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This Is the Beginning F Mur FEDERAL ELECTION COMMISSION WASHINGTON. D C. 204b3 THIS IS THE BEGINNING FMUR # DATE FILMED CAIMERA Ne '3 CAMERAM~AN6R PUBLIC RECORD INDEX - MUR 2433 1. Memo, 10 Feb 87, John D. Gibson (Reports Analysis Division) to Charles N. Steele (General Counsel), subj: Referral of the Federated Department Stores PAC, w/atch (RAD Referral Pkge) 2. First General Counsel's Report, 18 May 87. 3. Certification of Commission Action, 22 May 87. 4. Ltr, 8 Jun 87, Scott E. Thomas (Chairman, FEC) to Russell S. Davis (Treasurer, Federated Dept. Stores PAC), w/atch (Factual and Legal Analysis). 5. Ltr, 29 Jun 87, R.S. Davis to F.E.C. 6. Ltr, 24 Jul 87, Klaus M. Ziermaier (Counsel) to S.E. Thomas, w/atch Designation of Counsel Statement. 7. Ltr, 5 Aug 87, K. Ziermaier to FEC 8. General Counsel's Report, 24 Aug 87. K 9. Certification of Commission Action, 27 Aug 87. 10. General Counsel's Report, 17 Oct 87 11. Certification of Commission Action, 19 Oct 87 12. Ltr, 23 Oct 87, L.M. Noble to K.M. Ziermaier, w/atch (executed conciliation agreement) -END- r- NOTE: In preparing its file for the public record, O.G.C. 0routinely removes those documents in which it perceives little or no public interest, and those documents, or protions thereof, which are exempt from disclosure under the Freedom of Information Act. 87NF-8 THROUJGH 7' -41 FEDERAL ELECTION COMMISSION WASNINCTON D C 20463 February 0, 1967 NNMORADUN, TO, CHARLES N. STE3U4 GENERAL COUNS3A THROUGH: JOHN C. SURIN STAFF DIREV FROM: JOHN D. GIBSO ( ' ASSISTANT STAF IRECTOR REPORTS ANALYSI DIVISION SUBJECT: NON-FILER RiFERRALS Or MONTHLY UNAUTHORIZED COMITTEES r. Attached is a listing of thirty-four (34) monthly filers which failed to file a report covering the pre-election period by Election Day, November 4, 1986. In accordance with Standard 3 of the 1985-1986 RAD Review and Referral Procedures, further N" examination is required by your office. On September 29, 1986, prior notification was sent to all unauthorized committees which specifically informed monthly filers of the requirement to file a 12 Day Pre-General Report by October 23, 1986 (Attachment 35). Each committee which failed to submit either a 12 Day Pre-General Report or a November Monthly Report was sent a Non-Filer Notice on November 14, 1986 r(Attachment 36). The following six (6) committees were not sent Non-Filer Notices because a report covering the pre-election Cperiod was indexed by November 14, 1986: - Federated Department Stores PAC (C00091660) /' The attached printout lists the nsae, address and treasurer for each coinittee being referred. Any telephone Conversations are referenced under Contacts with Filers. The SUary Pages of the late-filed reports and/or letters of explanation are included under Reports Fled/Response(s). Zn addition, a OCO index has been included for each committee. Please note that the aggregate receipt and disbursement figures may be inflated in some cases because a) reports were submitted covering portions of the same period (e.g., a 12 Day Pre-General Report covering October 1, 1986 through October 15, 1986 and a November Monthly Report covering October 1, 1986 through October 31, 1986), or b) 1987 February Monthly Reports have been filed. If you have any questions, please contact Lisa Stolaruk at 376-2480. Attachments / C00091660 Federated Dept. Stores PAC 0 12 FEDERATED DEPARTMENT STORES POLITICAL ACTION COMITTEE (Attachments 15a and 15b) FEDERAL ELECTION COMMISSION COMMITTEE INDEX OF DISCLOSURE DOCUMENTS - (C) (85-86) DATE PAM4FEW7 I NON-PARTY RELATED P COITITZ DOCUMENT RECEIPTS ------- DISBURSEMENTS -- TYPE -orFfLM ----- uzwor--- ----- ----- ----- --- -- -- --- --- ---- --- -- -- COV KA DA PA MC FrA1T' STORES PAC CONNECTID ORGAIZATIONs I! ATI IJ ARTI'IT STORES InC NOW-PRT! OuILWI= D s0oC9omm 1985 ST mMIT OF ORGANIZATION - AMENDMENT FRUARY MONTHLY MARCH MNTH~LY 591 0 JIA5s -3lThJUi 2 6UW33IU6 APRIL MONTHLY 0 0 1136 -2Ulmm * 613G43$# MAY MONTHLY 2,775 0 13m -3133s5 .4 UftOS13476 JUNE MONTHLY 1,390 0 1IN" -30APM3 12la i6umJ3I42e=W12me 639 2.000 I - =l?]m JULY MONTHLY 1,856 1MAY5 -313MSS FOR ADDITIONAL INFORMAT'OII 0 FOR ADDITIONAL IFORMATION 2ND Mn -34Al AUGUST MOMTHLY laIs -30Im *1 4,088 1,000 12 8Mh3"/U=S SrXTEMmER MONTHLY 6,765 1O15SUMlLS -31J1111-31TAUM OCTOBER MONTHLY 1.000 IANIOSS -.3]ANOS 7.201 3,000 1? 1I402,/1114i NOVEMBER MONTHLY 4,421 181Ms -Nine 15 U.I46Ult D1D33 MONTHLY 0 10CT65 -310LTM 2,670 0 5,551 6.000 1986 FZRUY IOIILT 2,085 1J@6 -31M166-165-31mam MARCH ONWTHLT 0 17 O13 1 I4 APRIL MON'BLY 1,496 0 2,599 5.000 11336 -W26WS MAT MONIYLT 1,833 13M38 -311U36 17 IWU4141*35 Ju NONTHLY 2,000 1*lt86 -30APM 1,206 4.500 JULY MONTHLY 5,938 1MAY86 -31MAY6 -Wdr MOMMHL 2.000 laul6 -30auft OcUE MONTOLY 4,011 8,000 1JULO6 -3115.66 n olalmitasl 4,935 11,000 OVEMBE IOW'HLYr 3,836 WIM -31U NOVIU= MONTHLY 4,000 36 WW1?*M 3,817 0 3.076 1OCT6 -310CT66 36MOM t. ego 10ST LE= IIiFORMATIONAL NOTICE 0 1NOV86 -3No6 23 6WW14)Istm YTER-NW 10M -3800 7,174 4,000 ION= -3110= 79,955 0 53500 40 Im - Ending cash-on-hand as of 12/31/86. $46,261 >' 0 Debts: $o All reports have been reviewed. a a ., -;p-..-ru' "~& JP & W.V.V"9 ON kw Lbft 44ii- -I . - Tow"r.opw Awreed ftwomn Seem. ftflw m .- b~lesaa * 3 U A40- 4M. lbOV * mmomom dwapult w lm 9 -ft r -tm fr I'_ -. ~ 13 m ~ 0 ~. Va . ******... S ~~ *****.. SO 6649 *ee .. 3 63 B .3 qa f~milm ofovpaie ftQwvftm1wft m 4 - - sonsom Tom Now &"Ium b -Arm" m-PW - m w - lu"Mlmem I I .1 I 0 r'~ ~ ffU~~ ~-. *#777~f Wee~aga~,D.C. 20443 -on w FIR1ST GUINRA COUWSUL' S IDOR? DA?!Z AMD ??HZ Or t9AZITTAL MAO U??ILALS 9N78 , 4W. By OGC To inI COUZSSZON STAFF xNZaU Debrah Cucry SWUM OF HURS 1 T Z A9A LL T 0 2 N 21 AT 2 3331D3US' ANNS: PN.% -&2- Federated Dept. Stores PAC and Russell S. Davis, as treasurer p 0 3-- DZ.ZYUAT STAUTZs: 2 U.S.C. S 434 (a) (4) (3) and 11 CF.l. 104.5(c)(3)(ii) INTWRIAL RWPORTS CEUCZD: Disclosure Reports FEDERAL AGENCIES C1N32C None I. GERA ,?OWoF ATTER This matter vas generated by the Reports Analysis Division (ORADO) after a review of the disclosure reports of the above- named comittees. The RAD referral reveals that the above mentioned comittees and their treasurers, say have violated 2 Co U.S.C. I 434(a)(4)(3) by failing to file the 1986 Pre-General Election Report in a timely manner. ,. FACTUAL AND LEGAL ANALYSTS Attached is a listing of thirty-four (34) monthly filers vhich failed to file a report covering the pro-election period by Election Day, November 4, 1986. (Attachment 1) On September 29, 1986, prior notification was sent to all unauthorized Comittees which specifically informed monthly filers of the requirement to 0file a 12 Day Pre-General Report by October 23, 1966. (Attachment 1, page 137) Each commLttee which failed to submit either a 12 Day Pie-General Report or a November Monthly Report was sent a Non-Viler Notice on November 14, 1986. (Attachment 1, page 139) The following six (6) committees were not sent Non-Filer Notices because a report covering the pro-election period was indexed by November 14, 1986: Federated Department stores PAC - -- 4 The attached printout lists the name, address and treasurer for each comittee being referred. (Attachment I, pages 5-10) Any telephone conversations are referenced under Contacts with Filers. The Sumary Pages of the late-filed reports and/or letters of explanation are included under Reports Filed/Response (s). C" In addition, a "CO index has been included for each M mcoittee. (Attachment 1) Please note that the aggregate V. receipt and disbursement figures may be inflated in some cases because (a) reports were submitted covering portions of the sane period (e.g., a 12 Day Pre-General report covering October 1, 1986 through October 15, 1986 and a November Monthly Repoct covering October 1, 1986 through October 31, 1986), or (b) 1987 February Monthly Reports have been filed. 2 U.S.C. S 434(a)(4)(B) requires that monthly filers file a Pre-General Election Report, covering financial activity from October 1 through October 15, by October 23, 1986. The above * 0 referenced committees tailed to file the 1986 Pro-General .lection Report by the required deadline. Therefore, though the Commission is in receipt of report(s) disclosing financial act vity covering'he pre-general election pe:Lod, such :epo:t s, were not filed in a timely manner. With regard to thirty-two non-filers listed below the Office of General Counsel reComnda that the Commission open Utls and find reason to believe these committees and their treasurers violated 2 U.S.C. S 434(a)(4)(B). With regard to, Association of ?ndependent Colleges and Schools Political Action o Committee ($253 recelpts/O ezp's) and Tramell Crow Partners Political Comittee (0 recelpts/0 ezp's), the Office of General Counsel recommends that the Commission decline to open a MU because of the low aount of financial activity during the pre- • election reporting period. 11I. RUCOOINDMATOwS 1. Open WiRs with respect to those comittees listed in Recommendation 2. 2. Find reason to believe the following comittees and their treasurers violated 2 U.S.C. S 434(a) (4) (B): 2I 0 Ped.ate Dept. Storos PLC and Russell S.
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