This Is the End of Mur I Jl~2
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i I . ....! r " , k ! . i FEDERAL ELECTION COMMISSION WASHINGTON, D.C. 20463 THIS IS THE END OF MUR I JL~2 0D ~~1D EIZCTIO~ p. The above-esc~ibed ,-t.,-- oe fc~ti~ ..... file pursiuant to the fo11owing ex,.;ptio provided i the- 'reedon of " ""iio Ace TSu.$ . Sect ion" 5 2 (b):- (1) Classified:Infor- ti- -I,. (6) Personzal privacy. i!! (2) Internal r 1es and (7)rivest,.gatory i practices ) .,Ex- ed byv othe_ staute (9).1' ell Information :i (4) Trade secrets and co~mercia1 or Cgeographic or -financial information geophysical) (5)"* Internal Doch'ents J L I, datex "I .~" ?EC 9-2!-77 , 4 a ... i ii iz' !J ii ' r i i FEDERAL ELECTION COMMISSION WSHINCTON. D.C. 20463 February 14, 1983 CERTIFIED MAIL RETURN RECEIPT REQUESTED Charles 14. Kerr, Treasurer Citizens for Sarbanes d/o Venable, Baetjer and Boward 1800 Mercantile Bank & Trust Building Baltimore, Maryland 21201 Re: MUR 1500 ., Dear Mr. Kerr: __ On October 29, 1982, the Commission notified you of a complaint alleging that your committee had violated certain S sections of the Federal Election Campaign Act of 1971, as amended. The Commission, on February 8, 1983, determined that on the - basis of the information in the complaint (and information provided by you) there is no reason to believe that a violation C of any statute within its jurisdiction has been committed. Accordingly, the Commission closed its file in this matter. This S matter will become a part of the public record within 30 days. ~Sincerely,. ~Charles N. Steele By: K nnt .Gos Associate General Counsel cc: Honorable Paul S. Sarbanes * w .. .. + Vw +++... +....+ ++' + r+i..+.. FEDERAL ELECTION COMMISSION 6~ WASHINGTON, D.C. 20463 CERTIFIED MAIL RETURN RECEIPT REQUESTED Charles M. Kerr, Treasurer Citizens for Sarbanes d/o Venable, Baetjer and Howard 1800 Mercantile Bank & Trust Building Baltimore, Maryland 21201 Re: MUR 1500 Dear Mr. Kerr: On October 29, 1982, the Commission notified you of a S complaint alleging that your committee had violated certain sections of the Federal Election Campaign Act of 1971, as amended.. The Commission, on , 1983, determined that on the basis of the information in the complaint (and information C provided by you) there is no reason to believe that a violation of any statute within its jurisdiction has been committed. Accordingly, tbe Commission closed its file in this matter. This matter will become a part of the public record within 30 days. +'+. Sincerely, .... Charles N. Steele General Counsel By: Kenneth A. Gross Associate General Counsel cc: Honorable Paul S. Sarbanes '!&%17)~FEDERAL WASHNGTCON, ELECTIOND.C. 20*3 COMMISSION February 14, 1983 REUN RCITREQU/ESTED Lawrence J. Hogan d/o Hogan for Senate P.O. Box 545 Seabrook, Maryland 20706 Re: MUR 1500 Mr. Hogan: ! Dear the allegations Commission has reviewed The Federal Election and determined that on dated October 25, 1982, (and "- of your complaint provided in your complaint the basis of the information there is no reason to S by the Respondents) Act of . information provided Federal Election Campaign that a violation of the believe Act'), has been committed. 1971, as amended ("the th_ iei . hm adecde osekjdcato cls Acrd gl.y th Commissiona complainn The Act allows See this matter. dismissal of this section. review of the Commission's S 437g(a) (8). - 2 U.S.C. attention which information come to your " Should additional a violation ofthAcyumyfla 2 U.S.C. you believe establishes requirements set forth in complaint pursuant to the S 111.4. S 437g(a) (1) and 11 C.F.R. Sincerely, Charles N. Steele General Counjsel/7 Associate General Counsel ' ' 'i . ' . ' . ... i......., - V Y ,J.~. BEFORE TIlE PED3ML ELECTION CO)SQSROu In the Matter of Citizens for Sarbanes MUR 1500 Senator Paul S. Sarbanes CERTIFICATION I, Marjorie W. Enunons, Secretary of the Federal Election Comission, do hereby certify that on February 8, 1983, the Commnission decided by a vote of 6-0 to take the following actions in MUR 1500: 1. Find no reason to believe the Citizens for Sarbanes violated 2 U.S.C. S 434(b) and no reason to believe Citizens for Sarbanes or Senator Sarbanes violated 2 U.S.C. S 441a~f). 2. Close the file. 3. Approve and send the letters as attached to the First General Counsel's Report dated February 3, 1983. Commissioners Aikens, Elliott, Harris, McDonald, McGarry and Reiche voted affirmatively in this matter. Attest: Date Marjorie W. Enumons (JSecretary of the Commission Received in Office of Commission Secretary: 2-3-83, 4 :03 Circulated on 48 hour tally basis: 2-4-83, 2:00 V February 3, 1983 MZMOMANDWI TO: Marjorie V. Emns FROM: Phyllis A. Kayson SUBJC: MUR 1500 Please have the attached First General Counsel 's Report distributed to the Coniission on a 48 hour tally basis as a sensitive matter. Thank you. Attachmet cc : Mims FESRALU~fl~IN CWUISSIOR Q 5:OF- .Th 1325 KI StreetwN.W. CW5T Washington, D.C. 20463 83FfB 3 p4l: 03 FIRST GENERAL COUNSEL'S8EPR DATE AN TINE OS TRNITTAL KURM 150 DY OUC To THU CWUISIOU1 I 3 .--.f . DATE C7INJTI RUCEIZVED SENSITIVE ,,,, CONFPLAINAN'S INM: Lawrence J. Hogan RESPONDENTS' NAMS: Citizens for Sarbanes and Senator Paul S. Sarbanes a ,.. REEVN STAkTUTE: 2 U.S.C. SS 434(b) and 441a(f) INTRA REPOUS8 CHECKED: None FEDERAL AGENC IES CHECKED: None 0Y S0U!ARY OF ALEGTIONS8 This matter is in all pertinent respects identical to the central allegation made in MUR 1486. (In that matter, Citizens for Sarbanes was also made a respondent). Complainant here .,,merely reiterates the assertion made by the complainant in MUR S 1486 and seeks to ensure that Senator Sarbanes and Citizens for Sarbanes are included in MUR 1486. No new facts or legal analysis is presented by Mr. Hogan. FACTUAL AND LEGAL ANALYSIS An in-depth analysis of the activities of the Council for a Livable World as they affect the Sarbanes organization is presented in the MUR 1486 General Counsel's Report circulated -2- " this same date. There the General Counsel recommends that the i Commission find no reason to believe the candidate committee respondents violated 2 U.S.C. SS 434 or 441a(f). For the reasons stated therein and due to the lack of any additional factual data or legal analysis in Mr. Hogan's complaint, the Office of General Counsel recommends that the Commission determine there is no reason to believe the Citizens for Sarbanes Committe violated 2 U.S.C. S 434(b) and no reason to believe Citizens for Sarbanes , or Senator Sarbanes violated 2 U.S.C. S 441a(f). __ Recommendations 1. Find no reason to believe the Citizens for Sarbanes violated CO2 U.S.C. S 434(b) and no reason to believe Citizens for Sarbanes or Senator Sarbanes violated 2 U.S.C. S 441a(f). 2. Close the file. 3. Approve and send the attached letters. _______________ Charles N. Steele Date General Counsel By: ._ _ _ _ __ _ __,_ _ _ _ Kenneth A. Gross -' Associate General Counsel Attachments 1. Response to complaint 2. Proposed letter to Lawrence Hogan 3. Proposed letter to Citizens for Sarbanes E, .."J~RANDfOWARD 83 JAN 14 PtI: ATTOMN IYi AT L.Aw i3 -* A PAtTNERSNOP SWIUON@ P6@r66IONA. COSPORATroNS 1600 M3SCA~mLC SIAl • TmwgT Sua.wo O630O P. O*bo mI.TIM@E. MAS.YLAND I101 *0 U .U *000w 0 dO.. (3@.~3.474*@ 000 w. pII. € 0o) I-IMO0 oI 050£l 6060 .a0* 6 . : esos. o A. 00*30 0A.6., 60666 a,.I 066. P060 0*0i0 S. *00*0W VENAIE SAUI..DO N@0WAR. a COVsiZY • amo.. m6 05Mm .UIn660~A OlO. , ..* .oodevuI Il 6306 P3NNSYWAN AV.SlUO. N. W. mm 30*09556. dO OSIabO . 03. AO. 06656.0. 0*000* SEW. d06W96 ..e o -.gg 9 0 I, . 0966 6o 090 . OUoHpoP. ,,. 9b5mis 66963 g. ~* . ibIOa i6o0g . i0gol° I * dl., 60.. 005 o II II N II*I 0 0W 9 .069060 AEbbSI .eemuI 605eoI0. oaevlu. ogI-Ietl u @0*00 30 050. og0*0 [email protected] walin0g 60066 N0003 0 244-7544 January 12, 1983 CERTIFIED MAiL/RETURN RECEIPT REQUESTED AssociateKenneth A. General Gross, CounselEsquire Federal Election Commission Washington, D. C. 20463 Re: MUR 1486 L1500 Dear Mr. Gross: This letter is written in response to your letters of October 22 and 29, 1982, advising me, as treasurer .of Citizens for Sarbanes (the "Sarbanes Committee"), of the above-referenced complaints, and is intended to serve as the Sarbanes Committee's response. With regard to MUR 1486,. the Complaint filed by The Washington Legal Foundation does not name the Sarbanes Committee as a respondent. The Complaint does appear to allege, however, that the Sarbanes Committee received in-kind contributions from the Council for a Livable World attributable to fund-raising costs which have not been reported by the Committee and whiich have a value in excess of'the $5,000 contribution limit applicable to multi-candidate political action committees. The other allegations made in the Complaint appear to be directed to CLW and the other named respondents rather than the Sarbanes Committee. MUR 1500, Kenneth A. Gross, Esquire January 12, 1983 Page Two filed by Senator Sarbanes' Republican opponent in the 1982 - Maryland general election, Lawrence J. Hogan, likewise appears to be addressed to the reporting of in-kind contributions to the Sarbanes Committee .by CLW. Although neither complaint is particularly clear on the point, both also appear to question the CLW practice of collecting contribution checks made to the Sarbanes Couuaittee and forwarding those checks to the Sarbanes Committee.