REPORT - House Committee on Ethics

CONFIDENTIAL

Subject to the Nondisclosure Provisions ofH. Res. 895 of the 110th Congress as Amended

OFFICE OF CONGRESSIONAL ETHICS UNITED STATES HOUSE OF REPRESENTATIVES

REPORT

Review No. 12-9525

The Board of the Office of Congressional Ethics, by a vote of no less than four members, on August 24,2012, adopted the following repOli and ordered it to be transmitted to the Committee on Ethics of the United States House of Representatives.

SUBJECT: Representative Aaron Schock

NATURE OF THE ALLEGED VIOLATION: In March 2012, Representative Aaron Schock may have solicited contributions for an independent expenditure-only political committee in excess of $5,000 per donor, in violation of federal law, House rules, and standards of conduct.

RECOMMENDATION: The Board of the Office of Congressional Ethics recommends that the Committee on Ethics further review the above allegation because there is substantial reason to believe that Representative Schock violated federal law, House rules, and standards of conduct.

VOTES IN THE AFFIRMATIVE: 6

VOTES IN THE NEGATIVE: 0

ABSTENTIONS: 0

MEMBER OF THE BOARD OR STAFF DESIGNATED TO PRESENT THIS REPORT TO THE COMMITTEE ON ETHICS: Omar S. Ashmawy, Staff Director and Chief Counsel.

1

CONFIDENTIAL


FINDINGS OF FACT AND CITATIONS TO LAW

Review No. 12-9525

I. INTRODUCTION .............................................................................................................. 3

A. Summary of Allegations .................................................................................................. 4

B. Jurisdictional Statement ................................................................................................... 4

C. Procedural HistOlY ........................................................................................................... 4

D. Summary ofInvestigative Activity .................................................................................. 5

II. REPRESENTATIVE SCHOCK SOLICITED CONTRIBUTIONS FOR CAMPAIGN FOR PRIMARY ACCOUNTABILITY, INC .......................................... 6

A. Law, Regulations, Rules, and Standards of Conduct.. ..................................................... 6

B. CP A Received Contributions from Representative 1, the 18th District Republican

Central COlTIlnittee, and Donor 1 ..................................................................................... 8

C. Representative Schock Asked Representative 1 to Contribute $25,000 to CPA ............. 9

D. Representative Schock's Campaign Committee May Have Asked the 18th District

Republican Central COlTIlnittee to Contribute $25,000 to CPA ..................................... 12

E. Representative Schock Asked Donor 1 to Contribute to CPA ...................................... 16

III. RODNEY DAVIS, ROB COLLINS, MICHAEL BIGGER, AND PAUL KILGORE REFUSED TO COOPERATE WITH THE OCE ......................................................... 18

IV. CONCLUSION ........................................................................................ , ........................ 21

V. INFORMATION THE OCE WAS UNABLE TO OBTAIN AND RECOMMENDATIONS FOR THE ISSUANCE OF SUBPOENAS ......................... 21

2

CONFIDENTIAL


OFFICE OF CONGRESSIONAL ETHICS

UNITED STATES HOUSE OF REPRESENTATIVES

FINDINGS OF FACT AND CITATIONS TO LAW

Review No. 12-9525

On August 24,2012, the Board of the Office of Congressional Ethics (the "Board") adopted the

following fmdings of fact and accompanying citations to law, regulations, rules, and standards of

conduct (in italics).

The Board notes that these fmdings do not constitute a determination that a violation actually

occurred.

I. INTRODUCTION

1. In March 2012, Representative Adam Kinzinger and Representative Don Manzullo

were opponents in the Republican primary election for the 16th District of Illinois.

2. On or about March 8, 2012 a political committee, Campaign for Primary Accountability, Inc. ("CPA"), began making independent expenditures opposing

Representative Manzullo with direct mail, email, and online advertisements.

3. On or about March 11,2012, Representative Aaron Schock began soliciting

contributions for CPA.

4. CP A needed to raise a large amount of funds quickly in order to purchase television

and radio commercials opposing Representative Manzullo before election day on

March 20,2012.

5. In four days, from March 14 to March 17, 2012 CPA received contributions of at least $115,000 as a result of the efforts of Representative Schock and his campaign

committee, Schock for Congress. The donors were: 18th District Republican Central Committee ($25,000); Every Republican is Crucial PAC ("ERIC PAC") ($25,000);

Donor 1 ($35,000); and Donor 2 ($30,000).

6. During the same four-day time period, CPA made independent expenditures totaling approximately $130,000 to oppose Representative Manzullo, including television and radio commercials.

3

CONFIDENTIAL


7. On March 20,2012, Representative Kinzinger defeated Representative Manzullo in the primary election.

8. On or about April 6, 2012, Representative Schock explained in an interview with Roll Call that he had approached Representative 1 in March 2012 and requested a contribution for CPA's television advertising in suppOli of Representative Kinzinger. The following statement was attributed to Representative Schock: "I said, 'Look, I'm going to do $25,000 [specifically] for the Kinzinger campaign for the television campaign,' and said, 'Can you match that ?'" "And he said, 'Absolutely. ",1

A. Summary of Allegations

9. In March 2012, Representative Aaron Schock may have solicited contributions for an independent expenditure-only political committee in excess of$5,000 per donor, in violation of federal law, House rules, and standards of conduct.

10. The Board finds that there is substantial reason to believe that Representative Schock violated 2 U.S.C. § 44li(e)(1)(A); House Rule 23, clause 1; and the Code of Ethics for Govemment Service, ~ 2, by soliciting campaign contributions for an independent expenditure-only committee in excess of $5,000 per donor.

B. Jurisdictional Statement

11. The allegation that is the subj ect of this Review concem Representative Aaron Schock, a Member of the United States House of Representatives for the 18th District of Illinois. The Resolution the United States House of Representatives adopted creating the Office of Congressional Ethics ("OCE") directs that, "[n]o review shall be undeliaken ... by the board of any alleged violation that occurred before the date of adoption of this resolution.,,2 The House adopted this Resolution on March 11, 2008. Because the conduct under review occun"ed after March 11, 2008, the OCE has jurisdiction in this matter.

C. Procedural History

12. The OCE received a written request for a preliminary review in this matter signed by at least two members of the Board on Apri130, 2012. The preliminary review commenced on May 1,2012.3 The preliminmy review was scheduled to end on May 30,2012.

1 John Stanton, Eric Cantor Gave $25K to Anti-Incumbent PAC to Aid Adam Kinzinger, Roll Call, Apr. 6,2012. 2 H. Res. 895, 110th Congo §l(e), as amended (the "Resolution'). 3 A preliminary review is "requested" in writing by members of the Board of the OCE. The request for a preliminaIY review is "received" by the OCE on a date certain. According to the Resolution, the timeframe for conducting a preliminaIY review is thhiy days from the date of receipt of the Board's request.

4

CONFIDENTIAL

Subject to the Nondisclosure Provisions ofR. Res. 895 of the 110th Congress as Amended

13. At least three members of the Board voted to initiate a second-phase review in this matter on May 29,2012. The second-phase review commenced on May 31,2012.4 The secondphase review was scheduled to end on July 14, 2012.

14. The Board voted to extend the second-phase review for an additional period offoUlieen days on July 13,2012. The second-phase review ended on July 28,2012.

15. The Board voted to refer the matter to the Committee on Ethics and adopted these findings on August 24,2012.

16. This report and findings in this matter were transmitted to the Committee on Ethics on August 30,2012.

D. Summary of Investigative Activity

17. The OCE requested and received testimonial and, in some cases, documentary information from the following sources:

(1) Representative Schock;

(2) Representative Schock's Chief of Staff;

(3) Representative Schock's Campaign Director;

(4) CPA Development Coordinator;

(5) CP A Managing Director;

(6) Donor 1;

(7) Donor 2;

(8) Representative 1;

(9) Senior Advisor of Representative 1; and

(10) Lobbyist Donor 1.

18. The following individuals declined to produce documentmy and testimonial infonnation in response to Requests for Information and were detennined to be non-cooperating witnesses:

4 According to the Resolution, the Board must vote on whether to conduct a second-phase review in a matter before the expiration of the thitiy-day preliminary review. If the Board votes for a second-phase, the second-phase begins when the preliminmy review ends. The second-phase review does not begin on the date of the Board vote.

5

CONFIDENTIAL


(1) Michael Bigger, Chainnan, 18th District Republican Central Connnittee;

(2) Rob Collins, Partner, Purple Strategies LLC;

(3) Rodney Davis, former staffer of Representative John Shimkus; and

(4) Paul Kilgore, Treasurer, 18th District Republican Central Committee.

II. REPRESENTATIVE SCHOCK SOLICITED CONTRIBUTIONS FOR CAMPAIGN FOR PRIMARY ACCOUNTABILITY, INC.

A. Law, Regulations, Rules, and Standards of Conduct

Federal Election Campaign Act ("FECA ")

19. Pursuant to 2 u.s.c. § 441i(e)(1)(A), a "candidate, individual holding Federal office,

agent of a candidate or an individual holding Federal office, or any entity directly or

indirectly established, financed, maintained or controlled by or acting on behalf of 1 or

more candidates or individuals holding Federal office shall not solicit, receive, direct, transfer, or spend funds in connection with an election for Federal office, including

funds for any Federal election activity, unless the funds are subject to the limitations,

prohibitions, and reporting requirel1'lents of [the Federal Election Campaign Act}. "

20. "[NJo person shall make contributions . .. to any other political committee (other than a

committee described in subparagraph (D)) in any calendar year which, in the aggregate, exceed $5,000 .... ,,5

21. "No multicandidate political committee shall make contributions . .. to any other political committee in any calendar year which, in the aggregate, exceed $5,000. ,,6

22. The Federal Election Commission ("FEC") issued an Advisory Opinion explicitly discussing federal officials soliciting for independent expenditure-only comm-ittees. 7

"Federal officeholders . .. may not solicit unlimited contributions from individuals,

corporations, or labor organizations on behalf of independent expenditure-only political committees ('IEOPCs') .... Federal officeholders . . , may solicit up to $5,000 from

individuals (and any other source not prohibited by the Actfrom making a contribution to

52 U.S.C. § 441a(1)(C). 6 2 U.S.C. § 441a(2). 7 FEC AdvisOlY Opinion 2011-12 (Exhibit 1 at 12-9525_0002-0006).

6

CONFIDENTIAL


a political c01nmittee) on behalf of an IEOPC, because those funds are subject to the Act's amount limitations and source prohibitions. ,,8

23. IEOPCs "may accept unlimited contributions from individuals, corporations, and labor organizations; however, the Act's solicitations restrictions remain applicable to contributions solicited by Federal candidates . ... ,,9

24. The FEC also published additional explanatory i71formation in its Campaign Guide for Congressional Candidates and Committees. 10 The guide explains that "Federal

candidates and officeholders may raise funds on behalf of IEOPCs so long as they only solicit funds subject to the Act's amount li711,itations and source prohibitions-i. e., up to

$5000 from individuals (and any other source not prohibited by the Actfrom making a contribution to a political committee). ,,11

25. The House Ethics Manual acknowledges that the FEC is the primary source for

interpretations of FECA and states that "FECA is eliforced primarily by the [FEC}, and

House Members and their campaign staff should refer to the explanatory materials and advisory opinions issued by the FEe. ,,12

House Rules and Standards of Conduct

26. "While FECA and other statutes on campaign activity are not rules of the House,

Members and employees must bear in mind that the House Rules require that they

conduct themselves 'at all times in a manner that shall reflect creditably on the House' (House Rule 23, clause 1). ,,13

27. "In addition, the Code of Ethics for Government Service, which applies to House

Members and staff, provides in ~ 2 that government officials should '[u}phold the

Constitution, laws and legal regulations of the United States and of all goverl1lnents therein and never be a party to their evasion. ,,,14

8 Id. at 12-9525 0004. 9 Id. at 12-952(0005 (emphasis added). 10 FEC Campaign Guide for Congressional Candidates (August 2011) (Exhibit 2 at 12-9525_0008-0011). ll Id. at 12-9525 0010. 12 House Ethics Manua1122. 13 Id. 14 Id.

7

CONFIDENTIAL

Subject to the Nondisclosure Provisions ofB. Res. 895 of the 110th Congress as Amended

28. "Accordingly, in violating FECA or another provision ofstatutory law, a Member or employee may also violate these provisions of the House rules and standards of conduct. ,,]5

29. "Moreover, under these rules, a Member or employee must take reasonable steps to

ensure that any outside organization over which he or she exercises control - including

the individual's own authorized campaign committee or, for example, a 'leadership PAC'- operates in compliance with applicable law. ,,]6

B. CPA Received Contributions from Representative 1, the 18th District Republican Central Committee, and Donor 1

30. CPA is a political committee registered with the Federal Election Commission ("FEC")

as an independent expenditure-only committee, which may raise funds in unlimited amounts. 17

31. In March 2012, CPA became involved in an Illinois primary election between two

Republican incumbents, Representative Adam Kinzinger and Representative Donald

Manzullo. I8

32. In early March 2012, CPA Managing Director learned that a Bouse staffer, Rodney Davis,I9 planned to have contributions sent to CPA from various donors for television

commercials opposing Representative Manzullo?O

33. Mr. Davis expected CPA to use the contributions to pay for at least $100,000 of

television commercials.21 The email below is a follow-up communication between Mr.

15 House Ethics Manual 122. See also House Comm. On Standards of Official Conduct, In the Matter of Representative Jay Kim, H. Rep. 105-797, 105th Cong., 2d Sess. (1998) (involving a Statement of Alleged Violations that included a violation of House mles based on a violations of FECA). 16 House Ethics Manual 123. 17 Campaign for Primmy Accountability, Inc. FEC Statement of Organization, dated September 27, 20 11 ("CPA Statement of Organization") (Exhibit 3 at 12-9525_0013). According to its website, the mission of CPA is "to bring tme competition to our electoral process, to give voters real information about their choices, and to restore fair, not fixed, elections." About Campaign for Primmy Accountability, http://www.campaign4primmyaccountability.org/about/. To achieve this goal, CPA created the Equalizer Campaign which was intended to "level the playing field in primmy elections." Id. 18 See Memorandum ofInterview of CPA Managing Director, July 12,2012 ("CPA Managing Director MOl") (Exhibit 4 at 12-9525_0021). 19 Mr. Davis, at the time, was a staffer for Representative Jolm Shimkus and a volunteer for Representative Shimkus' campaign committee. CPA Managing Director learned about Mr. Davis from the Co-Chairman of CPA, Eric O'Keefe, who told CPA Managing Director to contact Mr. Davis because Mr. Davis knew of individuals who would contribute to CPA. CPA Managing Director MOl (Exhibit 4 at 12-9525_0021). 2oId.; Email from Rodney Davis to CPA Managing Director, dated March 16,2012 ("Rodney Davis Email") (Exhibit 5 at 12-9525_0024). 21 Rodney Davis Email at 12-9525_0024.

8

CONFIDENTIAL


Davis and CPA Managing Director concelning the status of contributions received and expenditures for television commercials?2

1"'(;'11: ~Q(ji'!$YDavi~~wjlllltiil!fs!l)r,.tiWnk1JM'!i> $'iltll:lleit: ~~t ()ul (:1 qffle'i" ,

,)tl\!l: MM:h la, '<'Otf:a:2:t:!a' l"MCOr Te.: ,illlI111eoi<ifY '~I:l!IZI!1I1tHl:rli;?:af1'af1eii;org:;. CQ; "Eric O'KAi<lr." ~m!ilo.nef>

jlUnteJ, th:« t.Sk eatw£~ YiS'$lwav W<!$H.1:5dl'!oe:;:i. Mrl.ttle m,;ml$'{ waa'wlt'i!dlQday'ftom. tn~'Wth (:Qft~r~~5jOIt<11 Dlstnc,tPAC; Tl1at ~~t$ )'tlwa,t . S))O,Ooo ,jdre.3tl'{ Mfl.i'd, $Hli Oi1O mtliflitt~y hll'ieutHHl wirlili lQdiy Ho,u 'Cilm\11'lg, bitt! am i4}~, ~u;n;o J!ill:r(t. Hav@·lolliig~t mg ii 'Cop"{·o~ ·tile· buy t~<ltgI'K,!W$l.IUftll$tllUl();OOO b~!1i $l1gf\t.~" ,Rcc~fon:rr\i,~nd.n'f'~blllO\ltl~s yo\'! have- ~\id~d. TI1i<~ , .

34. The CPA Development Coordinator told the OCE that Mr. Davis was the contact person for the $120,000 that CPA received from the following donors: Representative l's Leadership PAC ($25,000); the 18th District Republican Central Committee ($25,000);

Donor 1 ($35,000); Donor 2 ($30,000); and the American College of Radiology PAC ($5,000).23

35. Mr. Davis refused to cooperate with the OCE. As a result, the OCE was unable to obtain

infom1ation from Mr. Davis conceming his role in soliciting contributions for CPA and

his interactions with Representative Schock related to the contributions.

C. Representative Schock Asked Representative 1 to Contribute $25,000 to CPA

36. Representative 1 told the OCE that, on or about March 12,2012, he received a telephone call from Representative Schock,24

37. Representative 1 stated that Representative Schock asked him whether he would give

$25,000 to a political committee in Illinois that was involved in the race between Representative Kinzinger and Representative Manzullo?5 Representative 1 later leamed

that the political committee was CP A.26

38. According to Representative Schock, sometime after March 10,2012, he called

Representative 1 and said something to the effect of "We're doing $25,000," and asked if Representative 1 would "consider doing $25,000.'.27 He stated that the words "we're

22 Id.

23 Memorandum of Interview of CPA Development Coordinator, July 12, 20 12 ("CPA Coordinator MOl") (Exhibit 6 at 12-9525_0028); FEC Form 3X of CPA, Reporting Receipts and Disbursements for March 1 to March 31,2012 ("CPA Form 3X") (Exhibit 7 at 12-9525_0036-0040). 24 Memorandum ofhlterview of Representative 1, July 20,2012 ("Rep. 1 MOl") (Exhibit 8 at 12-9525_0086). 25 !d. at 12-9525 0087. 26 Id. -

27 Memorandum ofInterview of Representative Schock, July 26,2012 ("Schock MOl") (Exhibit 9 at 12-9525_0091).

9

CONFIDENTIAL


doing $25,000" refel1'ed to the 18th District Republican Central Committee contribution.28

He told the OCE that he refel1'ed to it as "we" because it was a donation being made from within his district. 29

39. Representative 1 told Representative Schock on the call that he would contribute $25,000 to the committee.3o

40. Representative 1 also put Representative Schock in contact with Rob Collins because he believed that Mr. Collins would be able to assist Representative Schock with raising funds for CPA. 31

41. Mr. Collins is the former Chief of Staff of Representative 1 and is a partner with the political strategy finn Purple Strategies LLC.32 Representative 1 described Mr. Collins as someone who could assist Representative Schock with raising money for CP A. 33

28 Id. 29 Id.; Representative Schock also told the OCE that his request for Representative 1 to "consider doing $25,000" was "DC speak" for asking whether Representative 1 could "come up with" $25,000 in any of a variety of ways. When asked for general examples of how one may come up with a contribution, Representative Schock stated that a Member may contribute from his campaign committee; solicit from citizens; contribute from a Leadership PAC; or contribute from another political committee. Id. Representative Schock said that he did not discuss such alternative ways of contributing with Representative 1 when he asked for the $25,000 contribution. Id. 30 Rep. 1 MOl (Exhibit 8 at 12-9525_0087). 31 Id.

32 Biography of Rob Collins, http://www.purplestrategies.com/people/. 33 Rep. 1 MOl (Exhibit 8 at 12-9525_0087).

10

CONFIDENTIAL


42. As seen in the email below, on March 15, 2012, Mr. Collins provided Ray Allen, a consultant for ERIC PAC (Leadership PAC of Representative 1) with the wiring instmctions for sending a $25,000 contribution to CP A. 34

From: Rob Collins (Ptlrple:t StrategIes) ptirplastretli!grQ$.coo;l S~l1t~ Thursday. Marefi15t 20121CI:$

" Ta:".".,"m, •... ''''.~=< '*-~"Ray:,AUen.""<-~,-""""~~-.-.. -<>'.'.<>m.'. ""' •. ,""~, ."~,., ,." ,..,.,,,,",,,,,m,",",,,,,,,,",,,",,,,,.,·, '" " .. ,

'A(tactummlS: 'CPAJ>m!lpee.tus_and~replyjCirm,pdr.' OPJ\..VvlrioaJnstruOllans,Pdf

Ray",,,below is some information for the super pao that js, in that II. race. You want me to connect you with the super pac person i:odEll! vi~amaU? ps~we dant need to do $100k as B,D said we could. the other Members have done $25k, we snourd match that.

HeyTad~

It was ,good to talk to you today. Below is the Youtube link for the ad that Shimkus, Schock and Cantor hav-e sent money in to support that the Campaign for Primary AccountabIlity is funning. They are a 527 organized super PAC, The mailing and wiring information is attached. I have also cc1ed and attached Jamie Story's, the, President for the Campaign for Primary AccO'untabUity, contaot information if you have any questions about where Of how to send a contribution. Thanks fertile

.support, we reallyappreefate'it.· """, ,,,.

Rob

YouTube.; hitp:I~~e.comfwa1¢hZM~(bbzNsZiF§g

Jamie Story P~sicfe,nt The CUizen leader Alliance P,O, Box27133 Houston, Texas 77227

43. On the same day, Mr. Allen called Representative 1 to confilm that he wanted ERIC PAC to contribute $25,000 to CP A.35 Representative 1 asked him whether it was legal to make such a contribution and Mr. Allen told him that the contribution was legal. 36

44. ERIC PAC contributed $25,000 to CPA on March 15, 2012. 37

34 Email from Rob Collins to Ray Allen, dated March 15,2012 (Exhibit 24 at 12-9525_0142), 35 Rep, 1 MOl (Exhibit 8 at 12-9525_0087). 36 Id, 37 CPA FEC FonD 3x (Exhibit 7 at 12-9525_0036),

11

CONFIDENTIAL


D. Representative Schock's Campaign Committee May Have Asked the 18th

District Republican Central Committee to Contribute $25,000 to CPA

45. The 18th District Republican Central Committee is a political patiy committee affiliated with the Illinois Republican Patiy.38 The committee has a federal account registered with

the FEC.39

46. Michael Bigger is a member of the 18th District Republican Central Committee.4o Paul Kilgore is the Treasurer of the 18th District Republican Central Committee.41

47. Representative Schock, who represents the 18th District of Illinois, assisted the 18th

. District Republican Central Conmlittee with establishing its federal account.42

Representative Schock's Campaign Director opened the bank account for the 18th District

Republican Central Committee.43

48. The 18th District Republican Central Committee is also a member of Representative

Schock's joint fundraising committee, Schock Victory Fund.44

49. Representative Shock's Chief of Staff told the OCE that he works for Representative Schock's campaign committee as an "unofficial political advisor".45 He advises

Representative Schock on various issues, including campaign contributions

Representative Schock should make.46

50. Representative Schock's Campaign Director told the aCE that she reports to Representative Schock and occasionally to Representative Schock's Chief of Staff.47 She

38 18th District Republican Central Committee FEC Statement of Organization (" 18th District Committee Statement of Organization") (Exhibit 1 0 at 12-9525_0096). 39 Id. 40 Schock MOl (Exhibit 9 at 12-9525_0091); Memorandum ofInterview of Representative Schock's Campaign Director, July 26, 2012 ("Campaign Director MOl") (Exhibit 11 at 12-9525_102); Memorandum ofInterview of Representative Schock's Chief of Staff, July 20, 2012 ("COS MOl") (Exhibit 12 at 12-9525_105). 41 CPA Statement of Organization (Exhibit 10 at 12-9525_0094). 42 Schock MOl (Exhibit 9 at 12-9525_0090). 43 Campaign Director MOl (Exhibit 11 at 12-9525_101). 44 18th District Committee Statement of Organization (Exhibit 10 at 12-9525_0098); Schock VictOlY Committee FEC Statement of Organization (Exhibit 13 at 12-9525_0111). The 18th District Committee was first named as one of the four committees participating in joint fundraisers with the Schock VictOlY Committee in the March 2011 amended statement of organization. Prior to March 2011, Kinzinger for Congress was one of the four committees affiliated with the Schock VictOlY Committee according to Schock VictOlY Committee statements of orgmlization filed with the FEC. 45 COS MOl (Exhibit 12 at 12-9525_105). 46Id. 47 Campaign Director MOl (Exhibit 11 at 12-9525_101).

12

CONFIDENTIAL


stated that Representative Schock or Representative Schock's Chief of Staff tells her when to make contributions from Schock for Congress to other political committees.48

51. On or about March 14, 2012, Representative Schock's Chief of Staff contacted Representative Schock's Campaign Director and asked her to make a $25,000 contribution from the 18th District Republican Central Committee to CP A.49

52. Representative Schock's Campaign Director asked Representative Schock's Chief of Staff whether this contribution was "ok" because she was concerned about the large amount of the contribution. 50 Representative Schock's Chief of Staff assured her that the contribution was "0k.,,51

53. Representative Schock's Campaign Director did not recall needing any additional approval from anyone else to make the contribution. 52

54. Representative Schock's Campaign Director had access to the 18th District Republican Central COlmnittee's banle account and authority to make the contribution. 53

55. Representative Schock's Campaign Director made a contribution of $25,000 from the 18th District Republican Central Committee's banle account to CPA via CPA's website. 54

56. After the 18th District Republican Central COlmnittee made the contribution online, CPA Development Coordinator learned that CPA's receipt of the contribution would be significantly delayed. 55 Specifically, CPA's vendor responsible for processing online

48Id. 49 Id.

SOld. On March 14,2012, Mr. Davis sent Representative Schock's Chief of Staff instructions on donating to CPA online and by bank wire. Email from Rodney Davis to Representative Schock's Chief of Staff, dated March 14, 2012 (Exhibit 14 at 12-9525_0115). 51 Campaign Director MOl (Exhibit 11 at 12-9525_101). As stated in Part Il.A, supra, a committee may contribute an unlimited amount to an IEOPC, such as CPA. The $5,000 limit applies to the amount solicited by the Federal officeholder, not the amount contributed. 52 Id. 53 Id.

54 The Board notes the close nature of the relationship between the 18th District Republican Central Committee and Representative Schock's campaign and congressional staff. The initial $25,000 contribution from the 18th District Republican Central Committee was made without any apparent involvement of the committee's Treasurer or Chainnan. Representative Schock's Campaign Director and Representative Schock's Chief of Staff appear to have had complete authority to make the contribution despite neither having a formal role with the committee. In addition, CPA apparently had no contact with the committee's Treasurer or Chainnan except for a thank you note that Representative Schock's Campaign Director had forwarded to him based on his official role with the committee. 55 CPA Managing Director MOl (Exhibit 4 at 12-9525_101); CPA Coordinator MOl (Exhibit 6 at 12-9525_0028).

13

CONFIDENTIAL


contributions would not be able to deposit the payment into CPA's bank account until after the Illinois primary election. 56

57. CPA Development Coordinator informed CPA Managing Director of the anticipated delay in receiving the contribution. As a result, CPA Managing Director instructed CPA Development Coordinator to contact Representative Schock's Campaign Director to request that the 18th District Republican Central Committee's $25,000 contribution be made by bank wire instead of online. 57

58. According to Representative Schock's Campaign Director, she informed Representative Schock's Chief of Staff of the need for a wire transfer from the 18th District Republican Central Committee. 58

59. She stated that Representative Schock's Chief of Staff then contacted the Chailman of the 18th District Republican Central Conmlittee, Mr. Bigger, and asked him to wire $25,000 to CPA because neither Representative Schock's Chief of Staff nor his Campaign Director had authority to make bank wire transfers from the 18th District Republican Central Committee. 59

56 CPA Coordinator MOl (Exhibit 6 at 12-9525_0028). 57 Id. CPA Development Coordinator and CPA Managing Director considered Representative Schock's Campaign Director to be the primaty contact person for the 18th District Republican Central Committee. See Email from Jonathan Martin to CPA Development Coordinator, dated March 16,2012 (Exhibit 15 at 12-9525_0117); Email from Representative Schock's Campaign Director to CPA Development Coordinator, dated March 14, 2012 (Exhibit16 at 12-9525_0120). 58 Campaign Director MOl (Exhibit 11 at 12-9525_102). 59 Campaign Director MOl (Exhibit 11 at 12-9525_102).

14

CONFIDENTIAL

Subject to the Nondisclosure Provisions ofH. Res. 895 of the 1 10th Congress as Amended

60. On March 16, 2012, the $25,000 bank wire transfer was made from the 18th District Republican Central Committee to CPA. 60 The original $25,000 contribution made online

was refunded to the 18th District Republican Central Committee. The email below :fi.-om CP A Development Coordinator to Representative Schock's Campaign Director references

the refund of the original online contribution and CPA's receipt ofthe wire transfer. 61

S'ubje(lt: Wlt&'rra I'lsfer .ReeeN':$d

From; "'Ha fli't!Wh efu'»1twm"'~ntimpalg04prim~tyt!inetl:U~~Uty;~g> ~t$; Fri,M~t46,2Qi.21ik'l4~m

Tt;!'; ~aarona~~i\,ct»rl

OureiC¢01:J~1I;t'ipJ; ns:i tJfi{:fanl$ tiTtit tM::$25{t:}OOC(;.¥.ntrl'Otit1ph Wl'):5 rt:C£\!1Z!f0f1l :~hl~ Jn~tnjpig. ttlall~ '1t:~i'K.~t1 PYJlt;t{ to !n:~i,.lfld .\;1l(~ (?i't~'i:;1};li 'C~,*furl~tltm t-o the l.;Sth C():t1gre:$f;:t~!!liJ Cl}$r;f[,ct·;lw~t:tHtHhBt tl:l1$'Y' ht!'\'~averysrQw pr;)Ct%1tl' Wfl\:,~tf jtC(}nT~.'ii tornrundillg oI11~1;e 91rm:t,Pleasj'? ltat;ITr,,~ RtldW 1f1\/,3::\'1 {it}

not recehro iii refurio by l'lextThursdav" I wlH b~ mtire t(1ii11~}raf.l~}il to '\:;;'~ii thtY.rY.l ?(nd 'St'!:'!e wh~i~~ ti:~$ fnOflfW is,

61. Representative Schock told the OCE that he has never requested that the 18th District Republican Central Committee contribute to any political campaigns. He also stated that

he is not aware of his Campaign Director's involvement in any contributions that the 18th

District Republican Central Committee made to other committees.62

62. CPA Development Coordinator stated that Representative Schock's Campaign Director was the contact person for the 18th District Republican Central Committee.63

63. Representative Schock told the OCE that he first learned of the 18th District Republican

Central Committee's contribution to CPA approximately on March 10, 2012, when Mr. Bigger told him that the committee planned to make the contribution. 64

60 CPA FEC Form 3x (Exhibit 7 at 12-9525_0036); Rodney Davis Email (Exhibit 5 at 12-9525_0024). 61 Email from CPA Development Coordinator to Representative Shock's Campaign Director, dated March 16, 2012 (Exhibit 17 at 12-9525_0122). 62 Representative Schock's Campaign Director is his sister. She told the OCE that she established the bank account for the 18th District Republican Central Committee's federal account and she routinely transfers money into the account from Representative Schock's joint fundraising committee. Campaign Director Mor (Exhibit 11 at 12-9525_101). 63 CPA Coordinator MOl (Exhibit 6 at 12-9525_0028). 64 Schock MOl (Exhibit 9 at 12-9525_0091).

15

CONFIDENTIAL


64. Representative Schock's statements do not explain why Representative Schock's Chief of Staff and Representative Schock's Campaign Director made the initial $25,000 contribution from 18th District Central Republican Conm1ittee to CPA.

65. Representative Schock's Chief of Staff told the OCE that on or about March 11, 2012, Representative Schock had a conversation with Mr. Bigger where Mr. Bigger stated that the 18th District Republican Central Committee was going to contribute to CPA. 65

Representative Schock is the person who told Representative Schock's Chief of Staff about the conversation. 66

66. Representative Schock's Chief of Staff stated that Mr. Bigger called him and asked for the information to make a wire transfer to CPA. 67 This statement conflicts with the statement of Representative Schock's Campaign Director who recalled that Representative Schock's Chief of Staff contacted Mr. Bigger and asked him to make the wire transfer. Also, Representative Schock's Chief of Staff did not disclose to the OCE any details regarding the initial request he made to Representative Schock's Campaign Director to make the $25,000 contribution.

67. Mr. Bigger refused to cooperate with the OCE. Paul Kilgore, Treasurer of the 18th

District Republican Central Committee, also refused to cooperate.68 As a result, the OCE was unable to obtain inforn1ation from the 18th District Republican Central Committee concerning the circumstances of the contribution to CP A. Pursuant to Rule 6, and as explained in Part III, irifra, the OCE draws a negative inference from the non-cooperation of Mr. Bigger and Mr. Kilgore.

E. Representative Schock Asked Donor 1 to Contribute to CPA

68. On or about March 11,2012, Representative Schock called Donor 1 and asked ifhe could support CPA and its activities related to the Kinzinger/Manzullo race. 69

65 COS MOl (Exhibit 12 at 12-9525_106). 66Id. 67Id. 68 Counsel for Mr. Bigger submitted a letter informing the OCE that Mr. Bigger declined to interview with the OCE and only had one document responsive to the OCE Request for Information. Counsel's letter also included a statement suggesting that Mr. Bigger decided to contribute $25,000 from 18th District Republican Central Committee to CPA and then informed Representative Schock of the decision. The OCE Board does not consider the representations of Mr. Bigger's attol11ey in this matter as evidence under H. Res. 895 of the 110th Congress §1(c)(2)(D) (as amended) and OCE Rule 4. 69 Memorandum of Interview of Donor 1, July 25,2012 ("Donor 1 MOl") (Exhibit 18 at 12-9525_0125); Schock MOl (Exhibit 9 at 12-9525_0092).

16

CONFIDENTIAL


69. Donor 1 told Representative Schock on the call that he would suppOli CPA and that he would ask others to help, as well.7o Representative Schock told him that he would forward him the infOlmation to make the contribution to CPA, 71

70. On March 14, 2012, Donor 1 received the infOlmation about CPA from Representative Schock's Chief of Staff in the email below.72

From.; SI6'v(!n Sheamr To, IlfHPtlschock ,com>: @gmaU.c>olt1»

SUbjMh Pwd; CQntribulion info,$UPER PAC Khrzinger·MliIrI::l:ullo O$tl1f; W~d, Mf.'Ir14, 2012 $;07 pm

AttMhmentsl C ItlA~pf(,l$pectus_andJeply_fQrm,pdf(51 OK) I CPA..\h/irln(Unl>llruoUohS, pdf (7$K)

71. On March 14, 2012, Donor 1 contributed $35,000 to CPA,73

72. Donor 1 and Representative Schock both told the OCE that Representative Schock did not request a contribution of any particular amount from Donor 1.74

73. Donor 1 stated that he decided to contribute $35,000 because CPA Managing Director told him that there was a fundraising goal of $1 00,000 to be raised in three days.75

74. Donor 1 told the OCE that as a result of Representative Schock's request for contributions to CPA, Donor 1 solicited a contribution from Donor 2 to help reach the

$100,000.76

75. On March 16, 2012, Donor 2 contributed $30,000 to CP A, 77 Donor 2 told the OCE that she contributed to CP A because Donor 1 requested that she contribute.78

70 Schock MOl (Exhibit 9 at 12-9525_0092); Donor 1MOl (Exhibit 18 at 12-9525_0125). 71 Donor 1MOl (Exhibit 18 at 12-9525_0125); Email from Representative Schock's Chief of Staff to Representative Schock and Donor 1, March 14,2012. (Exhibit 19 at 12-9525_0128). 72 Email from Representative Schock's Chief of Staff to Representative Schock and Donor 1, March 14,2012. (Exhibit 19 at 12-9525_0128). 73 CPA FEC Form 3X (Exhibit 7 at 12-9525_0038). 74 Donor 1 MOl (Exhibit 18 at 12-9525_0125); Schock MOl (Exhibit 9 at 12-9525_0092). 75 Donor 1 MOl (Exhibit 18 at 12-9525_0125). 76 Donor 1 MOl (Exhibit18 at 12-9525_0125). Donor 1 also solicited contributions from Jo1m Canning and Ron Gidwitz. !d. Based on CPA FEC Form 3X, Mr. Canning and Mr. Gidwitz did not contribute to CPA. 77 CPA FEC Form 3X (Exhibit 7 at 12-9525_0040). 78 Memorandum ofInterview of Donor 2, July 25, 2012 (Exhibit 20 at 12-9525_0131).

17

CONFIDENTIAL


76. Donor 1 told the OCE that he did not ask Donor 2 to contribute any specific amount, but he did inform her that he was contributing $35,000.79

III. RODNEY DAVIS, ROB COLLINS, MICHAEL BIGGER, AND PAUL KILGORE REFUSED TO COOPERATE WITH THE OCE

77. Based on the nature of the allegation in this Review, the OCE requested infonnation from

witnesses who were identified as having knowledge of relevant facts.

78. All of the identified witnesses cooperated except the following: Rodney Davis; Rob Collins; Michael Bigger; and Paul Kilgore.

Rodney Davis

79. Mr. Davis is the former Budget Director of Representative John Shimkus and a fonner

volunteer for Representative Shimkus' campaign committee.

80. CPA Managing Director identified Mr. Davis as the person with whom she was put into

contact because he knew of potential donors to CPA for political ads opposing Representative Manzullo.

81. CPA Development Coordinator identified Mr. Davis as the contact person for the

following donors: the 18th District Republican Central Conmlittee ($25,000); ERIC PAC

($25,000); American College of Radiology PAC ($5,000); Donor 1 ($35,000); and Donor

2 ($30,000).

82. The OCE requested information from Mr. Davis to determine whether Representative

Schock had any involvement in soliciting contributions in excess of $5,000 from these donors 01' any other potential donors.

83. Mr. Davis refused to cooperate with the OCE.

84. Pursuant to OCE Rule 6, the OCE draws a negative inference from Mr. Davis' refusal to

cooperate with the OCE. The OCE infers that the information Mr. Davis refused to

provide, taken together with the factual findings in this referral, supports the conclusion that there is substantial reason to believe that the alleged violation occUlTed.

79 Donor 1 MOl (Exhibit 18 at 12-9525_0125). 18

CONFIDENTIAL


Rob Collins

85. Mr. Collins is the former Chief of Staff for Representative 1. He is currently a pminer with Purple Strategies, which provides services related to "corporate communications, reputation management and issue advocacy.,,8o

86. Representative 1 identified Mr. Collins as the person with whom he put Representative Schock in contact because Mr. Collins could assist Representative Schock with raising funds for CPA.8

!

87. Lobbyist Donor 1 identified Mr. Collins as the person who put him in contact with CPA. 82 Lobbyist Donor 1 is a registered lobbyist for the American College of Radiology

Association.

88. The email below shows Lobbyist Donor l's request to have Mr. Collins credit Representative Schock for the American College of Radiology Association PAC contribution to CP A. 83

89. The OCE requested information from Mr. Collins to detennine whether Representative Schock had any involvement in soliciting contributions in excess of $5,000 from this donor or any other potential donors.

90. Mr. Collins refused to cooperate with the OCE.

91. Pursuant to OCE Rule 6, the OCE draws a negative inference from Mr. Collins' refusal to cooperate with the OCE. The OCE infers that the information Mr. Collins refused to provide, taken together with the factual findings in this referral, supports the conclusion that there is a substantial reason to believe that the alleged violation occurred.

80Purpose of Purple Strategies, http://www.purplestrategies.com/purpose/. 81 Representative 1 MOl (Exhibit 8_12-9525_0087). 82 Memorandum ofInterview of Lobbyist Donor 1, July 17, 2012 (Exhibit 21 at 12-9525_0134). 83 Email from Lobbyist Donor 1 to Rob Collins, dated March 15,2012 (Exhibit 22 at 12-9525_0138). See also, Additional Email from Rob Collins to Lobbyist Donor 1, dated March 15,2012 (Exhibit 23 at 12-9525_0140).

19

CONFIDENTIAL

Subject to the Nondisclosure Provisions of H. Res. 895 of the 11 Oth Congress as Amended

Michael Bigger

92. Mr. Bigger is the Chairman of the 18th District Republican Central Committee.

93. The 18th District Republican Central Committee contributed $25,000 to CPA on March 16,2012.

94. The OCE requested information from Mr. Bigger to determine whether Representative

Schock had any involvement in soliciting contributions in excess of $5,000 from the 18th District Republican Central Committee or any other potential donors. The OCE

also requested infonnation to determine the involvement of Representative Schock's

campaign in the 18th District Republican Central Committee's contribution of $25,000 to

CPA.

95. Mr. Bigger refused to cooperate with the OCE.

96. Pursuant to OCE Rule 6, the OCE draws a negative inference from Mr. Bigger's refusal

to cooperate with the OCE. The OCE infers that the infOlmation Mr. Bigger refused to

provide, taken together with the factual findings in this refenal, supports the conclusion

that there is a substantial reason to believe that the alleged violation occurred.

Paul Kilgore

97. Mr. Kilgore is the Treasurer for the 18th District Republican Central Committee. He is

also the Treasurer for Schock for Congress and Schock Victory Committee.

98. The 18th District Republican Central Committee contributed $25,000 to CPA on March 16,2012.

99. The OCE requested information from Mr. Kilgore to detelmine whether Representative Schock had any involvement in soliciting contributions in excess of $5,000 from the

18th District Republican Central Committee or any other potential donors.

100. Mr. Kilgore refused to cooperate with the OCE.

1 01. Pursuant to OCE Rule 6, the OCE draws a negative inference from Mr. Kilgore's refusal to cooperate with the OCE. The OCE infers that the information Mr. Kilgore refused to provide, taken together with the factual findings in this referral, supports the

conclusion that there is a substantial reason to believe that the alleged violations in this Review OCCUlTed.

20

CONFIDENTIAL


IV. CONCLUSION

102. Based on the information before the OCE, the Board finds that Representative Schock solicited Representative 1 to contribute $25,000 to CPA.

103. In addition, the Board finds that there is substantial reason to believe that Representative Schock's campaign committee solicited the 18th District Republican Central Committee to contribute $25,000 to CPA.

104. For the foregoing reasons, the Board of the Office of Congressional Ethics recommends that the Committee on Ethics further review the above allegation because there is substantial reason to believe that Representative Schock solicited contributions for an independent expenditure-only political committee in excess of $5,000 per donor, in

violation of2 U.S.C. § 44li(e)(1)(A), House Rule 23, clause 1, and the Code of Ethics for Govel11ment Service, ~ 2.

V. INFORMATION THE OCE WAS UNABLE TO OBTAIN AND RECOMMENDATIONS FOR THE ISSUANCE OF SUBPOENAS

105. The following witnesses, by declining to provide documentmy and testimonial evidence in response to the OCE's Requests for Information, did not cooperate with the OCE's review.

a. Michael Bigger, Chailman, 18th District Republican Central Committee;

b. Rob Collins, Partner, Purple Strategies LLC;

c. Rodney Davis, former staffer of Representative John Shimkus; and

d. Paul Kilgore, Treasurer, 18th District Republican Central COlmnittee.

106. As a result, the OCE was unable to obtain certain infol111ation regarding whether

Representative Schock solicited certain contributions in excess of $5,000 per donor.

107. The Board recOlmnends the issuance of subpoenas to Michael Bigger, Rob Collins, Rodney Davis, and Paul Kilgore.

21

EXHIBIT 1

FEDERAL ELECTION COMMISSION Washington, DC 20463

CERTIFIED MAIL RETURNRECEIPTREQUESTED

ADVISORY OPINION 2011~12

Marc E. Elias, Esq. Ezra W.Reese: Esq. Jonathan S. Berkon, Esq. Perkins Coie L1,P 700 Thirteenth St., NW, Suite 600 Washington, DC 20005-3960

Dear Messrs. Elias, Reese, and Berkon:

June 30~ 2011

We are responding to your advisory opinion request on behalf of Majority PAC (fo1'1nerly knO\vn as Commonsense Ten) and House Majodty PAC (the "Committees"), conceming the application of the Federal Eleotion Campaign Act of 1971. as amended (the "Acf'), and Commission regulations, to the Committees' plan to ask F edernl officeholders and cHndidates, and officers of national party committees, to solicit unlimited individual, COI})Orate, and labor organization contributions on behalf of the Committees. The Commission concludes that Federal officeholders and candidates, and officers of national purty committees, remain subject to the Act's amount limitations and source prohibitions when they solicitcolltributiol1s on behalf of the Committees. Additionally, the Commission concludes that Federal oi:l1ceholders and candidates, and national party officers, may attend, speak at, and be featured guests at fundraisel's for the Committees at\vhich unlimited individuul,cOl'porate, and labor organization contributions are solicited, so long as they restrict any solicitation they make tonll1ds subject to the limitations, prohibitions and reporting requirements of the Act.

Background

The facts presented in this advisory opinion are based on your letter received on May 19,2011, materials submitted in connection 'with Advisory Opinion 2010-11 (Co111monsense Ten), and on publicly available reports filed with the Conmlission.

A02011-12 Page 2

On June 11, 2010, Majority PAC, under its previous name, Commonsense Ten, filed its Statement of Organization. 1 On the same day, it filed an Advisory Opinion Request with the Commis.sion tegardingitsplannedactivities. In its 2010 request, Majotity PAC represented that it planned to pay for independent expenditUl'es butthat it would not make any direct or inckindcontributions to Federal candidates, political party committees, or to any other political committee that makes contributions to Federal candidates 01' party committees. Advisory Opinion Request 201 0-11 (Commonsense Ten) at 3 .. Majority PAC also stated that it wouid solicit and accept contributions from corporations and labor organizations, as well as from individuals .andFederalpolitical committees in excess of $5,000 per calendar year. fd. It would not, however, solicitor accept contributions from foreign nationals, Federal contractors, or national banks or cOl'porations organized by any law of Congress. fd. Majority PAC also stated that it would report ali conttibutiohs aggregating· in excess of $200 a year to the COlmnission. !d. On July 22, 2010, the Commission approved the proposal1n Advisory Opinion 2010-11 (Commonsense Ten). On July 27, 2010, Majority PAC filed a letter with the Commission stating that it intended to make independent expenditures and raise funds in unlimited amounts, but that it would not make any ·contributions to Federal candidates ot to Federal political committees. wlrether direct, in-kind,orby means of coordinated communications. 2

.

On April 11, 2011, House Majority PAC filed its Statement of Organization. On the same day, House Majotity PAC filed a letter stating that it intended to make 11tdepelldent expenditures and raise funds inutilimited,amounts, but that it would not make any contributions to Federal candidates or to Federal political committees, virhether direct, in-kind, or by means of coordinatedconm1Unications.

Both Committees represent that they have solicited aild accepted contributions in accordance ,vith Advisory Opinion 2010-11 (Commonsense Ten), and that they report these contributions to the Commission. Both Committees have filed the required disclosure reports, and these reports are available on the Commission's website.

Questions. Presented

1. lvfay Federal officeholders and candidates, andofJicers of national party committees, solicit unlimited oontributions Fom individuals, corporations, and labor organizati071son behalf of political committees that make only independent expenditures?

2. If the answer to Question One is no, may Federal officeholders and candidates; and officers of national party committees, participate in jimdrai sers for such political committees, at which unlimited indiVidual, cOlpotate, and labor organization

1 OnMarch9. 2011, Majority PAC filed an amended Statement of Organization indicating a name change from Commonsense Ten to Majority PAC.

2 The Commission approved the use of a template for this type of letter in Advisory Opinion 20 1 0-09 (Club for Growth).

A02011-12 Page 3

contributions 'will be solicited, so long as the officeholders, candidates, and officers do not themselves solicit such contributions?

Legal Analysis and Conclusiolls

1.M ay Federal officeholders and candidates, and officers of national party cotntnittees, solicit unlimited contributionsfi'om individuals, corporations, and letbor organizations on behalf of political comlnittees that make only independent expenditures?

No, Federal officeholders, candidates, and ·officers of national party committees may not solicit unlimited contributions from individuals, corporations, or labor organizations on belui:lfof independent expenditure-only politicalcQinmittees ("iEOPCs"). However, Federal officeholders and candidates, and officers of national party committees, may solicit upio $5000 from individuals (and any other source 110t prohibited by the Act ii-om making a contribution to a political committee) on behalf of an mopc, because those funds are subject to the Act's amount .limitations and source

1 'b' . 3 pro 11 . l1101'1S.

TIle Act limits contributions by any person to "any other political conunittee" (other than authorized candidate committees, and .national and state party committees) to $5000 per calendar year. 2 U.S.C. 441a(a)(1)(C). FUlthenl1ore, national banks, corporations, labor organizations,Federal contractors,and foreign miti.olials ate prohibited ftom nlaking arty contributioniti connection with any Federal election. 2 U.S.C. 441b(a), 441c, 441e.

On January 21,2010, the U.S. Supreme Court held ill Citizens Uf1itedthat corporations l1iay make unlimited independent expenditures and e.lectioneel'1ng conul1unlqations using corporate treac;ury funds. Citize11S Unitedv~ FEC, 558 U.S. _, 130S.Ct. 876, 913 (2010)~ On March 26, 2010, shortly after the Citizens United decision, the U.S. COUliof Appeals for the District of Columbia Circuit1leld that the Act"s contribution limits are unconstitutional as applied to individuals ' contributions to political Qonlmittees thatma:ke only independent expenditures. SpeechNow.org v. FEC, 599 F.3d686, 696 (D.C. Cil". 2010) (en banc). Consistent with the Citizens United and SpeechNow opinions, the Commission concluded that corporations, labor organizations, political committees, and individuals may each make unlimited contributions to IEOPCs, and that these IEOPCs may solicit Ullfimited oontributions fro111 these sources. AdvisOlY Opinion 2010-11 (Commonsense Ten). TIle Committees have registered as rEOPCs, and therefore 11iayaocept unlimited contributions from individuals, political conIDlittees, corporations, and labor organizations.

However, Federal officeholders and candidates, their agents, and entities directly or indirectly established, financed, or maintained, or controlled by, or acting on behalf of, Federal officeholders and candidates, may not raise or spend funds in connection with an election for Federal office; "unless the funds are subject to the limitations, prohibitions,

3 See 2U.S.C. 44li(e)(1)(A); n CFR300.61.

A02b11~12 Page 4

andrepoltingl'equirements" of the Act. 2 U.S.C. 441i(e)(1)(A); 11 CPR 300.61. Persons subject to secticm44li( e) also may not raise or spend funds in connection with any election other than an election for Federal office unless the funds are raised within the Act's contribution limits and are not from prohibited sOl.~rces. 2 U.S.C. 441i(e)(1)(B); 11 CFR 300.62. Similar1y~_l1atiollal party conmlittees, their officers and agents, and any entity that is directly or indirectly established, financed, maintained,_ or controlled by a national patty committee or a natiol'lal congressional campaign cOfhmittee, may not solicit, receive, direct or speild"any funds [] that are not subj ect to the limitations, prohibitions, and repolting requirements of the Act." 2 U.S.C. 44li(a)(1); 11 CFR 300.lO(a).

Section 441i was enacted by Cong1"ess long after the Act's contribution limits and source prohibitions.4 It was upheld by the Supreme COUli in McConnell v. FEC, .540 U.S. 93, 181~184 (2003), and remains valid since it was not disturbed by either Citizens United or SpeechNow. See, e.g.,RNe v. FEC, 698F. Supp.2d 150, 156~60 (D.D.C. 201O),ajf'd 130S. Ct. 3544 (2010).

It.is clem"that under Citizens United, the Committees may accept U11lililited contributions from individuals, corporations, and labor organizations; however, the Act's solicitation restrictions remain applicable to contributions solicited by Federal candidates, officeholders, and national party cotnmittees and their agents. Thus, Federal candidates, officeholders, and national patty committees and their agents may only Solicit contributions of up to $5000 from individuals (other than foteign nationals or Federal contractors) and Federal political action committees for an mopc.

2. lfthe answer to Question One is no, may Federal officeholders and candidates, and officers of national party CQil1mittees, participate Il1fundraisers for such political committees, atwhich unlimited indiVidual, corporate, and labor organization contributions will be solicited, so long as the officeholders, candidates, andoJjicers do not themselves solicit suchcontri butions?

Yes, Federal officeholdets and candidates, and officers of l1atioiHti patty committees, may attend, speak at, or be featured guests at fundraisers for the Committees, at which unlimited individual, corporate, and labor organization contributions will be solicited, so long as the officeholders, candidates, and officers of national patty cOl11mittees restrict aily solicitations they make tb funds subject to the .1itnitations, prohibitions, and repOlting requirements of the Act.

4 Congress passed the solicitation prohibition at 2 U. S. C. 441 i as part of the 2002 Bipartisan Campaign Refonn Act of 2002 ("BCRA").

A02011-12 Page 5

In April 2010, the Commission adopted revised regulations covering "patticipatioll by Federal candidates atldofficeholders .at fundraising events in connection with an election for Federal·office ... at which funds outside the amount limitations and s~urce prohibitions of the Act or Levin funds are solicited." 11 CFR 300.64(a).5 Under the revised regulations, a Federal candidate or officeholder may "[a]ttend~ Bpeak at, or be a featured guest" at such a fundraising event. 11 CFR300.64(b)(1). In the course of participating in such an event, however, a Federal candidate or officeholder may not solicit any funds that are not "subject to the limitations, prohibitiorts, and reporting requirements of the Act." 11 CFR300.61.Rather, aFederal candidate or officeholder who solicits funds at such an event must limit any solicitation "to funds that comply with the anloU11t limitations and sourcevrohibitions ofthe Act." 11 CFR300.64(b)(2).

This response constitutes an adviso1Y opinion cancet11ingihe application of the Act and Commission regulations to the specific transaction or activity set forth in your request. See 2 U.S.C. 437£ The Commission emphasizes that; ifthere is a change in any of the facts or assumptions presented, and such facts or assumptions are material to a conclusion presented in this advisory opinioil, then the requestor may not rely 011. that C011clusion as support for its proposed activity. Any person involved in any specific transaction or activity which is indistinguishable in all its material aspects from the transaction or activity with respect to which this advisory opinion is rendered may rely on this advisory opinion. See 2 U.S.C. 437f(c)(1)(B). Please note the analysis or conclusions in this advisory opiilion may be affected by subsequent developinents in the law including, but not limited to, statutes, regulati011s, advisory opinions, and case law. The cited adVisory opinions are available on the Commission's website, www.fec.gov,or directly from the Commission's Advisory Opinion searchable database at http://www .fec.gov! searchao.

On behalf of the Commission,

(signed) Cynthia L. Bauedy Chair

5 See also Final Rules for 11 CFR 300.64: Participation by Federal Candidates and Officeholders at NonFederal Fundraising Events, 7S FR 24375 (lv.[ay 5, 201 0), available at www.fec.gov/fosers.

EXHIBIT 2

Fundralsing by Federal Candidates at'ld Officeholders

Appendix E. Fundraising by Federal Candidates and Officeholders

Prohibition The Federal EJection Campaign Act (the Act) and Commission rElgulations restrict the ability of federal candidates and officeholders to raise funds. Specifically, federal candidates and officeholders, their agents and entities established, financed, maintained or controlled by them, may not solicit,' receive, direct,2 transfer, spend or disburse funds in connection with a federal elec:;tion,induding funds for federal elec:;tion activity, unless the funds are withih the Acfs limits, prQhibitions arid reporting requirements. 300,6 L

In addition,fedEwal candidates and offkeholders may solicit, receive, direct, transfer, spend or disburse funds 'in connec:;tion with a nonfederal election only in amounts and from sources that are consistent With state law and that

To solicit means to ask, request or recommend, explicitly or implicitly, that another person make a contl'ibution, donation, transfer of funds or otherwise provide anything of value.A solicitation Is an oral or written communicatiOn that, constl'ued as reasonably undel'stood ih the context in which it is made (including the .conduct of the pel'sons involved),contains a dear message asking, requesting 01' recommending that anothel' pel'sOn make a contl'ib.ution, donation,tl'ansfElI' of funds or otherwise provide anything of value.A solicitation may be made dit'ectly or indirectly, and does not include mere statements of political SUppOI't or mere guidance as to the app licability of.a particulal' law 01' regulation. 300.2(m). See the regulations at 300.2(m)(1 )-(3~ for examples of communications ana statements that do or do not constitute solicitations.

2 To dil'ect means to gUide, directly 01' indirectly (through a conduit or intel'lneaiat'y),.a person who has expressed an intent to make a contribution, donation, transfer offunds or othelwlse provide anything of value, by identifying a candidate, political committecol'ol'ganization for the rec<;lipt of such funds or things of value. Direction does not include merely providing information 01' guidance as tothe appllcabilityofa pal'ticular law or regulation. 300.2(n).

do not exceed the Act's contribution limits or come from prohibited sourCEls. 300,62.

The Act and Commission regulations provide for exceptions and clarifications to these general prohibitions, as discussed below.

I. Fundraising forState/local Candidates and Elections

Nonfederal Elections Afederalcandidate, officE:iholder or his or her agents, and any entity directly or indirectly established, financed, maintained or controlled by, or acting on behalf of, oneot' more federal candidates or officeholders, may raise funds in connection with a nonfederal election, but only in amounts consistent with .state law and that do not exceed the Act's contribution limits or come from prohib.itedsources.3 300,62; See also 300.64(b )(2),4

Ballot Initiatives In AO 2010-07, the Commission concluded that Members of Congress could solicit funds outside the Ads limits and prohibitions on behalf of ,a California ballot initiative comrriittee,Yes on FAIR, during the time bElfore the initIative qualified for the ballot, and afterward could solicit up to $20;000 from 'individuals on behalf of the committee"For additional information on ballot initiatives, see AOs 2007-28,2006 -Q4,2005-IO, 2004-29 and 2003-12.

3 See 300.2(b) and (c;) fora list of the factol's considered by the Commission in determining whether an entity is directly 01' indirectly established, financed, maintained or controlled by; 01' aoting on behalf of; a fedel'al oandidate, officeholder or agent. See alsoAOs 2006-04,2005-02 and 2004-33.

4 Please rrotethat the Commission superseded the second paragl'aph in the answer to Question 2 In AO 2005-02. See the Explanation and Justification to rules on participation by federal candidates and officeholders at nonfedel'Cil funaraising events, prescribed June 4, 201 0,75 Fed. Reg. 24375 (May 5,2010).

151

152

Appendix E

Candidates Who Run for Both Federal and Nonfederal Office Commission regu lations provide a limitedexception for federal candidates and officeholders who seek state or local office. The restrictions on raising and spending funds outside the Act's limitations and prohibitions do npt apply to any federal candidate or officeholder who is or was also a candidate for state or local office so long as the raising or spending of funds is I) solely in connection with his or her state or local campaigt1i 2) refers only to him or her ,or to other candidates for that same state or local office; and J)ls permitted under state law. 300.63.

Ifthe candidate or officeholder is simultaneously running for both federal and state or local offices, then the candidate or his or her agents may only raise and spend funds within the limits, prohibitions and reporting requirementsof the Act for the federal election. 300.63; See also AOs 2007-0 1,2005-12 and 2005-02.5

2. Nonfederal Fundraising Events

Particip.ationat N onfederal Fundraising Events A federal candidate or officeholder may attend, speak at ,and be a featured guest ata nonfed-eral fund raiser. 300.64(b){I). Heor she is also free to solicit fUhdsat the fundralsingevent, provided that the solicitation for funds is within the limitations and prohibitions of the Act and consistent with state law. 300.64(b) (2),

Such a solicitation should either be explicitly limited or should be limited by displaying at the fundraiser a dear and conspicuous written notice, or by making a clear and conspiCUOUS oral statement, that the solicitation Is not for Levin

5 Please note that the Commission superseded the second paragraph it1 the answer' to Question 2 in AO 200S-02.See the Explanation ·and Justification to rules on p.at'ticipatio.n by federal candidates and officeholders at notifederal fundt'aisingevents, prescribed June 4,2010,75 Fed. Reg. 24375 (May 5,2010).

funds (when applicable) and does not seek funds in excess of federally permissible amounts. or from corporations; labor organizations, national banks, federal government contractors and foreign natiohals. 30Q,64(b )(2)(i-li), If the federal candidate or officeholder chooses to make an oral statement, it need only be made once,

Publicity for Nonfederal Fundraising Events FEe regulations also address the publicity for nonfederal fundraisers induding,but not II mited to, ads, annou ncements or pre-event invitation materials,regardless of format or medium ·of the communication. 3QO:64(c)

If the publicity does notconta.ln a solicitation or solicits only federally permiSSible funds, then the federal candidate or officeholder (or agent of either) .is free to consent to the use of the name or likeness of the federal c(lndidateor officeholder in the pUblicity for the nonfederal fundraiseI'. 300.64(c)(1 )-(2).

If the pUblicity contains a solicitation for funds outside the limitations 01' prohibitions of the Act or Levin funds, the federal candidate or officeholder (or agent of either) may consent to the use the name or likeness of the federal candidate or .officeholder in the publicity, only if:

• The federal candidate or officeholder is identified ina manner not specifically related to fundra:ising, such as a featured guest, honored guest, special guest, featured speaker 01' honored speaker; and

• The publicity includes a clear and conspicuous oral or written disclaimer that the solicitation is not being made by the federal candidate or officeholder. 300.64(c) (3)(i). Examples of disclaimers are provided in the regulation at 300.64(c)(3')(iv).

However, a federal candidate or officeholder (01'

agent of either) may not agree to the use of his or her name or likeness in pUblicity that contains a solicitation of funds outside the limitations and prohibitions of the Act or of Levin funds if:

The federal candidate or officeholder is identified as serving in a manner specifically related

Fundraising by Federal Candidates and Officeholders

to fundraising,$uch as honorary chairperson or member of a host committee; or is identified in the pUblicity as extending the invitation to the event; or

• The federal candidate or officeholder >signs the commu nication.

• These restrictions apply even if the public-ity contains a disclaimer. 300.64(c)(3)(v).

In addition,the federal candidate or officeholder is prohibited from disseminating publicity for nonfederal fundraisers that contains a solicitation of funds outside the limitations or prohibitions of the Act or of Levin fu nds. 30D.64(c)(3)(vi).

1. Supporting Independent Expenditure Only Political Committees

Political committees that make only independent expenditures may solicitahd accept unlimited contributions from indiViduals, corporations, labor organizations and other political committees. They may n6t accept contributions from foreign nationals, federal contractors, national banks or federally chartered corporations. SeeAO 20 I 0-1 I. Such committees, known as Independent Expenditure Only Political Committees or IEOPCs, must register with the Commission and comply with all applicable reporting requirements of the Act. See also Citizens United v. FEC, I 30 S. Ct.S76, 913 (20 I 0) and SpeechNow.org v. FEC, 599 F. 3d 686 (D.C Cit: 20 I 0).

Federal candidates and officeholders may raise funds on behalf oflEOPCs so long as they only solicit funds subject to the Act'samoljntlimitations and source prohlbltions-i,e. up to $5000 from individuals (and any other source not prohibited by the Act from making acontriblltion to a political committee).Additionally, federal candidates and officeholders may attend, speak at and be featured guests at fundraisers for IEOPCs at which unlimited individual, corporate and labor organization contributions are solicited, so long as they restrict any solicitation they make to funds subject to the limitations, prohibitions and reporting reqUirements of the Act.AO 20 I 1-12. See 300.64(b)( I) and (2).

4. Supporting Tax-Exempt Organizatio ns

General Rule for Solicitations A federal candidate, officeholder or his or her agents may make soliCitations for certain taxexempt organizations. The regulations regarding solicitation for tax-exempt organizations differ depending on whether the funds solicited will be used for certain federal election activities and whether the organization's principal purpose is to conduct federal election activity;

limits and Prohibitionson Solicitations General Solicitations A federal candidate or officeholder (orindlvidual acting on behalf of either) may make a general solicitation on behalf of a 50 I (c) tax-eXel11pt organization, or an organization that has .applied for this tax status, without limits on the source or amount of funds, if

• The organization does not engage in activities in connection with elections, or

• It is hot the principal purpose of the organization to conduct election activities, includ-ing certain federal election activity, and

• The solicitation is. not to obtain funds for activities in connection with an election, indudingcertain federal election activity.300.65(a) and (c) ..

SpecifkSolicitations for Federal Election Activity

A federal candidate or officeholder (or individual acting on behalf of either) may also make a specific solicitation explicitly to obtain funds to pay for federal election activities conducted by or for a tax-exempt organization whose principal purpose is to undertake such activities. The federal election activities for which such a specific solicitation may be made are limited to:

• Voter registration activity during the period that begins 120 days before the date of a regularly scheduled federal election and ends on the day of that election; and

153

154

Appendix E

• Voter identification,get-out-the vote or generic campaign activity conducted in connection with an election in which a federal candidate appears on the ballot (regardless of whether a state or local candidate also appears on the ballot). See 100.24, 100.25 and 300.65(<:).

When making .specifit solicitations for a ta~exempt organization, the candidate may solicit only individuals and may solicit no more than $20;000 per calendar year from each contributor. 300.65(b).

General Prohibition

Federal law permits solicitations by federal candidates and officeholders only for the specific federal election activities listed above; these individuals must not make any solicitations ·on behalf of a 50 I(c) organization, or anorganization that has applied for this tax status, for any other types of election activities, such as pUblic communications promoting, supporting, attacking or opposing federal candidates. JOO.65 (d).

Safe HarboJ

To determine whether a 50 I (c) organization is not one whose principal purpose is to conduct election activities, such as those outlined in the above two paragraphs, a federal candidate or officeholder or their agent may obtain and rely upon.a written certification, signed by an officer or other authorized representative of the organization with knowledge of the organization's activities., stating that:

• It is not the organization's prindpal purpose to engage in election activities, including the types .of election activity described above; and

• The organization does not intend to pay debts incurred from expenditures or disbursements in connection with an election for federal office (including for federalelectionactivities) ina prior election cycle.

If the federal candidate or officeholder (or an agent of either) .has actual knowledge that the certification is false,then the certification may not be relied upon.

300.65{e) and (f).

EXHIBIT 3

Campaign for Primary Accountability, Inc. RECEIVEr

Federal Election Commission 999 E Street, NW Washington, DC 20463

3900 Essex Lane, Suite 575 2011 SEP 29 AM/I: 35 Houston, Texas 71027

September 27th, 2011 FEe MAIL CENTER

Via Hand Delivery

Re: Form 1, Statement of Organization-Unlimited Contributions

To Whom It May Concern:

The Campaign for Primary Accountability, Inc. intends to make independent expenditures, and consistent with the U.S. Court of Appeals for the District of Columbia Circuit decision in SpeechNow v. FEe, it therefore intends to raise funds in unlimited amounts. This committee will not use those funds to make contributions, whether direct, in-kind, or via coordinated communications, to federal candidates or committees. Enclosed please find the committee's Form 1 Statement of Organization.

Respectfully submitted,

Jonathan Martin

enclosure 4~~

r FEe

FORM 1

1. NAME OF COMMIITEE (in fUll)

STATEMENT OF ORGANIZATION

O. (Check if name Is changed)

1.1" !

Illllllll!I.lI! 111111 I J •• I

o. (Check if adclress is changed)

I 1..1 , I I .( ... 1. .1 I I

I.....J LI

I I I

I •• J.....J

RECElvr:~l ...,

2Uff SEP 29 AM": 35

ER

I I J.....L.J

L! I I

1 .... 1. !._I L~! 1.. tti I .. I

I !! . L J . I. .1 . !.

CITY ST~E ~PCODE

COMMITTEE'S E·MAIL ADDRESS (P~ae pro\lide only one e-mail address)

O (Check if address Is changed) L, ! I L. I .1. I I. I ! I I .1

COMMIITEE'S WEe PAGE ADDRESS (URL)

O (Check if a(fdrf)$S Is ohanged)

2. DATE

3, Fee fDENnFlCATION NUMBER

.. ! I. I

I I

!

.1 I

J t

4. IS THIS STATEMENT 181 NEW (N) OR o AMENDED (A}

I"L.1 ... L I . ..1 I

! j I

I

!

!.! I !.1 .1 • !, I >oj J

I .J L

! !

I certify that I have examined this Statement and to the best of my knowledge and belief it is true, C()rrect and camplete.

Type or Print Name of 'ireasurer ~~~~~~~--~------------------------------------

Signature of 1teasurer Date

NOTE: Submission of fulw, elTQnsol$, Qr il1¢()mpl~te InfotmallOO ITlI!IY subject the pel$On slgnfng tbls Statement to the penalties of 2 U.S.C. §437g.

ANY CHANGE IN INFORMATION SHOULD BE. REPORTED WITHIN 10 DAYS.

Office For ful1her Inforl'nslkm COl'ltmlb FEe FORM 1

L Use FedwaI Election CoITTIni!mlon

.J Only. TOll Fmo lICX)...tI,2;t.953() (Ral/isM (212009) l..ocA! 2.02-69'M 1 00

r FEC Fonn 1 (Revised 0212(09) Page 2

5. TYPE OF COMMITIEE

Candidate Committee:

(a) o (b) D Name of Candidate

Candidate

This committee Is a principal campaign committee. (Complete the candidate information below.)

This committee is an authorized committee, and is NOT a principal campaign committee. (Complete the candidate information below.)

I I I I I I I I I I I I I I I .I. I I I I ~.~r.~:';"',,:;'~~.~ Office State

fl""""""l t:.'2,,~

Party Affiliation i' '/ e';.j!',,';·,'('~:.r.;!~T.)"! Sought: D House D Senate D President ~~"'''~ District fl., .. ~.J

(0) 0 This committee supports/opposes only one candidate, and Is NOT an authoriZed committee.

Name of Candidate l I I I I I I t I I I I I I I I I I I I I I I I I I I I I I

_ I I I I I I I I I I I I I I I ! I I I I I ! I I I I I I L

Party Committee:

(d) D This committee is a ~'-'f~'-""i~f

L~"P&~'B (National, State or subordinate) committee of the

r.t~:·t.··r:l..~9

~r.:l'."-h~'Zr'V,;~~~n (Democratic, Republican, etc.) Party.

I"'I'f Political Action Committee (PAC):

(e) D This committee is a separate segregated fund. (Identify connected organization on line 6.) Its connected organization is a:

(f)

D Corporation o Corporation wlo Capital Stock

D Membership Organization o Trade Association

o 111 addition, this committee Is a LobbyistlRegistrant PAC.

o Labor Organization

D Cooperative

This committee supports/opposes more than one Federal ca!ldldate, and 18 NOT a separate segregated fund or party committee. (i.e., nonconnected committee)

o In addition, this committee is a I.DbbyistlAegistrant PAC. o In addition, this committee 10 a Leadership PAC. (Identify sponser GTIline 6.)

Joint Fundraising Repre.$entative:

(g)

(h)

L

o o

this committee collects contributions, pays fundraising expenses and disburses net proceeds for two or more political committeeslorganizatlons, at least one of Which is an authorized committee of a federal candidate.

This committee collects contributions, pays fundraising expenses and disburses net proceeds for two or more political committees/organizations, none of which is an authorized committee of a federal candidate.

Committees Participating in Jeint FundraiBef

1.

2.

3.

4.

I I I I I I I I I I I l I I I I I I I ! I !i·~4ll~'W"·~r.c=-ir;v"~~r~t,:U"~~~~~~~1

I J FEe ID number~C~! n ~~;;:::;;,-·;;~·:-:;.s:5 .. :r:':::T~'r.a-7!"'":'P&.';"~~~~\f;;'fl-.:~J

I I 1..1 J 1 1 1 1 I J L I 1 I 1 I I I I I I FEC ID number~Cf~·~~:or .. ~.~X,.,~aK'~~~~<-<!~' C).7.;;:.L~~";~.~~:I£.~';'!:\7o'.c.,':1.';"M;,·.:.t.':'~·1~:ro..::.t.';:"'~$'iI.~Ji~ E't"'~f~~'''2'i.:'''''lPtr..;,'''t-ii~~P(lU'"; ...... ~~~''tl::''%.~'{*''ol:ittt-~J

1-l..J..1 ..J..I-II-I-I ..J..I-.I.......I...I ..1.1-11",""",-1 ..J..I-.\I-,,-I .... 1 -11-....1-.1 ..&..1 -11--,-' ..&..1 -,1-0011 FEC 10 number~g1.~';"'i\"."d}~'!k:,".ob''''''''''h1.'''/'m~i>'''.J fi~1f';>I~r-:~.L~"?·ff)l,'1·~N-~'P""'~,=~,,,,,"]

I I I ! I I I I I I I I I I I I I I I I I I t FEe 10 number[jg~~o,;'~';~:"'~';"::~.~=E\n':';m"';. .... .." ..

..J

r FEC Fonn 1 (Revised 02120(9) Page 3

Wrlla or Type Committee Name

Campaign for Primary Accountability. Ino. 6. Name of Any Connected OrganiZation, Affiliated Committee, Joint Fundmising Representative, or i.eadenmip PAC Sponsor

f;J4>n~ I I I I I I I I I I I. I I I I I I I 1 I I I I I I ! I I. I I I I I I I ! I I I I I I I. L I I I I I I 1 I .1. L1J . I. I , I I I I I I I I I I I I I I I I I I I I I I I I I I I I J

Mailing Address I I I I I I I I I I I I I / I I I I ! I I I I f I I I I I I , I I I I

I I I I I I I I I ! I I 1 I I I I I I I I I I I I j I J I I .. J I I I I I I I II f I I I L I I I I I I I 'I LL.J I 1 I I ! 1-1..1 I IJ

CITY STATE ZIP CODE

Relationship: Deonnected Organization GmUated COmmitWe DOlnt Fundtalslng Representative Q.eademhiP PAC Sponsor

7. Custodian of Records: Identify by name, address (pllone number - optional) and position of the person In possession of committee books and recordS,

Full Name l!9nSitnaljl ¥!JrtiC! I ! I ! ! ! ! !

Mailing Address 117,3~ ~Cf.Y9a~~ !jigtJ~al. I It!

@pit@ I-~4E I I I I .1_1

I I I! I I I I

Title or Ftlsition CITY

I !

I I I I

! I

@£j

STATE

I I I !

I I I ! I 1

! 1 ! !

g~12! I-I ! I

ZIP CODE

Telephone number 18gB! 1-l?V I 1-~

8. Treasurer: Ust the name and address (pbone number - optional) at the treasurer of the committee; and the name and address of any designated agent (e.g., assistant treasurer).

Full Name of Treasurer

Mailing Address

Title or Position

l!r,e~syrxr I I I

L

IC~!:I~!1 ! ! I 1.1 1 I

CITY

I I ! I ! f

! I ! I , I I I ! ! I I I I I I I I I! ! I

i I I I ! .I @£J 1?!t412, I-I. I I I

STATE ZIP CODe

Telephone number @3B! 1- {7~71 1-_ .J

... 1

r FEC Fonn 1 (Revised 0212(09)

Full Name of Designated

Page 4

~~t ~~I~I~~~~~~~~~~~~~~~~~~~-k~~~~~~~~~

Mailing Address

Title or Pos~ion

I 1 1 1 1 1

CITY LLJ L J - ,-' ...L....L..-I......I

ZIP CODE STATE

Telephone number L-.1-....J-JJ -I I I 1- 1-1 ...I..I-,-.l-..I

Banks or Other Depositories: US! all banks or other depos~orles In Which the commmee deposits funds, holds accounts, rents safety deposit boxes or maintains funds.

Name of Bank, Depos~ory, etc .

....; !B§!n~ 2f t!J1e[ic,a! ! ! I ! 1 ,

Mailing Address !3~Ot ~i9hp19np ~V@·I

1_.1 L

~Og71

CITY STATE ZIP CODE

Name 01 Bank, Depository, etc.

Mailing Address 1 I J

l.J.J CITY STATE ZIP CODE

L .J

Federal Election Commission ENVELOPE REPLACEMENT PAGE FOR INCOMING DOCUMENTS

The FEC added this pade to the end of this filing to indicate how it was received.

~ Hand Delivered Date of Receipt

9/P-'1/ l (

Postmarked D USPS First Class Mail

D USPS Registered/Certified Postmarked (RIC)

Postmarked D USPS Priority Mail

Delivery Confirmation TM or Signature Confinnation TM Label' D Postmarked D USPS Express Mail

D Postmark Illegible

D No Postmark

D Overnight Delivery Service (Specify): Shipping Date

Next Business Day Delivery D

D Received from House Records & Registration Office Date of Receipt

D Received from Senate Public Records Office Date of Receipt

D Received from Electronic Filing Office Date of Receipt

D Other (Specify): Date of Receipt or Postmarked

~~~ 9/J-1/1( PREPARER DATE PREPARED (3/2005)

EXHIBIT 4

CONFIDENTIAL


INRE:

REVIEW NO.:

DATE:

LOCATION:

TIME:

PARTICIPANTS:



MEMORANDUM OF INTERVIEW

CP A Managing Director 12-9525

July 12,2012

1101 COlmecticut, NW

\V:ashington, DC 20005

1:03 p.m. to 1:49 p.m. (approximately)

Kedric L.Payn:e

Paul J. Solis

Lee Goodman

SUMMARY: The witness is the Managing Director of Development for Campaign for Primary

Accountability ("CPA"). The OCE requested an interview with the witness on July 12, 2012,

and she consented to an interview. The witness made the following statements i11 response to our

questioning:

1. The witness was given an 18 U.S.C. § 1001 waming and consented to an interview. She signed a written acknowledgement of the waliling, which will be placed in the case file in this review.

2. The witness is the Managing Director .of Development for CPA and works in Austin,

Texas. She is also the Managing Director of Development forthe Alliance for Self Gove111ance CASG").

3. She is the President of Citizen Leader Alliance ("CLA").

4. The witness told the OCE that CLA, ASG, and CP A do not have any fonnal relationship,

but the entities share many of the safne employees .

.5. She stated that the CPA Co-Chainnen are Leo Linbeck and Eric O'Keefe. The Chief of Staffis Michael Bamhart. The witness reports to Mr. Ba111hart.

6. The CPA staflet's are divided among three groups: fundraising, communications, and the

political team. The witness and HalUlah Christian are the only staff in the fundraising

group. Kelly O'Keefe is in the communications group.

7. When: asked to describe her job duties related to fun:draising, the witness stated that she calls prospective donors, build relationships with the donors, and updates donors on CPA

activities. She is not certain, butbelieves that she has sent direct mail to potential donors.

MOl-Page 10f3 OFFICE OF CONGRESSIONAL ETHICS

CONFIDENTIAL

Subject to the Nondisclosure Provisions ofB. Res. 895 of the 110th Congress as Amended

8. She stated that her fundraising telephone calls are made to people that the Co-Chairmen identify. She does 110t make cold calls and she does not believe that Ms. Christian makes cold calls.

9. 'TIle witness .also fundraises for CLA and ASG. She told the OCE that Ms. Christian also fundraises for ASG.

10. TIle witness is not involved in deciding how CPA spends its funds fot elections. She also is not involved in compiling records for CPA's reports filed with the Federal Election Commission.

11. She does not personally know Representative John Shimkus or his staffers.

12. She described Rodney Davis as her main contact for contributions that CPA received for the Representative Kinzinger race. She told the OCE that in March 2012, she spoke with Eric O'Keefe and he told her to call Mr. Davis because he knew of individuals\,vho would contribute to CPA's efforts in Representative Kinzinger's election. She recalled that she called Mr. Davis and provided him with wiring instructions for contributions.

13. The witness stated that she did not ask Mr. Davis for the contribution or for a specific amount of money. She did not know whether Eric O'Keefe asked for the contribution or Mr. Davis offered to contribute.

14. TIle ,~dtness was shown an email from Mr. Davis to her dated March 16, 2012 (CPA 000019). She told the OCE that the email refers to a $25;000 contribution from the 18th

District Republican Central Committee that wasinitially made online. The online contribution was rescinded because Ms. Clu'istian infOlmed the witness that the online contribution would not credit to the CPA bank account before election day in the Representative Kinzinger race due toa delay with CPA's online contribution vendor.

15. She stated that Mr. Davis put her in contact with someone at the 18th District Republican Central Committee who wired the contribution to CPA. TIle witn:ess was familiar with the name of the Committee but not who they were. The witness does not know ifthereis any affiliation between Representative Aaron Schock and the 18th District Repuhlican Central Committee.

16. She recalled that Mr. Davis' statement in the email ''that puts you at $90,000 already wired," refe11'ed to various. donors who contributed to CPA.

17. She did not know what the following statement was regarding: "$10,000 more may have been viTired today from Canning." She did have any knowledge of Canning.

MOl - Page 20f3 OFFICE OF CONGRESSIONAL ETHICS

CONFIDENTIAL

-------" - -----Subject to the Nondisclosure Provisions ofH. Res. 895 of the 110th Congress as Amended

18. The \;\1itness told the OCE that Mr. Davis wanted o011fin11atio11that CPA spe11t $100,000 on Representative Kinzinger;s race. She stated thai Mr. Davis had the understanding that

the contributions would he spent 011 Representative Kinzinger's raoe before she was first

put in contaotwith him. She is not SUi"e how he came to have this understatiding.

19. When shown a copy of Schedule A of CPA's FECReport covering activity in March 2012, the witness identified the following as entities where Mr. Davis was her contaot:

18th Distriot Republican Central Committee; American College of Radiology.

20. 111e. witness told the OCE that she ll'jst.communicated with Mr. Davis byemailto

congratulate him 011 the win.in the primary.

21. The witness does not personally know Representative Aaron Sohock or Steve Shearer.

She does notpersonaUy know Representative Cantor.

22. The witness does not know Ted Bumes. When shown an email from Ted BunYes to Rob

Collins, dated March 15, 2012 CCP A000017), the \"1tness stated that she does not knmv

the meaning orihe email because she was copied on the email. 8he does not know the significanoeofthe statement in the email "We 'Udo $5k, and credit Schock" She told

the OCE that .CPA does not credit contributions tocettain people.

23. 111e witness does not know Tania Hoen', but she believes that Mr. Davis put her in c011tactwith Ms. HoelT. She believes Ms. Hoen was the contact for the 18th District

Centra:! Republican COlUmittee. The witness luj.s no understanding of the relationship

between the 18th District Central Republican Committee and Representative Sohock's.

campaign.

24. The witness stated that she does 11 at know \"hether Rob Collins has an·affiliation with CPA.

25. She told the OCE that she perfon11ed searches of her files in response to the OCE Request

for Inf01Ulatiol1 and she did not withhold any documents.

This memorandum was prepared on July 13, 2012, based on the notes that the OCE staff

prepared during the interview withthe witness on July 12,2012. I celtifythat this memorandum

contains all pertinent matter discussed with the witness on July 12,2012.

Kedric L. Payne Deputy Chief Counsel


EXHIBIT 5

F.(om: Radl1(JyDavls __ .... §l~,o!unteetslorsfi!mk\J1iLl:Ir9> $ubl~t: R'ii!: OU~ Qhffto~

f)nte: Ma:id11~,20i22:a7d8 PM COT .' TCI:. ,,'at'fll~d')ttiry ~CmUml$adi:iam~vlClMf9> Cc: "S)rki(YKIii:!f*·~Mhic,t1~l> . .. .

J('lffiia, th~ 25ke'he:ck ya.terday was re~'lnded, and toe money wasw\red 1odayTrom tnt') l8.th Congfe$sfot1~f l)istrl(tPAf;. That P!.Jt$· yeu ~t $90,OOO·alreatly' wll'ed. $10,000 m()t¢ m<lyhavl<'be~n witedtodayfrQn:\ tlll1n!ng, but Ian) :mjt$urli!th~re, HlIv& JoM gstme il c~1PYQf thlit ~tly th~t ~hov"s .. t /(JlIst $'100,000 Q~!iig sp$l1iQI'l Rockford TV anciany (~bl~ tmtlift$Yov. haveito'de,:!, Thx. .

REDACTED CPA 000019 12-9525_0024

EXHIBIT 6

CONFIDENTIAL

---------------------------,- -Subject to, the NO,ndisc1O,sure Pro'visions o'fH. Res. 895 O,fthe 110th Congress as Amended

INRE: REVIEW NO.:

DATE: LOCATION:

TIME: pARTICIPANTS:


MEMORANDUM OF INTERVIKW

CP A Development Coordinator 12-9525 July 12,2012 1101 COlmecticut, NW

W:ashington, DC 20005 12: 10 p.m. to 12:49 p.m. (approximately) Kedric L. Payne Paul 1. Solis

Lee Goodman

SUMMARY: The witness is the Development Coordinator for Campaign for Primary

Accountability ("CPA"). The OCE requested an interview with the witness on July 12,2012, and shecQnsented to an interview. The \~vitness made the following statements inresponse to' our

questioning:

1. The witness was given an 18 U.S.C. § 1001 waming and consented to an interview. She signed.a written acknowledgement of the warni1)g,which '\vill be placed.in the case file in this review.

2. The witness is the Development Coordinator for CPA. She has been employed with CPA since November 2011.

3. Since August 2011, she has also been employed with the Alliance for Self Governance ("ASG") and Citizen Leader Allianc.e ("CLA"). The vilitness told the OCE that ASG and CLA are 501 (c)( 4) organizations. She is the Development Coordinator for ASO and does not have a title with CLA.

4. She is also employed with Citizens for SelfGovemance ("CSG"), which is a 501(c)(4) organization. She has been employed with CSGsince January 2012 .

.5. When asked aboutthe relationships among CPA, CLA, ASG, and CSG, the witness stated that there is no coordination among the entities and they do not share office space. She also stated that the organizations do not have joint events.

6. The witness told the OCE that CP A is comprised of several individuals. TIle CoChairmen, Leo Linbeck and Eric O'Keefe, are the heads of the organization. Mike

MOl-Page lof 4 OFFICE OF CONGRESSIONAL ETHICS

CONFIDENTIAL


Barnhalt is the Chief of Staff. Jamie Story is the Managing Director. Corey Whalen is

the Political Director. The witness repOlts to Ms. Story and Mr. Bal11hmt.

7. The witness'job responsibilities with CPA include making bank deposits, compiling

infonnation for rePOltS with the Federal Election Commission ("'FEC"), fundraising "cold

calls," direct mailing, and miscellaneous administrative "catchall" duties.

8. TIle witness makes records of contributions that CP A teceives in spreadsheets. TIle

spreadsheets include info1111ationthat is required for FEC repolting. She provides the

infonnation from the spreadsheets to CPA's Treasurer, Jonathan Matiin. The witness

stated that no one assists her \vith herrecordkeeping duties.

9. TIle witness told the OCE that she makes cold calls to potential donors. She determines

vii}lom to call by revieyving neVi'S mticles and deciding \1\1ho may want to make

contributions to particular elections. The witness stated that no one assists her with the

cold calling. She stated that Ms. Story makes phone oalls to potential donors based on

the Co-Chainl1en's personal contacts.

10. The witness does not cold call Members of Congress.

11. TIle direct mailing is sent to individuals who are ona mailing list acquired by the CPA

Co-Chainfian. The witness is not involved in developing the list,but understands that the list is purchased for the mailings.

12. She was involved in fundraising for ASG in August and December 2011, but she has not

done any fundraising for CLA 01' CSG. CPA typically does not have a fundraising event;

occasionally a meeting is held where individuals are pennitted to make contributions.

13. Decisions concel1ling CPA expenditures aredetenninedby the Co-Chainnen, Me

Bal1lhrut and political teams. CPA has a Democratic political team and a Republican

political team. Ms. Story makes presentations to small groups, writes mailings, and

makes fundraising phone calls based onthe co-chairs; lists.

14. When asked about her familiarity ,vith the 18th District Central Republican Conunittee

("18th District Committee"), the witness stated that the committee contributed to CPA in

March 2012.

15. TIle witness did not request the contribution from 18th District Committee. She leamed

ofthe contribution vidlen Ms. Story called her and said that the contribution would be

made online through the CPA website.

16. She stated that Ms. Story did nQt tell her whether CPA requested that 18111 District

Conunittee make the contribution.

Mor -Page 20f 4 OFFICE OF CONGRESSIONAL ETHICS

CONFIDENTIAL


17. Ms. Story infolmed the witness that Tania Hoerr was the contact person for 18th District Committee who could provide the witness viTith Info1111ation on where to send a thank you note. The witness sent the thank you note to Mike Bigger. She did not receive a response,

18. The witness does not know whether Representative Aaron Schock's campaign is affiliated v\lith 18th District Committee. She does not know Representative Schock or his staffers.

19. The witness was s'110wn an email from her to T~nia Hoerr, Campaign Director for Schock for Congress, dated March 16,2012 (CPA 000003). She stated that the email concems the tefimdof the $25,000 contribution that 18th District Committee made on the CPA website and the wire transfer of $25,000 by 18th District Committee.

20. The online contribution was refunded because the witness leamed thanhe outside vendor responsible for pt'ocessing online contributions would charge multiple fees for the large contributions and the contribution would not be deposited into the CPA bank account until after the. Illinois primary election involving Representative Don Manzullo. The

witness explained that the money was needed before the primary election in order to buy

media ads.

21. She does not personally know Representative John Shimkus. The witness is familiar with Rodney Davis through emails but does not.knowhim personally. She knew that Mr.

Davis was affiliated with 18u1 District Committee and Every Republican is Crucial (ERIC

PAC).

22. TIle witness knows of Representative Eric Cantor but not personally, and does not know

any staffer fot Representative Cantor.

23. Ms. Story introduoed the witness to Mr. Davis over email in March or April of2012.

24. The witness told the OCE that Mr. Davis was the contact person fora group of cOliti'ibutions that were made to CPA a week or so before the IL primary election.

25. She stated that she contacted Mr. Davis to get the complete contact info1111at10n of these donors who made contributions by wire transfer and was supposed to let him know when CP A received the wire transfer and when CPA made the media buys.

26. The witness identified the following donors as part oHhe group of contributions to CPA '~Ihere Mr. Davis was the contact person: 18th District Committee, American College of Radiology Association Political Action Committee; David Hel1'0 Trust; ERIC PAC; and Anne Dias Griffin. She told the OCE that to her knowledge no one from CPA requested

the contributions from these individuals and entities.

MOI-Page30f4 OFFICE OF CONGRESSIONAL .ETHICS

12-9525_0028

CONFIDENTIAL

------------'" ,------------------Subject to the Nondisclosure ProvisionsofH. Res. 895 of the 110th Congress as Amended

27. The witness stated that she has not heen.contacted by the FEC regarding these events, or

any other govenlluent entity besides the aCE.

This memorandum was prepared on July 12,2012, based on the notes thatthe aCE staff

prepared during the ,interview with the witness on July 12, 2012. I celiify that this memorandum

contains all peliinent matter discussed with the witness on July 12, 2012.

Kedric L Payne

Deputy Chief Counsel

Mal - Page 4 of 4 OFFICE OF CONGRESSIONAL .ETHICS

EXHIBIT 7

Image# 12971195947

r FEe

FORM 3X

i. NAMEOF COMMITTEE (in full)

REPORT OF R.ECEIPTS AND DISBURSEMENTS For Other Than An Authbrized Committee

TYPE OR PRINT '" Example: If typing, type ·over the lines.

CAMPAIGN FOR PRIMARY ACCOUNTABILITY INC

ADDHESS (number and street)

'" Check if different than previously reported. (ACe)

I HOUSTON I I ! !

2. FEC .IDENTIFICATION NUMBER .,..

C00502849

II I

j I ! !

I I I ! 1

CITY ,&;

3. IS THIS REPORT

I ! I !

NEW eN) OR

STATE,&;

04120/201218 : 09

PAGE 1 154

Office Use Only

77027 -.J I I, I I I - I ,!

AMENDED (A)

ZIP CODE,&;

4. TYPE OF REPORT (Choose One)

(b) Monthly Feb 20 (M2) AepOit

May 20 (M5) Aug 20 (MS) Nov 20 (Mll) (Non-ElectIOn

(a) Quarterly Reports:

April 15 Quarterly Report (Q1)

July 15. Quarterly Report (Q2)

October 15 Quarterly Report (Q3)

JanuaryS1 . Year-End Report (YE)

July.31 Mid-Year Report (Non-election Year Only) (MY)

Termination Report (TER)

5. Covering Period

Due On: Mar 20 (MS) Jun20 (M6)

~~ Apr 20 (M4) Jul 20 (M?)

(c) 12-Day Primary (12P)

PRE-Election

Report for the: Convention .(12C)

Election on

(d) 3D-Day

POST-Election

Report for the:

Election on

General .(SOG)

through

Sep 20 (M9)

Oct 20 (MiD)

General (12G)

Special (128)

Runoff (30R)

in the State of

Yea! Only)

Dec 20 (M12) (Non-Electbn· Yem Dilly)

,Jan 3l(YE)

Runoff (12R)

Special (30S)

I certify that I have examined this Report and to the best of my knowledge and belief it is true,correct and complete.

Type or Print Name of Treasurer Jonathan Martin

Signature of Treasurer JonathanMartin [ElectJ'olliclllly Filed] Date

NOTE: Submission of false, erroneous, or incomplete information may subject the person signing this Report to the penalties of 2U.g.C. §4S7g.

FEe FORM 3X

L Rev. 12/2004

FE6AND26

12 ~9525 _0031

Image# 12971195948

r SUMMARY PAGE O.F RECEIPTS AND DISBURSEMENTS

FEG Form 3X(Rev. 02/2003)

Write or Type Committee Name


Rep'ort Covering thi'l Period:

6, (a) Cashon Hand January 1,

(b) Cash on Hand at

From:

Beginning of Reporting Period""""""

(c) Total Receipts (from Line 19) .""",, .. "

(d) S.ubtdtal (add Lines 6(b) and ,6(6) for Column A and Lines 6ta) and 6 (c) lor Column B)""",,,,,.,,,,

7, Total Disbursements (from Line.31)", .. ".""

8~ Cash on Hand at Close .01 Reporting Period

(subtract Line 7 from Line 6(d)) ",,""""'.''''

9. Debts and Obligations Owed TO the Committee (Itemize all on Schedule C and/or Schedule D) "."""""'"

10, Debts and Obligations Owed BY the Committee (Itemize all on

Schedule C and/o'r ScheduJe D) .'"''''''''''''

COLUMN A This Period

588119.46

64564.5,00

1233764.46

0,0

This committee has qualified as amulticandidate committee. (see F~C FORM 1M)

L FE6AN026

For further ·information contact:

Federal Election Commission 999 E Street, NW

Washington, DC 20463

Toll Free 800-424-9530 Local 202·694· 1100

To:

Page 2

COLUMN .8 Calendar Year·to·Dale

705612:08.

2378806,37

Image# 129711959.49

r FEe Form 3X (Rev. 06/2004)


DETAILED SUMMARY PAGE of Receipts


Report Covering the Period: From:

I. Receipts

11, Conil'ibutions (other than loans) From:

(a) Individuals/Persons Other

Than Political Committees

(i) Itemized (use Schedule A) ... "."" ..

(ii) Unitemized """", .... """ ....... "".".,,. (iii) TOTAL (add

Lines 11 (a) (i) and (ii) .. "" ..... " .. ,,~

(b) Political Party Committees " ... "."",, ....

(c) Other P61iticaiCommittees

(such as PACs)." ...... """"" .... """"." ... (d) Total Contributions (add Lines

11 (a)(iii), (b), and (cn (Carry

Totals to Line 33, page 5) ... " .. "." .. ~ 12. Transfers From Affiliated/Other

PartyCommitlees .. ,,, .. ,, ......... ,, .......... " ... " .. ,

13. All Loans Received ............. " ..................... ..

14. Loan Repayments Received""" ............. , .. ,

15, Offsets To Operating Expenditures

(Refunds, Rebates,etc,)

(Carry Totals. to Line 37, page 5)."."."."." 16, Refunds of Contributions Made

to Federal Candidates and Other

Political Committees.,,, .. ,,, """,, ....... , ........ , .. ,

17, Other Federal Receipts

(Dividends, Interest, etc.) "" ............... "" .... ..

0:00

18, Transfers from Non-Federal and Levin Funds :·=4"dlb.o:II1\ .. ·, ..... ·!,._!ti,_{~,Jitw,Jitw,Jitwk*d~:

(a) Non-Federal Account

(from Schedule H3) ........... "" .... , ........ .

(b) Levin Funds (from Schedule H5) .... , ....

(c) Total Transfers (add 18(a) and 18(b)) ..

19, Total Receipts (add Lines 11 (eI), 12,13,14,15,16,17, and 18(c)) ....... ,,~

20. Total Federal Receipts

(subtract Line l8(C) from Line 19) .... " ... ~

L FEBAN026

0.00

645645.00

Page 3

COLUMN B Calendar Year-to-Date

705612.08

0.00

705612.08

705612.08

...J

Image# 12971195950

r DETAILED SUMMARY PAGE of Disbursements

FEC Form 3X (Rev. 02/2003)

II. Disbursements 21. Operating Expenditures:

(a) Allocated Fedsra:I/Non-Federal .Activity (from Schedule H4)

(i) Federal Share ." .. "."" ........ "" .... .

(ii) Non-Federal Shate ...... "" ........... . (b) Other Federal Operating

Expenditures ................ " ................... .. (c) Total. Operating Expenditures

(add 21 (a)(i),(a)(ii), and(b)) ............. ~

22. Transfers 10 Affiliated/Other Party Committess." ..................................... " ..... ..

23. Contributions to Federal Candidates/Com mittees and Other Political Committees ............... ..

24. Independent Expenditures

25.~;~r~~~~~UI~a~~ .. Expendii~res··"· ........ · .. f~s~·~c~·e~~~1~)~!~ .... " ..................... " ..... ..

26. Loan Repayments Made .......................... ..

27. Loans Made ................................................ .. 28. .Refunds of Contributions To:

(a) Individuals/PersonsOlher Than Political Committees ..... " ..........

(b) Political Party Committees ............... .. (c) Other Political Committees

(such as PACs) ...................................... ..

(d) Total Contribution Refuiids

(add Lines 28(a:), (b), and (en ........... ~

29. Other Disbursements ................................ .

30.. Federal Election Activity (2 U.S.C. §431 (20)) (a) Allocated Federal Election Activity

(fromSchedu laH6) (i) Federal Share ......... " ................... ..

(ii) "Levin"Share ............................... .. (b) Federal Election Activity Paid Entirely

With Federal Funds ............... " (e) Total Federal Election Activity (add ..

Lines 3o.(a)(i), 3o.(a).(ii) and 30(b)) .... ~

31. Total Disbursements (add Lines 21 (c), 22, 23, 24, 25, 26, 27, 28(d), 29.and 3o.(c» ..

32. Total Federal Disbursements (subtract Line 21 (a)(ii) and Line 3o.(a)(ii) from Line 31) ................ " .. " .......................... ~

L FE6AN026

COLUMN A Total This Period

122793.34

795957.00

Page 4

COLUMN B Calendar Year-to-Date

1940998.91

..J

12 ·9525_0034

Image# 12971195951

r FEC Form ,3X (Rev. 08/2003)

III. Net Contributions/Operating Expenditures

.33. Total Contributions (other than loans) (from Line 11 (d), page 3) ......................... .

34, Total Contribution Refunds (from Line 28(d) ...... ,,, ........ , .. , .. , ........ , .... , ...

35, Net Contributions (other than loans)

(subtract Line .34 from Lirie 33) .... " .. "",, .. 36, Total Federal Operating Expenditures

(add Line 21 (a)(i) and Line 21 (b) ......... ~ 37, Offsets to Operating Expenditures

(from Line 15, page 3)" ................ " ..... , .. ,,' 38. Net Operating Expenditures

(subtract Line 37 from Une 36) .... " .... , .. ,~

L FE6AN026

DETAILED SUMMARY PAGE of Disbursements

COLUMN A Total This Period

645645.00

0:00

122793.34

Page 5

COLUMN B Calendar Year-la-Date

I mage#1297119595 2

SCHEDULE A (FEC Form aX) ITEMIZED RECEIPTS

Use separate sChedule(s) for each category of the Detailed Summary Page

FOR LINE NUMBER: (check only one)

Any information copl or iorcommercial nlJllIlJ>;H>i

by any person for the purpose of soliciting contributions co'mmittee to sbliCitcontributibns frorn such committe.e.

NAME OF COMMlnEE (In Full)


First, Middle Initial) . REPUBLICAN CENTRAL CDMMIITTEE (FEDERAL ACCOUNT)

Mailing Address PO BOX 1.0362

City

PEORIA

FEC ID number of contributing federal political committee.

Receipt For:

Primary [] General

Other (specify) "f

Full Name (Last, First, Middle Initial)

State IL

Zip Code

61612

Aggregate Year-to-Date V

25000.00

B. AMERICAN COLLEGE OF RADIOLOGY ASSOCIATION POLITICAL ACTION COMMITTEE

Mailing Address 1891 PRESTON WHITE DRIVE

City

RESTON

FEC ID humber ofoontributing federal political committee.

Full Name (Last, First, Middle .Initial)

C. Devin Anderson Mailing Address

City

Carmel

FECID number of contributing federal political committee.

NlA

State

VA Zip Code

20191

Aggregate Year-to-Date .,

State IN

Zip Code 46()32


5000.00

SUBTOTAL of Receipts This Page .(optional).............. ............ .................................. ................. ""

TOTAL This Period (last page this line number only).. ................. ............................ ................ ""

Date. of Receipt

Amount of Each Receipt this Period

2500Q.00

Individuaicontribution

Date of Receipt


5

Individualcolitribution

Date of Receipt


Individual contribution

35000.00

17

FE6N~026 FEe Schedule A (Form ,3X) Rev. 02/2003

Image#12971195953

SCHEDULE A (FEC Form 3X)

ITEMIZED RECEIPTS Use separate schedule(s) for each category of the Detailed Summary Page

FOR LINE NU . (check only one)

11b

Any information copied from.such Reports and Statements may not be sold or or for commercial purposes, other than the name and address of

by any person for the purpose of soliciting contributions committee to solioitcontributions from such committe.e.

NAME OF COMMITTEE (In Full)


Full Name (Last,

A. John n Srya Mailing Address

City

Lake Oswego

Middle Initial)


Retired

For:

[-] ~~:;rrspecifS--~ General


B. Jerome Cantrell Mailing Address

City

Gardendaie

FEe ID humber of contributing federal political committee.

Cantrell Development Company

i r: Primary D General

Other (specify) ...

City

Houston

FECIO number of contributing federal political committee.

Global Financial Services

Receipt For:

Primary I] General

Other (specify) ...

State

OR

Zip Code

97035·6019

Aggregate Year-to-Oate ...

State

AL

Zip Code

35071

Aggregate Year-to-Oate V

State TX

Zip Code

77056

Managing Director

Aggregate Year-to-Oate 'f

10000.0.0

SUBTOTAL of Receipts This Page .(optional)........................... ........... ...... .................................. po.

TOTAL This Period (last page this line number only).. ...................... ...... ...................... ...... ..... po.

Date of Receipt

Amount of Each Heceipt this Period

10000.00

'Individual contribution

Date of Receipt


250.00

Online contribution

O.ate of Re.celpt

.Amount of Each Receipt this Period

1000.00

Individual contribufion

11250.00

17

FEGAN026 FEe Schedule A (Form 3X) Rev. 02/2003

I mage# 12971195954


Use separate schedule(s) for each category of the Detailed Summary Page


Any information copied from such Repo or for commercial purposes, other than

Statements may hot be sold or used by any person for the purpose of soliciting contributions nanieand address of any political co'mmittee to solicit contributions from suCh committee.



City

Cincinnati


Taft Settinius Hollister Receipt For:

Primary [] General

Other (specify) V


B. David Herro Trust Mailing Address

City

Chica

FEC ID number of contributing federal p.oliticalcommittee.

i

Ri Primary Li General

j Other (specify) V

Full Name (Last, First, Middle Initial) C. John Eads

Mailing Address 11339 Kirby Drive

City Houston

FEb ID number of contributing federal political conimittee.

Texas Power Products Receipt For:

["] Primary Ii General

IJ Other (specify) V

State OH

Zip Code 45235-3948


State

IL

Zip Code

6.0610

Aggregate Year-la-Date Y

State TX

Zip Code

77019

Aggregate Year-to-DateV

1000.00

15000.00

SUBTOTAL of Receipts This Page (optional) ............................................................................ II-

TOTAL This Period (last page Ihis line number only) ............................................................... ~

Date. of Receipt

.f [:;~'i '","~~,,~9:1~p,[ Transaction ID : SA11AI.4723



Date of Receipt


Individualcoritribulion

Date of Receipt


15000,,00

Online contribution

51000.00

17

FE6AN026 FEe Schedule A (Form 3X) Rev. 02/2003

Image#129711.95955


Use separate schedule(s) for each category of the Detailed Summary Page


Statements may not be sold or used by any person for the purpose of soliciting contributions name and address of olltical committee to solicit contributions from such committee.



Full Name (Last, First; Middle Initial) . A. EVERY REPUBLICAN IS CRUCIAL (ERI

Mailing Address 25 E MAIN STREET

City

RICHMOND

FEC 10 numbeJ of contributing federal political committee.

Receipt For:

r''l Primary l,J General

[,J Other (specify) "f

Full Name (Last, First, e Initial)

B. Jonathan Farber

FEC 10 number of contributing federal political committee.

State VA

Zip Code 23219

C00384701

Aggregate Year-to-Date"f

State

¢T Zip Code

06880

25000.00

Lime Rock Partners Co-founder and Managing Director

i r: Primary General

Other (specify) "f


C. John FJatowicz Mailing Address

City Sugar Land


Briggs & Veselka Co. 1':

Primary [] General

Other (specify) "f

Aggregate Year-to-Date "f

State TX

Zip Code

77479


SUBTOTAL of Receipts This Page (optional).............. .................................. ...... ................. ..... ....

TOTAL This Period (last page this line number only) ............................................................... ....

Date. of Receipt


2

Individual.contribution

Date of Receipt


Individual Contribution

Date of Receipt


10

Onlin.e contribution

126000.00

17

FE6AN026 FEe Schedule A (Form aX) Rev. 02/2003

I mage#1297119595 6




and Statements may not be sold or used by any person for the purpose of soliciting contributions the nanie and address of ,olitical committee to sQlicitcontributioris from such committee.

(Las!, Rrs!, Middle Initial) French III

Mailing Address 1811 Bering Drive

City

Houston


Northwlnd Energy Partners, LtC


B. Anne Dias Griffin Mailing Address 18QN. stetson

City

FEC 10 number cifcontributlng federal p.olitical committee.

ame Aragon Global Management, LLC

Receipt For:

Primary D General

other (specify) V

Full Name (Last, First, Middle Initial) C. Kittle's Furniture

Mailing Address

City

Indianapolis

FECID number of contributing fedElraJ political committee.

State TX

Zip Code

77057


State

IL

on

Zip Code

6060.1

Aggregate Year-to-Date Y

State IN

Zip Code

46250c1533

Aggregate Year-to-DateY

10000.0.0.

SUBTOTAL of Receipts This Page .(optlonal) ............................................................................ II-

TOTAL This Period (last page this line number only) ........ " ..................... " ....... " ............ " ....... ...

Date. of Receipt

"·o·::;F:·p"·::,} ! t;&4 & f J Q wmrm:~:

!~",,~g.t¥ .. >. • 1AI.4886


Online contribution

Date of Receipt



Date of Re.celpt



17

FEBAN026 FEe Schedule A (Form 3X) Rev. 02/2003

Image#129711.95957



PAGE 11 OF 54

Any information copied from .such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions or for commercial purposes, other than .usihg the nanie and address of any political co'mmittee to si:ilioitcontributions from such committee.



Full Name (Last, First, Middle Initial) A. ThomasC Knox

Mailing Address

City Boerne


Name of Employer

Cobisla"Greenvilie Energy Receipt For:

r'-.] Primary r] General LJ Other (specify) 'f

Full Name (Last, First, Middle Initial) B. Benjamin Kohlmann

Mailing Address

City

San Diego

FEC ID humber of contributing federal political committe.e.

Name of Employer US Navy

Receipt For:

Primary General

Other (specify) V

Full Name (Last, First, Middle Initial) C. Leo Linbeck III

Mailing Address

City

Houston


Name of Employer

Aquinas Companies, LLC Receipt For:

Primary [I General

Other (speCify) V

State TX

Zip Code 78O.OS

Aggre9ate Year-to-DateV

State

t;A Zip Code

9210.1


State TX

Zip Code

77227

occupation

President & CEO


50.0..0.0

SUBTOTAL of Receipts This Page (optional) .............. , .............. , .................................. , ........... ""

TOTAL This Period (last page this line number only)............. .................................................. I!>-

FEGAN026

Date. of Receipt

f'9'W'F4IFF { ! f'4f"··::""Y"j!Fy.'~;{·.

0.3 i ..... §t .••. '1k2O.!~',6.~.,.,.·.1 ... , .• .<'--;..~ .. ~~>, ":. '--;:",~ , Transaction ID :SA11AI .. 486.4-'-____ _


50.

On lin e contribution

Date of Receipt


Online contribution

Date of Receipt

j"'?'''£'''V''''i:F'vv'. .y .•. ,

':_i_ •. , ,_0tr~1'" ..... 2O.JZ.:.; .. ;b .• ;w]; Transaction JD : SA11A1.4722

Amount of Each Heceiptthis Period

250.0.00..0.0


FEe Schedule A (Form 3X) Rev, 02/2003

image#129711.95958


Use separate schedule(s) for each category of the Detailed SummarY Page

PAGE 12 OF 54

17

Any information copied from.such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions or forcornmerciaJ purposes, other than using the name and address of any political c6mmittee to sblicitcontributibns from such committee,

NAME OF COMMIDEE (In Full)


Full Name (Last, First, Middle Initial) A. Leo Linbeck III

Mailing Address

City

Houston


Name of mploy,er

Aquinas Companies. LLC

Receipt For:

[""1 Primary l. ; General

[] Other (specify) 'f


a. Colleen McLane Mailing Address

City

Midland

FEC ID humber of contributing federal political committee.

Name of Employer Self-employed

Receipt For:

Primary 0 General

Other (specify) 'f

State TX

Zip Code

77227

Aggregate Year-Io-Date 'f

State

TX Zip Code

79705


Full Name (Last, First, Middle Initial) C. Peter C. Morse ---------------------------------------------1

lviailing Address 100 Front Street

Suite 900 City

W. Conshohocken


Name of Employer

Morse Partners, Inc. Receipt For:

Primary [J GeneJal

Other (specify) 'f

State PA

Zip Code

19428

Aggregate Year-.!o-Date V

SUBTOTAL of Receipts This Page .(optional)...................................................... ...................... ~

TOTAL This Period (last page this line number only).. .................................................. ........... ~

FEGAN026

Date of Receipt

--r:';6,:':;;~;·:::D:1~ / ;.'ii,:';V;,;t::··:y·:~·~'/wtjL\/· .. y:<:.<

!:~""i 1,_+£94*,-,.1 TransactionlD: SA11A1.4770


100000.00


Date of Receipt

Transaction 10: SA11AI.4740


IndiVidual cOhtribution

Date of Receipt

,''''flf''if'wf'': 1

03


15000 .. 00

Onlin.e contribution

120000.00

FEC Schedule A (Form ax) Rev. 02/2003

Image#12971195959

SCHEDULE A (FEe Form aX)

ITEMIZED RECEIPTS Use separateschedule(s) for each category of the Detailed Summary Page

PAGE 13 OF 54

17

Any information copied from such Reports and Statements may not be sold or used by any person for the purpose of solicitihgcontributions or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.



Full Name (Last, First, Middle InitiaJ) A. Kathleen N. Peters

Mailing Address _

City

Cincinnati

FEC ID number of contributing federal political committee,

Name of Employer

NiA Receipt For:

[--I Primary [] General

L] Other (specify) 'f


B. DUlwood Rorie Mailing Address

City

Cincinnati

FEC ID humber of 60ntributing federal pOlitical committee.

Name of Employer N/A

Receipt For:

Primary LI General

Other (specify) 'f


State OH

Occupation

N/A

Zip Code 45243

Aggregate Year-.to-Date 'f

State

OH Zip Code

45243-32·12


Date of Receipt

tl·.yJiifiXVUi."

!',»_r,,~~.16"'>r.-) ~'lsaction 10: :?A1tAI.4744_. ___ _



Date of Receipt


Individualconttibution

C. Kevin V. Sprigg'--s ___________________ 1 Date of Receipt

Mailing Address _

City Daphne

FECID number of contributing federal pOlitical committee.

Name of Employer

Spriggs Enterprises Inc. Receipt For:

Primary [] General

Other (specify) 'V

State AL

Occupation

President

Zip Code 36526

Aggregate Year-to-Date 'f

SUBTOTAL of Receipts This Page .(optibnal)"""""""""""""""""" .. """"""""""""""."""."" )I>

TOTAL This Period (last page this line number only)"""""""""""""",,,,,.,,,,,,,,,,,,,,,,,,,,,,,,,,,,. )I>

FEGAN026


1500.0

Online contribution

3000.00

FEe Schedule A (Form 3X) Rev. 02/2003

Image#129711.95960

SCHEDULE A (FEC Form aX)

ITEMIZED RECEIPTS Use separateschedule(s) for each category of the Detailed Summary Page

PAGE 14 OF 54

17

Any information copied from such Reports .and Statements may not be sold or used by any person for the purpose of soliciting contributions or for commercial purposes, other than using the name and address of any political committee to solicit contributions from such committee.

NAME OF COMMITIEE (In FUll)


Full Name (Last, First, Middle Initial) A. Mark Thomas

Mailing Address

City

Midland

FEC ID number of contributing fe.deral political committee.

ame of f:mployer

PLains Marketing, l.P. Receipt For:

Primary [-] General

Other (specify) .,


State TX

Occupation

Zip Code

79705-1929

Oil MarketingS.. Trans.

Aggregate Year-to-Date 'V

500.00

B. ________________________________________________________ ~ Mailing Address

City

FEC IDnumber of contributing fedsral political committee.

Name of Employer

Receipt For:

R Primary General

.. .,1 other (specify) .,


C. Mailing Address

City


Name of Employer

Receipt For:

Primary [] General

other (specify) .,

State Zip Code


State Zip Code

Occupation


SUBTOTAL of Receipts This Page (optional) ............................................................................ po.

TOTAL This Period (last page this line number only) ......................................... " .................... po.

FEGAN026

Date of Receipt

500.00

Online contribution

Date of Receipt

Atnount of Each Receipt this Period

Date of Receipt

Amount of Each Hecsipt this Period

500.00

642500.00 ::.::';:E$%'~**,,#'.~~2:'4J:~~d"".j({!&1\~,'?·,,-~l]k:,;·····

FEe Schedule A (Form ax) Rev. 02/2003

Image# 12971195961

SCHEDULE B (FEe Form 3X)

ITEMIZED DISBURSEMENTS Use separate schedule'(s) for each category of the Detailed Summary Page

PAGE 15 OF 04

26 30b

Any information copied from such Reports -and Statements may not be sold or used by any person for the. purpose of soliciting contributions or for commercial pUrposes,other than using the name and address of any political committee. to solicit contributions from such committee.

NAME OF COMMITTEE (1n Full)


Full Name (Last, First, MldeJle Initial)

A. Bank of America

Mailing Address PO Box 25118

City

Tampa 'Purpose of DlsiJursement

Bank fees

Candidate Name

Office Sought:

State:

r-j~:~::e j'] President

District:


B. Brierfield Campaigns, Inc

Mailing Address 1000 EWilliam st. Suite 204

City Carson City Purpose of Disbursement

Filed work

Candidate Name

Office Sought:

State:

I·House ! Senate

Ii President District:


C. BRI Essex, LLC


City

Dallas Purpose of Disbursement Rent

Candidate Name

Office Sought: ! I House

[::j:~~s~::nt State: District:

State FL

Zip Code

33622-5118

Disbursement For: 2012

[~ Primary ['J General

LJ Other (specify) y

StateNV

Zip Code 89.701


[~ Primary LJ General

LJ Other (specify) y

State TX

Zip Code 75.320-3015


l~ Primary L J General

Li Other (specify) y

Category! Type

Category! Type

Category! Type

SU.BTOTAL of Disbursements This Page (optional) .................................................................. ...

TOTAL This Period (last page this line number only) .......................................... , .. , ................. ...

FE6AN026

Date of Disbursement

Transaction 10 : 56216.4893

Amouritof Each Disbursemeht this Period

Date of Disbursem.ent

Transaction 10: 5B21B.4899

Amount of Each Disbursement this Period


Transaction ID : 5B21 6.4897


FEe Schedule 8 (Form 3X) Rev. 0212003

Imlfge# 12971195962

SCHEDULE B (FEC Form aX)

ITEMIZED DISBURSEMENTS Use separate schedule(s) for each catElgory of the Detalled Summary Page

PAGE 16 OF 54

26 30b

Any .information copied from such Reports and Statements may not be sold or used by any person for the purpose of soliciting contributions or for commercial purpOses,olher than 'using the name and address of anypdlitical committee to solicit contributions from such committee.

NAME OF OOMMITTEE (In Full)


Full Name (Last, First, MideJ/e Initial)

A. Ceterus, Inc,


Oity

Kalamazoo Purpose of DIsbursement Accounting fees

Oandidate Name

Office Sought:

State:

House ........ 1 Senate

······1 President

District:


B. Hannah Christian

Mailing Address 3900 Essex Lane Ste.250

Oity Houston Purpose of Disbursement

Payroll

Oandidate Name

Office Sought:

State:

II ~:~:;e Li President District:

Full Name (Last. First, Middle Initial)

C. Hannah Christian

Mailing Address 3900 Essex Lane Sfe.250

Oity H.ouston Purpose of Disbursement OffiCe expense

Oandidate Name

Office Sought:

State:

! I House L. .. _ . ..!

! I Senate

LJ President District:

State MI

Zip Oode

49019


['VI Primary!! General : . .6l .f... •••••••• :

LjDther (specify) V

State' TX

Zip Oode 77027


[)g Primary] General

i Other (specify) V

State TX

Zip Oode

77027


15<j Primary [] General

LJ Other (specify) V

Oategoryl Type

Oategory! Type

Oategory! Type

SU.BTOTAL of Disbursements This Page (optional) ........................................ " ....... " ................ ...

TOTAL This Period (last page .this line number only) ............................................................... ...

FEGAN026


Transaction 10,: 5B21B.4892



Transaction 10 : 5B21 B.4906


1600.00

Date 6f Disbursement

Transaction 10 : 5B21 8.4896


FEe Schedule B (Form3X) Rev. 0212003

Ima:ge# 12971195963

SCHEDULE B (FEe Form 3X)

ITEMIZED DISBURSEMENTS Use separate schedule(s) for each eatE1gory of the Detalled Summary Page

PAGE 17 OF 54

26 SOb

Any .information copied from such Reports 'and Statements may not be sold or used .byany person for the purpose of soliciting contributions or .for commercial purposes, other than 'usingthe .nameand a,ddress of any political committee, tosolieit contributions from such committee.

NAME OF COMMITTEE (in Full)


Full Name (Last, Rrs!, Middle Initial)

A. Lewis Advertising


City

Wetumpka Purpose of Disbursement Production and content consulting

Candidate Name

Office Sought:

State:

L_) House I Senate

[] President

District:


B. Jonathan Martin

Mailing Address 1739 Maybank Highway Suite T-346

State FL

Zip Code

36092


fYi Primary Ii General 1'1 other (specifY)~

City State' Zip Code 29412 ~~~oo OC

Purpos=-=e:-o=:if"D"'i-=OE!t07)u~rs:C;e=n:::::TEl=n::iCt --------

Treasurer fees

Candl ate Name

Office Sought:

State.:

I_Ii House i Senate

i' President

District:

Full Name (Last,. Rrst, Middle Initial)

C. Message & Media

Mailing Address 3101 Lee Highway

Suite 18 #136

City Bristol Purpose of Disbursement Production an d .content consulting

Candidata arne

Office Sought:

state:

J House I Senate I

ii President i I District:


IX Primary L:] General.

Li Other (specify) 'V

State VA

Zip Code

24202


15(1 Primary :---1 General

[] Other (specify)",

Category! Type

Category! Type

Category! Type

SUBTOTAL of Disbursements This Page (optional) ............. , ......................... " .......................... II>-

TOTAL This Period (last page this line number only) ............................................................... II>-

FEGAN026


Transaction 10 : SB21 B.4904



Transaction .10 : 8B21.B.4894


Date 6f Disbursement


Amo.unt of Each Disbursement this Period

FEe Schedule B (Form 3X) Rev. 0212003

Image# 12971195964

SCHEDULE B (FEe Form 3X) ITEMIZED DISBURSEMENTS

Any information copied from such or for commercial purposes, other


Use separate scheduIE*) for each category of the Detailed Summary Page


A. Piryx,lhc.

Mailing Address 144 2nd st. 1 . Flo.or

City

San Francisco

Credit card processing fees


B. James C. Story Jr.

Mailing Address

City Bedford

State:


C. The Schuman Group

Mailing Address 7660 Fay Aye.

City

La Jolla

State:

State CA

Zip Co'de

94105


I~ ~::;7speciJ;~ General

StaleTX

Zip Code .76021

. 2012

[)g Primary LJ General

LI Other (specify) 'V

State CA

Zip Code

.92037

ement 2012

[Xl Primary [OJ General

Li Other (specify) V

26 30b

by any person for the. purpose of soliciting contributions I committee. to solicit contributions from such committee.



Amourit of Each Disbursemerit this Period

Category! Type


Transaction ID: 5B21B.4905

·Amount of Each Disbursement this Period

Category! Type

H)

Date of Disbursemerit

Transaction ID : 5B21 B.4901


Category! Type

SU.BTOTAL of Disbursements This Page (optional) .............................. , ........ " ......................... p. 30405.63

TOTAL This Period (last page this line number only} ............................................................... ...

FE6AN026 FEe Schedule B (Form .aX) Rev. 0212003

Image# 12971195965

SCHEDULE B (FEC Form 3X)

ITEMIZED DISBURSEMENTS Use separate schedule(s) for .each category of the Detailed Summary Page

26 SOb

Any .information copied from such Reports and Statements may not be soldoI' used by any person for the. purpose of soliciting contributions or for commercial s, other than using the name and address of any political committee, to solicit contributions from such committee.



I

A. Thomas Graphics, Inc.

Mailing Address P.O. Box 142226

City

Austin

Production costs


B. Carie Whalen

Mailing Address

City Houston

Payroll

State:

ame

Full Name (Last" First, Middle Initial)

C.

Mailing Address

City

State TX

Zip Code

78714-2226


fVi Primary I.: General 11 Other (speci1'Y)''''

State' TX

Zip Code 77057

. 2012 [~primary L] General

l i Other (speci1'y) V L,,,,,,,c

State Zip Code

Disbursement For:

Primary II General

Other (specify) V

Category! Type

Category! Type

Category! Type

SUBTOTAL of Disbursements This Page (optional)"""" .. "" .. "" .. """" ... "" .. """,,,,,,,,,,,,,, .. ,,,,. p.

TOTAL This Period (last page .this line number only) .. """""""""" .. "" .. "" .. """,,, .. ,,,,,,,, .. ,,,, .. p.

FE6AN026

Date qf Disbursement

Transaction ID.: 88218.4898


22489.59


Transaction ID : 88218 .. 4900


Date cif Disbursement


FEe Schedule 8 (Form 3X} Rev. 0212003

Image# 12971.195966

SCHEDULE E (FEe Form aX) ITEMIZED INDEPENDENT EXPENDITURES


CAMPAIGN FOR PRIMARY ACGOUNTABILITY INC

PAGE 20 OF 54 FOR LINE 24 OF FORM 3X

FEC IDENTIFICATION NUMBERT ........ m~;·',~·~";,t/<'·":·' '.i~ ·}··;·~W·~ ··}"a"; ;';.;.;~.;;~;.,'.;

C00502849

Checl< if []24-hour report 48-hour report [] New report Amends report filed on

Full Name (Last, First, Middle Initial) of Payee

Campaign Grid

Mailing Address 414 Commerce Drive

Suite 100

City

Fort Washington

Purpose of Exp.enditLlre Online advertisements

State

PA

Name of Fe.deral Candidate Supported or Opposed by Expenditure:

SPENCER T. BACHUS

Zip Code

19034

Calendar Year-To-Date Per Election 1r""'."i"%"'~~""'P:CT~w,;""'"TI*'"

for Office Sought !\w.ii!idkmi%,l~mJ;\_~~J~.~",'%,,*-

Full Name (Last, First, Middle Initial, of Payee

Campaign Grid

Mailing Address 414 Commerce Drive

Suite 100

City

Fort Washington

Purpose of Expenditure Online advertisement

State

PA

Name of Federal Candidate Supported or Opposed by Expenditure.:

DONALD A. MANZULLO

Calendar Year-To, Date Per Electi.on JorOffice Sought

Zip Code

19.034

Date

ransacon

Office SOU9ht:~ i:X:~=-' House i Senate

r Presldeht

Checl< One: D SLjpport

. Disbursement For: !Xi Primary 2012 c--,. _. _. . LJ Other (specify) ~

Date

Amount

on

OfficeSoqght: ~I ~:~::e

[j President

Checl< One: [J Support

Disbursement For: ~ Primary 2012 ,. ... _..... ,._, LJ Other (specify) ~

(a,) SUBTOTAL of Itemized Independent Expenditures ............................................................. ~

(b) SUBTOTAL of Unitemized Independent Expenditures ........................................................ ~

(0) TOTAL Independent EXPenditures ........................................................................................ ~

State: AL

District: 06

~ Oppose

General

District:

IL

16

~ Oppose

I=l General

Under penalty of perjury I certify that the independent expenditures rnported herein were not made incobperation, consultation, or concert with, or at the rnquest or suggestion of, any candidate or authorized committee or qgent of eitl1er,or (if the reporting entity is nota political party committee) any political party committee or its agent.

Jonathan MaTlin [Electrollically Filed] Date

~s~ig~n-a7tu~rn------------------------------~------

FEG Schedule E (Form 3X) Rev. 0712011

12 ·9525_0050

Image# 12971195967

SCHEDULE E (FEe Form 3X) ITEMIZED INDEPENDENT EXPENDITURES




FEe ID.ENTIFICATJON NUMBER'~

Check if 24-hour report [] 4B-hdur report [-] New report [-:] Amends report filed on

Full Name (Last, First; Middle Initial) of Payee

Campaign Grid

Mailing .Addres·s 414 Commerce Drive

Suite 10.0 Oity

Fort Washington

Purpose of Expenditure Online advertisement

State

PA

Zip Code

19034

Category! Type


JO BONNER

Date

Amount

Tranon Office Sought:

Oheck One:

UiZ. House

i Senate b-i President

D SlIpport

State: AL

District: 01

~ Oppose

Calendar Ye.ar-To-Date Per Election ir""'tp""'¥'~~'W-IIIIIfF~r""~"\W"T~~P'im~,'

for Office Soug,ht f~d;@1wpj!,W!!j"'),,,,,J1'K,,;!k1111~1"""'1i,'E"""A'gs;'.'

Disbursement For: !XI Primary ['_',',",'_1. General 20~2 ~" '-'

Full Name (Last, First, Middle Initial, of Payee CMF Communications

Mailing Address 25000 Portoflno Cir,

#129

City Pl'\lm Beach Gardens

PurpOSe of Expenditure Hobo Calls

State FL

Zip Code

33148-1293

Category! Type

Name of Federal Candidate Supported or Opposed by Expenditure:

MARCY CHON. KAPTUR

LJ Other (specify) ~

Date

Amount

Office Sought: State:OH

District: 09

iXI Oppose .. .....-"

Calendar Year-To·Date Per Election for Office Sou9llt 10

2~~s~ursement For:~ Pnmary LJ General

Other (specify) ...

(a) SUBTOTAL of ItemiZed Independent Expenditures, ............................................................ ~

(b) SUBTOTAL of Unitemlzed Independent Expenditures ........................................................ ~

(c) TOTAL Independent Exp(:lnditures ........................................................................................ ...

Under penalty of perjury I certify that the independent expenditures reported her'ein were not made in cooperation, consultation, or concert with, or at the request or suggestion of, any candidate or authorized committee or €!gent of either, or (if the reporting entity Is not a political party committee) any political party committee or its €!gent.

Jonathml'Mm<tin [Electrollic{lily Filed! Date

~--~--------------------------------------

FEG Schedule E (Form 3X) R8\I.0712011

Il'I1age# 12971.195968





FEe IDENTIFICATION NUMBER· ...

Check if []24-hour report [] 48-hour report [] New report [-] Amends report filed on

Full NarnE;l (Last, First, Middle Initial) of Payee

CMF Communications

Mailing Address 25000 Ponofino Gir.

#129

City

Palm Beach Gardens

Purpose of Expenditure RoboCalls

State

FL

Category/ Type


MARCYC HON. KAPTUR

Full Nahle (Last, First, Middle Initial, of Payee CMF Communications

Mailing Address 25000 PortofinoCir.

#1.29

City

Palm Beach Gardens

Purpose of Expenditure Mailer

State .FL

Zip Code

331.48-1293

Category! Type


DEBORAH'DEBBIE'HALVORSON

Calendar Year-To-Date Per Election for Office Sou9llt

Date

Ainount

StE\te: OH

District: 09

Check One: 'IX! Oppose

Disbursement For: rv'i Primary [·.·.·_·1. General 2012 ._iA_,._ D Other (speci.fy) ~

Date

Amount

r on .3'4 Office Sought: ~~......... House

r" Senate

I President L.. ...... .

Check One: ~l Support

IL

District: 02

D Oppose

2~~s~ursement For: ~ Primary L .. J General

.' [J Other (sP~cify) ~

(~).SUEiTOTAL of Itemized Independent Expenditures ............................................................. ~ 15684.99


(c) TOTAL Independent Expfilnditures ........................................................................................ ~

Under penalty of perjury I certify that the independent expenditures reported hel'ein were not made In cooperation, consultation, or concert with, or at the request or suggestion of, any candidatedr authorized committee OT <\gentof either,or (if the reporting entity is not.a political party committee) .any political party committee or its agent.

Jonathan Martin [Electronically Filed] Date

~--~------------------------------~------Signature

FEG Schedule E (FOrm 3X) Rev .. 07/2011

Image# 12971195969

SCHEDULE E (FEe Form 3X) ITEMIZED INDEPENDENT EXPENDITURES PAGE 23 OF 54

FOR LINE 24 OF FORM 3X

NAME OF QOMMITTEE (In Full) FEe IDENTIFICATION NVMBERV CAMPAIGN FOR PRIMARYACCOUNTABILITYINC

Check if [}24-hour report D 4B-hour report New report [] Amends report filed on


CMFCommunications

Mailing Address 250.00 Portofino Cir.

#129 City

Palm Beach Gardens

Purpose of Exp,enditure Automated 'Calls

State

FL

Name of Fe,deral Candidate Supported or Opposed by Expenditure:

DENNIS J KUCINICH

Calendar Year-To-Date Per Election f""'1Ji'·'·;;'CP"::';;"i;""""ill"·;·";';ii" ;;/.""";;""'£

for Office Sought !;_0:'f""~_{:~_L~J:"",,,.

Full Name (Last, First, Middle InitialJ of Payee eMF Communications

Mailing Address 2500.0 Por'lofinoGir.

#129

City

Plllm Beach Gardens

Purpose of Expenditure Facebook Adervtisements

State ,FL

Name of Federal Candidate Supported or Opposed by Expenditure,:

DENNIS J KUCINICH

Calendar Year-To,Date Per Election fotOffice Sought

lip Code,

33148-1293

Date

Check One:

Disbursement For: ~! Primary 20.12 '-' , 0 Other (specify) II>

Date

AmoL1nt

r nsac IOn

Office SOL(ght: ~i~= ~:~::e

I President l.. ....... .

Check One: ~l Support

Disbursement For: ~ Primary

2012 ["1 Other (sp~;fy) fI>c

(a) SUBTOTAL of Itemized Independent Expenditures ............................................................. ~


(c) TOTAL Independent Expenditures ........................................................................................ ~

District: 09

Oppose

General

State: 'OH

District: 09

Oppose

Under penalty of perjury I certify that the independent expenditures reported herein were not made in cooperation, consultation, or concert with, or at tl1e request or suggestfonof, any candidateoT authorized committee OT agent of either,or (if the reporting entity is nota political party committee) any political party committee or its agent.

JonaJilan lilartin [Electronically Filed] Date

~S~ig-n-a7tu-re--------------------------------------

FEG Schedule E(FOrm SX) Rev. 0712011

Image# 12971.195970



CAMPAIGN FOR PRIMARY ,ACCOUNTABILITY INC

PAGE 24 OF 54 FOR. LINE 24 OF FORM 3X

FEe ID,ENTIFICATION NUMBER 'V

Check.if [] 24-hoLir report [.] 48·hour report [] New report [] Amends, report filed on


CMFCommunications

Mailing AddresS 25000 PO,rtofinoCir.

#129

City

Palm Beach Gardens

Purpose of Expenditure Facebook Advertlsme,nt

State

,FL


MARCYC HON. KAPTUR

Calendar Year· To· Date Per Election }-W!ir"lii""*'''''''''l'F"'"'Ifi''';'''';ii''''''\i?'''"'''fji'''';'ri'''l

for Office Sought l,;~,'.d"4i!!",*~"",,4]r_4r'@m:&mg,,{1_,.m:&m

Full Name (Last, First, Middle Initial} of Payee eMF Communications

Mailing Address 25000 PortofinoGir.

#129

City

Palm Beach Gardens

Purpose of Expenditure Automated Robo Calls

State

FL

Zip Code

33148-1293

Category! Type


DENNIS J KUCINICH

Calendar Year-To,Date Per Election for Office Sought

Date

District: 09

Check One: ~ Oppose

Disbursement For: iX! Primary General 2012 ,-' -' , 0 Other (specify) ~

Date

Amount

166,.66

Tr nsac on State:OH

Office Sought: ~1 ~:~::e

tj President District: 09

Check One~ &1 Support [] Oppose

Disbursement For:~ Primary 2012 " .~

L.J Other (specify) II>-

General

(a). SUBTOTAL of Itemized Independent Expenditures ............................................................. ~ 1017.0



Under penalty of perjury I certify that the independent expenditures reported herein were not made In cooperation, consultation, or concert With, or at the request ,or suggestion of, any candidate ,or authorized committee or agent of either, or (if the reporting entity is nota political party committee) ,any political party committee or its agent.

Jonathan Martin [Electronically Filell] Date

~--~------------------------------~------Signature

FEG Schedule E (Form 3X) Rev, 0712011

Image# 12971195971


NAME OF QOMMITTEE(ln FulL)



FEC ID.ENTlFICATION NUMBER V

Checl< if [_oJ 24-hour report [] 48,hour report [] New report Amends report filed


CMF Communications

Mailing Address 25000 Portofino Cir.

#129

City

Palm Beach Gardens

Purpose of Exp.enditure Mailer supporting Halvorson

State

.FL


DEBORAH 'DEBBIE' .HALVORSON

Calendar Year-To.Date Per Election F-&iJ¥"'''''¥-tF''''''&iJ¥''''''tFrnmw-'''A''''TF'''''j0'''·''''··';.:r···;:'''~

for 'Office Sought ~_"f""wdk\\S,&l't .... "r:>";;N" ..• i'>~:r,!;h'W&_.i;¥i:~~,,,~

Full Name (Last, First, Middle Initial) of Payee CMF Communications

Mailing Address 2500.0 Portofino Cir.

#129

City

Palm Beach Gardens

Purpose of Expenditure Email Advertisement

State FL

Name of Federal ·Candidate Supported or Opposed by Expenditure.:

DENNIS J KUCINICH

Calendar Year-To-Date Per Election for Office Sought

Zip Code

33148-1293

Amount

12539.42

~~. House i Senate

~ President

State: IL

District: 02

Check One: ~ Support Oppose

Disbursement For: Xl Primary [] General

20.12 'Other (sp~Gify) ~

Date

Amount

Tr nsac Ion

Office SOU~jht:~ ~: House Senate

i President L ...... .

Check One: ~] Support

OH

District: 09

Oppose

2~~s~ursement For: ~ Primary LJ General

. L]Other (sp~cify) ~

(~) SUBTOTAL of Itemized Independent Expenditures ............................................................. ~

(b) SUBTOTAL of Unitemized Independent Expenditures .. _..................................................... ~

(c) TOTAL Independent Expendltures ........................................................................................ ~

Under penalty of perjury I certify that the independent expenditures reported herein were not made In cooperation, consultation, or concert with, or at the request or suggestion of, any candidate or authorized committee or agent of either, or (if the repoJiing entity is not a political party committee) any political party committee or its agent.

Jonathan Marlin [Electrollically Filed! Date

~~~----------------------------~-----

FEC Schedule E (Form 3X) Rev. 0712011

Image# 12971.195972

SCHEOULE E (FEe Form aX) ITEMIZED INDEPENDENT EXPENDITURES

NAME 'OF CQMMITTEE(ln Full)


PAGE 26 'OF 54 FOR LINE 24 'OF FQRM 3X

FEC ID.ENTIFICATION NUMBER .",

Check if [] N-hour report [] 48,nour report [---I New report r-] Amends report filed on

Full Name (Last, First, Mi.ddl.e Initial) of Payee

CMF Communications

Mailing Address 25000 Poliofino Gir.

#129

Oity

Palm Beach Gardens

Purpose of Expenditure Direct Mail Piece.

State

FL

Zip Code

33148-1293

Category/ Type


JESSE JR JACKSaN

Oalendar Ye.ar-To-Date Per Election !?""""'l¥""'0t''''''9FWiwgw''''F-W-''''F''1i:~~''''F-'''iIf*'''''Ij

forOffi ce Sought r,_d0._-li\~'%.'%f""Fm..£"km~'dT'~7*""[c'%fd~"",,Jl



#1.29

city Palm Beach Gardens

Purpose of Expenditure 'Online advertisements

State

FL

Zip Gode

331.48-1293

Category/ Type

Name of Federal Candidate Supported or 'Opposed by Expenditure.:

JESSEJRJACKSQN

Calendar Year-To-Date Per Election for 'Office Sought

Date

Amount

'Office Sought: ~~~_~_ HOU. se State: IL

I Senate District: 02

r Preside"nt

Ol1eck 'One: [J Support ~ appose

Disbursement For: iXi Primary [".".".".'.1, General 2012 '-'

[] 'Other (specify) II>

Date

Amount

Transac Ion

QfficeSou.ght: ~I ~:~::e

[j President

f] Support ,-Disbursement For: ~ Primary 2012l~,

'Other (specify) II>

IL

District: 02

~ appose

LI General

.(a). SUBTOTAL of Itemized Independent Expenditures ............................................................. Ii> 19798.33

(b) SUBTOTAL of Ut1itemized Independent Expenditures ........................................................ II>

(e) TOTAL Independent Expendituri;ls ........................................................................................ II>

Under penalty of perjury I certify that the independent expenditures reported herein were not made in cooperation, consultation, or concert with, or at the request or suggestion of, any candidate or authorized committee or agent of either, or (if the reporting entity is not a political party committee) .any political party committee or its agent.

JonaJhan Map/in [Electrollicldly Filed! Date

~--~--------------------------------------


Image# 12971195973



CAMPAIGN FOR PRIMARYACCOUNTABILITY INC

RAGE 27 OF 54 FOR LINE 24 OF FORM 3X

FEe IDENTIFICATION NUMBERT

Checi< if []24-hour report [] 48-hour report [:] New report C=-] Amends report filed on


CMF Communications


#129

City

Palm Beach Gardens

Purpose of Expenditure Online advertising

State

FL Zip Gode

33148-1293

category/ Type


DEBORAH 'DEBBIE' HALVORSON

Calendar Ye.ar-To-Date per Election V""'¥P''¥P'~fW''''¥P''¥P'~'¥P''¥P''9P''mww-i[pW1'''j

for Office Sought f-mww."".f.:';:t-mww~.,;L.;L">;w'''i;''''''';'';'Si':'7',A!',&,;&



#129

City

Palm Beach Gardens

Purpose of Expenditure Email communication

State .FL

Zip Code

33148-1293

Category/ Type


DEBORAH 'DEBBIE' HALVORSON

Date

Amount

Transac I.on

Office Sought: ~~'~~ House i Senate

I Presideht

Gl1eci< One: ~ Support

Disbursement For: rv'! Primary !AI

2012 ,--, Oth ( ~f) I. i er speci y ~

Date

AmOUnt

State: IL

District: 02

Oppose

General

IL

District: 02

o Oppose


2~~s~ursement For:~ Primary LJ General

Other (specify) ~



(c) TOTAL IndE)pendent ExpE)nditures ......... , .............................................................................. ~

Under penalty of perjury I certify that the independeht expenditures reported herein were not made in .cooperation, consultation, or concert with, or at the request or suggestion of, any candidateoT authorized committee or agent of either, or (if the reporting entity is nota political party committee) .any political party committee or its agent.

Jonathan Martin [Electrollic(uly Filed] Date

~S~ig-n-a7tu-re--------------------------------------

FEe Schedule E (Form 3X) Rell.0712011

Image# 12971195974

SCHEDULE E (FEC Form aX) ITEMIZED INDEPENDENT EXPENDITURES




FEC ID.ENTIFICATION NVMBERT

Check if [=]24chour report [] 48-hoUf report [-] New report [] Amend:;; report fHed on


CMF Communications

Mailing Address 25000Portofino Cir.

#129

City

Palm Beach Gardens

Purpose 'of Expenditure Automated telephone robocalls

state

FL

Zip CO.de

33148-1293



Calendar Ye.ar-To-Date per Election H",s"*"""%''''9it-TM'T'''''''l''''''"'P'P'''''l~r

for Office Sought !~d;mmWl1iJ,"""~~ __ 'T"'T"T:~,,**,nJbm&f[b"'(3'

Full Name (Last, First, Middle Initial, of Payee eMF Communications


#129

City

Palm Beach Gardens


State .FL

Zip Code

33148-1293

Category/ Type


JESSEJRJACKSON

Calendar Year-To-Date Per EJection for Office Sought

Date

Amount

ransacon

Office Sought: ~H;~:~ House i Senate

r President

:g] Support

Disbursement For: :)(1 Primary 2012 '--'

'Other (specify) p.

Date

J

Amount

rans c ron

Office Sought: ~~~:~::e

U President

Check One: 0 Support


2Q12 [J Other (SP~Ci~)1J>:

(a) SUBTOTAL of Itemized Independent Expenditures ............................................................. II>

(b) SUBTOTAL of Unitemized Independent Expenditures ............................ _ ................. _ ......... II>

(c) TOTAL Independent Expenditure$ ........................................................................................ tI>

12

State: IL

District: 02

o Oppose

General

District:

IL

02

~ Oppose

II General

Under penalty of perju ry I certify that the independent expenditure's reported her"ein were not made incobperation, consultation, or concert with, or at the request or suggest[onof, any candidate or authorized committee or agent of either,or (if the reporting entity is not a political party committee) any political party committee or its agent.

Jonalhan Marlin [Electronically Filed] Date

~--~--------------------------------------Signature

FEe Schedule E(Form 3X) He\!. 0712011

12~9525_0058

Image# 12971195975



CAMPAIGN FOR PRIMARY ,ACC OUNTAB I LlTY INC


FEC IDENTIFICATION NUMBER'"

Check if []24-hour report [] 48-hour report [] New report Amends report flied on


CMF Communications


#129

City

Palm Beach Gardens

Purpose of Expenditure Auotmated telephone calls

State

FL


DEBORAH 'DEBBIE'HAL VO RSON

Full Name (Last, First, Middle Initial} of PElyee CMF Communications


#129 ,City

Palm Beach Gardens


State

FL


JESSE J.R JACKSON

Calendar Year-To-Date Per Election

Zip Code

33148-1293

Jor Office Sought ~"'A;"ih",d%*,d'~~_&~wJ];'_"*-

Amount ~~-m.~W'·";t..1l:'~~""::;:·~i;~~~'-~tf~;:: r::';Flli$.~7F:.~;:.·:.qr:l&S~*'~t:

; 4162.44 ~,

Tfa:n:actron~FB;: Sn5~:r t F -iNi .. _"'*'. Office Sought: ~~=.'. House State: IL

i Senate District; 02

r Preslde.hl '---

CI1eck One: ~ Support Oppose

DisburSement For: IX! Primary 'l'_"_"_"_1 General 2012 ,_. -

. Other (specify) I>

Date

Amount

Check One:

District:

IL

02

1><1 Oppose

2~~s~ursement For: ~ Prim<!ry D General

.' [-"lather (specify) II>:-

(a) SUBTOTAL of Itemized Independent Expenditures ............................................................. I> 5174.06

(b) SUBTOTAL of Unitemized Independent Expenditures .. _..................................................... p..

(0) TOTAL Independent Expenditures ........................................................................................ p..

Under penalty of perjury I certify that the independent expenditures reported herein were not made in cooperation, consultation, or concert with, or at tile request or suggestion of, any candidate or autilorized committee or <\gent of eitile r, or (if tile reporting entity is not ,a political party committee) .any political party committee or its agent.

Jonathan Martin [Electronic lilly Filed] Date

-~~~----------------------------~----

FEG Schedule "'(Form 3X) Rell: 0712011

Image# 12971195976





FEe ID.ENTIFICATION NUMBER .~

Check if 24-hour report [] 48-hour report [] New report Amends report filed on


GMF Communications


#129 City

Palm Beach Gardens

Purpose of Exp.enditure Email communication

State

FL

Zip Code

33148-1293

Categoryl Type



Calendar Ye.ar-To-Date per Election ;W&'··"2Z""''i7'''''·'''i·f''';E'·.<;'''',LT>~~;'~f''''·'''·1/"··"i"·'C;'{·

for Office Sought """~J"~'~_i&",~,.J.; ___ ,,,l;.]

Full Name (Last, First, Middle Initial, of Payee Dialing Services, LLC

Mailing Address 8 Riverside Drive

City

Roswell

Purpose of Expenditure Automated phone calls

St9,te

NM Zip CodE!

88'201

Category! Type


JO BONNER

Calendar Year-To,Date Per Election tor Office Sougllt

Amount

;-;i~~~~~1.&'t.~W;~~~"if'"t'&"·~<Y~K J ; ill ill ~~ A 1037.58 "

T~an;aC1:='~1!415~_?~"9Th1"~""'-'o",;: Office Sought: ~Bl-~. House Sta,te: IL

l Senate District; 02 I Presideht

~ Support Oppose

Disbursement For: I}{I Primary

2012 Olhe r (specify) I>

Date

Amount

ransac on

Office Sought: ~1 ~:~::e

H President

[] Support

Disbursement For: ~ Primary 2012 I.~

Other (specify) I>

General

AL

District: 01

i><10ppose .. -'>

[] General

(a) SUBTOTAL of Itemized Independent Expenditures ............................................................. I>

(b) SUBTOTAL of Unitemized Independent Expenditures ........................................................ I>

(c) TOTAL Independent Expfilnditures ........................................................................................ I>

Under penalty of perjury I certify that the independent expenditures reported herein were not made in cooperation, consultation, or concert with, or at the request or suggestlonof, any candidate or authorized committee or agent of either, or (if the reporting entity is not ,a political party committee) any political party commi.tteeor its agent.

Jonathan ~Martin [Electronically Filed] Date

~--~--------------------------------------

Signature

FEG Schedule E (Form 3X) Rev: 0712011

Image# 12971.195977

SCHEOULE E (FEe Form 3X) ITEMIZED INDEPENDENT EXPENDITURES

NAME. OF QOMMITTEE (In Full)



FEC ID.ENTIFICATION NUMBER ...

Check if []24-hour report [] 48-hour report [~] New report r:=] Amends report filed on

Full Name (Last,. First, Mi.ddle Initial) of Payee

Dialing Services .. LLC


City

Roswell


State

Nlvl Zip Code

88201

Category/ Type


SPENCER T. BACHUS

Calendar Year-Io-Date Per Election

for Office Sought J",'%J!..~.J';k.""Ak",,_.J~'4th,dLw8a""4t

Full Name (Last, First, Middle Initial) of Payee Dialing Services, LLC


City

Roswell


St~te

NM

Zip Code

88201

C~tegory/ Type


JO BONNER

Galendar Year-To,Date Per Election for Office Sou9llt

Office Sought: t>{~.~-:. House State:

1 Senate District:

r President

AL

06

Check One: D Support

Disbursement For: !Xi Primary 2012 .-. '

DOther (llpecify) ...

Date

Amount

Check One:

~~ ~:~::e U President

D Support

~ Oppose

General

AL

District: 01

~ Oppose

2~~s~ursement For: ~ Primary 1=] General

. .' [J Other (sp~cify) ...

(a) SUBTOTAL of Itemized Independent Expenditures ............................................................. ...

(b) SUBTOTAL of Unitemized Independent Expenditures ........................................................ ...

(c) TOTAL Independent Expenditures ........................................................................................ ...

Under penalty of perju ry I certify that the independent expenditures reported herein were not made in cooperation, consultation, or concert with, or at the request or suggesilonof, any candidate or authorized committee or (1gent of either, or (if the reporting entity is not a political party committee) any political party committee or its agent.

JonathaJ] Martin [Electrollically Filed] Date

··Signature


Image# 12971195978


NAME QFCQMMITTEE (In Full)


RAGE 32 'OF 54 FQR LINE 24 'OF FORM 3X

FEe IDENTIFICATION NUMBER ...

Check if []24-hour report [] 48-hour report [] New report [~] Amends report filed on

Full Name (Last, First; MiddLe Initial) of Payee

Dialing Service's, LLC

Mailing Addres's 8 Riverside Drive

City

Roswell

Purpose of Exp.enditure Automated phone calls

State

NM

Zip Code

88201

Category/ Type


SPENCER T. BACHUS

Calendar Ye.ar-To-Date Rer Election ('·'\1;'2' ·";i······+T·'·,+;"""W"""9!"""'~~IIII9f~W-~J

for Office Sought i_..fk.mmi;~wJ.B:'t-~~""{"fu,_"+k; .• 4k,,Jj'*,,xJ'~i%i .• d

Full Name (Last, First, Middle Initial} of Payee Dialing Services, LLC


City

Roswell

Purpose of Expenditure Automated telephone c.alls

State NM

Name iJf Federal Candidate Supported or 'Opposed by Expenditure.:

JQ BQNNER

Calendar Year-To-Date Per Electi.on for 'Office Sought

Zip Code

88201

Date

Amount ;:~~~"®:..'\..'4Wi:~'~"'~;~··S"~~;L'1i-:'·"~F,~r ;;~:nV::%2~¥:~a~:B:~'.V:

3234,.00 !: TtRf{~7a1Jtf(jn;&rt5:S.i!"mrw 1 1 r __ ' ,

State: AL

District: 06

'Office Sought:

~I ~:~::e U Preside.n!

Check 'One: D SlIpport ~ 'Oppose

Disbursement For: ~! Primary rl·.··.··.··.·J" General 2012 -' -' D Other (specify) ~

Date

Amolln!

QffiCesou9ht:

E ~. H.ouse

r- Senate

L President

Check 'One: []support

State:

District:

AL

01

[gJ 'Oppose

2~~s~ursement For: ~ Primary L.J General

.' [1 'Other (sP~clfy) ~

(a) SUBTOTAL of Itemized Independent Expenditures ............ "." ............ " ... "."" ...... " ........ " .. Ii'- 4901.19

(b) SUBTOTALbf Unitemized Independent Expenditures .......... _,,"", .. ,,'_",',""",.,"""""".",,. ~

(c) TOTAL Independent Expenditures, ..... " ...... ,,, ...... , ....... ,, ................. , .. , .. , ....... ,,,., .. , .. , ....... , .... , Ii'-

Under penalty iJf perjury I certify that the independent expenditures reported herein were not made in cooperation, consultation, or concert with, or at the request or suggestion of, any candidate or authorized comrnittee or agent of either, or (if the reporting entity is nota political party committee) any political party committee or its agent.

Jonathan Maptin [Electrollically Filed] Date

~~~----------------------------~----

FEe Schedule E (FOrm 3X) Rev 0712011

Image# 12971.195979

SCHEOULE E (FEC Form 3X)' ITEMIZED INDEPENDENT EXPENDITURES





'Check.if []24-hour rEiport [] 48-hour report [] New report [] Amends report filed on

Full Name (Last, First, MiddLe Initial) of Payee

Dialing Services, LLC

Mailing Address 8 .RiverSide Drive

Oity

Roswell

Purpose of Expenditure Automated telephone calls

State

NM


SPENCER T. BACHUS

Zip Code

88201

Calendar Ye.ar-To-Date Per Election i-.,WiIIft""¥F"":;r;:""'''Il-&¥¥''-~i!F'S:.''1

for Office Soug.llt L""'k;:",;f;,:,;l;;""'''''!&i~5~'';;'~~' '[";;:,'~t.:""J;

Full Name (Last, First, Middle Initial) of Payee Fortune Media, Inc.

Mailing Address 527 Avenue B

City

Redon do Beach

Purpose of Expenditure Television Advertisement

State CA


DENNIS J KUCINICH


Zip Code

90277-4183

Date

Amount

State: AL

District: 06

Check One: D SLlpport ~ Oppose

Disbursement For: iXl Primary '["",",",'!. General. 2012 ,-' _I

. Othe r (specify) p.

Date

Amount

Trans Office Sought:

Check One:

& ,1"'''''· 25000.00

::'~~\;s";'

~!""'"'' Hous.e State: OH

1-'" Senate District: 09

President ---

g:] Support I] Oppose

2~~S~u~~~~ent For: ~ Primary 1=] General

l I Other (specify) p.

(a) SUBTOTAL of Itemized Independent Expenditures ........ , .................................................... p.

(b) SUBTOTAL of Unitemized Independent Expenditures ........................................................ p.

(c) TOTAL Ind!?pendent Expenditures .................. , ............................................. """ .... ," ........... p.

Under penalty of perjury I certify that the independent expenditures reported hel'ein were not made in cooperation, consultation, Of concert with, or at the request or suggestion of, any candidateo'r authorized committee OT agent of either, or (if the reporting entity is not a political party committee) any political party committee or its agent.

JonathaJ1 Martin [Electronic (lIly FilellJ Date

~--~--------------------------------------

Signature

FEG Schedule E (Form 3X) Rail. 0712011

12-9525_0063

Irnage# 12971195980


NAME OFCOMMJTTEE (In Full)



FEe IDENTIFICATION NUMBER.

Checl( if r:-] 24-holir report [] 48-hour report [~] New report Amends report filed on


Katz Media Group, Inc.

Mailing .Address 125VVesl 551h st.

City

NewYbr'k

Purpose of Expenditure Online advertisements

State

NY


DONALD A. MANZULLD

Calendar Year-To-Date per Election i-IlilflmIlilflm"'''9W-P'''''fJ'''''9IIIiIfImIlilflmIlilflm-t''''9r

for Office Sought r_-tfW,F.m41~k""/(fc';;",fi,",,,['bm.,/k;;;;'b;";

Full Name (Last, First, Middle Initial) Cif Payee Lewis Advertising


City

Wetumpka

Purpose of Expenditure Radio Advertisement

:St<lte

FL


JO BONNER

Calendar Year-To,Date Per Election for Office Soug'llt

ZiR Code

36092

Date

~I ~:~::e District: 16

[j Presideht

D Sllpport ~ Oppose

Disbursement For; ~: Primaiy It_-_-·_-_-] General 2012 '-'

Dthe r (specify) II>

Date

Ambunt

ransac Ion •.

OOw",'.ht ~ ::::rn Check One: LJ Support

Disbursement For: ~ Primary 2012L~,

Other (specify) Ii>:-

State:

District:

AL

01

lZl Oppose

Li General

(,,)SUBTOTAL of Itemized Independent Expenditures ............................................................. II> 30600.00

(b) SUBTOTAL Cif Unitemized Independent -Expenditures .. _ ..................................................... II>

(e) TOTAL Independent Expenditures ..................................................................... "",,,,,,,,,,,,,,, Ii>:-

Under penalty of perjury I certify that the independent expenditures reported herein were not made in cooperation, consultation, or concert with, or at the request or suggestion of, any candidate .01' authorized committee or <\gentof either,or (if the reporting. entity is nota political party committe-e) .any political party committee or its agent.


%%fW~~----------------------------~-----

FEG Schedule E (Form 3X) Rav .. 0712011

Image# 12971.195981


NAME OFOOMMJTTEE (In Full)



FEe ID.ENTIFICATION NUMBER''''

Check if LJ24-hour report [] 48-hour report [] New report Co:] Amend:;; report filed on

Full Name (Last,. Fir:;;t, Middle Initi<ll) of Payee

Lewis Advertising

Mailing Addres's PO .Box 544

City

Wetumpka

Purpose of Expenditure TV Broadcast

State

FL

Zip Code

360.92


DONALD A. MANZULLO

Calendar Ye.ar-To.Date Per Election ! "&~'1!"::"'"W"g£q?'''t''K'''''''1P''''''''1!~%!fr'*mgi@-1!

for Office Sought i,_",~.,.IA_([;_~""'*i!'.J~ "_~;'4i'<kis"i-

Full Name (Last, First, Middle Initial, of Payee Lewis Advertising


City

Wetumpka

Purpose of Expanditure Television advertisement

State

FL

Zip Code

360.92

Category/ Type


DONALD A. MANZULLO

Calendar Year-Yo-Date Per Election for Office SoLlgllt 19

Date

Amount

Office Sought:

i Senate District:

IL

16 U'=: House St<\te:

Presideht ---

D Support

Disbursement For: [Xi Primary 20.12 '-'

Other (specify) Ii>

Date

Amount

Transac on

Office Sought: ~I ~:~::e

o President

Check One: [J Support

~ Oppose

General

IL

District: 16

i><i Oppose ._,

2~~sgursement For: ~ Primary LJ General

.' [J Other (sp~cify) II>-:

(a) SUBTOTAL of Itemized Independent Expenditures .............................................. , ........... , .. Ii>

(b) SUBTOTAL6f Unitemized Independent Expenditures ........................................................ Ii>

(c) TOTAL Independent Expenditures ........................................................................................ Ii>

Under penalty of perjury I certify that the independent expenditures reported herein were not made in cooperation, consultation, or concert with, or at the request or suggestion of, any candidate or authorized committee or C\gent of either, or (if the reporting entity is nota political party committee) .any political party committee or its agent.

Jonathan Martin [Electrollically Filed] Date

~--~--------------------------------------

Signature

FEG Schedule E (Form 3X) Ra\l~ 0712011

Image# 12971.195982




PAGE . 36 OF 54 FOR LINE 24 OF FORM 3X

FEC IDENTIFICATION NUMBERT

Check if []24-hour report 48-hour report [] New report [--] Amends report filed on


Lewis Advertising


Oity

Wetumpka

Purpose 'Of Expenditure Radio advertisement

State

.FL


DONALD A MANZULLO

Zip Code

36092

Date

Amount

ra Office Sought:

~·I ::~::e U Presideht

D support

State: IL

District: 16

~ Oppose

Calendar Year-To-Date Per Election t-'.IiI&1j1i%ti%llfill"''ll'''''''~r'·'''·\;;'·'''';·;'lj''''

for Office Sought ~>';";;)';F;)K.%:&mi.i":*".;4l,'h"",,1fuJT ••

Disbursement For: !Xi Primary If_-_] General 2012. '-' -' ....

Full Name (Last, First, Middle Initial) of Payee Message & Media

Mailing Address 3'101 Lee Highway

Suite 18 #136

City

Bristol

Purpose of Expenditure Email communications

Stilte VA

Zip Code

24202

Category/ Type


SPENCER T. BACHUS


. Other (specify) p.

Date

Amount

Office Sought:

Check One:

~~ ~:~::e [j President

D Support


2012 [J Other (Sp~--;;jfy) II>:

(a). SUBTOTAL of Itemized Independent Expenditures ............................................................. p.

{b) SUBTOTAL of Unitemized Independent Expenditures ........................................................ p.

(c) TOTAL Independent Expenditures ........................................................................................ ""

State:

District:

AL

06

i><i Oppose •• __ .!:l

General

Under penalty of perjury I certify that the independent expenditures reported herein were not made in cooperation, consultation, or concert with, or at the request or suggestion of, any candidate or authorized committee or agent of either, or (if the reporting entity is not a political party committee) .any political party committee or its agent


~S~ig-n-a7tu-re--------------------------------------

FEe Schedule E (Form 3X) Rev. 0712011

Image# 12971195983


NAME OFOOMMITTEE(ln Full)



FEe IDENTIFICATION NVMBER ....

Check if [:]24-hour report [:] 48-hour report [] f'Jew report [:] Amends report filed on


Message & Media


Suite 18#136

City

Bristol


State

VA


SPENCER T. BACHUS

Calendar Ye.ar-To-Date Per Election ,""':''''N''''''%F'''~'iW-?W~'''''W~9I!'''9I!''-W''''%t

for 'Office Sought t-w\lw~w#:\9I!".wJkiJ3'9I!"_"."J



Suite 18 #136

City

Bristol


State

VA

Zip Code

24202'

Category! Type


JO BONNER

Calendar Year-To,Date Per Electi.on for Office Sought 2139

Date

Amount

~ ~-.' House

r········ Senate

t Presideht

Check 'One: Dsupport

Disbursement For: 1><1 Primmy 2012 ~. '--' LI Other (speCify) ..

Date

Amount

ransae Ion

Office Sought: d!'" House 1-'- Senate

President


Disbursement For: .~ Primary

2012 r-]Other (SP~Ci~) Ii>:

(a) SUBTOTAL of Itemized Independent Expenditures ............................................................. po.

(b) SUBTOTAL of Unitemized Independent Expenditures ................... _ ........ _........................... po.

(c) TOTAL Independent Expenditures ........................................................................................ po.

State: AL

District: 06

.iX! Oppose

[lGeneral l _____ !

AL

District: 01

~ Oppose

General

1200.00

Under penalty of perjury I certify that the independent expenditures rep.orted herein were n.ol made in cooperation, consultation, or concert with, or at the request or suggestfonof, any candidate or authorized committee or agenl01 either, or (if the reporting entity is not ,a political party committee) any political party committee or its agent.

Jonathan Marlin [Electronically Filed] Date

~S~ig-n-a7tu-re------------------------------~------

FEe Schedule E (Form 3X) Rw 07120t1

Image# 12971195984


NAME OF COMMITTEE (In Fun)



FEC IDENTIFICATION NU.MBER'f'

C00502849

Check if [-]24-hour report [] 4B-hour report [] New report [] Amends. report filed on

Full Name (Last" First, Mi,ddle Initial) of Payee

Message & Me'dia


Suite 18#136

City

Bristol


State

VA Zip Code

24202

Category/ Type


JO BONNER


Mailing AddreS'S 3101 Lee Highway

Suite 18 #1.36

City

Bristol


State

VA Zip Code

24202

Category! Type


DONALD A. MANZULLO


Date

Amount

n State: AL

District: 01

Office Sought: ~H'- House r' Senate

t . Preslde.nt

Check One: D Support !}(! Oppose

Disbursement For: ~j Primary [:=:_1. General 2012. '-' ....... . n Other (specify) ...

Date

Amount

600,00 'Ii ns:ctT6tf!'1'fr(s'"~'ta-~~40t·;<,;·.·.,·

Office Sought: H'=:- House State: I L

Senate District: 16

L_ President

Check One: [] Support (><I Oppose

2~~s~ursement For:~ F'timary LI General

Other (specify) ...

(a) SUBTOTAL of Itemized Independent Expenditures .... , ..... , ... , .......... , ..................... , ... ", ....... ... 1200.00

(b) SUBTOTAL of Unitemized Independent Expenditures .... , ........... ,,, .......................... , .. , .... ,.. ...

(c) TOTAL Independent Expenditures" .. " .. " .... ", .. ""."" ............... ", ...... " ....... , ..... , ...... , ............. ...

Under penalty of perjury I certify that the independent expenditures reported herein were not made in cooperation, consultation, or concert with, or at the requestor suggestion of, any candidate or authorized committee or a,gent of either, or (if the reporting entity is not a political party committee) any political party committee or its agent.

Jonathan Martin [Electl'oltictilly Filed] Date

Sig-n-a7tu-re--------------------------------------

FEe Schedule E(Form 3X) Re\l~ 0712011

Image# 12971.195985



CAMPAIGN FOR PRIMARYACGOUNTABILITY INC


FEe ID.ENTIFICATION NU.MBER'V

Check if []24-hour report [] 4B-hour report [=] New report [] Amends report filed on


Message & Media


Suite 18#136

City

Bristol


State

VA


SPENCER T. BACHUS

C€\lendar Year-To-Date Per Election L11·"''i{irfif.'?'''m,'*l'il''''~''ff.®''0P'''''11-'¥f''''W

for Office Sought ~,_,J,1"'?&!;ilt,ff.J!)"""1k#"dik,wl[f'>",,d; .. "'iIii

Full Name (Last, First, Middle Initial) of P.wee Message & Media


Suite 18 #1.36

City

Bristol

Purpose of Expenditure Emailcommunicati.on

State

VA Zip Code

24202

Category! Type


JO BONNER

Calendar Year-To~Date Per Electi.on for Office Sought

Date

Amount

Office SOU9ht:~ i)(:~ House i Senate

r President


Disbursement For: ~: Primary

2012 LI Other (sP~Cify) p..

Date

Amount

ran on

omo. sooo" ~ :::::" Check One: [J Support

State: AL

District: 06

~ Oppose .~

General

AL

District: 01

lZJ Oppose

2~~s~ursement For: ~ Primary [=] General

.. ' []Other (SP~Cify) II>:-

(~) SUBTOTAL of Itemized Independent Expenditures ............................................................. p.. 1200.00

(b) SUBTOTAL of Unitemized Independent Expenditures ........................................................ II>:-

(c) TOTAL Independent Exp(;lnditures ........................................................................................ II>:-

Under penalty of perjury I certify that the independent expenditures reported herein Were not made in cooperation, consultation, or concert with, or at the request or suggesifonof, any candidate or authorized committee or €\gent of either,or (if the reporting entity is not a political party committee) any political party committee or its agent.

JonaJhcm lvfartin [E'/ectrollically Filed] Date

~S~ig-n-a~tu-~--------------------------------------


Image# 12971195986


NAME OF OOMMITTEE <In Full)



FEe ID.ENTIFICATION NU.MBER ...

Check if [:J24-hour report [] 48-hour report [] New report [] Amends. report filed on

Full Name (last, First, Mi.ddle Initial) of Payee

Message & Media


Suite 18 #136

City

Bristol


State

VA


JO BONNEH

Calendar Year-To-Date Per Election t~9fPI'IW1f'lW1f'lW1fP""i?""""l!i'lW1f''\i'''L\ll

for Office Sought r'-0G,,":J~,'si',,,,.;.;;.\,.,.JL,dJ\""'J""i?d

Full Nahle (Last, First, Middle Initial) of Payee Message & Media


Suite 18 #136

City

Bristol


State

VA

Name of Federal Candidate Supported OJ Opposed by Expenditure:

SPENCER T. BACHUS


Zip Code

24202

Disbursement For: D<i Primary 2012 ,~.

. Other (specify) II>:

Date

Check One:

~~ ::~::e [j President

[] Support

State: AL

District: 01

~ Oppose

General

AL

District: 06

iXI Oppose .. --~

2~~s~u~~~ent For: ~ Pnmary Li General

LJ Other (specify) 11>:.

(a) SUBTOTAL of Itemized Independent Expenditures ............................................................. j;. 1200.00

(b) SUBTOTAL of Unitemized Independent Expenditures ........................................................ II>:

(c) TOTAL Independent Expenditures ........................................................................................ II>:

Under penalty of perjury I certify that the independent expenditures reportedhetein were not made In cobperation, consultation, or concert with, or at the request or suggest/on Of, any candidate or authorized committee or (1gentof either, or (if the reporting entity is not.a political party committee) any political party committee or its agent.

Jonathan Martin [Electronically Filell] Date

··~S~ig-n-a7tu-re------------------------------~------


Image# 12971195987

SCHEDULE E (FEC Form aX) ITEMIZED INDEPENDENT EXPENDITURES




FEC IDENTIFICATION NVMBER ....

Cileck if [']24'hour report 48-hour report New report r--] Amends report filed on


Message & Me'dia


Suite 18 #136

City

Bristol


State

VA Zip Code

24202


DONALD A. MANZULLO

Calendar Year-To-Date per Election !i-"'lP'WiWmmqpmm"W-~~"''1'f'····''~/··:·''''iii·''·}·&'

for Office Sought Ikradi;'m'T~"'i/~;,zn,JJ"",dwJ,;mmqdimMibJ


Mailing Address 3'101 Lee .Highway

Suite 18#136

Clty

Bristol


State

VA Zip Code

24202

Category/ Type


DONALD A. MANZULLO

Calendar Year-To,Date Per Election for Office Sougilt

Date

Amount

ransacon

; Senate Office Sought: ~~-~' House

r Presideht


. Disbursement For: !Xl Primary

20.12 l~' 'Olh ( ~fy') ,j e rspeci .' I\>

Date

StElte: IL

District: 11

!Xi Oppose

r'] General L __

District: 13

Check One: ~ Oppose


.' [1 Other (sP~Cify) II>--

(a) SUBTOTAL of Itemized Independent Expenditures .............................................................. p..

(b) SUBTOTAL of Unitemized Independent Expenditures ........................................................ p..

(0) TOTAL .Independent Expenditures ........................................................................................ p..

Under penalty of perjury Ice.rtify that the independent expenditures reported herein were not made in cooperation, consultation, or concert with, or at the request or suggestion of, any candidate or authorized committee or agentof eithe r,or (if the reporting entity Is nota political party committee) any political party committee or its agent.

Jonathan MaTlin [Electrollicttlly Filed! Date

--~----------------------------~-----Signature

FEe Schedule EO .(Form 3X) Rev. 0712011

Image# 12971.195988





FEe ID.ENTIFICATION NUMBER V

Check if [] 24-hour report 0 48-hour report [] New report [] Amends report filed on


Message & Media

Mailing Address 310.1 Lee Highway

Suite 18 #136

City

Bristol


State

VA

Zip Code

2420.2

Category/ Type


DONALD A. MANZULLO

Calendar Year-To-Date Per Election iY""'_t""!l"''''9 _ _t_t_tf&lllll'P'''fuWlM'+J

for Offi ce Sought "~,."'."G.I.I ..•. Jll,'"0~>,,<,: •.... ,,};"".{'!x."'.,,[L;I,.,,;g,d


Mailing Address 310.1 Lee Highway

Suite 18 #136

City

Bristol

PLlrpose of Expenditure Email communication

State

VA


DONALD A. MANZULLO


Zip Code

2420.2

for Office Sought ;F'. ""d_lIl",.';;?;h_tMi@ijth_flfk~

Date

Amount

Office SOU9ht:~ ~;-~ House State: IL

i Senate District: 16 r Preside.nt

CI1eck One: D Sllpport

Disbursement For: iZi Primtlry

20.12 n Olh ( 'fy) J . er . speci ')!>'

Date

Amount

Tr sac Ion

OfficeSoqght: ~1 ~:~::e

U President

o Support

Disbursement For: ~ Primary 20.12 l~

Other (specify)!>.

.~ Oppose

General

IL

District: 1.6

l><Ioppose

General

(a) SUBTOTAL of Itemized Independent Expenditures ............................................................. )!>. 120.0..0.0.

(b) SUBTOTAL of Uriitemized Independent Expenditures ................................................ ..-..... )!>.

(0) TOTAL Independent Expenditures ........................................................................................ )!>.

Under penalty of perjury I certify that the independent expenditures reported herein were ndt made in cooperation, consultation, or concert with, or at the request or suggestion of, any candidate or authorized committee or €jgentof either, or (if the reporting entity is not a political party committee) .any political party committee or its agent.


~--~--------------------------------------

FEG Schedule E(Form 3X) Rev. 0712011

Image# 12971.195989





FEe IDENTIFICATION NUMBER V

Checi< if [] 24-hour report [] 48-tiour report [] New report [] Amends report filed on


Message & Media

Mailing Address 3101. Lee Highway

Su ite 18 #136

City

Bristol


State

VA


DONALD A. MANZULLO

Zip Code

24202

Date

Amount

StElte: IL

District: 16 dg. House ! Senate

~ President

Cl1eci< One: D Support IX! Oppose

Calendar Year-To-Date per Election V··'··Z;i'·"'>;"·;·""i~;;·"'··;'iF";·;;7;;·;'t\!?i!'i'!lll~?f'1;T~"""9~*;

for Office Sought t_.~m&j\~_~.J~_r;t1i.-".E;h,,;.ll\;,,\'t

Disbursement For: iX, Primary [] Geneial

2012 n 'O+h ( -Yfy')

Full Name (Last, First, Middle Initial) of Payee The Schuman Group

Mailing Address 7660 Fay Ave.

City

La Jolla

Purpose of Expenditure Radio Advertisement

State CA

Zip Code

.92037

Categoryl Type

Name of Federal .candidate Supported or Opposed by Expenditure:

JEANNETTE H SCHMIDT

Calendar Year-To-Date Per Election for Office Sou9llt

....... ! ,"er speci ~

Date

Amount

nsac Ion •

OfficeSou,ght: f?<~. ~:~::e

U President

[] Support

Disbursement For: ~ Primary 2012 ,~

Other (specify) I>.

(a). SUBTOTAL of Itemized Independent Expenditures ...... " .... " ......... ", .. ,,,, .. ,, ..................... ,, .. I>.


(e) TOTAL Independent Expenditures .................................................................... , ................... I>.

District:

OH

02

.!Xl Oppose ,-"

Li General

10900.00

Under penalty of perjury I certify that the independent expenditures reported hElI'ein were not made in cooperation, consultation, or concert with, or at the request or suggestion of, any candidate or authorized committee or qgent of either, or (if the reporting entity is nota political party committee) .any political party committee or its agent.

Jonathan Martin [Electronically Filed! Date

~--~----------------------------~-----Signature

FEC Schedule E (Form3X) Rev. 07/2011

Image# 12971.195990

SCHEDULE E (FEC Form 3X) ITEMIZED INDEPENDENT EXPENDITURES





Check if []24-hour report 48-hour report [] New report ["] Amends report filed on

FUll Name (Last, First, Middle Initial) of Payee

The Schuman Group

Mailing Address 7.660 Fay Ave.

City

La Jolla


State

CA

Zip Code

92037

Category/ Type


SPENCER T, BACHUS

Full Name (Last, First, Middle Initial) of PEiyee The Schuman Group


City

La Jolla

Purpose of Expenditure Automated Calls

State CA

Zip Code

92037

Category/ Type


JEANNETTEH SCHMIDT


Date

Amount

ra sac I.on

Office SOU9ht:~ ~C~ House i Senate

r President !


Disbursement For: !Xi Primary

2012 ,--, 'Oth ( ~fy) I i er speci .... ' ....... _! ....

Date

Amount

Office Sought: ~I ~:~::e

lj President



2012 [!Other (SP~Ci~) II>.-

(a) SUBTOTAL of Itemized Independent Expenditures .............. , .............................................. l>

(b) SUBTOTAL of Unitemized Independent Expenditures .. _ .................... _ ................................ l>

(0) TOTAL Independent Expenditures .......................................................................... " ............ II-

State: AL

District: 06

~Oppose

General

OH

District: 02

[gJ Oppose

Li General

Under penalty of perjLl ry I certify that the independent expenditures reported herein were not made in cooperation, consultation, or concert with, or at the request or suggestion of, any candidate or authorized committee or agent of el1l1er,or (if the reporting entity is not a political party committee) .any political party committee or its agent.

Jonathan Martin [ElectroniclIlly Filed] Date

~~~----------------------------~-----

FEG Schedule E (Form 3X) Rev. 07/2011

12-9525:-0074

Image# 12971.195991

SCHEOULE E (FEe Form 3X) ITEMIZED INDEPENDENT EXPENO.ITURES




FEC ID.ENTIFICATJON NUMBERT

Check if 24-110ur report [] 48-hour report [] New report Amends report filed on

Full Name (Last, First, Mi.ddle Initial). of Payee

The Schuman Group


City

La Jolla

Purpose of Expenditure Automated Calls

State

CA


SPENCER T. BACHUS

Calendar Year-To.Date Per Election

for Office Sought f_w&8&i\"di'c""";1I""""!;.x"/"T.',,,d,,,'<\""/

Full Name (Last, First, Middle Initial, of Payee The Schuman Group


City

La Jolla


State

CA

Zip Code

92037

Category! Type


SPENCER T. BACHUS

Calendar Year-To-Date Per Electi.on for Office Sought

Date

Amount

Disbursement For: IX! Primary 2012. .~.

. Other (specify) ~

Date

Amount

ransac Ion

Office Sought: ~~~:~::e

D President

Check One: ['j Support '--

Disbursement For: ~ Primary 2012 C~,

Other (specify) ~

(~) SUBTOTAL of Itemized Independent Expenditures ............................................................. ~


(e) TOTAL Independent Expenditures ........................................................................................ ~

District: 06

IX! Oppose

General.

State: AL

District: 06

[g] Oppose

[] General

Under penalty of perjury I certify that the independent expenditures reportedhel'ein were not made in cooperation, consultation, or concert with, or at tile request .or suggestion of, any candidate or authorized committee or a,gentof either, or (il the reporting entity is not.a political party committee) .any political party committee or its agent.

Jonathan Martin [Electroniclllly Filed] Date

~n,g~----------------~--

FEG Schedule E(Form 3X) Rev. 0712011

Image# 12971.195992

SCHEOULE E (FEe Form ax) ITEMIZED INDEPENDENT EXPENDITURES




FEC IDENTIFICATION NUMBER V

Checl< if []24-hour report [] 4B-hour report [:] New report [-] Amends report filed on


The Schuman Group


City

La Jolla


State

CA


SPENCER T. BACHUS

Calendar Year-To-Date Per Election f1!!WW4P'WW~WWP"T'WWWW¥''''''''W-\+'''':':<

for .office Sought [~_d.L":wJI,:;;i[b,.';i ... ;.;.~ .. ; ... jI\";;;.".;,,,;cr.i4ft;DdL-~;;

Full Name (Last, First, Middle Initial) of Payee Thomas GraphiCS, Inc.

Mailing Address P,O. Box 142226

City

AU$tin

Purpose of EXpenditure Radio Advertisement

State

TX Zip Code

78714-.2226

Categoryl Type


JEANNETTEH SCHMIDT

Calendar Year-To-Date Per Election for Office Soug!lt 119

Date

Amount

StEite: AL

District: 06

Check One: .~ Oppose

Disbursement For: iZI Primary [] General

2.012 n' 'Oth ( 'fy) .. J er speci It>

Date

Amount

Officesought

H ~;~ H.ouse

Senate

President

Checl< One: [J Support

OH

District: 02

iXI Oppose •. ---'<

2~~s~u~~~ment For: ~ Primary Li General

. l--.JOther (specify) ~

(a) SUBTOTAL of Itemized Independent Expenditures ...... " ..................... " .............. ,,, ... ,, .... ,, .. It> 23450.60

(b) SUBTOTAL of Unitemized Independent Expenditures ........................................................ It>

(0) TOTAL Independent Expenditures." ........................................................... , ......................... It>

Under penalty of perju ry I certify that the independent expenditures reported hMein were not made in cooperation, consultation, or concert with, or at the request or suggestion of, any candidate or authorized committee or <!gentof either, or (if the reporting entity is not.a political party committee) any political party committee or its agent.

Jonalhan Map/in [Electrollically Filed! Date

~~~----------------------------~-----Signature

FEe Schedule E (Form 3X) Rev. 07/2011

Image# 12971195993


NAME. OF OOMMITTEE (In Full)




Check if [] 24-hour report f] 48-hour report New report [] Amends report filed on " I,


Thomas Graphics, Inc.

Mailing Address P,O, Box 142226

Oity

Austin


State

TX


SPENCER T, BACHUS

Zip Code

78714-2226

Calendar Year-To-Date per Election j:-:rypmw.qp!®®jf"'M:rypmiiWjjPlI'''.q;::iD'''''''k/,':,''"ll

for Office Sought i'-mih:ITJ4,,,:J]':E,,J:7iii',d0::0"~,_dlmd




City

Austin


State

TX


SPENCER T. BACHUS

CaJendar Year-To,Date Per Election tor Office Sought

Zip Cod<;i

78714-,2226

Date

Amount

25000,,00

Office Sought: ~. House St<\te: AL

[""""" Senate ~-L President

District: 06

D SLlpport .~ Oppose

Disbursement For: [X: Primary ['.'_1 General 2012 '-' -

" Other (specify) I>

Date

Amount

rans Office Sought:

10530,00

":li"1J'!h:rypm~~i

R;:~ ,sHeOnUaS,tEie' State: AL

District: 06 President

[J Support ~ Oppose

2~~s~ursement For:!'-:S1 Primary Cl General

Other (specify) /I>:

(a} SUBTOTAL of Itemized Independent Expenditures ............................. " .............................. I> 35530,00

(b) SUBTOTAL of Unitemized Independent Expenditures ........................................................ I>

(c) TOTAL Independent Expenditures ................................. , .............. , .................. , .................... /I>:

Under penalty of perjury I certify that the independent expenditures reported hel'ein were not made in cooperation, consultation, or concert with, or at the request or suggestfonot, any candidate or authorized committee or agent of either, or (if the reporting. entity is nota political party committee) any political party committee or its agent.

Jonathan MaTlin [Electronically Filed] Date

~S~ig-n-a~tu-re--------------------------------------

FEe Schedule E(Form 3X) Rev. 0712011

Irnage# 12971195994



CAMPAIGN FOR PRIMARY .ACCOUNTABILITY INC


FEe IDENTIFICATION NVMBERV

Check if [--}24-hour report 48-hour report ? [] New repM [=] Amends. report filed on

Full Name (I-;ast, First, Middle Initial) of Payee



Oity

Austin


State

TX Zip Code

78714-2226

Category! Type

Name of Fe.cter£ll Candidate Supported or Opposed by Expenditure:

JO BONNER

Calendar Year-To-Date Per Election FiIi@''\~:~,,··,··;,········'··ji''·x··AtCu'\F~pc~''\'\,¥iIiiIi'\_Wm~''H

for Office Sought !~_Jiti#.~,.,d;\pc¥¥mJ.:lbwiliili'\¥J;~_~lI.~, .• )-

Full Name (Last, First, Middle Initial, of PElyee Thomas Graphics, Inc.


City

Austin


StElte

TX Zip Code.

78714·,2226

CEltegory! Type


JO BONNER

Calendar Year-TocDate Per Electi.on for Office Sought 70341-36

Date

Amount

.on State: AL

District: 01

Office SOU9ht:~ ~.~.~_ House i Senate

r Preside'nt

CI1eck One: D Support IX! Oppose

Disbursement For: 1><1 Prim£lry 2012 '-'

Other (specify) '"

iJ General l __ ._

Date

AmOunt

r-'~ District:

AL

01

Office Sought: H;"=~ HseOnUaStee State:

,President ---L. ..... .

Check One: [] Support ~ Oppose .. -'<

2~~s~ursement For: ~ Firimary L.J General

.' . [] Other (sP~cify) ~

(a). SUBTOTAL of Itemized Independent Expenditures ............................................................. '"

(b}SUBTOTAL of Uriitemized Independent Expenditures ........................................................ '"

(c) TOTAL Independent Expenditures ........................................................................................ '"

Under penalty of perjury I certify that the independent expenditures reported herein were not made in cooperation, consultation, or concert with, or at the request or suggestion of, any candidate or authorized committee or ggent of either, or (if the reporting entity is not a political party committee) any political party committee or its agent

Jonathan lvfartin [Electro1lically Filed] Date

~S"'ig-n-a~tu-ffi--------------------------------------

FEe Schedule E (Form 3X) Rav.0712011

Image# 12971.195995


NAME 'OF CQMMJTTEE(ln Full)

CAMPAIGN FOR PRIMARY.ACCOUNTABILITY INC

PAGE 49 'OF 54 F'OR LINE 24 'OF F'ORM 3X

FEe IDENTIFICATION NUMBER .~

Check if [] 24·hour report [] 4B.hour report [] New report [] Amends report filed on ·TC·t!'7'·)!

Full Name (Last, First, Mi.ddle Initial) of Payee


Mailing Address P.'O .. Box 142226

City

Austin

Purpose of Expenditure Maller

State

TX


SPENCER T. BACHUS

Calendar Year· To·Date per Election ; t"""~;;,:t·:·'·,,·'t'·:',f.:,,/:·:·::::1~z"""'!F"""£"J,,~J;}*"k~'''qr-qr

for 'Office Sought ;"""",.Ji0;...t,.1:.A""w&.rwAlJ;:L""",Ji@j\1)h,,,,,'

Full Name (Last, First, Middle InitialJ of Payee


Mailing Address P. 'O. Box 142226

City

Aus,tin

Purpose of Expenditure Maller

State

TX Zip Cod€!

78714-.2226

Category! Type

Name of Federal Candidate Supported or 'Opposed by Expenditure.:

SPENCER T. BACHUS

Calendar Year· To-Date Per Election for 'Office Sought

Date

District; 06

Check 'One: ~ 'Oppose

Disbursement For: I)(i Primary General 2012. '-'

'Othe r (specify) II>

Date

Amount

Tr nsac Ion

'Office Sought: ~~ ~:~::e

tJ President


Disbursement For: ~ Prtmary

2012 [J 'Other (SP~CifY) jlo,

District:

AL

06

iXl 'Oppose .. -"

LJ General

(a) SUBTOTAL of Itemized Independent Expenditures ............................................................. Ii>-

{b) SUBTOTAL of Uhitemized Independent Expenditures ........................................................ Ii>-

(c) T'OTAL Independent Expenditures ........................................................................................ II>

Under penalty of perju ry I certify that the independent expenditures reported herein were not made in cooperation, consultation, 0r concert with, or at the request or suggestfonof, any candidatedr authorized committee or agent 01 either,or (if the reporting entity is not a political party committee) any political party committee or its agent.

JOiJC1Jhan Martin [Electrollically Filed! Date

~~~----------------------------~-----Signature

FEG Schedule E(Form 3X) Rev .. '0712011

Image# 12971195996



CAMPAIGN FOR PRIMARY ACCOU NTABILITY INC


FEC IDENTIFICATION NUMBER",

Checl( if LJ24-hour report [] 4B-hour report [] New report [-] Amends report filed on




City

Austin

State

TX

Purpose of Expenditure Direct Mail Piece.

Category! Type


JO BONNER


for Office Sought f-~d'&mJ,"w4];",,_!b-!b-,,£~h!'Nd)':;"';

Full Name (Last, First, Middle In[tial) of Payee Thomas GraphiCS, Inc.


City

Austin

purpose of Expenditure Direct Mail Piece

State

TX

Name of Federal Candidate Supported or Opposed by Expenditure.;

SPENCER T. BAOHUS

Calendar Year-To-Date Per Electi.on for Office Sought

Date

Amount

state: AL

District: 01

~ Oppose

Disbursement For: I><! Primary

201 2 Oth ( "---:f') . er speci Y )I>

General

Date

Amount

Office Soqght: H!~'. sHeOnUaStee State: AL

District: 06 President

Check One: [J Support 1ZI Oppose


.' . [-10ther (sP~cify) )I>

(a) SUBTOTAL of Itemized independent Expenditures .............................................................. )I>

(b) SUBTOTAL of Unitemized Independent Expenditures ................... _ ......... _ ... _...................... ...

(c) TOTAL Independent Expenditures ........................................................................................ )I>

Under penalty of perjury I certify that the independent expenditures reported herein were not made in cooperation, consultation, 01' concert with, or at the request or suggestion of, any candidate or authorized committee or 8,gent of either, or (if the reporting entity is not.a political party committee) .any political party committee or its agent.

Jonathem 'MaTtin [Electronically Filed] Date

~--~------------------------------~------

FEG Schedule E (Form 3X) Rev. 07120t1

Image# 12971195997


NAME. OF COMMITTEE (In Full)



FEe IDENTIFICATION NUMBER.,

Check if r:] 24-hour report [] 48-hour report [:] New report [] Amendr;; report filed on




City

Austin

Purpose of Expenditure Direct. Mail Piece.

State

TX


DONALD A. MANZULLO

Calendar Year-To-Date Per Election ;,-IIiifIP'@IIjff~?'''@¥?''W¥fl~-~lIiifIP'l&d''@~W@lljff@lljffmA

for Office Sought ""C"C'C""",,"/>"'O"'1:0,""<.",'''''C)'''''',·' ""i7 <\"'c"K"",~jW"""""i"" .• ,'

Full Name (Last, First, Middle Initial) of Payee Thomas Graphics, Inc.


City

Austin

Purpose of Expenditure Direct mail piece

StiJ,te

TX Zip Code.

78714-,2226

Categoryl Type

Name of Federal Candidate Supported or Opposed by Expenditure;

DONALD A. MANZULLO

Ca;lendar Year-To,Date Per Election for Office Sought

Date

~I ~:~::e [j President

Check One: o Support

Disbursement For: :Xl Primary

2012 o Other (sp~Ci~) ~

Date

Amount

r nsac on

Office Sought: ~~: House Senate

President


Disbursement For: ~ Plimary

2012 I] Other (sp~cify) ~




St<\te: IL

District: 16

~ Oppose

General

District:

IL

16

lZJ Oppose

[] General

42290.32

Under penalty of perjury I certify that the independent E)xpenditures reported herein were not made In cooperation, consultation, or concert with, or at the request or suggestion of, any candidate or authorized committee or agent of either, or (if the reporting entity is not a political party committe'e) .any political party committee or its agent.

JonathaJ1 Martin [Electrollically Filed] Date

~~~----------------------------~-----

FEG Schedule E (Form 3X) Rail; 0712011

Image# 12971195998



CAMPAIGN FOR PRIMARY.ACCOUNTABILITY INC


FEe ID.ENTIFICATION NUMBER'"

Check if []24-hour report [] 48-hour report [] New report r::--] Amends report filed on

Full Name (Last,. First; Middle Initii;\l) of Payee



City

Austin

Purpose of Expenditure Post card mailer

State

TX


DONALD A. MANZU LLO

Calendar Ye.ar-To-Date Per Election !,,,,,·~;;t'·;··\r;""''''lF''';!f'''TT''''''1ii!p1ii!pIm,,,m*\T%ii

for Office Sought (." wwi'_JiwMelih ___ f'lm-m-mL""12\;;,",."..;; .. ,,,:,

FUll Name (Last, First, Middle Initial) of Payee Thomas Graphics, Inc.


City

Austin

Purpos.e of Expenditure Postcard mailer

State

TX

Categoryl Type


DONALD A. MANZULLO

Calendar Year-To,Date Per Electi.on for Office Sought

Date

Amount

State: IL

District: 16

Check 'One: ~ Oppose

Disbursement For: !}<! Primary General

20.12 ~I . '011 (~fy) _ .. .1 1e r .speci . Ii>-

Date

Amount

OfficeSoqght: p1~:~::e

tj President

[J Support

IL

District: 16

lZI Oppose

2~~sgursement For:~ Primary LJ General

Other (specify) /!>:

(a).$UEiTOTAL of Itemized Independent Expenditures ............................................................. Ii>- 53796.99

(b) SUBTOTAL of Unitemized Independent Expenditures ........................................................ 1'1>

(0) TOTAL Independent Expenditures ........................................................................... , ............ 1'1>

Under penalty of perjury I certify that the independent expenditures reported herein were not made in cooperation, consultation, or concert with, or at the request ot suggestion of, any candidate or authorized committee or agent of either,or (if the reporting entity is not.a political party committee) .any political party committee or its agent.

Jonathan Martin [Elect/'ollically Filed] Date

~S~ig-n-a~tu-re------------------------------~------

FEe Schedule E (Form 3X) Rev. 0712011

Image# 12971195999



CAMPAIGN FOR PRIMARYAGCOUNTABILITY INC


FEe IDENTIFICATION NUMBER .~

Check if [-]24-hour report [] 48-hour report [] New report [--] Amends report filed on




Oity

Austin

Purpose of Expenditure Postcard mailer

State

TX

Name of Fe.deral Oandidate Supported or Opposed by Expenditure:

DONALD A. MANZULLO

Calendar Year-To-Date Per Election f"""*lk'ill~j"Yf"""'\'i:'fu\"7?'''·'''W''jT;'·'·''··'·j <.;; ;"'·;;:;·'W"""··;,1"·····')

for Office Sought ~"j0ji\~¥t+j,,"'{'krz,, __ .""+'; .. '-.,.,d0~"'~..r


TV Alabama, Inc.

Mailing Address 800 Concourse Parkway

Suite 200

Date

District: 16

CI1eck one:~ Oppose

Disbursement For: 1><1 Primary [] General

20.12 D Other (SP~Cify) ~

Date

Amount t-~~~~~~~~~~------~~~~~~~~~~~~~~~----1

City

Birmingham

Purpose of Expenditure TeleVision advertisement

State

AL

Zip Code

35244

Category! Type


SPENCER T. BACHUS

Office Sought: AL

District: 06

Oheck One: Xi Oppose


2~~s~ursement For: ~ Primary [] General

.' [1 Other (SP~Cify) Ii>:

(a). SUBTOTAL of Itemized Independent Expenditures ............................................................. Ii>- 48434.37

(b) SUBTOTAL of Unitemized Independent Expenditures ........................................................ Ii>-

(c) TOTAL Independent Expenditures ........................................................................................ Ii>-

Under penalty of perjury I certify that the independent expenditures reported herein were not made in cooperation, consultation, or concert with, or at the request or suggestion Of, any candidate or authorized committee or agent of either, or (if the reporting entity is nota political party committee) .any political party committee or its agent.

Jonathan Marlin [Electrollieally Filed] Date

~S~ig-n-a~tu-re~~~~--~~~~----------~~--~--

FEe Schedule E (FOrm 3X) Rf.lIl.0712011

Image# 12971196000

SCHEDULE E (FEe Form 3X) ITEMIZED INDEPENDENT EXPENOITURES


CAMPAIGN FOR PRIMARY ACCOU NTABILITY INC



Checl( if []24-hour report [] 48-hour report [] New rep or! [] Amends. report filed on •


WBRC

Mailing Address 1720 Valley View Drive

City

Birmingham

Purpose of Expenditure Television advertisement

State

AL

Name of Fe,deral Candidate Supported or Opposed by Expenditure:

SPENCER T. BACHUS

Calendar Year-To-Date Rer Election VIm""Y"·'·j",",',.',,,¥,¥ ill

Zip Code

35209

for Office Sought 1 .• ""d&F_i!'""i~_"4fu,,"~~&.,cc;,l~''''''.db;;;;.:ci~IimwJ Full Name (Last, First, Middle Injtial) of Payee

Mailing Address

City State Zip Code

Purpose of Expenditure Category! Type


Calendar Year-10,Date Per Election

for Office Sought !:km,mfkRd&c'::<\.".&1l\m,~_ll_mfkmfkJt~"~,:c,,:,,

Date

AL

District: 06 L Rresideht

Check One: D Support ~ Oppose

Disbursement Fcir: !Xi Primary 2012 '-' -'

, Olhe r (specify) )Ii>

Date

Amount

Office Sought:

Check One:

~.~ .. ~ ~:~::e H President

[] Support

General

State:

District:

DOppose

Disbursement For: D Primary [] General

[10ther (specify) 11>'

(a) SUBTOTAL of Itemized Independent Expenditures ............................................................. )Ii>

(b) SUBTOTAL of Unitemized Independent Expenditures ........................................................ )Ii>

te) TOTAL .Independent Expenditures ........................................................................................ ~

Under penalty of perjury I certify that the independent expenditures reported herein were not made in cooperation, consultation, or concert with, or at the request or suggestion of, any candidateo'r authorized committee or agent of either, or (if the reporting entity is not.a political party committee) any political party committee or its agent.

Jonathan Martin [Electrolliclilly Filed] Date

~~~----------------------------~-----Signature

FEC Schedule E (Form 3X) Rev, 0712011

EXHIBIT 8

CONFIDENTIAL

Subjectto the Nondisclosure Provisions ofH. Res. 895 of the 110th Congress as Amended

INRE:

REVIEW NO.:

DATE:

LOCATION:

TIME:

PARTICIPANTS:




Representative 1 12-9525 July 20,2012 1776 K Street

\V:ashington, DC 20006 2:35 p.m. to 2:46 p.m. (approximately)

Omar S. Ashmawy

Kedric L. Payne

Jan W. Baran

Robert L.Walker

SUMMARY: Representative lis aMember of the United States of House of Representatives.

The OCE requested ati intetviewwith RepresentatiVe 1 01'1 July 12,2012, and he consented to ali

interview. Representative 1 (the "witness") made the following statements in response to our

questioning:

1. The witness was given an 18 U.S.C. § 1001 warning and consented to an interview.

2. I-Ie refused to sign a written acknowledgement of the warning that his statements ate

subject to the False Statements Act.

3. The witness stated that he is affiliated with ERIC PAC~ which he believes was

established in 2003 ot 2004.

4. He told the. OCE that ERIC PAC ooes not have an .official de.cision making policy with

respect to detenllining how it contributes to other political committees.

5. When the witness decides that ERIC PAC should make a contribution, he usually speaks

with Bill Dolbow and Ray Allen.

6. The witness does not know how many individuals affiliated vi1ith ERIC PAC have the

authority to make contributions fl:om theco11lmittee's account, however, he has final

authority on contributions.

7. He told the aCE that he became f&miliar with the Campaign for Primary Accountability

('~CPA") vidthoutknowing the name ofthe entity. This happened when he received a call

from Representative Aaron Schock approxitllately one week before the primary e1ection

of Representative Adam Kinzmger itl Illinois.


CONFIDENTIAL

,----~~------------- -.--------Subject to the Nondisclosure Provisions ofR. Res. 895 of the 110th Congress as Amended

8. Representative Schock called the witness and asked whether he would give $25,000 to a super PAC operating in Illinois in: connection with Representative Kinzinger's race.

9. In response to Representative Schock's request, the witness told him that he w(:mld give $25,000 to the committee.

10. TIle witness recalled that he put Representative Schock in contact with Rob Collins. TIle

witness described Mr. Collins as a political mind that he thought vilould be able to assist Representative Schock in raising funds for the committee that was CPA.

11. On or about March 15,2012, the viTitnesS stated that11e received a call fro111 Ray Allen and Mr. Allen asked whether the witness wanted to give $25;000 to CPA. TIw witness asked Mr. Allen vi'llether it was legal to make such a contribution. and Mr. Allen told him

yes.

12. The witness did not have any further conversations about the contribution with Mr. Allen at that time inMarch 2012.

13. The witness stated that he did not know Rodney Davis until after March 2012.

111is memorandum was prepared on August 1, 2012, based on the n6tes that the OCE staff prepared during the interview with the witness on July 20, 2012. I certify that this memorandum contains all pertinent matter discussed with the'~litness on July 20,2012.


Mor - Page 20f2 OFFICE OF CONGRESSIONAL ETHICS

EXHIBIT 9

CONFIDENTIAL

.~---------------------------------- -------------------------------Subject to the Nondisclosure Provisions ofH. Res. 895 of the 110th Congress as Amended

INRE: REVIEW NO.:

DATE: LOCATION:

TIME: PARTICIPANTS:




Representative Aaron Schock

12-9525

July 26, 2012

328 Cannon HOB Washington, DC 20515

9:40 a.m. to 10:30 a.m. (approximately)

Kedric L. Payne Omar S. Ashmawy

Robert K. Kelner

Derek Lawlor

SUMMARY: Representative Aaron Schock is a Memberofthe United States House of Representatives and represents t11e 18th District of Illinois. TheOCE requested an interview with

Representative Schock on July 26,'2012, and he consented to an interview. Representative

Schock (the ''witness'') made the following statements iii response to our questioning:

1. The witness was given an 18 U.S.C. § 1001 waming alid consented to an interview.

2. He refused to sign a ,,,,ritten acknowledgement ofthe warning that his statements ate


3. He first leamed of the Campaign for Primary Accountability ("CPA") through press

accounts of CPA's activity in Representative Jean Schmidt's 2012 primarY election in

Ohio.

4. The witness stated thathe contacted Ron Gidwitz to se.e if CPA was going to become

involved in the pri111aryelection of Representative Adam Kinzinger. The witl1ess knew

that CPA was 'Staltedby the Ricketts family~ He did not know the family, but Mr.

Gihvidz did, so the witness asked Mr. Gidwitz to reach out to them.

5. The witness told the DCE that he does not recall communicating with anyone who he

believed to be an employee of CP A. He recalled that he may have contacted CP A after

the Representative Kinzinget race when there were questions about whether the money raised by Illinois donors was used for the Representative Kinzinger race.

6. He believes that he may have contacted Jamie 8tory of CPA, but he is not certain. He

stated that he did not believe that he communicated with Leo Litibeck, Eric O'Keefe, or

MOl-Page lof 4 OFFICE OF CONGRESSIONAL ETHICS

CONFIDENTIAL


Hannah Christian. He did not think he was .asked by these individuals or anyone else affiliated with CPA for any campaign .contributions.

7. The witness has known Rodney Davis for eight to ten years. He communioate(j last with Mr. Davis approximately two weeks prior to this interview at a fundraiser the witness hosted fo1' Mr. Davis. The witness told the OCE that he has not discussed this OCE review with Rodney Davis.

8. The witness knew that during the time period around March 2012, Mr. Davis helped various. political oampaigns. The witness stated that he does not remember Mr. D<\.vis asking him to contribute to CPA, but that he was sure they had a conversation about it as :tv,Ir. D~vis \vas a very active political person in Illinois. That conversation may have heen .in the context of what CPA was doing in the campaigns that Mr. Davis and the witness cared about.

9. However, Mr. Davis was wOl'king for Representative Shimkus at the time and so Mr. Davis communicated more with the witness's staff than with the "vitness.When asked ,vith which staff Mr. Davis vlould have communicated, the witness stated that it

depended on the topic.

10. The witiless did not remember Mr. Davis asking him to contribute to CPA. The witness

did not remeniber if Mr. Davis asked any of the witness's staff to contribute toCP A.

11. The. witness only became aware of the extent of Mr. Davis' involvement with CPA asa result of the OCE investigation. At the time in March 2012, he was no't aware ·of lvIr. Davis raising money for CPA.

12. The. witness does not remenlberhaving any discussions with Representative John Shimkus concerning CPA.

13. The '~Iitness told the OCE that he is familiar with the 18th District Republican Central Committee. He de.scribed {he organization as three entities. The 18th District Republican Central Committee is «the political ann of my .congressional district." It is a political organization with two fundraising committees -a state and federal committee. It also has a board of directors. The witness has no role with the board, nor does he have any role

with the state fundraising committee.

14. The. federal account of the 18th District Republican Central Committee fundraises for federal campaigns. The witness stated that he assisted with establishing this federal account when he was first elected to Congress. The witiless is involved in fundraising for this committee with his joint fundraising committee.

MOl-Page 20f 4 OFFICE OF CONGRESSIONAL ETHICS

CONFIDENTIAL

-Subject to the Nondisclosure Provisions of H. Res. 895 of the 110th Congress as Amended

15. TIle witness state.d that he has never requested that the lSth District Republican Central COlml1ittee contribute to any political campaigns.

16. Mike Bigger is his primary contact with the l'Sth District Republican Central Committee. TIle witness stated that no one affiliated with the federal account ofthe 18th District Republican Central Committee has ever asked him to contribute to any political campaigns.

17. When asked \Nhether the Schock for Congress Campaign Director, Tania Hoen', has any role. with the lSth District Republican Central Committee, the witness stated that she is responsible for disbursements to the committee from the witness ' joint fundraising committee, Schock Victory Fund.

18. TIle. witness told the OCE that hevvas not aware if she was involved in any contributions that the lSth Disttict Republican Central Committee makes.

19. He stated that he learned that approximately ten days before Representative Kinzinger's primary election in March 2012 that the 18th District Republican Central Committee conttibuted to CPA.

20. Mr. Bigger told him about the contribution.

21. TIle witness told the OCE that he caJled Representative Eric Cantor to provide an update on the Representative Kinzinger !'ace because he knew that Represel1tative Cantor supported Representative Kinzinger. This was after he learned that people were contributing to CPA. Specifically, Mr. Bigger had told the witness that he had made a $25,000 contribution.

22. During the conversation the witnesstold Representative Cantor that the race was close. He also made Representative Cantor aware of CPA's involvement and of "my support" and asked Representative Cantor for his supp01i.

23. The '~Titness stated that he does not remeniberexactly what he told Representative Cantor, but he believes he said that "We're doing $25,000 would you be able 10 do $25,000."

24. "We're doing $25,000"refen-ed to the 18th District Republicall Central Committee's

contribution of $25,000 to CPA He refelTed to it as "we" because it was a donation being made within his district.

25. TIle witness told the OCE that when he asked whether Representative Cantor would "consider doing $25,000" it was "DC speak" for asking would Representative Cantor "come up" with $25,000. The witness did not discuss with Representative Cantor the various ways of coming up with $25,000. When the conversation is Member to Member,

MOl -Page 3 o:f4 OFFICE OF CONGRESSIONAL ETHICS

12~9525_0091

CONFIDENTIAL

Subject to the Nondisclosure Provisions ofH. Res. 895 of the 11 Oth Congress as Amended

'\ve don't discuss how" - whether you write a check from your campaign or get your

donors to do it or some other way.

26. When asked for examples of how a perSOn may "come up" with a contribution, the

witness explained various methods of "coming up" with money to contribute to patty

committees. According to the witness, a Member may: contribute an unlimited amount

from their campaign committee; solicit any citizen to contribute; contribute from a

leadership PAC; or contribute from ml0ther political committee.

27. As a fUltherexample, the witness explained that if the Speaker of the House told the witness that he owed $250,000 in dues to the National Republican Congressional

Committee, the witness could get the money from his distl'ict, his account, or anothet

place.

28. The witness stated that he also contacted David Herro in March 2012 about contributing to CPA. He has known Mr. Heno for approximately five years and he knew that Mr.

Hen'o supported Representative Kizinger.

29. The witness contacted Mr. Heno and told him that Representative Kinzinger's race was

close. Tlwwitness asked if Mr. Hen'o could help.

30. Mr. HelToagreed to help. The witness stated that he did not remember asking Mi'. Herro for any amount tocOlltribute to CPA. The witness does not remember telling Mr. Heno

about the $25,000 contribution from the 18th District Republican Central Committee to

CPA.

31. Mr. He11'O told the witness that he vilould help that he would attempt to have others to

help.

32. The witness knows Ms. Anne Dias Griffin. He did not discuss CPA with Ms. Griffin

and did not ask her tocotitribute.

33. The witness told the aCE that he reviewed the Request for Tnfo1111ationand did not

withhold any Info1111ation in his production to the aCE. He stated that his response vilas

complete to the best of his knowledge.

This memorandum was prepared on July 31,2012, based on the notes that the aCE staff

prepared during the interview with the witness on July 26,2012. I certify that this memorandum

contains all pertinent matter discussed with the witness on July 31, 2012.

Kedric L. Payne


Mal - Page 40f 4 OFFICE OF CONGRESSIONAL ETHICS

EXHIBIT 10

I mage# 12950440122

r FEe

FORM 1

1. NAME OF COMMITTEE (in full)

I i I L I i l~_~

ADDRESS (nunioer and street)

(C~eck if address. is changed)


(Check if name is changed)

i I I I ! I I

LO Box 10362 .Ll....J I I I I

~!!!

I

Example: If typing, type over the lines.

I ,J..~~~L-J-, I I

, I 1 I I I I 1 I

CITY

COMMITTEE'S E-MAIL ADDRESS (Please provide only one e-mail address)

02/06/2012 12 : 31

PAGE 1/5

office UseOnl

,.L I. I I I I l.."J-L~1 I I I I 1 !

-' 1 I I I I 1 1 I I 1 J

L~ STATE ZIP CODE

(Check if a.ddress is changed)

~pdscompliance. com cr::,J= .. ,L=J....J,.,~,' 1 I I 1 1 I! I I I j i I! I I IJ..~LJ .. J LL.L.L.L.L .. LL .... .LL.J_L~II-.....IJ-,....!'--'I'--JI---'I_J""...l....J. ...... .:L.L.l._1 _I_~J

i.,."L I

COMMITTEE'SVVEB PAGE ADDRESS (URL)

(Ched< if address Is changed)

61-61 -61 ~I ~~!~!-d~~!~I~I~'~I~I~i~I.-bI~-6~I~kl~~~_~1 ~1~1-d1-d1-d!-dI~I~I~1

.... 1.....;.........;....1 _11.......J1c........l1--J1-'I-.I.-l.--l.I ....... I...,.J..I.......J."...,.J..I ....... 1 ....... 1 ....... 1 --,-I --!-I --!-I .....!-.ol .....;....1 -"1"--"'--J1--J1--J1........L..1 I I L..LJ

2. DATE

3: FEC IDENTIFICATION NUMBER 000493460

4. IS THIS STATEMENT NEW (N) OR AMENDED (A)

I certify tilat //lave examined tilis statelllent and to tile best of my know/edge and beliefJt is true, correcl.andcompleie.

Type or Print Name of Treasurer ~~~ .. I ... ~I.I~.?!..~. __ ... __

Signature of Treasurer Paul Kilgore {ElectrollicIllly Filed] Date

NOTE: Submission of false, erroneous, or incomplete information may subject the person signing this Statement to the penalties of 2 U.S.C.§437g.

ANY CHANGE IN INFORMATION SHOULD BE REPORTED WITHIN 10 DAYS.

Office For further Information contact: FEe FORM 1 Use Federal Election Commission

L Only Toll Free800c424-9530 (Revlsed 02/2009) -1 Local 202-694-1100

Image# 12950440123

r FEC Form 1 (Revised 02/2009)

5. TYPE OF COMMITTEE

Candidate Committee:

(13,) This committee is a principal campaign committee. (Complete the -candiqate information below.)

Page 2

(b) This ·.committee. is an authorized committee, and is NOT a principal campaign committee. (Complete the candidate

information below.)

Name of Candidate

Candidate Party Affiliation

LLl-LL..' I ! I I

Office Sought:

I I ! I I I

House Senate President

tc) This committee supports/opposes only one candidate" and is. NOT an authorized committee.

Name of Candidate

Party Committee:

(d) ~ This committee is a ~.m:m.;~

Political Action Committee (PAC.):

(National, State or subordinate) committee of the

I I I I

State

District

(Democratic, Republican, etc.) Party.

J

(e) This conimittee [s a separate segregated fund. (Idehtify connected organization online 6.) Its connected organization is a:

(f)

Corporation Corporation w/o Capital Stock Labor Organization

Membership Organization Trade Association Cooperative

In addition, this committee is a Lobbyist/Registrant PAC.

This conimittee sllpports/opposes more than one Federal candidate,and is NOT a separate segregated fund or party committee . .(i.e., nonconnected committee)


In addition, this committee is a Leadership PAC .. (Identify sponsor on line 6.)

Joint Fundraising Representative:

(g)

(h)

L

This committee collects contributions, pays fundraisingexpenses and disburses net proceedsfortwo or more political committees/organizations,at least one-of which is an -authorized committee of a federal candidate.

This committee collects contributions, pays funclralsing expenses and disburses net proceeds for two -or more political committees/organizations, none of which is an authorized .committee of a federal candidate.

Committees Participating in Joint Fundraiser

1.

2.

3.

4.

I I I I I ! ,..lJ.j FEe IQ

...............~_l-Ll~-LI --ll-.L..I ~~.J....I ~--,--,-i _~~J-"j FEe 10

I_I U~I-L I I I '_L...' ~I~-b-i~~-"'--J.!-..JI FEe IDnumber!;_.;;.a""tF::':;:;;'::;::=;:;;:;~!:=::=; W""LL_L.L...I """"--i-L-I ",,1_ ,.."kl-L-l -1...1 ~~~~~L-"IJ FEe ID numberl£"&''''fbg''''_'''~@~b~W!i_''''''>

Image# 1295Q440124

r FEe Form 1 (Revised 02/2009) Page 3


18th District Republican Central Commiittee (Federal Account) ,6. Name .of Any Connected Organization, Affiliated Committee, Joint Fundraising Representative, or Leadership PAC sponsor

[1II1'n~i9 Re~upli~~n Party I Ii! I Ii! I i I Iii ! I I! 1 I_.L 1 I ii, ... '1 ' I 11 I _ ; , I ; ,_, I ! I I, I.._LL.L..L ___ I _, _, __ , ___ """"-_, _'"_,,,.4-' ~"",--",-.. __ .,J .. "",LJ.. •. .....!......k--"--'L_., -..,,_

I 1 I ! 1 I ! ! I I I I 1 I II I I I I I I ! I I I I I ! I ! I I 1 I 1 I I I I I P.O. Box 64897

Mailing Address LJ_li_LL! ! LLLLLLlllLL I J [I 1 ~~I I I I I I I IJ I I I I I I! I i I U_I I I I I II ! I

IL 60664

GJ ~~ib.dl-I II J CITY STATE ZIP CODE

Relationship: Connected Organization ';8!AffiliatedCommittee ~C~:JOintFundrajSing Representative rJkeadershipPAC Sponsor

7. Custodian of Records: Identify by name, address (pllone number -- optional) and position ·of the .person in possession of committee books and records.

Full Name L...l.".""L". I I I I "",~",.l..,.L.L...L.wLJ ... ,J_.J. I I 1"_L.L.L,L~,LL~,L""L.".,L"L.~~~I",,,....L.,,L,l.."WflLLJ

Mailing Address 1_1 J .1. .La I .L) I I i J_l I I I I I .L=='m....b..dW •• L 1 l ~

LI~I6dI~~_L~! ~I~~~_

U"I Title or Position CITY STATE ZIP CODE

I I ! I I I II ! I I ! L..u Telephone number I I I-I I ! I-I I I I I

8. Treasurer: List the name and address .(phone number -- optional) of the treasurer of the committee; and the name and addressor any designated agent (e.g., assistant treasurer).

Paul Kilgore Full Name or Treasurer I II I I I I I 1 I I! I ! L . ........1I~~1 """"",I --,-,-,-' ~Il.-. -11--!..1--J.-..l..--'---'---'-~-1..--'--'--'--.1..--'-->--J'--' ! I I I I I I I I I I

Mailing Address 12470 Dani.ell's Bridge Rd .8te 121

I I I ! .I ! II ! I

Title or Position I Treasurer L-l I I I L-L-~I~d--1!--J.!-dI,,,,,,,,,,,,I--'-..d-~I>--JI~-d

L

I ! I I I

j Lb J- I I I I

I ..

I G1AI

STATE

Telephone number

I I i , I J.. I I I I

130F~~ I ! l-lLt-L1 ZIP CODE

Imag~# 12950440125

r FEC Form 1 (Revised 02/2009) Page 4

Full Name of Designated Agent

Mailing Address

Title or Position

I I I I

L" I I II I I I

! I

I !

I I

L

I I I I 1 I

L-L-L 1 I

i I I I I I I

1 I 1 I I I I

CITY

I I I I I I I,.,..,LJ .. J

I I

I i I I

I I I

I L.LI

I 1

I

1 I

L.L.LJ

I I I I I I I I

I I I , , I I

I I I I I I I

I I I I I I

I I ! , tJ IU I I I I

STATE

~-,-L..b.i ~,-"I ZIP CODE

Telephone number l-k.--b.-II = 1 1 I I ~ b.1 .,.,.' --6.-1.1 J

9. Banks or Other Depositories: List all banks or other depositories in which the committee deposits fuhds, holds accounts, rents safety deposit boxes or maintains funds.

Name of Bank, Depository, etc.

IC~~CIU I I I I 1_.1 I I I I I I 1 I I I I I I! I I I I U

Mailing Address IPOBOX1715 I . I II J l.,.......!I,..,.,;I--'lJ--'lI"""""~~ ... 1 -1..1 """""I """",,' ....1-.1 -L....l.--'lI--.J""'""'~.,bI.....61 .....6....J..1 _"I ",""",,,,",,,,,,,,",,,,,1...,,.1 -"-"-"I""",,,,

I j I I...J I I I I I I I ! ! L I I I 1 I I L J

I Peoria 1 I ; !

CITY STATE ZIP CODE


Mailing Address

L

I I I I LJ

I I 1 I I 1 I I I I AA-lI'"""""--'li--'lI~I6."..JI,"",-~I~Ib..· J~,"""",-"-,,I. I 1 I I I L.J...-!I........l.........lI........l1

~~~~_.,bL.....6.....b!~ill~I~I"'"""'l"'"""'I~-"-"-"........l.........lI-"I--'l~I_1 i ! l-LL-Ll LI~I~I.~I~!~!~I~I~!--'I--'--6.1 ~I Ii! I LL .. ,J

CITY STATE ZIP CODE

Image# 12950440126

FORM 1S -STATEMENT OF ORGANIZATION (Supplemental Page) FEC Form 1 S (Revised 0612011) Page 5

Banks or Other Depositories: List all banks or other depositories in which the committee deposits funds, holds accounts, rents safety deposit boxes or maintains funds.

Name of Bank, Depository, etc. [ ADDITIONAL]

I , , ,

Mailing Address

w CITY. STATE. ZIP CODE A

[ ADDITIONAL] Name of Any Connected Organization, Affiliated Committee, Joint Fundralslng Representative, or Leadership PAC Sponsor

I S,C~O?k ,Vi,ct?rr ?o,m:ni,tt~e , , , , , , , , , , , , , ,

Mailing Address 12470 Daniell's Bridge Rd Ste 121

. , , , I , , , I , , ,

I , , ,

I Athens . , , , I

30606

1-. ...L'--,-' ...L...L......I1- .... 1 ..........................

CITY. STATE" ZIP CODE. Relation ship: o Connected Organization o Affiliated Committee 8 Joint Fundraising Representative D Leadership PAC Sponsor

Designated Agent

Full Name

Mailing Address

Title or Position.

Joint Fundraiser Participant

1",,",,"

CITY.

[ ADDITIONAL]

, , , , , , , ,

ZIP CODE.

Telephone number

[ADDITIONAL]

FEC ID number .'.c .. ' ________ .. 1

12 ·9525_0098

EXHIBIT 11

CONFIDENTIAL


INRE: REVIEW NO.:

DATE: LOCATION:

TIME: PARTICIPANTS:



Representative Schock's Campaign Director 12-9525 1uly26,2012 1201 Pennsylvania Avenue, NW Washington, DC 20004 1 :40 p.m. to 2:00 p.m. (approximately) Kedric L. Payne Omai' S .. Ashmawy

Robed K .. Kelner Derek Lawlor

SUMMARY: The witness is the Campaign Director for Schock for Congress, which is the congressional campaign committee of Reptesentative Aaron Schock. TIle OCE requested an

interview with the witness on July 26,2012, and she consented to an intervie'~T. The witness made the followillgstatements in respotiSe to our questioning:

1. TIie witness was given an 18 U.S.C.§ 1001 warning and conse11teo to an interview.

2. She refused to sign a \vritten acknowledgement of the ,vaming that her statements are subject to the False Statements Act.

3. TIle witness is an employee of Schock for Congress and serves as the Campaign Director.

She lias served as the. Campaign Director for approximately two and one half years.

4. When asked whether she has worked or volunteeredJor any other campaigns since 2010, the witness stated that she has also vohlliteered for: theca1l1paign:colnmittee of

Representative Bobby Schilling, Bobby Sullivan, and the school board election committee of Rick Cloyd.

S.TIle witness stated that her job duties as Campaign Director for Schock for Congress are

to: oversee the operations ofthe campaign office; coordinate fundraisers; review reports for the Federal Election Commission; deposit contributions; make contributions to other campaign committees; and seno thank you notes to donors.

6. TIie witness told the OCE that either Congressman Schock or his Chief of S1aff, Steve Shearer tells her ,,;hen to make contributions from Schock fbI' Congress to other

MOl-Page 1 of3 OFFICE OF CONGRESSIONAL .ETHICS

CONFIDENTIAL


committees. When instructed, the witness writes checks to the designated campaign

committees. She is authorized to sign checks for Schock for Congl'ess.

7. TIle witness rep01is to Representative Schock and sometimes to Mr. Shearer.

8. Schock for Congress has two pati-time staffers who report to her, Gina Kampf and Cindy

Crusan.

9. TIle witness is familiar with the 18th District Republican Central Committee. Sheassisted

the committee with establishing its bank account.

10. The witness told the OCE that a few days before March 16,2012, Mr. Shearer called her

and told her to contribute $25,000 from 18th District Republican Central Committee to

the Campaign for Primary Accountability ("CPA").

11. When Mr. Shearer asked the witness to make the contribution, she asked him if it was ok

because she thought it was a lot of money. He told her that it was ok.

12. The witness .made the contribution on the CPA website using their "echeck" form. She

told the OCE that she had the information necessary to make the payment because she

lmew the banking inf0111'iation of the 18th District Central Republican Committee fi'om

when she established the account (i. e. the acoount number and the bank routing number).

She also routinely deposits money into the committee's aC.count from Representative

Schock's joint fundraising committee, Schock Victory Fund.

13. The witness stated that she did not recall needing to get approval from anyone else other

thanMr. Shearer in order to make the contribution. The witness did not recall speaking

to Mr. Bigger prior to making the contribution.

14. The witness state'd that Mr. Shearer did not explain why the contribution was. being made

to CPA. The witness stated that she did not speakto Representative Schock at that time

about the contribution. The \vitness did not recall if Mr. Shearer told her if anyone

requested that the contribution be made.

15. TIle witness stated that she is not sure why Mike Bigger ofthe 18th District Central

Republican Committee did not make the contribution to CPA online.

16. The witness stated that after she made the contribution, someone from CPA called or

emailedher and told her that it would take a significant amount oftime to process the

'payment online atld asked whether a wire transfer could.be made.

17. The witness was shown an email from Hannah Christian of CPA to the witness, dated

Mat'ch 16, .20 12 (CPA 000003), The witness identified the email as the communication

MOl - Page 2 of3 OFFICE OF CONGRESSIONAL ETHICS

CONFIDENTIAL


she received about the refund of the online payment and a request for a wire transfer

instead due to the delay in processing the online payment.

18. The witness called Mr. She.arer to tell him about the ne:eq for a wire transfer. She stated

that she was not authorized to make a wire transfer.

19. TIle witness stated that Mr. Shearer contacted Mr. Bigger for him to make the

cOlltribution from 18th District Central Republican Committee to CPA via a wire transfer.

20. The witness told the OCE that she does not know Rodney Davis and never communicated

with him.

TIlis memorandum waS prepared on July 31, 2012, based on the notes that the OCE staff

prepared during the interview with the witness on July 26, 2012. I certify that this memorandum


Kedric L. Payne



EXHIBIT 12

CONFIDENTIAL


INRE:

REVIEW NO.: DATE: LOCATION:

TIME: PARTICIPANTS:



Representative Schock's Chief of Staff 12-9525 July 20, 2012 425 3rd Street, S W Washington, DC 20024

4:30 p.m. to 5:10 p.m. (approximately) Keclric L. Payne Omar S. Asmnawy

Robed 1<. Kelner Derek Lawlor

SUMMARY: The witness is the Chief of Staff for Representative Aaron Schock. The OCE requested an interview with thewithess on July 20, 2012, and he consented toan.interview. TIle

witness made the following statements in response to our questioning:

1. The witness was given an 1'8 U.S.C. § 1001 waming and consented to an interview.

2. He refhsed to sign a written acknowledgement ofthe warning that his statements are


3. 'TIle witness is currently the Chief of Staff for Representative Schock. He has held that position for about three years and a half. Before that, the witness was Representative

Schook's catnpaigtl manager. Pt'ior to serving as Representative Schock's campaign manager, the witness worked as a campaign manager for other oandidates.

4. The witness also currently works on Representative Schock's campaignconunittee, in atl

"unofficial" oapaoity .

.5. In addition to working for Representative Schock, the witness has consulting contracts with two other non~federal oampaigns. Also, hemay consult on state or federal campaign

"infol1nally. "

6. TIle, witness is the Vice-Chairman of the Peoria County Repliblican Central Committee.

7. When asked if he consulted on Representative Jolm Shimkus' oampaign, the witness said no.

MOt-Page lof 5 OFFICE OF CONGRESSIONAL ETHICS

CONFIDENTIAL

Subject to the Nondisclosure ProvisionsofH. Res. 895 of the 110th Congress as Amended

8. When asked if he works with the 18th District Republican Central Committee ("18th

District Committee"), the witness said no, but that he is frien~ds with the Chairman of the 18th District Committee, Mike Bigger, and they ''talk politics" regularly. When asked to clarify what ~'talk politics" means, the witness said that people ask him what they should do on their campaign to ,;yin. Resaid that with Mr. Bigger, it is different. They speak about the state of play regatding campaigns, \"here "things are going," and patty leadership.

9. When asked if there is anyone else affiliated with the 18th District Committee with whom he communicates, the witness explained that the Chairperson onhe Peoria County Republican Central Committee is associated with the 18th District Committee.

10. The witness does not have an official title for his wotk on Representative Schock's campaign. He is an "unofficial political advisor. " When asked what kind of advice he provides, the witness responded that "it varies." If invitations to events are received, the witness will give his opinion on whether it is important for Representative Schock to

attend.

11. The \~Iitness also lets Representative Schock know how candidates are doing and advises Representative Schock on his political future. To a lesser extent the witness also advises Representative Schock onto whom to contribute money. Most of the time Representative Schock will "runsomethitig by"the witness.

12. When asked if he works on fundraising for Representative Schock, the witness said that he does 110t really do that -that the most he does is consult with Representative Schock on who v,'ould bea good speaker to bl'ing backto Representative Schock's district.Whetl asked ifhe vets people asking for a contribution from Representative Schock's campaign and PAC accounts, the witl1ess teplieg, "notfi-equent, hut yes."

13. The witness knows Mr. Rodney Davis. Mr. Davis is a candidate fat Congress, but the witness has k110wn Mr. Davis for about 901' 10 years. Before running for Congress; Mr. Davis was the Executive Director onhe Illinois State Republican Party. He also wotked for Representative Shimkus, however the witness did not remember Mr. Davis' title. He did tecall that Mr. Davis was "number two" at the district office. Mr. Davis also worked for Representative Shimkus' campaign. The witness did not recall Mr. Davis title, but described him as a "senior campaign persoh."

14. TIle last time the witness communicated with Mr. Davis wasatthe end of June wheri Mr. Davis called to teU the witness what Mr. Davis' "fundraising numbers" were going to be. When asked if he and Mr. Davis discussed the OCE investigation, the witness stated that in May of this year he let Mr. Davis know the OCE asked to speak with him. When asked for Mr. Davis' reply, the witness said he did not remember him saying anything


CONFIDENTIAL


dit'ectly. Mr. Davis "mostly just took note ofit." When asl.ed why he told Mr. Davis

about the OCE investigation, the witness stated he told him because "I'd asked for the

wire itlformation for CPA." When asked what the "wire transfer" had to do with the OCE, the witness replied that they wete talking about "our support of Representative

Kinsinger" and that there "were other things going on about that."

15. According to the witness, Mr. Davis seemed mildly surprised. The witness did not tell Mr; DI.I-vis to not speak with the OCE.

16. The. witness ~sked ML Davis for the wire infollnation for CPA because Mr. Davis "knew

everyone" and the witness thought he would have the infonnatioll. The witness said that

he needed it because Mr. Bigger asked the witness to get it.

n. Representative 'Schockl.l-Iso ·asked if the witness could send the wire transfer infoll11ation to David Hel1'o.

18. According to the witness, Mr. Bigger contacted the witness to ask for the wire transfer

info11llationafter Mr. Bigger and Representative Schock had a conwrsation. This conversation OCCUlTed about eight o1'nine days priOl,to the Kinsinger primary. Mr.

Bigget and Representative Schock met in 111inois and Mr. Bigger told Representative

Schock that he wanted to contribute to CPA if the money could be used to help Representative Kinsinger.

19. Representative Schocktold the witness about this conversation a day or two afterwards

20. According to the witness, Representative Schock did not ask Mr. Bigger to contribute.

21. Mr. Bigger wanted to make a contribution to CPA from the 18th District Committee account.

22. The witness knows. Mr. David Hen'o - he is a major dOllor in Chicago to many

Republican candidates.

23. On or about March 15,2012, Representative Schock had a conversation virith Mr. Heno.

When the conversation was over, Representative Schock said Mr. He11'owanted to make a contribution to CPA and .asked the witness to get the wire transfer infonllation to Mr. Hen·o.

24. The witness believes this conversation took place in Illinois, but he was not with

Representative 8chockat the time. The conversation between Representative Schock and the witness took place over the phone.

25. The witness provided Mr. HelTo with the wire transfer for CPA.

MOl-Page 3 ofS OFFICE OF CONGRESSIONAL .ETHICS

CONFIDENTIAL

Subjecttothe Nondisclosure Provisions ofH. Res. 895 of the 110th Congress as Amended

26. The witness did not know if Representative Schock asked Mr. Heno to give a

contribution to CPA 'as it was a private conversation. When asked if Representative

Schock provided the witness with any additional infolll1ation, the witness stated that Representative Schock told him that Mr. Hen-o was going to make a contribution and to

get the wiring information to him. Representative Schock did not tell the witness how much Mr. Henowas goingto contribute.

27. Mr. Rodney Davis did not a"lk the witness to contribute to CPA.

28. The witness was shovi'll an email from Rodney Davis to the witness, dated March 14,

2012 (SCH_000047).

29. The witness was asked if he had seen the email before. He replied that he thought the

email Vilas the one Mr. Davis sent to him earlier so that the witness had the wiring

information for CPA.

30. The witness was shown an email from him to Representative Schock and David HetTo,

dated March 12,2012 (SCH_000043).

31. The witness hlld seen this email previously. The email address containing "DGH" is the

email for Mr. HelTo.

32. When asked the significance ofthe staienlent in the email about the link, the witness said that "Can do" refers to Mr. Herro. !twas to let Rep1"esentafive Schock know that the

witness followed up on Representative Schock's request.

33. The witness could not recall if he refelTed anyone .else to CPA for the purpose of making

a contribution.

34. The witness is fairly sure he did not ask anyone else to contribute.

35. When asked nhe or anyone elsellsked Representative Eric Cantoroi' anyone on

Representative Cantor's staff to make acontdbution to CPA, the witness replied that after

Representative Schock had a conversatiori with Representative Cantor, Representative Schock asked the witness to get in touch with Mr. Rob Collins "to see what they can do."

36~ When asked "to see what they can do" meant, the witness said it meant that Purple

Strategies or the Young Guns Network might help Kinsinger in some ,;.,ray.

37. The witness called Mr. Collins and Mr. Collins told the witness that he would see whathe could do. The witness told Mr. Collins that the race was very close. Mr. Collins replied to the witness - "ok let me see v,dmt I can do."

Mor -Page 40f5 OFFICE OF CONGRESSIONAL ETHICS

CONFIDENTIAL


38. A few days afterwards Mr. Collins called the witness and said that they w.ere going to do

their own radio spot. When asked to clarifY if "they" meant Purple ,strategies or Young Guns, the witness said he did not know.

39. When asked what the relationship was between Purple ,strategies and Young Guns, the

witness said he did not know.

This memorandum was prepared on August 1, 2012, based on the notes that tlw OCE staff

prepared during the interview with the witness on July 20, 2012. 1 cel1ify that this memorandum


Omar S. Ashmawy

Staff Director and Chief Counsel


EXHIBIT 13

linageU 11931607888

FEe FORM 1

1. NAME OF COMMITTEE (in full)

i I I I , , I , I

ADDRESS (numberand streel) ,.. (Check if address is changed)


(See instructions)

(Check if name is changed)

Example: l.ftypying, type ~overlhe lines

" " I' I " " 2470 Daniells Bridpe Rd Ste. 121 I I I II I I I I I I I I

I , II

CITY ...

COMMITTEE'S E-MAIL ADDRESS,(Pleaseprovideonly (;.nee-mail address)

(Check if address is changed)

1 ..... <fPdscompliance.com . I II I I I I I

I I , I I , II , I I ,

COMMITTEE'S WEB PAGE ADDRESS (URL)

,(Check if a:!dress is changed)

2.. DATE

3. FEC IDENTIFICATION NUMBER

4. IS THIS STATEMENT

I

NEW (N) OR AMENDED (A)

I cer.tify that I have exanlin.ed Ihis Statement and to the best 01 my knOWledge and belief itis b'ue, correcl and complete

Type or Print Name of Treasurer Paul Kilgore

Signatured Treasurer Electronically Filed by Paul Kilgore Date

06/10/2011 11 :08

Oflice use only

I

ZIP CODE ..

"

NOTE: Submission oHalse, erroneous,or incomplete information may subject the person signing this Statement to the penalties of.2 U.S.C. §437g.

ANY CHANGE IN INFORMATION SHOULD BE REPORTED WITHIN 10 DAYS

Office For further Information contact: FEe FORM 1 Use Feder.al Election Commission Only Toll Free 800-424-9530 (Revised 02/2009)

Local202-694-1l00

Image# 11931607889

FEG Form 1 (Revised 02/2009)

5. TYPE OF COMMITTEE (Check One)

Candidate Committee: r-!

(a) L,,,,J This committee Is a principal campaign committee. (Complete the candidate inf.ormation below.)

Page 2

(b) This committee is an authorized committee, and is NOT a principal campaign committee. (complete the candidate infbrmation'below.)

Name of Candidate

C.andidate Party Affiliation

I I I I I

Office So,lght: House

I I I I I I I

Senate President

(0) This committee supporls/opposesonly one candidate, and is NOT anauthorizedcommiUee.

Name. of

Candidate

Party Committee:

I I I I I

(d) This committee isa

Political Action CommittlM.(PAC):

I I I

(National, State (or sUbordinate) committee of the

State

District

I I I I

(Democratic, Republican,etc,) Party.

(e) ~~"W:. This committee.ls aseparate.segregated .lund. (Identify connected organization on line 6.) Its connected 'organization is a: >--;'!«ti<;,';

(I)

GOi-poration Corpol:ation w/oCapital Stock Labor Organization

Membership Organization Trade Association Cooperative


This committee supports/opposes more. than one Federal candidate, and is NOT a separate segregated fllnd or party committee. (i.e.,nonconnected committee)


In addition, this committee is a Leadership PAC. (Identify sponsor on line 6.)

Joint Fundraising Representative:

(g)

(h)

This commiitee collects contributions, pays fundraising l3xpenses and disburses net proceeds for two.or more political commiitees/organizations, at least one of which is an authorized committee of .afederal candidate.

This committe.ecoliects contributions,pays fundraising expenses and disburses net proceeds for two'or more political committees/organizations, none of which is an authorized committee of a federal. candidate.

Committees Participating in Joint FundraiseI'

I Schock for Conaress 1 .. I II I I I I I I I I I .FEC IDnumber

GOP Generation Y Fund 2. I I I I I II I I I I I FEC ID number

I 18th District Republican Central Committed 3. . I I I I I I r I I I I I I I I I [ I I ] FEC ID number

Image# 11.931607890

FEC.Form 1 (Revised02/2009)


Schock Victory Committee

Page3

6. Name of Any.conneoted Organization,Afflliated .committee, Joint Fundraising Representative, or Leadership PAC Sponsor

I N~nl I I I I

I I

Mailing Address ! I I I ! I I

I I I I I I I I I I I I I I I I I I I I I I I I

LLJ I-I

CITY. STATE. ZIP CODE A

Relationship:

I

Connected Organization Affiliated Committee Joint Fundraising Representative Leadership PAC Sponsor

7. Custodian of Reoords: Identify by name,address, (phone number -- optional), and position of the person in possessioriof born mittee books and records.

Full Name I I II I I I I II I I I I I I I I ! I r J I I I I I I I I I I I I

Mailing Address

Title or P.osltion 'f CITYA STATEA ZIP CODE"

Telephone number

8. Treasurer: List the name arid address (phone number -- optional) ·01 the treasurer of the committee; and the name and address·of any designated agent (e.g., assistant treasurer).

Full Name of Treasurer

Mailing Address

Paul Kilgore

Title or Position.,

Treasurer

2470 Daniells Bridge Rd Ste. 121

Athens GA 30606 -----

C.lTY A STATEA ZIP CODE"

Telephone number 706 534 _ _

Image# 11931607891

FEe Form 1 (Revised 02/2009) Page 4

Full Name of Designated Agent

Mailing Address

Title or Position Y CITY A STATE. ZIP CODE A

Telephone number

9. Banks or Other Depositories: List all banks or other depositories in which the committee deposits funds, holds accounts, rents safety deposit boxes or maintains funds.


PNC Bank I I I I I I " I I I I I I I I I I I I I I I I

Mailing Address 301 SW Adams St

" I I I I I I I I I I I I I I I I I I I I

I I I I I I I I I I I I I I I I I I I I I I

I ~e?rif I I I I I I I I I I I W I 61 6q2 I-I

CITY • STATE. ZIP CODE


I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I

Mailing Address I I I I I I I I I I I I I I I I I I I

I I 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1

I

I

I

I

,6,

I

I

I

I I

I I

I I I

I

I I I

1 I

I 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 ,--I --,1----,-1----,--1 --,-I -JI - LI -JI----,-I----,--I --'

CITY. STATE .. ZIP CODE A

EXHIBIT 14

Fwd: Contribution info Page 1 of 1

From: Rodney Davis s.org>

To: Steve Shearer'· 1 ====~;~~ Co; Craig RObarts·~

Subject: Fwd: Contribution info Date: Wed. Mar 14, 2012 2:49 pm

Attachments: CPA_prospeclU!U~r\(:Uepfyjorm.pdf (510K). CPA .. YVirlng_'nstructlons.pdf (73K)

Begin forwarded message:

From: "Jamie Story" 1!cltjzenleaderalliance.org> 4, 2012 1:20:10 PM COT

To: ~ ~~~; eel ~ Subject:Contflbution Info

Rodney, Thank you so much for helping us out. !'lIlet you know as soon as ( hear from John, our head Republic&rl strategiSt.

In the meantime. I've attached two documents: one is a short prospectus with a contribution reply form at the end {ideally, this completed form would accompany any checks that are mailed}. I'm also attaching wiring instructions. Finally, the easiest thing might be for people to donate online here: httQs;LLse(;ure.Qi!;yx.com/donate/FnTy7rRg!Campaign~for·Primary~ l\~countabmty/. Online contributors can either pay by eCheckor credit card (sCheck is essentially the same as wiring).

!'Il be in touch as soon as I hearfromJohnre: TV/radio buys. Thank you again!

"'Jamie

Jamie Story President

... ~, ........ _._._,_The._g.!!.~rLb~ader Alli~!!.f~ ....... __ .. , ___ .... ,_._ ..... _, .. ~. ___ .,_ ... ____ ...... __ "" .. ~_"" .. __ ",,,.,~,. ____ ,,_,,,_,,,,,,,,,,,,,,,~,, .. ,,,_._" __ "~.~_""' .. "~.".'''.'''''' P.O. Box 27:1.33 . Houston, Texas 712.27 •••• -Cell

SCH..Q00047

http://maiI.aoLoom/362.5Sw 111/aol~6/en~us/man/Pl'intMessage.aspx 6/512012

EXHIBIT 15

From: Jt)nathanMartin~@cet$:rusinQ.corrr> Subject: A$: $25,0.00 .

Date; March t6,20t2 10:02:10 AM COT to: Hann~h ChdstJan ~amance4selfgovemance;org> CO! _asappubHcaffaJrs.oom1i ". ,JamieStory

_@citizeni$aderaUlance,org>

On Thu, Mar lSi 2012 at:8:3tH~1VtfJonathan!\1artin ~qic~te:l:'tlsinc.com>wrote,:

r tJ!luthanMartin J.. .... " . .'

, (c)

I" 800.878;6742 (0

I On M;;'u"15 2012 ,'It 5~12 PM Hannf,'tliChtisUall <: .. .. . . . f... t .. I. . . ." ..

_QaiHfuiPtt4se.lfgtJverriance,org> ,~rr.ote:

I r spoke wHhTnl1lanot long i)go. CPAwiU be receiv~a wire for $25,000 totnorr6w. lwiH ref mid theanH:he contribtltibtt.

I Jonafrml1 w wiU you please Ietrne k110W wbenthe$2SK shows up 1.n .our ! . (1ccoU:nt?Td Hketo letTaniaRQ6w Wheh We receive It. "

, I ~~~'t.;b

Jonathan MartIn *C('terlls,. Ih(\ * Qffke269.544_ Di rbef843 A71_

CPA 000004 128 9525_0117

Cell 1739M<.lyhtHik HfghWtty; Sttite 'fw946 ICharl~ton, SC 294i2 \Vww~ctiterl~slnc;cO~l· *Metnber,Chath:stonM$tfo Chanlberof Conlmerce *

Ci rCt1h)t2~Q ~i isclo$ure: Th~ intetTh11 Revenue ServicerecenUy 1Ssued regulations that i'equlr(! wi'ittenacivice regatding h'iX matterS tonieet v~iydetailed nnd cotii.piehensi'Vereqttitements before i:tcan bereHed upon byataxpityet to l1voidpemltties that might t~pp:iy if the tax ben~flts or te$tll~s discUssed in the. doet:amentare disanowed.C()~np'Iiafice·Wi r1\ these t~g(;:rous$tm'ldar{1s l:rnd reqtdft:!111eiltsexceeds lhe sc(>peor this engagement ConB(~quenHYtthe analysis al"ld a~vicecontalned in this documerttregar<.Ung redeialtax matters is 'not intended to be used, ~nd j,t'tay ·ryo.t bt~reUed npoi1 by yottjfor the purposfi of av{}idingalW federal tax penalty~

CPA 000005 12-9525_0118

EXHIBIT 16

E.rJ.v.i I .Q.19.~fiWJn4o"~l

$I.lbj$ct: R~:Cbntrl~utlOO From: tallia h~ff ~@~aronsefi\)ckic9m> Pat(f~ ·Wed, M~r 14, 2012 4;31 ,pm

To: Wan!1$hChrlg;tian ~eampl¥iGn4ptimal'\Yt!leCoontabmty.~rg>

i Hi Haflnafl, YoU can addtessfhe letter to IhaH3{f, DletridtCommiltee,. ~1'Il<e6Ig~ar tsihe treaSU!<Ilf ofii'!at committee .

. Thanks, • T~rlia

On Wf:Jd, Mar 14, Z012t~t4:14 PM. Hannah Ohristian· ..... Il. g~tgtn:ttiJ,il~1lli!l:1~tft;;f,l!;yjlif:<~K'.tlK~i~~jji~;?I,~rf.l:;; viro1e: Hello. Tonyaj

)(!jl)"lle StorY asked that I contact you, l~mth:e D~velcpment Coordinator for CampaIgn for P.rfman; AccQwnt~bHlty (CPA), ram tryfogto send a thank YOll letter fiG!" thecontribli:tioh frorr'; th:e 18tb. Congresslon~r District Repuhlitatl t."erttral Committee, I'm notsul'e \t,,{ho i wlt!1 the organizatlOll, I should address this to. .

Can you help with thiS?

Thank you, Harrn:ah

T~lnia Hoerr Campaigt'JDlrector ·Schockf{)r~C(jng.re$s POBox: 10555' . P?oria.1 iL6161:2 309. 69Z" Offlce 30;9J$93.9~80 Fax

1/1

CPA 000001 12-9525_0120

EXHIBIT 17

· SUbJaei: Wln~'rrall$fQtReeeiV~d From: "jHarin~h¢~ri~tia!1k __ @eaml'algn4prim~tyal:l~~unt~bmtY,Qr9'> D~t~: flrl,Ml'ir16j201~10:14am

To; _@:J\ai'.QnschQi:lk>¢~m

Good mOHi;l'lg T~mJ~,

O(Jrac.(;oun~~t~t n~tlf{?~r.i n'1€ th;~t~h.e.$?:5190b.cohtrihutI9n WqS'~\i;:~hf,f$(: thts.I'rl6n~J!rtg. A,haVe1iJ:mked P\ldX to re.fi..n1dt;h;:~ ~%'{f:iin~ai' c;Wtl!rr;!t<ut!:Qtr t<:>t;hu, .i$:tl) CQt?g ~f1$$bi1)Jx! t;}~t:r!c:tl w.t~*~ t4Id~:hf:;t: tr'lBY llav~a VfJf',/slow P!"~tf;')$;~'Wh~~f'l it(;.om~s to refundingo:(1!1l'1<a: ;(fjrtifL Pl'e~$elat rrW~krio\A"lfiy~~u'dci not l'e·cetvea refund by next Thursday. 1 wlll b$ mot¢ t.i:ltiliW!!P\;lV·tCl pal! the#~ ~n(l Bl~e v.ifh(:;\N;~ th6 rncney is,

CPA 000003 12-9525_0122

EXHIBIT 18

CONFIDENTIAL

----- ----------------------------------------------------Subject to the Nondisclosure Provisions of H. Res. 895 of the 11 Oth Congress as Amended

INRE: REVIEW NO.: DATE: LOCATION:

TIME: PARTICIPANTS:



Donor 1 12-9525

July 25, 2012

Two North LaSalle Street Chicago, IL 60602

9:30 a.m. to 9:50 a.m. (approximately) Kedric L. Payne Omar S. Ashmawy

SUMMARY: Donor 1 is the Chief Investment Officer for International Equity of Han' is Associates L.P. The aCE requested an interview with Donor 1 (the'\vitness") on July 25,2012,

and he consented to an intervievil • The witness made the f0110wing statements in response to our questi011ing:

1. The witness was given an 18 U.S.C. § 1001 warning and consented to an interview. He signed a written aclrnowledgement of the warning, which will be placed in the case file in this review .

2. The witness is currently employed with Han'is and Associates where he is the Chief Investment Officer for International Equity.

3. The witness told the OCE that he has known Representative Aaron Schock since 2008.

He met Representative Schock during one of his campaigns for pUblic office.

4. He estimates that lw speaks with Representa:tiveSchock a:ppl'Oxirnately once ortwice every six weeks during an election year. The conversations generally relate to the

witness organizing fundraisers for Representative Schock or the witnesscol1necting Representative Schock with other elected officials.

5. DUl'ing ilOn-election Years, the witness estimates that hespealcs with Representative

Schock once every six months.

6. The. most recent fundraiser thatthe witness heldforRepresentativeSchock ,;vas around

March 2012.

7. The ,,,itness most recently communicated with Representative Schock during a dinner on or about July 21, 2012. The ,;vitness stated that he and Representative Schock did not

discuss the OCE matter.

MOl -Page 10f3 OFFICE OF CONGRESSIONAL ETHICS

CONFIDENTIAL

------------------------------------------------.----------------------Subjeot to the Nondisclosure Provisions ofH. Res. 895 of the 110th Congress as Amended

8. TI1e witi1essstated that durii1g the past month he spoke with Representative Schock's

attomey who is located in Washington, DC about the OCE investigation. TI1eatt0l11ey asked the witness about his contribution to the Campaign for Primary Aocountability

("CPA").

9. The \;\,Iitness recalled that on or about March 11, 2012, he teceived a phone call from

Representative Schock. Representative Schock asked him if he would help with

Representative Kinzinger's race in Illinois as it was going to be a tight.race.

10.TI1e. witness told Representative Schock that he would help. Representative Schock said

he would forward him information on how to help.

11. The witness told the OCE that Representative Schock did not request any amount of

support for him to give.

12. TI1e witness stated that he received an email from an email address for "GOP Steve".

The email fon~larded infOlTI1ation about CP A.

B.U1e witness. was shown an email from Steve Shearer to the witness and Representative

Schock, dated March 14, 2012 (SCH000043). The witness recalled that this email is

what he received concemingCP A.

14. After he received the email on March 14, 2012, he contacted Jamie StorYQf CP A to ask

to see the television commercial that ePA planned to broadcast related to Representative

Kinzinger's primary election.

15.TI1e witness told the OCE that he wanted to view the commercial and approve it before

contributing to CPA. The witness viewed the commercial and.approved.

16. Ms. Story informed the witness that CPA wanted to raise $100,000 in three days. Based on this fundraising goal, the witness decided to contribute $35,000 to CP A.

17. TI1e witness told the OCE that he solicited the foil owing individuals to contribute to CPA

to reach the $100;000 fundraising goal: Anne Griffm; John Canning, al1d Ron didwitz.

He stated that he told each of these individuals that he was contributing $35,000 and he

asked if each could help reach the $100;000 goal.

18. TI1e witness explained that the "David HetTo Tmst" is his hank account and he is the sole

member of the Tmst.

19. The witness told the OCE that he met Rodney Davis for the first time in July 2012 and he

has not discussedCP A with Mr. Davis.

20. The witn0ssdoes not know Rob Collins.

MOl-Page 20f3 OFFICE OF CONGRESSIONAL ETHICS

CONFIDENTIAL

Subject to the Nondisclosure Provisions of H. Res. 895 of the 110th Congress as Amended

21. The witness stated that he has never met RepresentativeShirilkus to the best of his

knowledge.

22. TIle witness received a phone call from Anne Griffin' sattomey, Kelmeth Gross, within the 24 hours preceding his interview vi/ith the aCE. Mr. Gross asked him questions about the witness' contribution to CP A and communications with Ms. Griffin.

This memorandum was prepared on August 1,2012, based on the notes thatthe OeE staff prepared during the interview with the witness on July 25,2012. r celiifythat this memorandum contains all peliinent matter discussed with the witness on July 25, 2012.


Mor -Page 30f 3 OFFICE OF CONGRESSIONAL ETHICS

EXHIBIT 19

Fwd: Contribution info, SUPER PAC Kinzinger~Manz\.tno

From: Steven Shearer To; aarPh$chock

Subject: Fwd: Contribution info, SUPER PAC I<inzinger-Manzullo Date: Wed, Mar 14, 2012 3:07 pm

A ttachments: CPAJ)ro$pectu$jjnd~reply _form.pdf (510K), CPA_ Wirlh~Ul1$truction$.pdf (73K)

Can do an eleotroniccheokwlth the link below, or wire.

---.original MeISSage·--·· From: Rodlv~y To: Steve Shearer Co: Craig Roberts Sent: Wed, Mar 14, Subject Fwd: Contribution info

Begin forwarded message:

From: "Jamie Story" 1l!citizenleaderalliance.org>

1~~4~~' ~20,12 1:20:10 PM COT .~ ~!

Rodney;

Page 1 ofl

Thank you so much for helping us out I'll let you know as soon as I hear from John, our head Republican strategist.

In the meantime, lIve attached two documents: one is a short prospectus with a contribution reply form at the end {ideally, this completed form would accompany any checks that are mailed}. I'm also attaching wiring ihstructions. Finally, the easiest thing might be for people to donate online here: https:!Lsft!c,l.jre.Eirvx.com!donate!FnTy7rRgLCam!;!algn·for-.Primary.AccountabHitv!. Online contributors can either Ilay by eCheCK or credit card (eCheck is essentially the same as wIring).

I'I/ be in touch as soon as I hear from John ra; TV/radio buys. Thank you again!

Jamie Story President The Citizen Leader Alliance P,O. Box 27133 Houston, Texas 77227 ____ -C911

http://mail.ao1.com/36294·111/aol-6/ en-us!mailfPrintMessage.aspx SCH·000043

616/2012

EXHIBIT 20

CONFIDENTIAL

Subject to the Nondisclosure ProvisionsofH. Res. 895 of the 110th Congress as Amended

INRE: REVIEW NO.:

DATE:

LOCATION:

TIME:

PARTICIPANTS:



Donor 2

12-9525

July 25, 2012

155 North Wacker Drive

Chicago, IL 60606

3:00 p.m. to 3:20 p.m. (approximately)

Kedric L. Payne

Omat S. Ashmawy

Kenneth A. Gross

Patricia M. ZVieibel Adam Cooper

SUMMARY: Donor 2 is the Managing Partner of Aragon Global Management. TheOCE

requested an interview with Donor 2 (the "witness ") on July 25, 2012, and she consented to an interView. TIle witrfess tllade the following 'statements in reSpoilse to our questioning:

1. The witness was given an 18 U.S.C. § 1001 waming alid consented to an interview. She signed a written acknow ledgementof the waming, which will he placed in the case file in

this review.

2. The witness is the ManagingPartller of Aragon Global Management.

.3. She told the OCE that she has known Representative S chock since sometime after 2010.

She met him when a fundraisingcoordinator asked to bring Representative Schock by to

introduce him to the witness.

4. The witness and Representative Schock tarely communicate. Shel110st recently communicated with Representative Schock around May 2012 at a fundraiser for

presidential candidate Mitt RonUley.

5. She estimated that she has communicated with him on feviler than teli occasions over the

past two years.

6. She stated that she does not know any of Representative Schock's congressional or

campaigll staff, inCluding Steve Shearer.

7. She first became familiar with the Campaign for Primary Accountability ("CP N') when

she was coritacted by David Herro in March 2012.

MOl - Page 10f2 OFFICE OF CONGRESSIONAL .ETHICS

CONFIDENTIAL

Subjectto the Nondisclosure Provisions ofR. Res. 895 ofthe 110th Congress as Amended

8. She believes Mr. HelTo coritacted her by email. He explained:to her who CPA was, that they were involved in supporting Representative Kinzinger in his primary election,8nd that he was going to make a contribution to CP A.

9: She asked Mr. HelTO how much he was contributing and he told her $35,000.

10. She told the DCE that she did not discuss contributing to CPA with Mr. Shearer, Representative Schock, or Rodney Davis.

11. She does not know Robert Collins.

This memorandum was prepared 011 July 31,2012, based on the notes that the OCE staff

prepared during the inteniiew with the \vitness on July 25, 2012. I certify that this memorandum contains all pertinent matter discussed with the witness on July 25, 2012.



EXHIBIT 21

CONFIDENTIAL

-,---Subject to the Nondisclosure Provisions of H. Res. 895 of the 11 Oth Congress as Amended

INRE:



REVIEW NO.:

Lobbyist Donor 1

12-9525

DATE: July 17,2012

LOCATION: 425 3rd Street, SW Washington, DC 20024

TIME: PARTICIPANTS:

1:07 p.m. to 1:56 p.m. (approximately) Kedric L Payne Paul 1. Solis

SUMMARY: Lobbyist Donor 1 (the "witness") works for the American College of Radiology

Association. The OCE requested an interview with the witness on July 17, 2012, and he consented to an interview. The witness made the following statements in response to our

questioning:

1. The witness was given an IS U.S.C. § 1001 Vlran:1ing and consented to an interview. He signed a written acknowledgement of the warning,which 'Nill be placed in the case file in

this review.

2. The witness ise111ployed with the Anlericati College of Radiology Association ("ACR"). He is the Director ofRADPAC and Political Education. He stated that 'he will eventually volunteer with Bome campaigns thisyeat~. ACRemploys tlu-ee lobbyists in-house. The

witness is a registered lobbyist.

3. His stated that his job duties for ACR are to raise money for RADPAC from ACR members mid to spelid the money on various political campaigns.

4. The following two employees in ACR's govenunent relations group repol1: to the wit11eSs: Heather Kaiser and Melody Ballesteros. The witness reports to Cindy MOratl and Josh

Cooper.

5. The witness told the OCE that he primarily makes the decisions on RADPAC contributions and he considers various factors. He considers whether the campaign being suppOlted is for a congressional committee with jurisdiction over ACR. He also considers the relationships that he, staff; and ACR members have with Members of Congress.

MOl -Page 1 of 4 OFFICE OF CONGRESSIONAL ETHICS

CONFIDENTIAL

Subject to the Nondisclosure Provisions of H. Res. 895 of the 110th Congress as Amended

6. He estimates that he receives approximately 80 fundraising requests and invitations per

day, which he reviews. These requests ate usually emails or phone calls. Thephone

calls generally are from the chiefs of staff of Me111bers of Congress 01' their fundraisers.

He is also contacted directly by Members of Congress,but not frequently. He also

receives solicitations via facsimile.

7. The witness stated that he is not very familiar with the Campaign for Primary

Accountability (':CPA") and he does not know anyone who is employed with CPA. The

witness stated that he does 110t really agree with everything CPA does.

8. He told the OCE that he is aware that RADPAC contributed $5,000 to CPA in March

2012. He believes. that som.eone for another organization, 110t CPA, requested that

RADP AC contribute to CPA. He stated that someone from Young Guns Maj ority

Victory Fund ("Youn:g Guns") may have requested that RADP AC contribute to CPA.

9. The witness has known Representative Aaron Schock since the fall of 2010. He

communicates with Repres.entative Schock a few times permonth. The witness stated

thatthe communications generally involve fundraising. The witness told the OCE that he

also personally knows Representative Schock's ohief of staff, legislative director,

legislative aide, and fundraisiilg team.

10. The witness stated that he last talked. to Representative Shock a week or two ago and has

had no conversation with Representative Shock about the OCE's review.

11. The witness stated that he knows Rob Collins and that Rob Collins is affiliated with

Young Guns and w01:ked for Representative Cantor.

12; The. witness was shown an email frQm Rob Collins to the ,vitness, dated March 15,2012 (CP AOOOO 18). He stated that he does not remember the conversation referenced in the

email between Mr. Collins and him.

13. The document n~fl'eshed the witness' recollection and he told that OCE that he likely

spoke to Mr. Co:11ins the moming of Match 15. The witness stated that he guessed he

asked "how can I help?" with the primary election of Representative Adam Kinzinger

and then someone told him to get in contact vi/ith Rob Collins.

14. The \vitness described Mr. Collins as the facilitator putting him in contact with CPA such

that ACR could make a contribution to OP A. The witness believes that he reached to Mr.

Collins to ask about other ways the witness could suppOli Representative Kinzinger

because ACR had already made the maximum contributions to Representative

Kinzinger's campaign committee.

MOl -Page 2 of 4 OFFICE OF CONGRESSIONAL ETHICS

CONFIDENTIAL

SubjecUothe Nondisclosure Provisions ofR. Res. 895 of the 110th Congress as Amended

15. TIle witness told the OCE that he does not believe that Representative Schock told him to .contact Mr. Collins. He stated that Representative Cantor did not ask hilT). to contact Mr. Collins. The witness knows Representative Cantor "a little hit" because it is hard to get more thana few minutes with him.

16. TIle witness was shown an email from him to Mr. Collins,copying Jamie Story ofCP A, dated March 15,2012 (CPA000011). \~Then asked why in the email he told Mr. Humes

"We'll do $Skand credit Schock," he stated that it is customary in ''the industry" to credit someone for a contribution. The witness stated that whether someone aSKs to be credited or not,"we want to give it to them." It is typically done for patty contributors.

11. He pt'ovided the aCE with a hypothetical exatnple ofa donor crediting a contribution to a Member of Congress. He described a Member·ofCongress requesting a contribution from ACR toanofher caillpaign, ACR making the contribution, ACRasking the campaign to credit the Member of Congress Who requested the contribution.

18. TIle witness told the OCE that altho.ugh he asked Mr. Collins to credit Representative Schock for the campaign, Representative Schock did not ask him to make the contribution.

19. He stated that he is not sure \¥hether he told Representative Schock that he credited him with ACR'scontribution tpCPA. In the past, he has infolmed Representative Schock about other :contributions that he credited to him.

20. TIle witness stated that he credited Representative Schock because he knew he was a close personal friend of Representative Kinzinger. He k11ew this through talking to the mell1bers at events and through conversation.

21. The witness also requested that RepresentativeS.chock receive credit for the contribution to CPA because he l'ecognized that Representative KiliZinger may learn of fhe contribution and the credit would help Representative Schock's relationship with

Representative Kinzinger.

22. He stated that Representative Schock had aske.d ACR to contribute to Representative Kinzinger' scampaign and ACR in turn contributed the maximum amount to

Representative Kinzinger's campaign for the primary and general elections.

23. TIle witness told the OCE thathe does .not remember whether Representative Schock told him to speak to Young Guns conceming supporting Representative Kinzinger's race. Although the witness stated that he may have discussed Young GutlS in general at some point \vith Representative Schock.

MOl - Page 30f 4 OFFICE OF CONGRESSIONAL ETHICS

CONFIDENTIAL

---------- -----------, Subject to the Nondisclosure Provisions ofR. Res. 895 of the 110th Congress as Amended

24. He has known Representative John Shimkus for approximately five or six years and he

communicate,s with him frequently when the witness travels tQ the Capitol. He also knows Craig Roberts and Chris Sm'ley, who are staffers for Representative Shimkus.

25. TIle witness stated that he initially met Rodney Davis in April or May of 2012. Mr.

Davis did nQt ask him contribute toCP A.

26. He has not conttihuted to the 18th District Central Republican Committee and has not

discussed the committee with Representative S.chock. He told the aCE that he does not

know of any 'affiliation Representative Schock may have with the committee.

27. TIle witness stated that he does not believe that he asked any individual or entity to contribute to CPA other than ACR.

This memorandum was prepared on August 3,2012, based on the notes tha1 the OCE staff

prepared during the interview with the v,litness on July 17, 2012. I celiify that this memorandum


l<.'edric L Payne


MOl - Page 40f 4 OFFICE OF CONGRESSIONAL ETHICS

EXHIBIT 22

REDACTED CPA 000017 12-9525.,.;0138

EXHIBIT 23

~rom:RobColllns{Purpfe Strategl~) III ......... ~rruAAtr.atgg!§;.v.9..ttd Se~ttThur$deyl .Ma~ 15,ZOlliO:24AM' Yo: BUMES, r~ Ce~ Jamte Sto~ <:: ~~jZ~nL~.§g§ta!l1at!f;~;.Qm> $ubjett~ .

Hey Ted:,

It wasgoQd to ta~ktb you today;g~tow i~ the YotltubeJimk fortheadthat Shimkus,Schock and Cantor hav~ ss~t moneykf. to stJpporHhat the Campaign. forPiimary Accountability· is runn!'hg, They afe 3527 organized super PAC. The maiJlng and wiringinrormatfori, is attached,j have aisocc'ooaridattaCl1ed'4emieStory'~t thePr~sldeht f(jrthe'Campalgn'for PrlmsryAcc(iuntability'lcontact: Information. if you h9veany qu~stroos about wh.~re or how to sendaoontrihutlQh. rhan~s for~he support. we rsaifyapprediateit,

Rdb

YouTube: http :I/\~j.Y:Q.,t;!ti:Ibg.po.P1f.wa}~r?v:::Jhbz;~~ 71E§;Q

~~amie S~dry Pr-es'!dent The Ci~izen Leader Aiiiante P"Q.8ox271$S

•H.O.us.t.on.,I., v.exi,a.'s 17'227

-Cel!

(see I\ttached nle;C?A .. 'pro$pect1JSi:."andJep~y_thr.m.pdtl [see nttached.fIle: CPA,_W!rhlg)tlstruct~0ns'P'<Hl '

Rob CoUins Partner Purnle Strategies

.............., .. M-~"""' ..... , , '" 'celi

CPA 000018 12m 9525_0140

EXHIBIT 24

t .....

From: Rob Collins (Purple Strategies) .I ••• ····@purp!estrategles.coml Sent: Thursday. March 15, 2012 10:60 AM '.fo·· -·-R~-Allefl-·-------'·-·~"·-"'~'·'·'·"· ,,-~ -~'-"-' ~,.' '.~~"'".''''-'-'''~''-.''''''''' , .. " ....

"'::Ati;~h'~~~~;-"--' '--, CPAj>rospectus_and,:,replyj"mi.pdf;' CPAjNirin9Jn~ini~tions.Pdf

Ray;....below is some infonnation for the super pac that is in that fL race. You want me to connect you with the super pac person today via email? ps-we dent need to do $100k as SD said we could, the other Members have done $25k, we shourd match that.

Hey Ted;

It was good to talk to you today. Below is the Youtube link for the ad that Shimkus1 Schock and Cantor have sent money in to support that the CampaIgn for Primary Accountability is running. They are a 527 organized super PAC. The mailing and wiring information is attached, 1 have also ected and attached Jamie Storyls, the President for:the Campaign for Primary Accountabilltyt contact information if you have any questions about where or how to send a contribution. ThankS for the

,~SUP&lOrt1 we really,appreelafe,fu' "",,,,

Rob

YouTube: f1ttp:llwww.youtube.com/watch?v;;::lhQzMs7iF50

Jamie Story President The Citizen Leader Alliance P.O. Box 27133

Texas 77227 -Cell

[see attached file; CPA....Prospectus_and""i"l'eply_fonn.pdf] rs~e attached Cde: CPA_ Wirln~LInstructions.pdf]

Rob Collins Partner,

cell

1

EC-OCEOOI

12-9525.,.:0142

CAMPAIGN

Thank you for considering contributing to the Campaign. fur Primazy Accountability (CPA). Please refer to the infOrn1lltion below tfyou wish to wlra funds. If you. have anyquesnons; please caJJ. Hannah Chlistian at 281~796'-.

~~~~'~'~"~",._."""" ••• ..m, •• .... ~i~ng;ln~!7~pns!h"......... '."

Campaign for PrImary Accountability 3900 Essex Lane, Suite 575

· .. Houston. !fX,·17027~S.17S Phone: (828) 777 __

.Acmunt.Number4~~~!!!==I.. Routing Number (vviresJ! (paper and electronic (AH~): ""

Contributions are.not tax deductlble •.. Campaign.for.Primavy·Accountability PAG,ts registered 'with thePederal Election Commission as an independent expenditure committee and your contrihutionwiU be used in connection with federal electio.ns~ .Unlimited. conttibuuons.[:rom..u.s .. .c4t1zensi eorporations and· other. organizations are permitted and accepted, except that we cannot accept t:onttibutiolls from foreign nationals, fprejg:n c.or,porat1ons. federal government contractors and national banks. Federnllaw reqnires us to use our best efforts to collect l:Incl report the name, mailing address, occupation and employer of individuals whose contributions exceed $200 this year.

Paid for by Campaign for Primary AccountabilIty PAC and not autborized by any candidate or cQmtl1ittee.877~795"

EC-OCEO02

12-9525.,.;0143

I.

CAMPAIGN ..... I ... · lId n II fI far j 11111 I' 1 t ua.

,---PRlMAft:YMG8tJmBItf:W:--::"-::'" :::-.... :.::::::- -::::: National)Ournai

Democracy Requires Fair .Elections ... The Campaign for Prima.ry Acoouritabllftyfs gaalla essentially to enforce tenn limits on members with

Washington pol.iticians should be accountable to the low approval ratings and $iilfe OD~ according to 1bair citizens in the district they reprasent. But general polling ... The rrIOney goinglnln these against th~ srain

efforts, might have an uouooaleffect 002012. clections are .not. comp~titive. 85% of U.S. House '''' '-Districts are daminated by one party and the average .USA Incumbt.mt won by 26% in th~ 2()~O general election. TODAY This marms that the decision em who w!ns the election -:-. .........; ___________ ~ ____ 2/_1O_12_l)12

is made in the primaQf of the dominant party 8$% of SUPSR PAC TARGEITS

. . ,~: .. t!~e..~".!~~.~~"~~~W~.~WfpN~~rl.Rri.~J~,, ... "."N"W .. W~~~::~:!~~;.~r~~~~;:~n;rop!;r so their vote wilt oount.Our goat is to bring true pao say they're out to level the playing field against competition into our elect<Wal process, to give voters entrenched incumbents in Co~g;ells titough a novel real information abput their choices, alid to restor~ mrateg),: Tal!letfng them in Pnmary eIeoOOll$.

fair. not fixed elections.

tevelingtha Playing Field tncumbents have a (\message monopoly" during primari~ they mis~ more money (rr-om lobbyists and special rnterests) and use those funds to teU wten; aIL of th~ "wonderful" things they've done. Of course. they never speak of the earmarks,pay raises, junkets and generaliz~ corruption that have infe<!tedpolitlCSc fn Washington, D,C.

Join Us .... Citizens from across the political spectrum have come together to lewl the playing field in primary el~t::tiQns through the Campaign for Primfll'Y A«ountability, We del nol: have an Ideological agenda. And becaUSf.'l both parties got Qur coontry into the mess we're in. we are working In both Dfilmoc;ratlc and Republican districts. Your generous donation win help put voters back in t:ontrol of the process.

Super PAC Targets Jackson Jr .. Race

NEW SUPER PAC SACKS EFFORT TO UNSEAT u.s. Rap sn .. \fESTRE RavES

SUPER PAO TARGE.TS "OUT OF STEP" SCHMIDT

"""""~ .....

NationalJournaJ. !/S1n(lla

FACING 'rQUGH PRIMARY, VETERAN REP. BURTON SOWS OUT

, ... ' ................ .;," . -, Blall&Slices .... poliUGS 11:>1(2012

,,~.Super PAC Siding with Kucinich in Ohio 9th

campaign4primaryaccountability.org _, ______ _

I Paid for bi Ulmpaign for Primary I§:o~~i/ity PAC and f1o~!@orized orany candldateofcandfd"ate's comm!ttee. {877P9S.

. ~ •• ' - <"v ....

CAMPAIGN ...... I • for __________ _

. ,~-.c-.cc=::;·'-fRIMARY__AG.NJABlUJf··

o Yes 1 will make a contributiOll to CPA. in the amount of: o $ZSfOOfi 0 $5,000 OOtber$~~ ____ _

0$10,000 0 $1,000

Name~ __ ~ ______________ ~ ________ ~ __________________ ~

Employer ___________ OccupatWn. _______ ~ __

. ·" .. "·~Address'''··'"·' ."" ..... ,,' ----~--~--~----------------~-----------.------.-.. -..

CityfState/Zip __ ~ ________________ ~~

E~il ________________________________________________ _

Phona __ ~~ ______ _....~.Fax, ___________ _

Pletlse make checlfS PllYfihle Clnd mail tfi:

CampaijJlljor Prlf!1ary AccountQbilt1;Y ~ C/O jrmatllan Martin. TreaPtirer

P.O. :Sox 22529~ Houston Texas 77227-.2529

For wiring illformation oontactJonathan Martin. 269,.5444 ... _

For credit CQl'd use circle one: ViSA .AM1JX Me Sec. Code ___ = ....... ~ ....... Exp. Date ___ _

CC# • " • ~ignatur~: _____ ~~_==_ Billing Addrass (if ditrel'eut fi'om above) _ .. ~ __ ~ _____________ _

Contributions are not tax deductible. Campaign for Primmy A(!(;ountability PAC IS registered with the Federal Election Co:mmission as an independent expenditure cOlnmittee and your contribution will be used in connection with federal elections. Unlimited contribntio:o.s from U.s. citizens, oorporationsand other organizations ate

( per.mitred and aCl!$pted. except that we cannot accept contributions from foreign nationals, foreign corpoxatioIDl; federal government contractors an.d national banks. Federnllaw requires us to llse our best efforts to conect and report the Wlme, mailing address. occupation and employer of the individuals whose contributions exceed $200 this year. ,

_-______ • campaign4primaryaccountability.org ,_, _ .. _. _____ _

I :?ald for Elf Campaign for.E~.malY Ac~~iltabi!ity PAC and "?tauthorized by any ca~didate or can~~dare(s committee. J~zn795.

EC-OCE004

,.

Documents

REPORT - House Committee on Ethics