na~d:orsaid State, personally appeared CiIARLWE CREAN , personally known to me (or proved to me on the oasis of satisfactory evidence) to be the person whose name is s~scribed to the within instrument and acknow- ledged that he/she executed the same.

WITNESS my hand and official OFFICiAL SEAL ALAN N OKAIN ______N OTAR'r PUBLIC . CALIFORNIA ______Mywrnm~ex;ira: NotarY Pu~T~ fl8 24, 1986 One ~t f1~ 10.h flr~ New~crt Bach, CA 92660 Ma~ee, .1 Ceuenu'idr~ j ~AflA7Ole tteueer.bie fleA er.a.r,~3.r1 'J1Jn'1IF~.V~J

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Name Spouse

Resdcnua~ AOOreSs

______CiWCi if 151f4,vipbo"eg

a.. eg~wm Oc:u~atiofl o Tiile ~e~f.empIO~2~. Place of Susinni

&.g ~ '*engi o~Aep Aee&e'e' * PlC I.D 491i&s P 0 Ic' ~d9 Cammac CA 920W

~s~E-~ ~r44

--- 4.

* 2, .- gd!. ~ C 83G~~~

CONGRESS OP THE UNITED STATES HOUSE OP REPRESENTATIVES WASHINGTON, D. C. 20515

RON PACKARD 43mm DeS~m.ci~ CAUPOPmA October 4, 1983

Federal Election Commission 1325 K Street, NW Washington, DC 20463 Attn: Kenneth A. Gross Associate General Counsel RE: MUR 1578, 1587, 1590, etc. Dear Mr. Gross: 0 I have received your transmittals of September 27 an4 September 29 pertaining to the above referenced matters, and I have reviewed the complaints contained therein with great care. Since all arrangements concerning the mailing of invitations to N the September 17 testimonial dinner in question were handled by a committee of campaign volunteers, I have absolutely no personal knowledge of the sources of information used for the creation of their mailing lists. I am very anxious to look into this situation and find out whether there was any inadvertent misuse of FEC reports. Please C permit me to extend an offer of full cooperation on the part of me, my staff and my campaign organization in this matter. I personally will be happy to respond to any requests for information or assistance which you or the other members of the FEC may make. The person who handled all of the list accumulation and mailing work for the September ~.7 event left the country for an extended vacation in Europe with her husband last week. It is my under- standing that she will return to her home in Carlsbad, California during the last week in October. While Mrs. Buckner is out * of the country, I know of no way that I can gain access to the computer files which she used in setting up her mailing lists. Since the complaints referred to in your conversation with my Administrative Assistant, Clyde Romney, have not all been received, I would respectfully ask that my campaign committee be afforded the opportunity to consolidate all such complaints and make a single response thereto, and that the time for such response be

9W PSiNYSSLI Se.m g~ui 0 Mr. Kenneth A. Gross October 4, 1983 Page 2

extended until Friday, November 4, 1983, which should be approximately one week following Mrs. Buckner's return, based upon information which I have been able to obtain from her husband's office. I hope that these requests present no problems. I thank you in advance for your courtesy:~, and cooperation. ~L< RON PACKARD Member of Congress

RP/cp

(7%

qQ. C,

wqrn

0 V cn FEDERAL ELECTION COMMISSION 'A ~SHINC10% DC 2O4h~

September 27, 1983

Mrs. Andrew Crean 109 Monarch Bay South Laguna, CA 92677

Dear Mrs. Crean: This letter is to acknowledge receipt of your complaint which we received on September 19, 1983, against Congressman Ronald C. Packard and the Friends of Ron Packard Committee which alleges violations of the Federal Election Campaign laws. A staff member has been assigned to analyze your allegations. The 0' respondents will be notified of this complaint within five days. You will be notified as soon as the Commission takes final action on your complaint. Should you have or receive any additional intormation an this matter, please forward it to this office. We suggest that this information be sworn to in the same mariner as your original complaint. For your information, we have attached a brief description of the Commission's procedure for o handling complaints. If you have any questions, please contact 523-4073. ~q. Sincerely, 0 ~q.

Kenneth A. Gro$ Associate General Counsel

Enclosure i FEDERAL ELECTION COMMISSION ~~ASHING1O\ DC 2O46~

S~47j~ ('A ~ September 27, 1983

CERTIFIED MAIL RETURN RECEIPT REQUESTED Mr. William L. Hardy Treasurer Friends of Ron Packard Committee P. 0. Box 1549 Carlsbad, CA 92008 Re: MUR 1587 Dear Mr. Hardy: (7% This letter is to notify you that on September 19, 1983, the Federal Election Commission received a complaint which alleges that your committee may have violated certair~ sections of the Federal Election Campaign Act of 1971, as amended ("the Act"). A 1% copy oj the complaint is enclosed. We have numbered this matter 15S7. Please refer to this number in all future correspondence. 0 Under the Act, you have the opportunity to demonstrate, in writing, that no action should be taken against your committee in connection with this matter. Your response must be submitted within 15 days of receipt of this letter. If no response is received within 15 days, the Commission may take further action based on the available information. Please submit any factual or legal materials which you believe are relevant to the Commission's analysis of this matter. Where appropriate, statements should be submitted under oath. This matter will remain confidential in accordance with 2 U.S.C. ~ 437g(a) (4)(B) and S 437g(a) (12) (A) unless you notify the Commission in writing that you wish the matter to be made public. 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 a statement authorizing such counsel to receive any notifications and other communications from the Commission. -2-

Charles N. Steele Gen~&l Counsel

cc: The Honorable Ronald C. Packard

Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement FEDERAL ELECTION COMMISSION V'lIYLt) ~.~ASHINCTON DC 20463 ~\uvmuE~, September 27, 1983

CERTIFIED MAIL RETURN RECEIPT REQUESTED The Honorable Ronald C. Packard 4001 Sunnyhill Street Carlsbad, CA 92008

Re: MUR 1587 Dear Congressman Packard: This letter is to notify you that on September 19, Federal Election Commission received a complaint which alleges1983, the that you may have violated certain sections of the Federal Election Campaign Act of 1971, as amended ("the Act"). A copy of the complaint is enclosed. We have numbered this matter MUR 1587. Please refer to this number in all future correspondence. Under the Act, you have the opportunity to demonstrate, in writing, that no action should be taken against you in connection o with this matter. Your response must be submitted within 15 days o~ receipt of this letter. If no response is received within 15 days, the Commission may take further action based on the available information. Please submit any factual or legal materials which you believe are relevant to the Commission's analysis of this matter. Where appropriate, statements should be submitted under oath.

This matter will remain.confidential in accordance with 2 U.S.C. S 437g(a) (4)(B) and S 437g(a) (12) (A) unless you notify the Commission in writing that you wish the matter to be made public. 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 a statement authorizing such counsel to receive any notifications and other communications from the Commission. -2-

Charles N. Steele Ge TLe~m~Cou nse L....

Kenneth A. Gross Associate General Counsel

cc: William L. Hardy, Treasurer

Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement ~2C~t~*ID AT4J~E FIC

o3SEP~N: 34 Mrs * Andrew Crean~ cf' 109 Monarch Bay South Laguna, CA.~2677 '9

Federal Elections Commission 1325 K Street Northwest Washington, D.C. 20463

Dear Commissioners:

I would like to make a formal complaint and request for an investigation into the fund raising practices of Congressman Ron Packard of the 43rd Congressional District.

I have attached a copy of a direct mail solicitation recently sent to me at my address listed above. Although I do not reside in this congressional district, I actively supported and contributed to the campaign of Johnnie Crean, the Republican opponent of Mr. Packard in the 1982 congressional election. I understand Mr. Crean was obliged to report my name and contribution in reports filed with the House of Representatives and the Secretary of State of California. 0 I swear that I have engaged in no political activity, other than my reported support of Mr. Crean, through which Mr. Packard could reasonably obtain my name as a prospect for such a solicitation. I have no residence or business listing within the 43rd Congressional District. Therefore, it seems Mr. Packard's activity is in violation of Public Law 95-521, Title I, Section 104(e) (1)(D) which states, "It shall be unlawful for any person to obtain or use a report for use, directly or indirectly, in the solicitation of money for any political, charitable, or other purpose.

I would appreciate your immediate attention to this Federal Elections Commission Page Two matter. Please feel free to contact me if you need any further information.

Sincerely, 1Ai&4~ (I ~

6~NE ~ Attachment (~s.At.o(t6w c*.6M5) cc: Mr. Johnnie R. Crean

STATE OF CALIFOR~LtA ss. COUNTY OF

N CHARLENE CREI~N , being duly sworn, deposes and declares under penalty of perjury under the laws of the State of California: That *be/she is over the age of 18 and is a resident of the State of California. That the above statements were made of ,bd~/her own free will, without cooercion or payment of any nature or kind and that the above statements are true and correct. N Subscribed and sworn to before me o , 1983. OFFICIAL SEAL

PUBLIC-CALIFORNIA~_ _ __ ORANGE COUNTY ry Pu My Comm. expires FEB 24, 1986

One Newport Plans. 10th FIr., Newport Beach, CA92660 (SEAL)

STATE OF CALIFOANIA ss. COUNTY OF

on &~*< 13 , 1983~ before me, the undersigned, a Notary Pu~ ic in and for said State, personally appeared CIIARLENE CREAN , personally known to me (or proved to me on the basis of satisfactory evidence) to be the person whose name is subscribed to the within instrument and acknow- ledged that he/she executed the same. WITNESS my hand and official OrPICIAL SEAL ALAN N O'KAIN

NOTARY PUBLIC -CALIFORNIA ______My comm. expires FEB 24, 1986 Pu.~T~

One ~ 10th FIr., Newport Beach, CA92660 9 '~3 Master ol Ceremonies 3 ~ C)4J~d7~ 4 ~ ~ itoaeerable Gal, W. Biargenar

Dinner Commitlee Mr. end Mrs James M. Guasrr. CAm. Mr. and Mrs. Bruce D. Backner Congressman and Mrs~ Ron Packard Mr. wad Mrs. Russell Bairkeil cordially invite you uo en evening of Mr. and Mrs. DeViri Ku.,: good food. good friends. and good entertainment Honorary Co-Chairmen with their special guest M,. Edwin Mew CongressananRobert C Batiham SenatorBerry Goitiwate, CongressmanTreni Lea SW Lvatay Reagan Senatorileword hAre CengrewseanPAul Geamm Cengrnssn.an Counselor I. Aesideavi Ronald ii. a.a Honorable EdevinI. Gray ConeressneanDan Laungren SerrelaryTrerri Mark A~dm Dergason Senator(hem 0. hatch CongressmanConnie on Saturday, September 17, 1953 Assemhiywonean JeAnS. hicCen Assemblyman861 Bentley SenatorF~.k itauhim Congressman at the WWiamCampbell REaperRqer ite*ecerk Cengromuan Al hicCauvEm Senator Heavier Uckinnon SeamierR'Wiam A. Crave. CengressnmanGuncan Honorable CRavenN, San Diego Hilton Held Conresuan.. Wild.. F. ilannemeyer Cengressneanhemp I. Hyde CengreusnsineRobert H. RAchel GovernorOwl. Oeukmrjtan Air Je.... C Jenkeag Assemblywon.a. SonnyMajoneler The International Ballroom SeamierRe~i Ni. ~ laiR Kemp CongressmanCalm J. Moorheed SeamierJam E8~ COqM.fiUeiniRobert I Lqaawaa.o Senator~ Eperaw 1775 Fast Mission Buy Drive Congrwnv.'. lobe Erienbern SeamierPaul Laud Avemblyman Lnsy Se~ CongresswomanBobbi ruder CongressneanJerry Lea.. CongeessammGuy Vanderiqi San Diego Assemblyane.Rabrrl C. Rena.. Secretarybees 0 Wave Senniorink. Gang SeamierPate When RSVP No host cocklalls 6:341 p.... Special Enterlmimusenl Reply card enclosed Dinner 7:341 p.m..

'Sing for m4naerica' A musical review produced and directed by MIchetil/Knos Eniertaimment.

N~ Petet - .d~ a 0o

0 0 0 (oqualle Si. Jeeque.s Salade Waldorf ('haieoubfltand de Burial Macnile I ~- Saute Perigourdatee ~1~.I i~ Baked Alaska FlansAc' n-nt ** ** AhAb * * * ********* '4= (ii110515 IIt Ale anti Airs hianyAt one Air oed Airs. Gordon I an*e Air. agedAirs Blamer I asarda I ft. s-J~ lie and Airs John ,tirsantia'e I Air and Ales.llonaid R AIvArihui 5-.. Air anti Airs I rank .tia'shara' U C Airs *tiiJianaR Ait.4rdle Ale. atatiAirs PeahenI ,gntirrsa'n Air, and tie RevA~ lair Ala anti Airs Na.Atalas C. itanehe Ak('ieiian z1~ Al, ,teihea,fleet. ha', Air ond Airs. Jane Ii Air wadAtrs Glenn Aivi oenas Ii 'tie liraneitan lint, At', 13 anelAirs. (beak Alansahang Al' Rta.alitrishee Air. 0 anti Alt's AnilaaaneAlone' Air atatiAirs Rathard A Burl Air Air. onti Airs (twisun Alteeas Ala attadAlas iitioiai I arpe'nia'e 0~ lion i)ta<~ Alearj'hv Air anti hits Rathard ChetA lie anti Airs i-u i Aiatrahy 1! 'vi, wetShits JathnI. (atna,, lit',.. heatsa Nasiantir ii III Ale atatiAl's Seen(aunts Air and Airs a;ets Owen *1 Ate anti Airs itehn 1 iaairs' lie and Airs iloe.ii'aaAard 4~ Air atedAles Kenneth lieGeattia lie and Ales Ii *'toi Va.Larti as Ale anti Ales Arar Orione. Jr Air anti Al's. lunats l'aajet' lie lata'e(attlan Air and Alec ja'. £ latiareil I. I Air and Ails ii (aasietaaanhoar lion anti Airs intes Radr Air JialanIA' i-aele ft. lion, anti Airs. iioteaasl Riley I AIrs Patti i-the. Jr Air ateti Air, and Airs ibde' Roi~OWY Ale anti Ais 1. larry Ftidoaxiten Ale and Airs Janet'sC. St Anaueit 0 FiletA I Ale agedAirs ShoanasC Ale. lierreStngh. Jr Air Chaties K. i-hither Ales.Gary Sneath Ale agutiAles Kanelieu-hi' Air. anti Air. anti Airs JavAt. Sneath Ale atatlAles RealeertC'. ilali lion. RogerSianiten Ale atariAirs SItilealetI. hiartie Air amntiAirs laneenheSirader Ale atadAles I 1~.iirtilataeg liven.i-ta Siea.iksnaa Sir. tagatihits I ireiretik liadete Air. IltelaStuilee Ala tantiAirs i)ataaelR. hull aicti Aims.liramar Siaetleai Ale anti Airs ba~ liatni lie Air atatiAirs. SielaivenWhra'ier Air atatiAles .iet~riahii Jactaida Air atadAles. Knos ia'ailaones Ale l)unaid Al Aitii Ale and Airs Aaaicw Ildison lie lie'., ilacesarKate' S arooliry Roisert C i aviaeag Ale, and Airs. Raigeu Air and Airs Airs. ,tiirga 5'asaaka#ahi ii i.naea'nae Air anti Ale, anti Airs ~ 1 iS awaia ta.aa 0 _____

ThaflA you fur ~uppd ring us with the following information as required or cam paaen reporting in accordance with elect ion law.

\drnr ______Spouse

keudentiJi ~ddress -______

nr'ioer ______Check if seIf.empLOvC~

iu; Zr .isdd~eSS______

)yu~diIOfl or Title ______

cc ernZuoea. Place ot Business

ad 'r ?. f enas Ron Paexard * FEC 1 0 ~)9574& P Bos 549 CarlsbadCA 92005

mJU Es ,~JDg~ui C&'*i#~I 4tc~rch~ ~ cA~ '~.2~17 'B

q~3. Fede~1 E1ect~.ona Coiwpuiaa~1on 1325 ~ Street No~th~re~t W~ph±n9ton, D.C. 2Q463 FEDERAL ELECTION COMMISS!ON

September 27, 1983

CERTIFIED MAIL RETURN RECEIPT REQUESTED Mr. William L. Hardy T re a surer Friends of Ron Packard Committee P. 0. Box 1549 Carlsbad, CA 92008 Re: MUR 1578

Dear Mr. Hardy: This letter is to notify you that on September 19, 1983, the £edeIa.~. i2~ection Commission received a co:~plaint wnich alleges

-~ ~ ~ ~ct of i~7l, ~.s ~n~cnae~ ("The ~.ct"). A 1%. copy of the complaint is enclosed. We have numbered this matter MUR 1578. Please refer to this number in all future cor res~on6~ noc. 0 Under the Act, you have the opportunity to demonstrate, in 'V writing, that no action should be taken against your committee in connection with this matter. Your response must be submitted within 15 days of receipt of this letter. If no response is received within 15 days, the Commission may take further action based on the available information. tIE, Please submit any factual or legal materials which you believe are relevant to the Commission's analysis of this matter. Where appropriate, statements should be submitted under oath. This matter will remain confidential in accordance with 2 U.S.C. § 437g(a) (4)(B) and S 437g(a) (12) (A) unless you notify the Commission in writing that you wish the matter to be made public. 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 a statement authorizing such counsel to receive any notifications and other communications from the Commission. -2-

Charles N. Steele General Counsel

Kenneth A. Gross' Associate General Counsel

cc: The Honorable Ronald C. Packard C~1

I~nclosures 1. Complaint 2. Procedures 3. Designation o 0

~*FEDERALELECTIONCOMMISSION ~AASHINGTON, DC 20463

September 27 1983

CERTIFIED MAIL RETURN RECEIPT REQUESTED The Honorable Ronald C. Packard U. S. House of Representatives Washington, D. C. 20515

Re: MUR 1578 Dear Congressman Packard: o This letter is to notify you that on September 12, 1983, the Federal Election Commission received a complaint which alleges that you may have violated certain sections of the Federal ~ Election Campaign Act of 1971, as amended ("the Act"). A copy of the complaint is enclosed. We have numbered this matter MUR 1578. Please refer to this number in all future correspondence. Under the Act, you have the opportunity to demonstrate, in o writing, that no action should be taken against you in connection with this matter. Your response must be submitted within 15 days of receipt of this letter. If no response is received within 15 days, the Commission may take further action based on the available information. Please submit any factual or legal materials which you believe are relevant to the Commission's analysis of this matter. Where appropriate, statements shoul~ be submitted under oath. This matter will remain confidential in accordance with 2 U.S.C. ~ 437g(a) (4)(B) and S 437g(a) (12) (A) unless you notify the Commission in writing that you wish the matter to be made public. 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 a statement authorizing such counsel to receive any notifications and other communications from the Commission. 0 -2-

Charles N. Steele General Counsel

Associate General Counsel

cc: William L. Hardy, Treasurer

Enclosures 1. Complaint v 2. Procedures 3. Designation o .4;

FEDERAL ELECTION COMMISSION

S WASHINGTON DC 20463 September 27, 1983

Mrs. John C. Crean 617 North Canon Drive Beverly Hills, CA 90210

Dear Mrs. Crean: This letter is to acknowledge receipt of your complaint which we received on September 12, 1983, against Congressman Ronald C. Packard and the Friends of Ron Packard Committee which alleges violations of the Federal Election Campaign laws. A staff member has been assigned to analyze your allegations. The 0 respondents will be notified of this complaint within five days. You will be notified as soon as the Commission takes final action on your complaint. Should you have or receive any aodit±onal information in this matter, please forward it to this office. We suggest that this information be sworn to in the same manner as your original complaint. For your information, we have attached a brief description of the Commission's procedure for handling complaints. If you have any questions, please contact 0 Cheryl Thomas at (202) 523-4073. Sincerely,

Kenneth A. Grog - Associate General Counsel

Enclosure 9 9 RECEIVED A? fI4E FEC

yet AID: 3! na S. Crean 617 North Canon Drive Beverly Hills, CA 90210

Federal Elections Commission 1325 K Street Northwest Washington, D.C. 20463 Dear Commissioners: I would like to make a formal complaint and request for an investigation into the fund raising practices of Congressman Ron Packard of the 43rd Congressional District. I have attached a copy of a direct mail solicitation recently sent to me at my address listed above. Although I do not reside in this congressional district, I actively supported and contributed to the campaign of Johnnie Crean, the Republican opponent of Mr. Packard in the 1982 congressional election. I understand Mr. Crean was obliged to report my name and contribution in reports filed with the House of Representatives and the Secretary of State of California. 0 I swear that I have engaged in no political activity, other than my reported support of Mr. Crean, through which Mr. Packard could reasonably obtain my name as a prospect for such a solicitation. I have no residence or business listing within the 43rd Congressional District. Therefore, it seems Mr. Packard's activity is in violation of Public Law 95-521, Title I, Section 104(e) (1)(D) which states, "It shall be unlawful for any person to obtain or use a report for use, directly or indirectly, in the solicitation of money for any political, charitable, or other purpose." I would appreciate your immediate attention to this Federal Elections Commission Page Two matter. Please feel free to contact me if you need any further information. Sincerely,

DONNA S * CREAM Attachment cc: Mr. Johnnie R. Crean

STATE OF CALIFORNIA )

~ ) ss. COUNTY OF ~

DONNA S. CREAM , being duly sworn, deposes and declares under penalty of perjury under the laws of the C, State of California: That he/she is over the age of 18 and is a resident of the State of California. That the above statements were made of kxs/her own free will, without cooercion or payment of any nature or kind and that the above statements are true and correct.

Subscribed and sworn to before me on ______,1983. OFFICIAL SEAL 0 4 4~\. ALAN N OKAIN PUBLIC - CALIFORNIA ______ORANGE COUNTY otary Public ____ My Comm. expires FED24, W8$

Oie N~wtin~ PI~ I~h rIP, T4~w~rt Bw?~, CA 92~6O (SEAL)

STATE OF CALIFORNIA ) ) ss. COUNTY OF

On ______, l9~ before me, the undersigned, a Notary Pub Tic in and for said State, personally appeared DONNA S. CREAM , personally known to me (or proved to me on the basis of satisfactory evidence) to be the person whose name is subscribed to the within instrument and acknow- ledged that he/she executed the same.

WITNESS my hand and official OFFICIAL SEAL

-~___ ALAN N OKAIN r~c NOTARY PUBLIC - CALiFORNIA ORANGE COUNTY My comm. expires FEB 24, ~ Notary Public 1~ ~' ~~17~&1 Master of Ceremonies .) Itoesorabie CRateW. Bergenee Dinner Committee Mr. and Mrs. James M. Gnaw Chisa. Mr. and Mrs. Bruce D. Buckner Congressmancordially invite and you Mrs. teen Ron inning Packard of Barbell Mr. and Mrs. Russell good entertainment Mr. and Mrs. DeViri Kunz good food. good friends. and with their special guest Honorary Co-Chairmen Mr. Edwin Meese Counselor to I~esident Ronald Reagan SenatorUwy Gatdu.wter CongrasmenCangresinsen SalIrenE LanepLost CongressnmasiRobere E SedAns. CongressmenPhil Grame Senatorhoward Baker CangressnianDan Langren 17. 1953 Honorable Edwin I. Grey Comm A~* on Saturday, September SecretaryTerrel H Belt 0. 11,5cC Cangressenen Seeuaearcksin JeAnS.a*c~in at the AuemktywOmesflMorse. Swgeson PamelaHaukens Congressmen Senator Car4eeamenAl A&~Ems As.sesnkiynueflBiN Dewdiep Major RogerIledgeroek L~MO thin AtcKdnm Diego Hilton hotel SenatorWiBinin C.q.beS CorsgresssnenDiencu itanter HownNr San SenatorWitiinsn A. Craven lt~sle Cav4rtsia'a' RobertH. hikAtI CongressmenHenryJ. Mqjeeinler The International Ballroom CangresonenWifl~an K. Deawuwyor Air, JamesE. Jenkins Assembeywowsen Siam, lhaknuejinn Cengresse Cairn I. *iaerh GovernorGeorge Cer4rusmffenJ.* F. Keep 5gwaw 177.5 East Mission Bay Drive Robe'sDale Senator~ Senator Cengresmen Raberel. Lqem'sine SawSue SenatorJon EBis SenatorPad Lasete AuenublymonLwy San Diego CongressmenJohn Kteab.o.en CongresSmanJeury Lewis Cangre*tiinUiCu, Venderiegt CongresswomenRabbi under SesrV~oryJames 0. Watt AssenibtynienRobert C Paw SeanceFete ~dso. Cern Senatorlake No host cocktailsDinner 6:307:30p.m. p.m. RSVPReply card enclosed Special Enteetalnaneot

- 'SingforAnserke~ Easeevtaiusmenl. A musket review produced and directed by MIdsettl/KnOIls Na piaat amesbi a dh.n~

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- -

T~hanA .'(ILd 7or ruppi ring us with the following information as required for campalen reporting in accordance with election gaw.

N~,me . SPOUIC

Residrnhiai ~adrefs

L mpo~er - ______Check if seIf-empIO~Cd

jnrs~ ~JIre'

e~i rmflIo~eU. Place ot Business

Ron Packad' * P~C I D ~57~ P Bo~ 549 Carlsbad. C~ 92005

UN CA 9o~o

Federal Elections Commission 1325 K Street Northwest Washington, D.C. 20463 *~*~ ~

FEDERAL ELECTION COMMISSION 132~ K S1R~LI N.W. WASIUNG1ON.D.C. 20461

TillS IS THE BEGIWIING OF MUR t~ 2 5I7~'

Date Filmed Camera No. * 3

Cameraman