6. From January
January 2009, defendant Larry
Craig was a UnitedStates Senator from Idaho. In 2007, Mr. Craig was a candidate, within the meaning
2 U.S.C. § 431(2), for the United States Senate in the 2008 election. Mr. Craig
currently aprincipal in New West Strategies LLC, which has its principal place
business in Washington,D.C.
Defendant Craig for U.S. Senate ("Craig Committee") was and is a politicalcommittee within the meaning
U.S.C. § 431(4). Mr. Craig designated Craig for U.S. Senateas his authorized principal campaign committee, within the meaning
431(5)-(6),for the 2008 election for United States Senator representing Idaho. As such, Craig forU.S. Senate was authorized to receive contributions and make expenditures on behalf
thecandidate, Mr. Craig. 2 U.S.C.
O'Riordan was and is the Treasurer
Craig for U.S. Senate.No expenditure
or on behalf
the Craig Committee could or can
made without theauthorization
the treasurer or her agent.
RELEVANT STATUTORY AND REGULATORY PROVISIONS
Under FECA, contributions accepted
a candidate may lawfully
(1) to finance authorized expenditures in connection with the candidate'scampaign for federal office and (2) to pay ordinary and necessary expenses incurred inconnection with duties
the individual as a holder
federal office. 2 U.S.C.
439a(a)(1),(2).10. The Act specifically provides that contributions or donations described in2 U.S.C.§ 439a(a) "shall not
any person to personal use." 2
§ 439a(b)(1). For purposes
this prohibition, a contribution or donation "shall be considered tobe converted to personal use
the contribution or amount is used to fulfill any commitment,