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
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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
KennethAssociate A. General Gross, EsquireCounsel 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. As to the latter point, the Complaint filed in MUR 1486 appears to concede that CLW's collection of checks ¢" tO candidate committees for forwarding to those committees ~was previously considered by the FEC in MUR 1028 and found not to be objectionable. See MUR 1486 Complaint at p.8. -- The Sarbanes Committee has n-'o reason to beli.eve that contributions it has received in this manner violate either ~the applicable statutory provisions or regulations. With regard to in-kind contributions from CLW to the Sarbanes Committee, our Committee has reported the in-kind contribution made to it by CLW as it has been o notified by CLW of such contributions. Enclosed, in that r regard, please find copies of the following correspondence: 1. Letter from CLW to Sarbanes Committee dated January 21, 1982, advising of in-kind contributions totalling $1,164.92. 2. Letter from CLW to Sarbanes committee dated April 9, 1982, advising of in-kind contributions totalling $7.82. 3. Letter from CLW to Sarbanes Committee dated July 8, 1982, advising of in-kind contributions totalling $14.00. 4. Letter from CLW to Sarbanes Committee dated October 18, 1982, advising of in-kind contributions totalling $256.36. I"
Kenneth A. Gross, Esquire January 12, 1983 Page Three
,So far as the Sarbanes Committee is aware, in-kind contributions to it from CLW have been fully and fairly accounted for. The Committee has no way of independently verifying these figures, nor does it have any reason to believe that these sums are not correct. Please let me know, at the address and telephone number set forth on the letterhead, if our Committee can provide any further information you require in considering these complaints.
.r .r Kerr reasurer, Citi ens for Sarbanes
CMK: rmc Enclosure
a~ I~Y~ Senator Paul Sarbanes Jau.e 2__,. ,'. Citizens for Sarbanes Ctfuc~ff wlr P. 0. Box 10644 * ncil Baltore, Maryland 21204 Dear Senator ra Sarbanes: ivable in-kind The Federalto CitizensElection forComission Sarbanes vill.auouncin be notified g to $1,164.92 of .coutributions- for the period July 1 - December 31, 1981.
Beacon Stresi The sum is itemized thus in the FEC rep~ort: :szo. Mass, 02106 acne: (617) 742.4395 $102.70 out of $2,465.00 expendture to Mass. Envelop. EORGE K6V ,Kw5~y Company, P'. 0. Box 3871, Boston, MA 02241.
,m .owm $6.66 our of $40.00 expenditure to Aztech Corporation, .Mary~an venueNE 1621 Connect:icut Ave., N.W., Wasqhington, D.C. 20009, ast~Wggn0C 02 '* for label printing. 9ione: (202) 543-4100 I .* , ) c"I $61.79 out of" $873.85 expenditcure to Azr:ech Corporaton, OA,:OO OIETR -.. as above. :e Ve /$555.l9 out of $1,702.79 expenditure t.o Cantrell/Cutter, .A.LEN -'99 Co. Capitol St., S.W., Wash~ngron, D.C. 20003, for E;dA j pr±nri~g.
,'/$295.58 out of $886.75 expenditure to S & S Mailing," ROME FRPLJ( J5171 Lawrence Drive, Eyatrlsville, 20781, for
- ,N K!JNl4E7H GALSAIIIh • mailing and postage. "15.64 out of $119.10 expenditure to pett cash for
; CRGE K.sTrLA cKKY |posage,11/9/81..
OMIRAL .10MN U. LEE £ Net), (Repgwj '3. i$13.53 out: of $50.00 expendture to pet cash frpsae AiTHE[W MES!LISOtJ " -0/22/81.."1 UMES PA O0N
liNEPOKORNY $15.75 out of $250.00 expenditure to GPO BoStOn, Permit Fee Window, G. , Boston, HA 02205, for Business Reply \ o0. Envelope account, 11/23/81. EDWARD PURCELL E.CRGI RA?.HEp4 $98.08 out of $500.00 expenditure to GPO Boston, as J SAGA above, 8/4/81.
Please call with any questions you may have.
SIIiEiv£ ThOMA S Sincerely, ICOSTA ,7SI-- S
P,.:;C. WAANIKE
-Z ~ 3. WINER Catherine Clark Asst. Executive Di: V
/ *
April 9, 1982
Senator Paul Sarbanes Ci.tzens for Sarbanes P. 0. Box 10644 Baltimore, Maryland 21204 ivable Dear Senaor Sarbanes:
The Federal Election Comi ssion will be notified of contributions- in-kind to the Citizens for Sarbanes amounting to $7.82 for the SBeacon Sno . period January 1 - March 31, 1982. Osbon, Mass. 02108 hone: (617) 742.4295 The sum is itemized thus in the FEC report: EROME[ GRqOSMAN $7.82 'but Qf $50.00 expenditure to cash for petty cash. :AMERINE. L.ARqK
00 Maryland Avenue. N.E. Please call me with any questions you may have. 'thone: (202) 543.400 S incerely,
BOA8 ) OF DIRECTORS tUTMI ADAMS Catherin~e Clark Asst. Executive Di.rector CC mb
.IAAUACE POAN
JE~rO!wPRA.S[.O ,m -
GEORIE KSTOWSIC uri.nOry (AW*
GENE SOKRN
EDWAR P.WRCE hwmUr w GEORG.s RAxwhJSnS O
QbIr~ 1)p~ : ,4 , i . / , , ,, .i Z
co.' t A fl July 8, 39.82
Senator Paul Sarbanes Citizens for Sarbanes P. 0. Box 10644 .ivble Baltimore, .' 21204 SVorld Dear Senator Sarbanes: pson. Mm. 02106 The Federal Election Cownission'will be notified of contributions-in-kind to the Citizens for Sarbanes amounting to $14.00 for the period of April 3.through MlIdGROSSMAN4 June 30,"*1982.
thus in the FEC report: May 4and Aveflue. N.E. The sum is temized isw;Vz. 0.C. 20002_ no: (12D2) 543-.4100 $6.67 out of $500.00 expenditure to Postmaster, Boston, Permit Free Windov, GII, Boston MA 02205, A: OF DIRECTORS for BRE account. $7.33 out of $250.00 expenditure to GPO, Boston, Stare House, Boston MA 02108, for postage.
Please call me with any questions you may have. ijR'.I FOX Sincerely,
I .
Catherine Clark Asst. Executive Director p"' P 14oTI GA5RT CC:mb
ERAL.RJC. .L.
Fgnme &hme'n INS~aPS ICSN R.E. C. Sq SI=:P.wl~
~4~flNg 'Jf~' . October 18, 3982
menace Cic:ens for Sarbanes oe~ciearww P.O. Box 10644 ~ncil Bltimore, MD 21204
Dear Senator Sar:banes: notified of atributiols- The Federal Election CommiLssion will be amounting to $256.36 in-k:ind to the Citizens for Sarbanes camPaiign 13, 1982. for the period October 1 through October" lescon Street gon. Mas. 02tOS8 742-93g5 nel: (617) The sum is itemiLzed thus in the FEC r:eport:: au of $6,18O.58 expenditure to Mssachusetts $256.36 M TOu.E ROSSAN Envelope Company, 30 Cobble i iU. Pload, Somerville, 02143, for envelopes. DM Man Avenue,, N.E. ts,.0DC. 20002 54."0).3.4, 00 with any questions you may have. MN SAA.CSe Please call me DARD OF DIRECTORS
Sincerely, I35P,,tS •
Ass t. Executive Director I9ud)3E rnI~t
MR,% U. LE
EFSPATTON uw ammw3 Lm
£EOORKYAl pm RLS PRCEN
ce , a.T :t.IVM AROPUCEL
ORI RAYSS 1'T SAGA.€.WN E )
.Jamaary
* Senator Paul Sarbanes Citizens for Sarbuites To wW 3NWS P. 0. lox 10644 Ola--
Dear: Senator Sarbane: for a of coutributl The Federal Election Coumissiot wil be notified ons- $1,164.92 for tb ~~in-kind to Citizens for Sarbanes amountilng t~o Y oxdperiod July 1 - December 31, 1981. n The sun is itemized thus in the FEC report: n Becn 02106 Boston Ms to Mass. Envelope Phone: (51 77.43 " $102.70 out of $2,465.00 expenditure Boston, MA 02241. Cnm Company, P. 0. Box 3871, of $40.00 expenditure to Aztech Corporation, A EebCA,*E CLARK 6.66 out Ave., N.W., Washington, D.C. 20009, 100 ,M nd~*m, . 1621 Connecticut W00shingt Aonu.. 000 ( for label printing. PhoR* (202) 543-4 .00~ $873.85 expenditcure to Aztech Corporation, BOARD,.,OF0RETR L i /$61.79 out: of" ....:.as above. $555.19 out of $1,702.79 expenditure to Cantrell/Cutter, s.IWAwwsmm ";" St., S.W., Washington, D.C. 20003, for MCMAILALLN ./499 Co. Capitol
BEANARO FE.O printing.• ROGER FtSNER ,,uA, ~r~ox$295 8 ouCof $886.75 expenditure coS 6 S Mailing, fyattsville, MD 20781, for A.r RNJ 5171 Lawrence Drive, o ,, m mailing and postcage. of $119.10 expenditure to pecty cash for jiOME GROSMA .J$15.64 out
cash for post o- ... , 3.53out of $50.00 expenditure to pecty age,
Reply CDMP~v , Fee Window, GMF, Boston, MA 02205, for Business u,,,,,,, e..,, }Envelope account, 11/23/81.
P Bsoa aGEORGE RA11E5$8.8otof$0.0exedtret
ERET SCOYLLE AF questions you may have. MNc w Please call with any JANE SNARP Sincerely, c~ m,
C a r. " -rKOA 1T1Pt5 Catherine Clark* PAUL.€.wA~lKe Asst. Executive Director JEROoES WSSNURe i, . & , MU UU:mD (t4f~1UVEWL~~J~ ')I'1 0 FEDERAL ELECTION COMMISSION WASHINGTON, D.C. 20463
Lawrence J. Hogan d/o Hogan for Senate P.O. Box 545 Seabrook, Maryland 20706 Re:= MUR 1500
- Dear Mr. Hogan: the allegations Election Commission has reviewed TheFeeral 1982, and determind_ ha o-n your complaint dated October 25, . of provided in your complaint (an the basis of the information there is no reason to rovided by the Respondents) Campaign Act of infomaton violation of the Federal Election bieveohata~ has been committed. ? 1971, as amended ("the Act"), in has decided to close the file Accordingly, the Commission to seek judicial hisAmate . The. Act alws a complainant t of thsscin See review of the Commission's dismissal U.S.C. S 437g(a) (8). 2 which information come to your attention :"" Should additional Act, you may fsile a establishes a violation of the S you believe set forth in 2 u.S.C. complaint pursuant to the requirements S 111.4. S437g(a) (1) and 11 C.F.R. Sincerely, Charles N. Steele General Counsel
By: Kenneth A. Gross Associate General Counsel FEDERAL ELECTION COMMISSION WASHINGTON, D.C. 20463
CERTIFIED MAIL RETURN RECEIPT REOUESTED
CitizensCharles M.for Kerr, Sarbanes Treasurer d/o Venable, Baetjer and Howard 1800 Mercantile Bank & Trust Building Baltimore, Maryland 21201
Re: I.UR 1500 Dear Mr. Kerr:
complaintOn October alleging 29, that1982, your the cotuuitteeCommission had notified violated you certain of a S 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 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,
GeneralCharles CounselN. Steele
By: AssociateKenneth A. General Gross Counsel
cc: Honorable Paul S. Sarbanes 83 ~'...... *.' ,E. DBA,,TJR AD HOWARD.
CoRPORAT A pARNERSIIIP INCLUSING P@VSSI@"L
wOW .5 . 6Owe O5341aP _____. samO~o. 5. i SieMl MARYLALNO 31301 e As5 . 50.C, yg..wv ,. ewaba. SALTIMORE. a. AOH. '.5 goOl S. SUlm (90) 344.7400 'a* B. 01eegueS A. UA0SN SrSAV 'W . t.g~gOPlY WS A I. r _ g, UgMEoNr o. MlE ICE A. SWVUg,4a W, l. D. C. OPP wASMINOTON, TI SAi~ETJl. HOWAPOI S CIViLE -a g.a.w... 5.5.mw QINgy 0156r6. 06 W ~~VENASLE, v s.' .s.5S- 704 SUITE[ L .asaaam m S.dO-- 0. AVEUE. N. W. gwmYS w.. MSS .oegO O.US 13O1 PD3NNSYLVAN guomir a.. oOS5e~ ee,,4a.A YAS'w. p.. 3000OOC .M04 WASHINGTON. oSamE a. 5gwl P5S. e@tSYlIn D. sa *guAN . AMilE9 PS a|Ol) 7.3.-300 ag.., ~gA .SbA* T E s.. mVILI EISPw.mmOI - as.l *U.*U o. oAYS, a EANOS . O. wegus~lei. OM st"gw WY. 5m , , lr, l. . grr a.m SW .6l'l . .*e*" SY A iN Veg, _ . Ps.MSaWS N A. 55W sELml *A.OEU WYaaWS S AShN t,.sVlAU ses s. 055.5,le . WA4m'aS £U8SW~ . o. 65055WOPPUW U.
um .ES gESoO5_
. IINll N. PSYDS SISNASO5. o,.UASYJESl vS5A OAEl iNNi56)L gegSlO0) aneW00o l I DW@-'~E~ CwAls.SS Woo. oOe, wfeYWS244-7544 gPS5 aUNSSNulIS0
January 3.2, 1983
RECEIPT REQUESTED CERTIFIED MAL/RETURN
Kenneth A. Gross, Esquire Associate General Counsel Federal Election Commission Washington, D. C. 20463 Re: IUR 1486L1500
Dear Mr. Gross: to. your letters letter is written in response treasurer of This advising me, as 22 and 29, 1982, the of October Committee"), of (the -Sarbanes for Sarbanes serve as Citizens is intended to complaints, and above-referenced response. the SarbaneS Committee's by Complaint filed to MUR 1486, the With regard not name the Sarbanes Foundation does Washington Legal does appear to The The Complaint as a respondent. in-kind Committee Committee received hattheSarbanes attributable allee, oweer, Livable World thet Conclfoe by the contributionsfrom otonot been reported rmhcosts whichoni have cotiuinfund-raising of the $5,000 a value in excess and which have political Committee to multi-candidate limit applicable in the contribution allegations made The other other named action committees. to CLW and the appear to be directed 1500, Complaint committee. MUR than the Sarbafles respondents rather ,, V . / . % .
Esquire Kenneth A. Gross, January 12, 1983 page Two
opponent in the€nise: 1982 n filedbySeator sable' Republican . Hoan i-ken onr. tO election, Larene Maryland general to the reprtngoi--idAlthough neithercomplaint apea so be addressedCom-ittee- by CLW. topteSares aloar to" poit bot eto ceCkS arlY clear on the c onti ispri~ ractice of collectlg thoeh*k questi clth CL ----Co ttee and forwarding mae ton the Sable Committee- to the Sarbafles filed in the Complaint of checks to the latter point, CLW'5 collection As to concede that comir~Uttees MUR 1486 appears to those commi.ttees for forwarding I4UR 1028 and found to candidate by the FEC in p.8. considered 1486 Complaint at wspreviously SeeMU~tR to believe ta not to be objectionlable-has no reason either Sarbafles Commi.ttee this manner violate oThe has received in contributions it or regulations. statutory provisions the applicable CLW to contributions from regard to in-kind has reported the with our committee been SarbanleS Committee, by CLW as it has the made to it Enclosed, in that in-kind contribution contributions. by crW of such correspondence: notified copies of the following regard, please find dated to Sarbafles Committee Letter from CLW totalling 1. of in-kind contributions 21, 1982, advisinlg January dated to sarbanes committee Letter from CLW $1,6422. contributions totallinlg advising of in-kind April 9, 1982, dated to Sarbanles Committee Letter from CLW totallinlg $7.2.3. of in-kind contributions Zuly 8, 1982, advisinlg
$140u.4. Letter from CLW to Sarbanles committee dated October 18, 1982, advis5ing of in-kind contributions totalling JanuaryKenneth A.12, Gross,1983 Esquire Page Three
So far as the Sarbanes Committee is aware, in-kind contributions to it from CLW have been fully and fairly accounted for. The Committee has no way of independently verifying these figures, nor does it have any reason to believe that these sums are not correct. Please let me know, at the address and telephone number set forth on the letterhead, if our Committee can provide any further information you require in considering these complaints.
reasurer, Citi ens for Sarbanes (Jr s Ke
0D CMK: rmc
Enclosure ii Ja .ry2, t R+~
Senator Paul Sarbanes Citizens for lSarbanes L njc e' mer P. 0. Box 10644 • ,,,. Baltimore, Maryland 21204
Sora Dear Senator Sarbanes:
The Federal Election Coiission will1 be niotified of.comtr~butio g- in-kind to Citizens for Sarbanes amounting to $1,164.92 for the period July 1 - December 31, 1981.
Beacon Street. The sum is itemized thus in the FEC report: sion. Mass. 02106 t~Cne: (617) 742-9395 "/$102.70 out of $2,465.00 expenditure to Mass. Envelope Company, P. 0. Box 3871, Boston, MA 02241. .ROME GROSSMAN
DMEl~lnAvnu.N.E. 1621 Connecu~cut Ave., N.W., Washington, D.C. 20009, ~&hntn. D.C. 20002 * for label printing. 3sI "EC~0hrE~22) 543.41 i . , $,,6.66our of $40.00 expenditure to Az tech Corporation, [). ~~c i$61.79 ou., of $873.85exp,editure t:o Aztech Corpora tio,. OARD OF DIRECTOR- ... as above
,c .e ,/$555.19 out of $1,702.79 expenditure to Cantrell/Cutter, QJtCn. (C21V'tIl q p LU~I .l ,t r printing.
* ,$295.58 out of $886.75 expenditure to S & S Miailing, J/5171 Lawrence Drive, Hyatsville, MD 20781, for mailing and postage. S5.64 out of $119.10 expenditure to petty cash for V'" 4srg ,\11/9/ posage- 81..•
AUE.. PRaaA, .a £woaesrw. [3 j13.53 out of $50.00 expenditure to petty cash for postage, 1z, ATENEW UESELS t4
AMES4RPRCTIO Fee$15.75 Window, out ofGMF, $250.00 Boston, expenditure to GPO Boston, Permit / MA 02205, for Business Reply GEN EPO c m,'S Envelope account, 11/23/81.
m1E5r, P E ' L.J $98.08 out of $500.00 expenditure to GPO Boston, as above, 8/4/81.
£c'R' PAlNTP*..;S Please call with any questions you may have.
;;;,s Cj.r, AKEa Sincerely,
.E=.AM I. wTSSNEW LaenEac.' . Catherine Clark Asst. Executive Director CC:mb w 1:/:: : :,.: :/ :!
AprilZ 9, 1982•
Of ,' Jclea v t Senator Paul Sarbanes Citizens for Sarbanes P. 0. Box 10644 for a ~Baltimore, Maryland 21204
Livabie Dear Senatr Sarbanes:
The Federal Election Comzuissi.on will in-kind to the Citizens be notified of contrib~tio - IIBeacon Sirsel for Sarbanes mounting to $7.82 for the oston. Mess. 02108 period January 1 - March 31, 1982. : ne' (617) 742.9395 -OGKZSTkhKOWSKY
ROuS GROSSMAN The sum is itemized thus in the FEC report: CAThERI CLARK $7.82 out Qf $50.00 expenditure to cash for petty cash.
100 tIt~,andl Avenue. N.E. Please call me with any Wa, ington, D.C. 20002 questions you may have. hona;. (202) 543-4100 OH 5rAACS Sincerely,. BOARD OF DIRECTORS RUTh @ MS 6?4~ SALLEN
BERNiARO FELO Catherine Clark U7, Asst. Executive Director CC:mb
'o ~ Ur~w y
JO,4N KENNE'PH GALSERAITh
.IEROM GROSSMAN a..s ss £ec..ive CEC KlSTAKOWSKY RirvaI Ufl'efW?1 .#,OMI.AL. JOHN M.LE U.S Navy Itwe) MATTHEw MESELSON Mrua, uwy JAES PATTON
GENE POKORNuY
CAkRL-ES PRICE Iwwhy 1Pa EDWARD PURCEkJ. - nm-vm GEORGE RATHJEPJS
Eu SAGAN
HERBERT SCOVUL.. JsA
WIL.LIAM E 7;ARLOW SIbnsa Eae *v STEP41EN THOMAS tKOSTA TS"PI
PAUL. C. WAnNKE A Onsy JEOEE ISE Scombt rhe IW Of tu.?Uf tl July 8, 198.2
Senator Paul Sarbanes Citizens for Sarbanes S'ble P. 0. Box 10644 Baltimore, )D 21204
Dear Senator Sarbanes: Beacon Sweet mon. MaSs. 02108 fle: (617) 742-9395 The Federal Election Commission'will be notified'of EORGI. KITKOWSKlY contributions-in-kind to the Citizens for Sar1baues [ROMi GROSSMAN amounting to $14.00 for the period of April 1 through June 30, 1982. £oc~ew O~ DMa?~in Avenue. N.E. The sum is temized thus in the FEC report: a'uhingl,,n, D.C. 20002 * oflO,.202) 543.4100 $6.67 out of $500.00 expenditure to Postmaster, Boston, Permit Free Window, GMF, Boston MA 02205, IOARD OF DIRECTORS for BRE account. u'. ADS S7.33 out of $250.00 expendirure to GPO, Boston, EtIARD FELO State House, Boston MA 02108, for postage.
Please call me with any questions you may have.
Sincerely, H KENNETh GALSRA(T.1 1** •.RtCMS: GROSSMAN J.~. ,'~ ii.- C: C> :. :RG .STA OwS KY a'a¢Urneiny Catherine Clark OMORAL JONN U. LEE Asst. Executive Director CC:mb MES PATON ol..,U Famm.t Un5 IENE PCORNY KARLES PRCE
O WARO PURCJL ,DbtIO Uflw.Slly fEORGE RATNJENS L-'SAGAN
• ER.EE'T SCCvLLE. JR,
,..,LIA £ A..O
T1EPHEN ThOMAS
[OSTA TS PIS
;AUL. C. WARNKE V
OctobtT 18, 1982
ccrf. Lt ie meflh of n ,cJear wet P.O.Cit:izens 3ox for1064 Sarbanes 3altimo~e, HD 21204
Sar:bales: Dear Senator contributions- will be notified of Federal Election Commission mountiLng to $256.36 The for SarbafleS campaigsn in-kiLnd t~o the Citi:Lzens 1982. ri 1 h~ough October 13, for the period October Beacon Street FEC report: ston, Mas O210OS itemized thus in the one: (6'7) 742-4395 The sum is to Massachusetts G;REK.ISI,&KOWSKY of $6,180.58 expenditure MA $256.36 out Road, Somerville, C,E GROSSMAN 30 Cobble Utill Envelope Company, 02143, for envelopes. t.?LyW. ADvenue. N.E. may have. any questions you Please call me with N ISACS .icrey 3AR6' F DIRECTORS Sincee ,4£ELL.IN ~NAPD FE.O Catherine Clark Asst. EcecutiVe Director
Rt.PE FR&NK
n,?,.KEfNTH GA,.SRAtrH
.v, ,G£RCSSMAN QOQfS WOWSCY
UA,RAL,. JO*IN M. LEE Tr H~w UESLS.ON
ME.S PAITON
E P0O(ORNY
ARL.ES PRICE
ANR=PURCELL
[ORGE RAThJENS
ERBERT SCOVULE. JR.
NE Se.4ARlP
MLIM F. TR:.OV
£PE Th bIAS
ACt. 2 wtESNER J \lar 11 ' R
* Senator Paul Sarbanes Citizens for Sarbanes To wim~ em nwmin P. 0. Box 1064 Baltimnore, Maryland 21204 foa Dear Senator Sarbanes: The Federal Election Coirmission will be notiLfied of contrLbutiLons- in-id to Ctizens for Sarbanes amounting to $1,164.92 for the period July 1 - December 31, 1981.
sum in the FEC report: 11Beaoon S8eet The is itemized thus Boston. Mass. m0o Phone: (61?) 742-9396 " $102.70 out of $2,465.00 expenditure to Mass. Envelope GEORGE KSThIOWSKY Company, P. 0. Box 3871, Boston, HA 02241. .IEOU GOSM A cAheR,,,E cLARK $.,6.66out of $40.00 expenditure to Aztech Corporation, - 1621 Connecticut Ave., N.W., Washington, D.C. 20009, 100 Msrnr md Avenue. N.. for label printing. Washington. D.C. 20002 .. PhoI. (202) 543-4100 .. Jo.s N ( )1 /$61.79 out of $873.85 expenditure to Aztech Corporation,
8OARD OF OIRECTOR -... ;: as above.
8&IWAAR8*II j 55.•19 out of $1,702.79 expenditure to Cantrell/Cutter, ALE ./499 Co. Capitol St., S.W/., Washington, D.C. 20003, for esMROF0 printing ROGERq USHER ,u~smx,'$295.58 out of $886.75 expenditure to S & S Hailing, JE/T' FRN 5171 Lawrence Drive, Hyattaville, MD) 20781, for
Jo"0W~lWUIJmaling an postage. .MJSHKENNETH GAI.RAIH, /- '...g LoeoJ 1.6 u £ 1910epndtr o et cs o
GROSSMAN . 15.64 out of $11.0 expenditure to petty cash forpot GAnEKSTAKOsKY ' osae0/2 811//1 ige,
w, mu ' $15.75 out of $250.00 expenditure to GPO Boston, Permit cm. / IFee Window, GZ)f, Boston, MA 02205,-for Business Reply S~PsCEum .'.' Envelope account, 11/23/81.
MaeoRGERAT.5t4r -(.V)I', 3, $98.08 out .Of $500.00 expenditure to GPO Boston, as
ELI SAAN above, 014101. I4ERSERT SCOVLLE, JR ADRs Cwnl Aao.in Please call with any questions you may have. .hANE SH4ARP WILLIAM U. TARLOW Sincerely, STEPHEN THOMAS
T~SPe KOSTA &tt%~ MIT C(A PAUL C. WAR;NKE Catherine Clark Asst. Executive Director JEROME S.WESNER *41 CC :mob FEDERAL ELECTION COMMISSION WASHINGTON. D.C. 20463 October 29, 1982
Mar jorie W. Euuuons MEMORANDUM TO: George Demougeot~ FROM: 1500 - Expedited SUBJECT: MUR i . Please have the attached Memo to the Commission "distributed to the Commissionl on piak paper per expedited procedures. Thank you.
I Attachment WASHIGTON DC'8 OT29~ P3: 20
October 29, 1982
MEMORANDUM TO: THE COMMISSION PROM: CHARLES N. STEELE GENERAL COUNSEL ~BY:KENNETH A. GROSS KV-, ASSOCIATE GENERAL COUSE
SUBJECT: COMPLAINT RECEIVED - MUR 1500
~On October 28, 1982, the Office of General Counsel ~received a complaint from Lawrence J. Hogan which alleges that Senator Paul Sarbanes' committee violated 2 U.S.C. i, SS 434 and 441a. oD Specifically, the complaint sets forth allegations essentially similar to those stated by the Washington Legal F Foundation in MUR 1486 (that the Council For A Livable World o undervalued in-kind contributions associated with its fund raising efforts on behalf of Senator Sarbanes). Letters notifying the respondents have been sent. This ~is a matter which we believe warrants awaiting responses of the persons notified. Our Office will make a recommendation to the Commission regarding the merger of the two MUR's together with substantive recommendations upon receipt of the responses in both matters. ':s B0x 545 pZ: ~3 82 OCT2Z9 P3: 19 sEABooK,M
October 2g., 1982
Mr. Frank Reiche .. Chairman Federal Election Commission 1325 K Street, N.W. Washington, D.C. 20463
Dear Mr. Chairman: I am hereby filing this complaint against Paul a candidate for the office of U. S. Senator S. Sarbanes, Sarbanes, 1600 Mercantile Maryland, and Citizens for from Place, Baltimore, and Trust Building, 2 Hopkins violation Bank to 2 U.S.C. Sec. 437g for Maryland 21201, pursuant re- of 2 U.S.C. Sec. 441a artd the contribution limits of U.S.C Sec. 434 by undervaluinlg requirements of 2 a Livable porting made by the Council for the in-kind contributions World (CLW). interest for a Livable World, a special Council has, by soliciting earmarked political action committee, candidate, been avoiding contributions for a specific law's $5,000 contribution ._•2 qr with the election 1982 compliance Events of September 25, limits. According to Human Sarbanes $36,500 or according CLW has raised for Senator In effect, Co Post of July 28, 1982 $23,200. to the Washington fund raiser for eight has been acting as a professional CLW requiring those candidates candidates without actual senatorial fund raising. Were the to pay the full costs of be assessed to those candidates, costs of fund raising to the in- be reporting far more than Senator Sarbanes would reports. It of $1,164.92 shown on 1982 kind contribution so, any excess the $5,000 limit and, if may well exceed Commission should be refunded. Further, the should whereby CLW can evade immediately stop this procedure should Still further, the Commission contribution limits. since these contributions received ! order the refund of all unlawfully. contributions were generated
of October 18, 1982 (attached)It has inbeen the broughtWashingtonl to myTimes attention by an article Foundation ha ied a complaint that the Washington Legal the position against CLW. I support its with the Commission Legal Foundation. However, taken by the Washingtonl and not against the recipients complaint is against CLW
PHYLLIS DALLEY. TREA5URE BY AUTHORITY HOGA FOR SENATE, Page Two of the contributions. My complaint, though similar in nature, is against Paul S. Sarbanes as recipient of contributions. CIW has been following this practice of soliciting earmarked contributions for a number of years. In."fact, it was six years to the day in 1976 that Senator Sarbanes reported a contribution-in-kind in the amount of $2,778.37 from CLW. It was noted that this figure was "the cost of mailings". Considering the increase in postage rates and the fact that the 1976 contribution was over twice that of 1982, I would certainly question the basis for arriving at the contribution-in-kind figure. I have seen publicity concerning CIW which states it has "a unique way of backing words with political action and resources," ie. the distribution of $2.2 million to t those senatorial candidates who support its objectives. Another quote,"In addition, the group (CIW) avoids the -- $5,000 primary and general election contribution limits for PAC's because the money doesn't come from the eounci 0 itself".
GO It is obvious that if all PAC's adopted CIW methods it would make a shambles of our election laws and reports of contributions would become incomprehensible fiction.
I trust the Commission will investigate promptly "this complaint. "-" C Sincerely,
Lawrence 3. Hog
Enclosure
Subscribed and sworn before me this ..?. day of October 1982.
JIL ~&~cZX~ 8.30 40 I 5 I.
.. , , .
undin viol tion whichsuch the as committeesdeveloping mailing list - laid to peaelbbwsthonbalofroincur in their By Tamdiazualdarr N~bIINGTNawsI ee af il ed oa izae - L Acc+ord nlyo h complaint, pUlic interest law firm has ve bleWold(CLW ).t CLW charged cal Action Committee e ea e al|- h n be several iPro-nuclear freeze and the Nuclear n atCIAV supports iction political Freeze Pol|itial candidates and Peace Senate s caofltees and their Action t'ommittee. PAC supports officers The foundailmn House candidates (Nuclear with violating asked the F'EC to not Freeze is III federal election affiliated with I! laws impose civil penalties the other two whtile channeling campaign of front 80,0 grUps). funds to to $3 mill ion against the i'('nnni.... .,
i m cadidt...... "'leSl~e~dill: ('"f"idaUs - -,.,u5Cs fundsand to rettih 'Washington iLegal Foundation caomitie John lsaacs, legislative director chiargetd in a complaint filed CLW, said ot of l~'deruJl with the Paul W Juir( candicl;gmes to return any behalf of CLW, Peace PAC, l'lectii,i Commission that cy have ,and their officers colinittees the Arms C recci~'ed from the that, "The comp~lalit have not filed required 'Cs' was filed two weeks before reports and have not Agcy the eleutiton the properly declared his capac arnkc, formic director simply as harassment." value of their "in-kind" services Uiitrcl of the candidates to chairman and l);sarmameglt lsaacs also said such as senators Paul Sar- 'as named that the FEC has banes, l).-Md.. "i'd William E in ilie cumplaint in already ruled on the pro-freeze Kennedy D.-Mass. and ity as a director fundraising groups' and hioward Metzenbaum, Jeron of CLW and methods and found D.-Ohio, and" treasurer of the Peace ~ along legal. But them congressmenj Mike Barnes, with Paul Kamenar, the founda- Barney D.-Md. and istered Thrlow, treasurer tion's direetoir Frank, D--Mass., among lot'he of CI.W, of litigation, said that others. The foL (rossmaI~ president and the FEC ruling 'The complaint - to which filed last Friday - and of Peace PAt and referred Issacs asked the i"EC to conduct Peace CLWs reg- does not cover either the a "'complete laws by f,'byist. ure fail- to report the full value of inda; ion charges that (21W contributions, in-kind or the report fling vio- PA~ have 'nilated election lations alleged in the complaint. ailing to repw't as in-kind "WASHINGTON. D.C. 20463 ~FEDERAL ELECTION COMMISSION October 29, 1982
Mr. Lawrence J. Hogan Hogan for Senate P.O. Box 545 Seabrook, MD 20706
Dear Mr. Hogan: This letter is to acknowledge receipt of your complaint of ''October 25, 1982, against Citizens for Sarbanes which alleges t 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 manner as your original complaint. For your information, we have 0 attached a brief description of the Commission's procedure for handling complaints. If you have any questions, please contact .... " Steven Barndollar at (202) 523-4073. C Sincerely,
Enclosure -" FEDERAL ELECTION COMMISSION
i' ! WASHINGTON. D.C. 20463 S1414 01October 29, 1982
CERTIFIED MAIL RETURN RECEIPT REQUESTED Citizens for Sarbanes. 1800 Mercantile Bank and Trust Building No. 2 Hopkins Plaza Baltimore, MD 21202
Re: MUR 1486/1500
-- Dear Sir/Madam:
This letter is to notify you that on October 28,1982, the o Federal Election Commission received another complaint which alleges that your committee may have violated certain sections of S the Federal Election Campaign Act of 1971, as amended ("the (D Act".). A copy of the complaint is enclosed. We have numbered this C matter MUTR 1486/1500. Please refer to this number in allfuture r correspondence. C 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 co of receipt of this letter. If no response is received within 15 days, the Commission m.ay 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. W'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 Corrnission 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 CoSmmission 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-
staff Ifmember you haveassigned any questions,to this matter please at contact(202) 523-4039. Stephen Mims,For yourthe information, we have attached a*brief description of the Commission's procedure for handling complaints. Sincerely, Charles N. Steele General Counsel
By Kenneth A. Gross Associate General Counsel
m
Enclosures 1. Complaint 2. Procedures 3. Designation of Counsel Statement cc: Honorable Paul S. Sarbanes MUR ... DTLL
PLEASE PROVIDE THE NAMES AND ADDRESSES OF ALL RESPONDENTS IF A PRINCIPAL OF THE COMPLAINTS TO BF, SENT A cOPY tS TO BE SENT WHICH ARE A CARBON COPY IS A RESPONDEN.TJ COIMMITTEE ADDRESS O)F THE CAMpAIGN THE NAME AND PLEASE PROVIDE TO" THE CANDIDATES FA BESIDE THE CANDIDATESNM. AND PUT A "CC" TO THE CANDIDATE IS TO BE SENT A CARBON COPY A REsPONDENTs PROVIDE THE CAN DIDATE IS PLEASE PAIGN COMMITTEES PRINCIPA L CAM AND PUT A CANDIDATEIS CAM PAIGN COMMITTEE OF THiE PRINCIPAL INFORM ATION, NAMVE AND ADDRESS PROVIDE THIS ' NAME. PLEASE YOU. BESIDE THE COMMITTEE'S No'riCE, THANK - -'CC" OF THIS i 24I HouRs OF RECEIPTr • oN T.is sHET'.WITHIN I -.....-. ..
,,%' \ _Ot\ "~ 's c QcU.. uk.QL '" ?,, \ - " . m _- & ,cQ .\%(,..I ,Aw., ,L S
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~ 0 %f~5L\5 ~ ~o1oC* ~v~t MVI
SEABROOK,PO~1 uira'~n MARY! g October 2 ,, 1982
g Mr. Frank Reiche Chairman Federal Election Commission 1325 K Street, N.W. Washington, D.C. 20463
Mr. Chairman: Dear Paul this complaint against am hereby filing S. Senator ~I for the office of U. S. Sarbanes, a candidate 1800 Mercantile and Citizens for Sarbanles, from Maryland, .Baltimore, Building, 2 Hopkins Place, .. Bank and Trust 437g for violation 21201, pursuant to 2 U.S.C. Sec. ... Maryland 441a and re- limits of 2 U.S.C. Sec. of the contribution 434 by undervaluing , of 2 U.S.C Sec. a Livable porting requirements made by the Council for PO the in-kind contributions
a special interest Council for a Livable World, earmarked committee, has, by soliciting ~political action been avoiding for a specific candidate, ~contributions law's $5,000 contribution compliance with the election of September 25, 1982 According to Human Events ~limits. $36,500 or according raised for Senator Sarbanies $23,200. In effect, CLW has Post of July 28, 1982 ~to the Washington fund raiser for eight been acting as a professional CIW has requiring those candidates candidates without the actual senatorial of fund raising. Were to pay the full costs candidates, to be assessed to those costs of fund raising far more than the in- would be reporting It Senator Sarbanes shown on 1982 reports. contribution of $1,164.92 excess kind limit and, if so, any well exceed the $5,000 should may Further, the Commission should be refunded. CLW can evade stop this procedure whereby should immediately Still further, the Commission contribution limits. received since these the refund of all contributions order unlawfully. contributions were generated by an article been brought to my attention 1982 It has Times of October 18, (attached) in the Washington filed a complaint °n Legal Foundation has that the washingt I support the position Commission against CLW. its with the Foundation. However, by the washington Legal recipients taken CLW and not against the complaint is against
TREASURER FOR SENATE. PHYLLIS DALLEY. BY AUTHORIT HOGA Page Two
of the contributions. My complaint, though similar in nature, is against Paul S. Sarbanes as recipient of contributions. CIW has been following this practice of sol¢icting earmarked contributions for a number of' years. hI-lfact, it was six years to the day in 1976 that Senator Sarbanos reported a contribution-in-kind in the amount of' $2,778.37 from CIW. It was noted that this figure was "the cost of mailings". Considering the increase in postage rates and the fact that the 1976 contribution was over twice that of' 1982, I would certainly question the basis for arriving at the contribution-in-kind figure.
I have seen publicity concerning CIW which states Nhas it "a unqu way of backing words with political action and resources," ie. the distribution of $2.2 million to t those senatorial candidates who support its objectives. ... Another quote,"In addition, the group (CIW) avoids the $5,000 primary and general election contribution limits M for PAC's because the money doesn't come from the council itself". It is obvious that if all PAC's adopted CIW methods ~it would make a shambles of our election laws and reports 0 of contributions would become incomprehensible fiction. - I trust the Commission will investigate promptly this complaint.
~Sincerely,
Lawrence 3. Hog4((J
Enclosure
Subscribed and sworn before me this day of October 1982. ulWrne orm r dlire~tor of the Control a Disarmament cy, Was named iLthe mplaint in o f CLW and iscpacity aU a dirn~o with ~o5 ~~ f hePeat PAaln . ; E. lowteaurer of CLW, j~a erome Grossmn, president and i va r of Peace FIC ndCLWs reg- The foundation charges that CLW *r- and Peace MAC have :violated election Up, liaes by failing to veport as in-kind ~'M 'w
FEDERAL ELECTION COMMISSION WASHINGTON, D.C. 20463
THIS IS THE BEGINNING OF MUR $ /Soo.
m