~9~P*q THIS IS THE EN4D OF MUR 'ii4 Date Filmed Camera No, 2- C&I~rD~LL 4.1 (1) Classified InfoZ mtion (6) prac(ce) '(4): Trade sec rets and coummIercial, or .(geographic~ or financial information geophyswical) (5, J.Iteral WumeIP 4! -- Signed - - - - Ate a FEC 9-21-77 FEDERAL EL «"2 WASHMNTON. D.C~~ CERTIFIED MIL RETUR RECEIPT RMM III D Mr. Andrew Phillips 412 First Street, Sot Virginia, Minnesota151"5579 Re: MUX914, Dear Mr. Phillips: As you are aware, the CbcissLon has previously found 0reasonable cause to believe 'that the VerMillion East Range Conservation Council has vl e 'a U.S.C.' 1433's 41:34 000, 441d. On October 9,' 199, the Cbomssion riound raoal cause to believe that the Council has violated 2 U.S.C. S432. Additionally, the Coimission voted to approve the conciliation agreement which you have offered as settlement 0 of this matter on behalf of your client. Accordingly, the Commnission has closed its file in this matter. Enclosed you will find a fully executed copy of the ..,_conciliationagreement for your files. Should you have any questions, please contact Suzanne Callahan at 202/523-4529. S~nerely/, William C. Oldaker - --. -- - . -- General -Counsel- Enclosure Conciliation Agreement 3370; MI IOONC610 ~ c~ M, s ;a the matter of) )MUR 914 Vergllion Bast Range) Conservation Council) CONCILIATION AGREIN This matter having been initiated on the basis of information ascertained in the normal course of carrying out its supervisory responsibilities, an investigation havling' been conducted, and the Commission having found reasoznAbl cause to believe that respondent, Vermillion East Range, Conservation Council (the *Council"), violated 2 U.S.C. $432r S433, S 434p. S 441d; Now, therefore, the respective parties herein, the Federal Election Commission and respondent having duly entered into conciliation pursuant to 5 437g(a) (5), do hereby agree as Eoilows: I. That the Federal Election Commission has jurisdiction over respondent and the subject of this proceeding. II. That respondent has had a reasonable opportunity to demonstrate that no action should be taken in this matter. III. That the pertinent facts in this matter are as follows: a. The Council made independent expenditures in the amount of $4,779 in connection with the Senate campaign of Robert Short. b. The Council failed to register as a political committee with the Commission within ten days after it made expenditures in excess of $1,000. 4 h ouclfaldtofl and ea enditwros with the Ccows±.in in a fashion, d The Council failed to keep comlete contrib66 records. e. The Council failed to place an appropriate dis'-sim~ on its advertisements which it placed on b*b*3X Of Robert Short without the candidate's authorization. *?REFORE, respondent agrees: 1,I Respondent's action in failing to keep complete con- C tributor records is in violation of 2 U.S.C. S 432. II. Respondent's action in failing to register with the Comission is in violation of 2 U.S.C. S 433. III. Respondent's action in failing to file reports of receipts and expenditures with the Commission is in violation of 2 U.S.C. S 434. O IV. Respondent's action in failing to place an appropriate disclaimer on its advertisements is in violation of 2 U.S.C. I 441d. V. That it will pay a civil penalty in the amount of $500.00 pursuant to 2 U.S.C. S 437g(a) (6) (B) Ci). VI. Respondent agrees that it will not undertake any activity which is in violation of the Federal Election Campaign Act of 1971, as amended, 2 U.S.C. S 431 et seq GENERAL CONDITIONS I. The Commission, on the request of anyone filing a complaint under 2 U.S.C. S 437g(a) (1) concerning the matters at issue herein, Ditict Of Columbia. U1. it is mutually ag reed that this agreement at O*fft-ve 4& of the 4ate that all pr$shr1o~v ard'the commission has approved the entire agreeme1t. Ill. it in agreed that responldenlt shall have, no M 45S days, from the date of this agreement ,to iq~iement with the requirements contained here11n, or so notifyl MTE: General Counsel Federal Ele .ction Commnission DATE ___ Abbert. Dagg pet Vermillion East Range Conservation Council Dear Kr. PhIllips: ivsoale ase to lo", M~ Y' CoeevaioCwm3J~ %.~ah~2 1.0. 5g433 44 m 441d.* On, 1-01100IiIISLP00~ivsaml eaUMe to thiem USC.voiluo~*M 432. AdditionallI, t"m 0*0"it VotmA t coniliation arekt whiob 7"u bfave of IMeNO of this matter on bs*lt of yOst @lientO Accordinglyr th* Winiseios has 01"0osG i 1 fsfletthi8 matter* Unclosed you wini 01WS w fully esaticopy .5 the oonciliation wrI =I~ ft r youI*= 111 Should you have any -- etvs laeftkact SsMOMe Callahan at (202) 523-49. "~'Iiwrey William C. Oldaker amoeral Counsel Enclosure Conciliation Agreement 9/25/79 cah '~~ Z-A the Iatt~~oW ~ ~j~> V lion btRan~ge Conservation couancil ) It Marjorie W. Emns, Secretary to the Psj~ Election Comission, do hereby certify that onOoe 9, 1979, the Comussion decided by a vote of 5-0 to take the following actions regarding the above-captiond matter: 1. Find REASONABLE CAUSE TO BELIEVE the Vermillion East Range Conservation Council has violated 2 U.S.C. S 432. O2. Accept the conciliation agreemnt, attached to the General Counsel's Report dated September 27, 1979, c as settlement of this matter. 3. Send the letter attached to the General Counsel's Report dated September 27, 1979. 4. Close the file. Voting for this determination were Commissioners Aikens, Harris, McGarry, Reiche, and Tiernan. Attest: Date Mroi .Emn Secretary to the Commission Signed by the General Counsel: 10-3-79 Received in the Office of the Commission Secretary: 10-4-79, 11:40 Circulated on 48 hour vote basis: 10-4-79, 4:00 #1~..hav* the attac 00 3U= '914, distributed to tally .basisa Thank you. ObeASSion haes previously found aoai a4t belie" that the Yeormillionl East Range Conservation Cotza*4i1 (tie Counoi1") has violated 2 U.S.C.o 3 434an44. Sbqbtto the Coumisoion' s reasonable mu~st, to LMM findings, the Office of General Counsel received additiaal information indicating a recordkeeping violation may have been comm~itted by the Councilas well; on August 29, 1979, the Commission found reason to believe that the Council may have violated 2 U.S.C. S432. On August 30, 1979, the respo' dent was notified of the additional Commission finding and sent a conciliation agreement which was amended to include the S432 violation. The Council does not refute the Commission's reason to believe finding and has signed the amended conciliation agree- ment. Therefore, it is recommended that the Commission find reasonable cause to believe the Council has violated S432 and accept the attached conciliation agreement as settlement of this matter. fto lieVe the Vermillion'' As'vi latod 2. U.:S.C. S 432. 2. conciliation agreement as to of this matter MW i Ind'' th. attached letter. 3. Cloto the fil.. /0/3 ,f WIZAJ, Date Wilam laer- General Counsel Letter to Andre Phillips rnl the matter Of V~uA~Uion Rat- Range""R9.4 9~I Omimsrvation Council CONC1L;?A7bOU- AGEIN This matter having been initiated. on th. basis of: information ascertained in th. normal course of carrying ..out., its. supervisory- responsibilities, an. investigatio. haUWi :5,- boen conducted, and the Commission..having, found- reaso* *cause. to-believe that.- respondento, Vermillion, East-.ng Conservation Council (the "Council") ,-violated .2 U. S, c, S432-,p S433, S 434... S:4d;- Now, thereforer the respective parties. herein, the, Federal' Election Commiss ion and respondent having duly entered-into O conciliation pursuant to 5 437g(a) (5), do hereby agree -as follows: 1. That the-. Federal Election Commission-. has ..Jurisdiction. C over respondent and the subject. of. this-proceeding. IZ., That respondent has-had- a reasonable, opportunity- -to demonstrate that- no action should be taken-in.this matter. III... That the pertinent. facts in this matter are. as-follows: a. The Council made independent expenditures in the amount. of $4,r779. in, connection. with the Senate campaign of Robert Short.. b. The Council failed to register as a political. committee- with the Commission. within- ten days after it made expenditures in excessof $1,000. -.-. '-J, N- 3L.- * - a 0..-U., CMOUnoi failed to file rprso and, expenitures vitfr the0bwom1~. do"*U: T Council. fatiled to keep, complete cOntr5E~t records., a.-. The Council failed to place. an appropriate dis@aAmer on its. advertisements which- it- placed- on behal Ot Robert Short witho.the--candidate's authon-itatA*M. - *T!ZRZPOREj respondent- agrees: 1, Respondent's action in failing to keep complete:,con- tributor. records- is in violation- of- 2. U.S.C., S 432. 11I. Respondent's action in.failing to register-. with the' ~Cuiiission is in-. violation of 2 U.S.0C._ 433. 111. Respondent's action- in failing to file reports of receipts C and expenditures with the Commission. is in violation of 2.U.S.,C. S-4 34. p IV. Respondent's action in.failing to place.an.-appropriate disclaimer on- its advertisements.-is. in violation of 2-U.S.C.,.S 441d. V. That it will pay a civil penalty in.the amount-of $500.00 pursuant to 2 U.S.C., S 4 37g (a) (6) (B), (i). VI. Respondent agrees that it will not undertake any activity which is in violation of the Federal Election Campaign Act of 1971, as-amended, 2 U.S.C. S 431 et-sec. GENERAL CONDITONS I.