BEFORE THE FEDERAL ELECTION COMMISSION In the Matter of 1 ) MUR 4885 1 RESPONSE OF THE REPUBLICAN NATIONAL COMMITTEE TO THE SUBPOENA TO PRODUCE DOCUMENTS AND ORDER TO SUBMIT WRITTEN ANSWERS The FLepublican National Committee ("RNC") hereby responds to the Subpoena to Produce Documents and Order to Subinit Written Answers issued by the Federal Election Conimission ("Commission") in the above-referenced matter. I'ursuant to the Commission's Instructions and Document Requests and Interrogatories. thc discovery request is limited to documents and information from February I, 1995 to present, relating to the April 3, 1995 combined $1 5,000 contribution inadc to the RNC by Mr. Gary G. Jacobs and his wife. It should also be noted that the RNC has redacted certain non-responsive portions of document,s that i: is submitting to the Commission. The RNC nssures the Commission that these redacted areas do not include information requested by the Commission in the above-referenced matter. Furthermore, although the Commission's Subpoena and Order refercncc an attachment of "March 27, I998 Correspondence from I Ialcy R. Barbour (1 pagc)," the RNC did not receive the referenced attachinent. Since the RNC could not take into account said attachment when foriiiulating its response, the RNC hereby rcservcs the right to supplement its response after receiving the attachment in question from the Commission. WRITTEN ANSWERS A. C'onc.e,ning the solicircrriot?qf'the conrr.ihirtion: 1. The solicitation was made by Mr. Wayne Bemian, a member of tlilc 1995 RNC Gala Committee. during a .Innirary, 199s "plionc day" pledgc drivc at tlie Willard Hotel in Washington, D.C. Mr. Berman telephoned Mr. Jacobs to ask him for a contribution to thc Gala. 2. Mr. Berman appears to have received ftindraising credit for the April. 1995 contribution from Mr. Jacobs. 3. The RNC has no responsive documents in regard to this rcqucst. However, the RNC is providing a copy ol'a 1995 RNC Gala invitation to tlie Commission. The RNC is not aware of whether Mr. Jacobs was sent such an invitation 1. A $IS,OOO coinniitnieiit was iiiadc by Mr. Jacobs to Mr. I3eriiimi iii January. 1995. 2. The RNC is not certain wlictlicr the contribution \V;IS transmittcd or lorwarded by mail or by hand, allhough il believes the contribution ivould have been transmitted or forwarded by iii:iil, The contributicin from Mr Jacobs was received in April, 1995, in response to an earlicr fundraising drive for the 1995 RNC Gala. The 1995 RNC Gala was hcid on February 9, 1995 at the Washington Convention Center, 900 9th Street, N.W.. Washington, D.C. The contribution was neither solicited nor received at the Gala event. 3. llic RNC is not aware of who actually tr:msmitted or forwarded the contribution, and it is not aware of who actually received thc contribution at the RNC. 4. Included in the responsive documents arc ;I daily deposit summary sheet. ;I deposit ticket, a source document containing a copy of Mr. .I~cobs'check, a thaiik you lettcr for the contribution, a documcnt listing Laredo National t3ank under the name Wayne Bernman, and general donor intimiation records pcrtaining to Mr. Jacobs. A copy ofa 1995 RNC Ciala invitation is also included. C. ldetiti,$ till pr.sot~.swho provided myi+rttitttio)I or ri.s.si.sliince risecl i)?!kc prepiir~i~imofthc responses to these qiiestiotw rind tiocirtiieti/ reqiie.s/.s. If'ot erich pe~w)iitleii/$eti. .s/rrtefi,r which qirestioti or tiociitmtit ret/ires/ /lie infiirt~~trtiotior ri.ssi.sttince 1wr.s itseti. For the Commission's requests pertaining to this matter, the RNC Counsel's Office: coordinated with the following individuals to organize responsive information and to respond to each of the Cominission's questioiis: Ms. I'atly 3 Luther (Director of Membership Services), Ms. Lauric Prysock (Director of Republican Eagles), Ms. Beverly Shea (Deputy Director of Finance), fvls. Jnnicc Knopp (Deputy Director of Finance), Mr. Waync Berman (Republican fundraiser), Ms. Paige Lance (Southern Representative of Republican Eagles), and Mr. Steve Ellis (Director of Computer Services). Each of these individuals can be contacted through the Counsel's Office of the RNC. Respectfully Submitted, Counsel for the Republican N2tional Committee April 22, I999 A SWORN TO AND SUBSCRIBED before me this '' day of April, 1999. n My Commission Expires 1. i"',, . .. x 'x. .. .. ! .. 49 z 4 6 Mr. Gary G. Jacobs President and CEO Laredo Natioml Bank Post offica Box 59 LaridO'TX 78042 AS M Eade you we recog&& nationwide as a member of one oftbe most disPineyidid and celebrated pupof Republicans. The fb%~cislwppart and ldcrsbip you khge0 OW entire Pf@' at d kvsls of government display a ran levei of commitment for wbich we we &ply indebted. lo addition, continuing your Esgles mern%Pership gives you dque opprtunities 10 old tie mnd develop new friendships with o&ep Republican leaders hmthe politid sbd business coi%munitim Who share your exeordjonry commitment to our Party and ~\lrn&n9S futUn3. Yaw Eagles membership is effective foe B AtU twelve months and atitbyou to all tho benefirs we have designed s~ficallyto honor individuals of youp caliber, and offers ~QUa full mge of smial and business activities with your fellow members and the leaders of out Party. I look foward to seeing you at ow next nafiond meeting or wgiooal &$es event, and tRanking you personally for your continuing generosity to the Eagle program. I On behalf of&eentire P&y, ptwknow how much 1 spprcche yow commitmen?to the Republican Eagles. We are honored to have you join us 85 we continue to &eng&ea QUIPeply the 1996 presidential election cycle. EAGLE 1 ;)::a744 LA2E;IO NA?IGhbL SANK I Siz-7L3-115 1 PRij23ENT t CEO 04/13/1996 5 12- 7 23 - 115 1 MR. GARY c. ~llCa3S POST OFFICE CQAtrER 59 LAREDO TX 7E042 ~PRNLNG This list is the property of the Republican National &omsittee any unauthoraxcd use is st~ic21yPRilHP3ITED lhis list contains eecoy names to monitor list USBgQ. LAREDO NATIONAL BANK $1 5,000 TOTAL: Add- Typo: Delivery (Primary) Addri: Post ORFca Box 59 Add& Cky: Laredo Stab: ‘IX ZIP: 780426059 ~o~~j~u~on~: _.-Data: statuo: Amount: % Projaran: Accaun% sm; U17fBS Fua SlS,OCO.CQ Remval UIObE REIU: EWiW ’! ’! \ U2lW 12:03:04 PM PAC ID I PfdX Flwt Name MN east Mame SMffIX Mr. Gary G. Ja& Add@) Post Ofcce Box 59 Add@) Strwt City Laredo state Tx ZIP 70042-0059 PmLAddr B - Doric; Typo I MayLOWO E Caunmcnb Wshld Rag Cong Diet \ I I I014A 04/17/1995 22262669 015,000.00 UWRM 04117,11865 I k 'I _.- .... .. .I ! 104th Congress .~ . .. ..." i., IPJAWGW GAkA Geoqette Mos p. HONORARY IN CHWRPAAN,WEPUBLlCAN NATIONAL CO Haley Barbur cmm,REPeWLICrn NATIONa FINPNCE GO E John A. Moran CORPORKrE ClcPAIRMApIl Craig E. Fuller Jmv And 'I%orne 6. Awbter Roger v. &dl Donald B. Mamn er Richand M&pwic& WilbJ. Mhue w Bm Betty %auhniMulphg David M. Brewer Naacy BrhkeP Edgar Branhnan Arcadio Cadk Lodwrick FA. 6hk Jack L CopW Mr. & MS. &le M. Craig, 1. Sugar Rautbod RdKn Day James D. Robinson, IHI Juanita Duggan Linda Gosden W&wn Melvyn 1. Estrin Rockwell Sch~kl Julie FMey Stephen Schwanmn Stephen Friedman Theirse Shaheen Walter J. Ganzi, Jr. Saul Steinberg Harvey Golub Ftaink D. Stella MR. Greenberg Peter Terpeluk, I. Patricia S. Harrison Constance E. Tipton John M. Hennessy Donald 1. Trump Jon Huntsman, Jr. Wob(ea Van Dine Gary G. Jacobs / Dirk Van Dongen Robert W. Johnson, 1V Elliott H. Vernon James H. Lake George Votis Kenneth L. Lay Linda L. Wacbner Howard H. Leach Leslie H. Werner Drew Lewis Stephen Wynn '\ (List as of 12/28/94 .Complete Leadership lut to bc printed UI Inaugural Gala Program.) \ ........... ........ .-.-- __..... - , : .1; ... ..;I, ,~ ',..A ..:r *'.. ,.I.. - b .... .. ) '.' :: i. ...... ....,A *e":. I... ': With Special Guests '. Thursday, the Nin Nineteen hundred and ninety-five? Washington ~QnventiQarCenter 900 Ninth Street, N.W. 638 p.m. Cocktail Recepticcrs Black Tie 238 p.m. Gala Dinner anand Program eply Enclosed Tickets will not be mailed The ticket "WiD Cd" DwkJor individual ticket and table buyers will be open from %'UO am. to 8:ODp.m. a! the Coonventzh Center on Thursday, Febq9, 1'995. .. ? 1 .. .. , L .... .... ... __ ~._........... 9-3 c/o The Republican National Committee 310 First Street, SE, Washington, DC 200103 i ----?-y i. 5. .- I I I CREDIT CARD INFORMATION L_ You may make your contribution to the RNC by credit card if you choose by completing the infor- mation below. b Q Peisonal D Corporate 0 Mastercard 0 VISA a American Express Credit Card Number: / I-______- -__ Expiration Date: - _-________c- Name as it appears on Card: . ......- x___ Signature: - Amount of Conmiution: $ - Paid for by the Republican National committee and the Republican National State Elections Committee. Only those contniutions which do not fall under the limitations and prohibitions of the Federal Campaign Act will be used by the Republican National State Elections Committee. Federal election law requires us to report the following information: Occupation:- Employer: 0 Check here if self-employed To compile your membership profile, please complete the following and make any corrections to your name listed on the reverse side of this R.S.V.P. form. Name Salutation: Home- Telephone: c_---_ Offce Telephone: ___ __ I , Fax Number:__ . ., ...'. " . ., . ..: - John A. Moran, Republican National Committee FinanceChairman Max M.Fisher, Honorary Inaugural Chairman Georgette Mosbacher, Inaugural Chairman e Craig L. IbUer, Corporate Chairman FA @#4/99.5 si+W.&m Yd BEWEFITS FOR INAUGURAL LEADERSHIP The 1995 Republican i'naugural win be one of our their fiand business associates to increme Party's truly historic events.