ABBOTT

LAW FIRM
RICHARD

LLC

L. ABBOTT, ESQ. 302.489.ALAW

HICI-I@RICHABBO'l'TI,A"VPIRM.COM

July 14, 2011 VIA HAND DELIVERY The Honorable Charles M. Oberly, III United States Attorney District of Delaware 1007 Orange street, Suite 700 Wilmington, DE 19801 Re:

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CREW Allegations Against Christine 0 'Donnell

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Dear Mr. Oberly: I am writing to request the investigation into false statements submitted to your office and the Federal Elections Commission regarding the above matter on behalf of my clients, Christine O'Donnell and Friends of Christine O'Donnell. On September 20, 2010, the Citizens for Responsibility and Ethics in Washington ("CREW"), by their Executive Director Melanie Sloan, submitted a request to your office seeking an investigation into Ms. O'Donnell for purportedly "converting campaign funds to personal use, for making false statements on forms filed with the Federal Election Commission ("FEC"), and for tax evasion." A copy of the letter is enclosed for your reference. A copy of the CREW Complaint filed with the FEe was submitted to your office soon after. A copy of the Complaint submitted by Ms. Sloan on behalf of CREW, as well as the FEe confirmation of receipt letter, are enclosed for your reference. The matter submitted to your office relies in part on an Affidavit of David C. Keegan. Based upon tape recorded statements made by Mr. Keegan, some of the contents of his Affidavit were false. This same date, a Complaint has been filed with the Delaware Attorney General's office,. requesting that the Department of Justice immediately conunence an investigation and undertake any appropriate prosecution of Mr. Keegan for potential violations of the Delaware State Criminal Code. A copy of the letter is enclosed. The CREW submission to your office also alleges that rent was paid by Ms. O'Donnell from campaign funds for a personal residence, despite the fact that it was well established that the premises at issue were in fact utilized for purposes of a campaign headquarters. Indeed, the enclosed Lease documents show that the tenant was the campaign, not Ms. O'Donnell. It is obvious that paying rent for campaign offices and campaign staff housing is a legitimate campaign expense.
724 ¥ORI{LYN HOAD • SUITE

240

• fiOCH:ESSIN.

DELA'WARE

19707

• FAX 302.489.2535

The Honorable Charles M. Oberly, III United States Attorney July 14, 2011 Page 2

The CREW submission to your office was suspiciously timed. It occurred just days after Ms. O'Donnell won an upset Republican Primary election victory in the United States Senate race. And not surprisingly, the publicity that arose from CREW's bogus complaint was played up in the media during the course of the ensuing general election season. Although the purely political motives behind the submission to your office are not illegal, making false statements to the United States Attorneys' Office andlor FEC would violate Federal law. Under Title 18, § 1001 of the United States Code, it is a crime for a person to knowingly and willfully make "any materially false, fictitious, or fraudulent statement or representation;' in "any matter within the jurisdiction of the Executive, Legislative, or Judicial Branch of the government of the United States." The CREW Complaint to the FEC and your office constitute matters which are in the jurisdiction of the U.S. Government. The complaints were made without proper vetting of the Keegan Affidavit, which is now known to be false. They were also submitted directly in the face of evidence indicating that the allegations about rent payments were both untrue and legally erroneous. As a result, your office is respectfully requested to immediately commence an investigation and undertake any appropriate prosecution of Ms. Sloan for potential__j£_ violation(s) of Federal law. ~

.

*"

It should also be noted that the September 20,2010 letter from Ms. Sloan to your office contends that Ms. O'Donnell committed certain crimes. Specifically, Ms. Sloan alleged that Ms. O'Donnell "violated 2 U.S.C. § 439(a)(b) and § 437(g)(b)(I)(A)(ii)," and "knowingly and willfully ... [committed a] violation of 18 U.S.C. § 1001." To the extent that the mails or interstate wire communications were involved with the filings made by CREW and Ms. Sloan, there also could be violations of the Federal Criminal Code provisions governing Mail Fraud and Wire Fraud, 18 U.S.C. §§ 1341 and 1343. The September, 2010 submission to your office purports to be made via facsimile transmission. Follow-up communications with your office may have been submitted by means of the U.S. Postal Service.

The Honorable Charles M. Oberly, III United States Attorney July 14,2011 Page 3

I look forward to receiving your reply.

RLA:cth

Enclosures
File No. 353.01

FOR IMMEDIATE RELEASE DATE: July 16,2011

CONTACT: Brian Jones bookings@blackrockgrp.com / 703-535-3390

CREW Complaint Against Christine O'Donnell Dismissed by Delaware U.S. Attorney
"I write to inform you that [the U.S. Attorney's Office] has closed its review and does not intend to pursue criminal charges .... "
- Charles M. Oberly, III, United States Attorney (July 15, 2011)

"The justice system should not be used as a political weapon, and we're going to keep fighting back."
-Christine O'Donnell via Twitter (July 15, 2011)

Wilmington, DE - The United States Attorney for Delaware, Charles Oberly, III, late yesterday notified attorneys for Christine O'Donnell and Friends of Christine O'Donnell that his office has dismissed the complaint filed against them by Melanie Sloan and Citizens for Responsibility & Ethics in Washington ("CREW") last September. "We are, of course, very pleased that the US Attorney's office has finally seen through the bogus CREW complaint and concluded it is without merit, because there were never any facts to support their allegations," said Christine O'Donnell. "CREW interjected itself into the campaign within hours of my winning the Delaware GOP primary, even though CREW had no actual basis for its complaint. Even more troubling is that CREW, as a 501(c)(3) organization, is prohibited by law from intervening in political campaigns - but they more than intervened in the campaign, doing everything they could possibly do to sabotage my election." Cleta Mitchell, attorney for the O'Donnell campaign said Friday, "the CREW complaint was nothing more than yet another partisan hit job by Melanie Sloan, an ultra-liberal Democratic operative and former Biden staffer posing as a nonpartisan activist. This is not the first time a citizen has been unfairly maligned by CREW and Melanie Sloan, always to great press fanfare when the attacks are launched. However, my clients have always prevailed against CREW's attacks because CREW consistently and continually files false allegations. It is high time we put a stop to these unlawful, politically motivated CREW schemes that waste countless hundreds of thousands of taxpayer dollars being reviewed by federal authorities, only to ultimately be dismissed." "We are absolutely confident the FEC complaint will also be dismissed because there are no facts to support any of CREW's allegations against Christine or the campaign," Mitchell added.
###
Paid for by Friends of Christine O'Donnell

FROM USAO DISTRICT DE

(FRI) 7.15' 11 16:49/ST.16:48/NO.

4861728720

P2

u.s. Department of Justice
District of Delaware r.o. B(lX2046
United States Attorney ~ Office

1007 Omngs Street. Suite 700
Wil11lil'lgton, Delaware 19899-1046

(3(2) 573-6277

FAX (301) S73·,mO

July 15,2011 Via Facsimile 9.nd U.S. Mail Cleta Mitchell, Esq.

Foley & Lardner, LLP 3000 K Street, N.W. Suite 600
Washington) DC 20007

Re:

Christine O'Donnell

Dear Ms. Mitchell:
In or about September 2010, this office received
Responsibility and Ethics in Washington ("CREW")

a referral from Citizens for
certain criminal campaign

alleging

finance violations committed by Ms. O'Donnell, As you are aware, this office has been reviewing these allegations. which principally involve the claim that Ms. O'Donnell illegally converted campaign funds to her personal use and made corresponding false
statements on forms filed

with the Federal Election Commission.

pursue criminal charges at this time.

It is my understanding that the CREW complaint was also filed with the FEe) and we intend to refer this matter to that agency.

I write to inform you that this office has closed its review and does not intend to

If you have any questions, please contact Assistant United States Attorney Keith M. Rosen, the Chief of our Criminal Division. Very truly yours.

United

CHARLES M. OBERLY, III
States

Attorney

http:"freedomist.com/2011/01/breakin9-exclusive-crew christine-odonnell-tea-party-newsl

-d irector-uses-own

-fathe r-to-levy -fec-c ha rges-a 9a inst-

Breaking Exclusive: Crew Director uses own Father to levy FEe charges against Christine O'Donnell- Tea Party News
O'Donnell attacker, Melanie Sloan, uses her own father to file trumped up charges with FE
The Freedomist has been investigating the charges levied against Tea Party champion Christine O'Donnell by the partisan group, CREW (Citizens for Responsibility and Ethics in Washington- which targets conservative leaders), led by former Biden staffer Attorney Melanie Sloan. In the course of that investigation, The Freedomist has learned that the group, CREW, filed a charge on behalf of a Leonard S. Togman. (see the official charges here from a PDF posted on the crew site): http://www.citizensforethics.org/crew-calls-for-odonnell-criminal-investigation FEDERAL ELECTION COMMISSION In the matter of: Christine O'Donnell ... "Complainant Leonard S. Togman is a citizen of the United States, a registered voter, and a resident of the State of Delaware. As a registered voter, ... " While Mr. Togman may be a Delaware voter, what has been omitted from Melanie Sloan's statements on this case, from the official complaint filed by the FEC, and the official statements made by CREW, is that Leonard Togman is Melanie Sloan's father. Not only is Leonard Togman the father of Melanie Sloan, like Melanie Sloan herself, he also happens to be a heavy Biden supporter. This story is about much more than Tea Party challenger Christine O'Donnell, this is about the tactics being used by progressives to assault our Tea Party and Conservative Leaders over and over again with personal assaults, using accusations, false charges, and a myriad of Alinksy-like tactics to undermine the person, since they cannot stand in front of the American people and tell them to vote for their kind of candidate, ones who are beholden to big government, big unions, and political class elitism. This is why we call on our Freedomist readers to help us get this story out about Melanie Sloan and her Father, political class elitists using our own government to attempt to destroy any Freedom-loving leader that dares stand in the way of their big government agenda. How can y.0u hele? You can link this site onto your own site. You can tweet this story out. But more importantly, you can do this: Here is more information about this emerging controversy now surrounding the accuser herself, Melanie Sloan: 1) Melanie Sloan's father is Leonard S. Togman, a retired attorney from Potter Anderson & Corroon LLP.@l LEONARD S. TOGMAN (her father) for

2) CREW's Complaint against Christine O'Donnell is based upon "standing" of a Delaware voter. 3)

Leonard S. Togman's campaign donations are almost exclusively donations to JOE BIDEN and Thomas Carper. brought on behalf of a Delaware voter LEONARD S.

The Complaint against Christine O'Donnell is officially/formally TOGMAN.

This same Leonard S. Togman has made 16 donations to Biden in the last decade, totaling $9,975, and 8 donations to Democratic Senator Tom Carper, whom everyone expects Christine O'Donnell to run against for the US Senate in 2012,

totaling $4,500
67.7% of all of the Togman's political donations have been to JOE BIDEN 30.5% of all of the Togman's political donations have been to TOM CARPER, possible future opponent for Christine O'Donnell in 2012. Melanie Sloan is using her father, a Biden-Carp supporter (as she is) as the COMPLAINTANT in the FEC Complaint.

Here is the link to the pdf file that lists Leonard S. Togman as the official complainant in the charges trumped up by his daughter, Melanie Sloan: http://crew.3cdn.netlbcObf09cc6b884f9fO vdm6b4gjx.pdf

hUp:llwww.nytimes.com/2007/09/23/fashion/weddings/23sloan.html?ref=weddings

- Here is an article which references

Melanie Sloan being "... the daughter of Barbara and Leonard S. Togman of Wilmington, Del." Here are the Togman's official campaign contribution records· Individual Contributions Arranged By Type, Giver, Then Recipient Contributions to Political Committees
TOGMAN, LEONARD S WILMINGTON, DE 19803 CARPER, THOMAS R VIA CARPER FOR SENATE 04/05/2000

1000.00

20020202632

TOGMAN, LEONARD S WILMINGTON, DE 19803 POTTER ANDERSON & CORROON BIDEN. JOSEPH R JR VIA CITIZENS FOR BIDEN 05/25/1999 11/13/2001 10/13/2003 06/16/2004 06/13/2005 06/13/2005

500.00 500.00 500.00 250.00 250.00 975.00

99020061587 22020021813 24020091956 24020472437 25020331549 25020331550

TOGMAN, LEONARD S WILMINGTON, DE 19803 POTTER ANDERSON & CORROONIATTORNE BIDEN, JOSEPH R JR VIA CITIZENS FOR BIDEN 04/19/2006 06/08/2006 07/10/2008

250.00 1000.00 250.00

26020522713 26020522713 29020120922

TOGMAN, LEONARD S WILMINGTON, DE 19803 POTTER, ANDERSON & CORROONIA TTORN CARPER, THOMAS R VIA CARPER FOR SENATE 10/18/2005 07/31/2006 05/22/2007

300.00 300.00 400.00

26020052735 26020632639 27020212941

TOGMAN, LEONARD S WILMINGTON, DE 19803 POTTER, ANDERSON, & CORROSON, CARPER, THOMAS R VIA CARPER FOR SENATE 04/18/2008

LLP

400.00

28020323058

TOGMAN, LEONARD S WILMINGTON, DE 19803 WILMINGTON FAMILY OFFICE/CONSULTA CARPER, THOMAS R VIA CARPER FOR SENATE 04/0212009 06/29/2010

400.00 400.00

29020234359 10020444479

TOGMAN, LEONARD S. WILMINGTON, DE 19803 POTTER, ANDERSON & CORROON LLPIAT CARNEY, JOHN CHARLES JR VIA JOHN CARNEY FOR CONGRESS 12101/2009 250.00 TOGMAN, LEONARD S. WILMINGTON, DE 19899 POTTER ANDERSON CORROON LLPIPARTN BIDEN, JOSEPH R JR VIA BIDEN FOR PRESIDENT, INC. 03/20/2007 1000.00 Total Contributions: 8925.00

10930304261

27930576984

Individual Contributions Arranged By Type, Giver, Then Recipient Contributions to Political Committees TOGMAN, BARBARA WILMINGTON, DE 19803 DELAWARE SCHOOL DISTRICT BIDEN, JOSEPH R JR VIA CITIZENS FOR BIDEN 05/25/1999 TOG MAN, BARBARA WILMINGTON, DE 19803 HOMEMAKER

500.00

99020061587

BIDEN, JOSEPH R JR VIA CITIZENS FOR BIDEN 11/13/2001 500.00 10/13/2003 500.00 BIDEN, JOSEPH R JR VIA BIDEN FOR PRESIDENT, INC. 06/01/2006 1000.00 TOGMAN, BARBARA WILMINGTON, DE 19803 HOMEMAKER/HOMEMAKER BIDEN, JOSEPH R JR VIA CITIZENS FOR BIDEN 06/01/2006 1000.00 BIDEN, JOSEPH R JR VIA BIDEN FOR PRESIDENT, INC. 03/20/2007 1000.00 TOGMAN, BARBARA A WILMINGTON, DE 19803 SALES CARPER THOMAS R VIA CARPER FOR SENATE 10/30/2000

22020021813 24020091956

27930577591

26020522713

27930576984

250.00

20020422707

Total Contributions:

4750.00

l eO:
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CREW Allegations Against Christine 0 'Donnell

Cbv###BOT_TEXT###amp;nne viebne(
9!t11\l"f

c...'" ~'f\l.'i!e

N A-M 1::.

Dear Mr. Oberly: I am writing to request the investigation into false statements submitted to your office and the Federal Elections Commission regarding the above matter on behalf of my clients, Christine O'Donnell and Friends of Christine O'Donnell. On September 20, 2010, the Citizens for Responsibility and Ethics in Washington ("CREW"), by their Executive Director Melanie Sloan, submitted a request to your office seeking an investigation into Ms. O'Donnell for purportedly "converting campaign funds to personal use, for making false statements on forms filed with the Federal Election Commission ("FEC"), and for tax evasion." A copy of the letter is enclosed for your reference. A copy of the CREW Complaint filed with the FEe was submitted to your office soon after. A copy of the Complaint submitted by Ms. Sloan on behalf of CREW, as well as the FEe confirmation of receipt letter, are enclosed for your reference. The matter submitted to your office relies in part on an Affidavit of David C. Keegan. Based upon tape recorded statements made by Mr. Keegan, some of the contents of his Affidavit were false. This same date, a Complaint has been filed with the Delaware Attorney General's office,. requesting that the Department of Justice immediately conunence an investigation and undertake any appropriate prosecution of Mr. Keegan for potential violations of the Delaware State Criminal Code. A copy of the letter is enclosed. The CREW submission to your office also alleges that rent was paid by Ms. O'Donnell from campaign funds for a personal residence, despite the fact that it was well established that the premises at issue were in fact utilized for purposes of a campaign headquarters. Indeed, the enclosed Lease documents show that the tenant was the campaign, not Ms. O'Donnell. It is obvious that paying rent for campaign offices and campaign staff housing is a legitimate campaign expense.
724 ¥ORI{LYN HOAD • SUITE

240

• fiOCH:ESSIN.

DELA'WARE

19707

• FAX 302.489.2535

The Honorable Charles M. Oberly, III United States Attorney July 14, 2011 Page 2

The CREW submission to your office was suspiciously timed. It occurred just days after Ms. O'Donnell won an upset Republican Primary election victory in the United States Senate race. And not surprisingly, the publicity that arose from CREW's bogus complaint was played up in the media during the course of the ensuing general election season. Although the purely political motives behind the submission to your office are not illegal, making false statements to the United States Attorneys' Office andlor FEC would violate Federal law. Under Title 18, § 1001 of the United States Code, it is a crime for a person to knowingly and willfully make "any materially false, fictitious, or fraudulent statement or representation;' in "any matter within the jurisdiction of the Executive, Legislative, or Judicial Branch of the government of the United States." The CREW Complaint to the FEC and your office constitute matters which are in the jurisdiction of the U.S. Government. The complaints were made without proper vetting of the Keegan Affidavit, which is now known to be false. They were also submitted directly in the face of evidence indicating that the allegations about rent payments were both untrue and legally erroneous. As a result, your office is respectfully requested to immediately commence an investigation and undertake any appropriate prosecution of Ms. Sloan for potential__j£_ violation(s) of Federal law. ~

.

*"

It should also be noted that the September 20,2010 letter from Ms. Sloan to your office contends that Ms. O'Donnell committed certain crimes. Specifically, Ms. Sloan alleged that Ms. O'Donnell "violated 2 U.S.C. § 439(a)(b) and § 437(g)(b)(I)(A)(ii)," and "knowingly and willfully ... [committed a] violation of 18 U.S.C. § 1001." To the extent that the mails or interstate wire communications were involved with the filings made by CREW and Ms. Sloan, there also could be violations of the Federal Criminal Code provisions governing Mail Fraud and Wire Fraud, 18 U.S.C. §§ 1341 and 1343. The September, 2010 submission to your office purports to be made via facsimile transmission. Follow-up communications with your office may have been submitted by means of the U.S. Postal Service.

The Honorable Charles M. Oberly, III United States Attorney July 14,2011 Page 3

I look forward to receiving your reply.

RLA:cth

Enclosures
File No. 353.01

FOR IMMEDIATE RELEASE DATE: July 16,2011

CONTACT: Brian Jones bookings@blackrockgrp.com / 703-535-3390

CREW Complaint Against Christine O'Donnell Dismissed by Delaware U.S. Attorney
"I write to inform you that [the U.S. Attorney's Office] has closed its review and does not intend to pursue criminal charges .... "
- Charles M. Oberly, III, United States Attorney (July 15, 2011)

"The justice system should not be used as a political weapon, and we're going to keep fighting back."
-Christine O'Donnell via Twitter (July 15, 2011)

Wilmington, DE - The United States Attorney for Delaware, Charles Oberly, III, late yesterday notified attorneys for Christine O'Donnell and Friends of Christine O'Donnell that his office has dismissed the complaint filed against them by Melanie Sloan and Citizens for Responsibility & Ethics in Washington ("CREW") last September. "We are, of course, very pleased that the US Attorney's office has finally seen through the bogus CREW complaint and concluded it is without merit, because there were never any facts to support their allegations," said Christine O'Donnell. "CREW interjected itself into the campaign within hours of my winning the Delaware GOP primary, even though CREW had no actual basis for its complaint. Even more troubling is that CREW, as a 501(c)(3) organization, is prohibited by law from intervening in political campaigns - but they more than intervened in the campaign, doing everything they could possibly do to sabotage my election." Cleta Mitchell, attorney for the O'Donnell campaign said Friday, "the CREW complaint was nothing more than yet another partisan hit job by Melanie Sloan, an ultra-liberal Democratic operative and former Biden staffer posing as a nonpartisan activist. This is not the first time a citizen has been unfairly maligned by CREW and Melanie Sloan, always to great press fanfare when the attacks are launched. However, my clients have always prevailed against CREW's attacks because CREW consistently and continually files false allegations. It is high time we put a stop to these unlawful, politically motivated CREW schemes that waste countless hundreds of thousands of taxpayer dollars being reviewed by federal authorities, only to ultimately be dismissed." "We are absolutely confident the FEC complaint will also be dismissed because there are no facts to support any of CREW's allegations against Christine or the campaign," Mitchell added.
###
Paid for by Friends of Christine O'Donnell

FROM USAO DISTRICT DE

(FRI) 7.15' 11 16:49/ST.16:48/NO.

4861728720

P2

u.s. Department of Justice
District of Delaware r.o. B(lX2046
United States Attorney ~ Office

1007 Omngs Street. Suite 700
Wil11lil'lgton, Delaware 19899-1046

(3(2) 573-6277

FAX (301) S73·,mO

July 15,2011 Via Facsimile 9.nd U.S. Mail Cleta Mitchell, Esq.

Foley & Lardner, LLP 3000 K Street, N.W. Suite 600
Washington) DC 20007

Re:

Christine O'Donnell

Dear Ms. Mitchell:
In or about September 2010, this office received
Responsibility and Ethics in Washington ("CREW")

a referral from Citizens for
certain criminal campaign

alleging

finance violations committed by Ms. O'Donnell, As you are aware, this office has been reviewing these allegations. which principally involve the claim that Ms. O'Donnell illegally converted campaign funds to her personal use and made corresponding false
statements on forms filed

with the Federal Election Commission.

pursue criminal charges at this time.

It is my understanding that the CREW complaint was also filed with the FEe) and we intend to refer this matter to that agency.

I write to inform you that this office has closed its review and does not intend to

If you have any questions, please contact Assistant United States Attorney Keith M. Rosen, the Chief of our Criminal Division. Very truly yours.

United

CHARLES M. OBERLY, III
States

Attorney

http:"freedomist.com/2011/01/breakin9-exclusive-crew christine-odonnell-tea-party-newsl

-d irector-uses-own

-fathe r-to-levy -fec-c ha rges-a 9a inst-

Breaking Exclusive: Crew Director uses own Father to levy FEe charges against Christine O'Donnell- Tea Party News
O'Donnell attacker, Melanie Sloan, uses her own father to file trumped up charges with FE
The Freedomist has been investigating the charges levied against Tea Party champion Christine O'Donnell by the partisan group, CREW (Citizens for Responsibility and Ethics in Washington- which targets conservative leaders), led by former Biden staffer Attorney Melanie Sloan. In the course of that investigation, The Freedomist has learned that the group, CREW, filed a charge on behalf of a Leonard S. Togman. (see the official charges here from a PDF posted on the crew site): http://www.citizensforethics.org/crew-calls-for-odonnell-criminal-investigation FEDERAL ELECTION COMMISSION In the matter of: Christine O'Donnell ... "Complainant Leonard S. Togman is a citizen of the United States, a registered voter, and a resident of the State of Delaware. As a registered voter, ... " While Mr. Togman may be a Delaware voter, what has been omitted from Melanie Sloan's statements on this case, from the official complaint filed by the FEC, and the official statements made by CREW, is that Leonard Togman is Melanie Sloan's father. Not only is Leonard Togman the father of Melanie Sloan, like Melanie Sloan herself, he also happens to be a heavy Biden supporter. This story is about much more than Tea Party challenger Christine O'Donnell, this is about the tactics being used by progressives to assault our Tea Party and Conservative Leaders over and over again with personal assaults, using accusations, false charges, and a myriad of Alinksy-like tactics to undermine the person, since they cannot stand in front of the American people and tell them to vote for their kind of candidate, ones who are beholden to big government, big unions, and political class elitism. This is why we call on our Freedomist readers to help us get this story out about Melanie Sloan and her Father, political class elitists using our own government to attempt to destroy any Freedom-loving leader that dares stand in the way of their big government agenda. How can y.0u hele? You can link this site onto your own site. You can tweet this story out. But more importantly, you can do this: Here is more information about this emerging controversy now surrounding the accuser herself, Melanie Sloan: 1) Melanie Sloan's father is Leonard S. Togman, a retired attorney from Potter Anderson & Corroon LLP.@l LEONARD S. TOGMAN (her father) for

2) CREW's Complaint against Christine O'Donnell is based upon "standing" of a Delaware voter. 3)

Leonard S. Togman's campaign donations are almost exclusively donations to JOE BIDEN and Thomas Carper. brought on behalf of a Delaware voter LEONARD S.

The Complaint against Christine O'Donnell is officially/formally TOGMAN.

This same Leonard S. Togman has made 16 donations to Biden in the last decade, totaling $9,975, and 8 donations to Democratic Senator Tom Carper, whom everyone expects Christine O'Donnell to run against for the US Senate in 2012,

totaling $4,500
67.7% of all of the Togman's political donations have been to JOE BIDEN 30.5% of all of the Togman's political donations have been to TOM CARPER, possible future opponent for Christine O'Donnell in 2012. Melanie Sloan is using her father, a Biden-Carp supporter (as she is) as the COMPLAINTANT in the FEC Complaint.

Here is the link to the pdf file that lists Leonard S. Togman as the official complainant in the charges trumped up by his daughter, Melanie Sloan: http://crew.3cdn.netlbcObf09cc6b884f9fO vdm6b4gjx.pdf

hUp:llwww.nytimes.com/2007/09/23/fashion/weddings/23sloan.html?ref=weddings

- Here is an article which references

Melanie Sloan being "... the daughter of Barbara and Leonard S. Togman of Wilmington, Del." Here are the Togman's official campaign contribution records· Individual Contributions Arranged By Type, Giver, Then Recipient Contributions to Political Committees
TOGMAN, LEONARD S WILMINGTON, DE 19803 CARPER, THOMAS R VIA CARPER FOR SENATE 04/05/2000

1000.00

20020202632

TOGMAN, LEONARD S WILMINGTON, DE 19803 POTTER ANDERSON & CORROON BIDEN. JOSEPH R JR VIA CITIZENS FOR BIDEN 05/25/1999 11/13/2001 10/13/2003 06/16/2004 06/13/2005 06/13/2005

500.00 500.00 500.00 250.00 250.00 975.00

99020061587 22020021813 24020091956 24020472437 25020331549 25020331550

TOGMAN, LEONARD S WILMINGTON, DE 19803 POTTER ANDERSON & CORROONIATTORNE BIDEN, JOSEPH R JR VIA CITIZENS FOR BIDEN 04/19/2006 06/08/2006 07/10/2008

250.00 1000.00 250.00

26020522713 26020522713 29020120922

TOGMAN, LEONARD S WILMINGTON, DE 19803 POTTER, ANDERSON & CORROONIA TTORN CARPER, THOMAS R VIA CARPER FOR SENATE 10/18/2005 07/31/2006 05/22/2007

300.00 300.00 400.00

26020052735 26020632639 27020212941

TOGMAN, LEONARD S WILMINGTON, DE 19803 POTTER, ANDERSON, & CORROSON, CARPER, THOMAS R VIA CARPER FOR SENATE 04/18/2008

LLP

400.00

28020323058

TOGMAN, LEONARD S WILMINGTON, DE 19803 WILMINGTON FAMILY OFFICE/CONSULTA CARPER, THOMAS R VIA CARPER FOR SENATE 04/0212009 06/29/2010

400.00 400.00

29020234359 10020444479

TOGMAN, LEONARD S. WILMINGTON, DE 19803 POTTER, ANDERSON & CORROON LLPIAT CARNEY, JOHN CHARLES JR VIA JOHN CARNEY FOR CONGRESS 12101/2009 250.00 TOGMAN, LEONARD S. WILMINGTON, DE 19899 POTTER ANDERSON CORROON LLPIPARTN BIDEN, JOSEPH R JR VIA BIDEN FOR PRESIDENT, INC. 03/20/2007 1000.00 Total Contributions: 8925.00

10930304261

27930576984

Individual Contributions Arranged By Type, Giver, Then Recipient Contributions to Political Committees TOGMAN, BARBARA WILMINGTON, DE 19803 DELAWARE SCHOOL DISTRICT BIDEN, JOSEPH R JR VIA CITIZENS FOR BIDEN 05/25/1999 TOG MAN, BARBARA WILMINGTON, DE 19803 HOMEMAKER

500.00

99020061587

BIDEN, JOSEPH R JR VIA CITIZENS FOR BIDEN 11/13/2001 500.00 10/13/2003 500.00 BIDEN, JOSEPH R JR VIA BIDEN FOR PRESIDENT, INC. 06/01/2006 1000.00 TOGMAN, BARBARA WILMINGTON, DE 19803 HOMEMAKER/HOMEMAKER BIDEN, JOSEPH R JR VIA CITIZENS FOR BIDEN 06/01/2006 1000.00 BIDEN, JOSEPH R JR VIA BIDEN FOR PRESIDENT, INC. 03/20/2007 1000.00 TOGMAN, BARBARA A WILMINGTON, DE 19803 SALES CARPER THOMAS R VIA CARPER FOR SENATE 10/30/2000

22020021813 24020091956

27930577591

26020522713

27930576984

250.00

20020422707

Total Contributions:

4750.00

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