U.S.

Department of Justice

Criminal Division
Washington, D.C. 20530

AUG 2 7 2013

National Fiscal Conservative PAC Attn: Gerald Weygandt (Treasurer) Custodian of Records 8221 White Chapel Court Brentwood, TN 37027 Dear Sir or Madam: Enclosed please find a federal grand jury subpoena calling for the production of documents and information. Instead of personally appearing before the grand jury, you may arrange to comply with this subpoena by providing all responsive items, together with the attached business records certificate, no more than seven days prior to the date of your appearance, to: Special Agent Karen LoStracco FBI 9325 Discovery Blvd Manassas, VA 20109 If you have any questions concerning the subpoena or compliance with it, please contact Special Agent LoStracco at (703) 686-6241. Thank you for your cooperation in this matter. Sincerely, JACK SMITH Chief, Public Integrity Section

By: Richard C. Pilger Director, Election Crimes Branch Public Integrity Section 1400 New York Ave., NW Suite 12100 Washington, DC, 20005 (202)514-1412

AO 110 (Rev. 06/09; DC 4/10) Subpoena to Testify Before a Grand Jury

UNITED STATES DISTRICT COURT
for the District of Columbia SUBPOENA TO T E S T I F Y B E F O R E A GRAND JURY

To:

National Fiscal Conservative PAC, Attn: Custodian of Records 8221 White Chapel Court, Brentwood, TN 37027

Y O U A R E COMMANDED to appear in this United States district court at the time, date, and place shown below to testify before the court's grand jury. When you arrive, you must remain at the court until the judge or a court officer allows you to leave.

Place: United States District Court 333 Constitution Avenue N.W. Washington D.C. 20001

Date and Time:
09/20/2013 9:00 am

You must also bring with you the following documents, electronically stored information, or objects (blank
applicable):

ifnot

See attachment.

NOTE: Instead of personally appearing before the grand jury, you may arrange to comply with this subpoena by providing all responsive items, together with the attached business records certificate, no more than seven days prior to the date ofyour appearance, to Special Agent Karen LoStracco at FBI, 9325 Discovery Blvd, Manassas, VA 20109.

AUG 2 7 2013
Date:

^

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< 0

-

ANGELA D, CAESAR, VLEFtk OF CO&RT

Signature of Clerk oi ^ OF

Deput^Elerk

CO^

The name, address, e-mail, and telephone number ofthe United States attorney, or assistant United States attorney, who requests this subpoena, are: ry f7
Richard C. Pilger (<C* Director, Election Crimes Branch, Public Integrity Section Criminal Division, United States Deptartment of Justice 1400 New York Ave., NW, Suite 12100, Washington, DC, 20005 richard.pilger@usdoj.gov; (202)514-1412 GJ12-3/DOJ010

AO 110 (Rev. 06/09; DC 4/10) Subpoena to Testify Before Grand Jury (Page 2)

PROOF OF S E R V I C E

This subpoena for (name
was received by me on (date)

of individual or organization)

D I served the subpoena by delivering a copy to the named person as follows:

on (date)

; or

I returned the subpoena unexecuted because:

I declare under penalty of perjury that this information is true.

Date:
Server's signature

Printed name and title

Server's address

Additional mformation regarding attempted service, etc:

A T T A C H M E N T - National Fiscal Conservative PAC

1. For the period January 1, 2010, to the present, any and all records, in any form, related directly or indirectly to financial transactions (or attempted or proposed transactions) or accounts involving the following person(s) in any capacity as well as accounts of any other entity in which such person(s) might have a financial interest: MICHELE PAC BACHMANN FOR PRESIDENT BRETT O'DONNELL PETER WALDRON BOB HECKMAN BILL MCGINLEY MARCUS BACHMANN AUGUSTUS BUSCH For the period November 2, 2010 to the present, any and all records, in any form, related, directly or indirectly, to communications (or attempted or proposed communications), meetings, or agreements with the following person(s) in any capacity, including their official or unofficial representatives or agents, as well as accounts of any other person or entity in which such person(s) might have a financial interest: MICHELE PAC BACHMANN FOR PRESIDENT MICHELE BACHMANN BRETT O'DONNELL PETER WALDRON BOB HECKMAN BILL MCGINLEY MARCUS BACHMANN AUGUSTUS BUSCH

CERTIFICATION REGARDING BUSINESS RECORDS Pursuant to 28 U.S.C. § 1746,1, the undersigned, declare: My name is .

I am a United States citizen, and I am oyer 18 years of age. I am the custodian of records ofthe business named below, or I am otherwise qualified as a result of my position with the business named below to make this declaration. I am in receipt of a United States grand jury subpoena requesting specified records ofthe business named below. Attached hereto are original records or true and accurate copies of records responsive to the subpoena. Pursuant to Rules 902(11) and 803(6) of the Federal Rules of Evidence, 1 hereby certify that the records attached hereto:
1

1.

were made at or near the time ofthe occurrence ofthe matters set forth by, or from information transmitted by, a person with knowledge of those matters; were kept in the course of the regularly conducted business activity; and were made by the regularly conducted business activity as a regular practice.

2. 3.

I declare under penalty of peijury that the foregoing is true and correct. Executed on
(Date) (Signature of Declarant)

.

(Name of Declarant)

(Position of Declarant)

(Name of Business)

(Address of Business)

'As used in this declaration and as defined in Fed. R. Evid. 803(6), the term "record" includes memorandum, report, record, or data compilation, in any form, of acts, events, conditions, opinions, or diagnoses; the term "business" includes business, institution, association, profession, occupation, and calling of every kind, whether or not conducted for profit.

Checklist of Litigation Support Specifications

The following is a summary o f t h e Department of Justice Criminal Division's litigation support specifications d o c u m e n t . IMPORTANT: This d o c u m e n t is not meant t o replace the full version of the DOJ Criminal Division's litigation support specifications document, but rather highlight t h e most i m p o r t a nt aspects of the document. Please refer t o the full d o c u m e n t in order t o fully c o m p l y w i t h all of the specifications. The producing party is requested t o provide: • • Single-page Group IV TIFF files at 300 DPI resolution (page 1 , section A). DAT and OPT load files containing the fields listed in t h e specifications d o c u m e n t (pages 2-3, section D). • • PST, NSF, ZIP, and RAR file must be extracted (page 1, section A). Every Tiff image must be bates numbered and endorsed w i t h a n u m b e r t h a t includes a sufficient n u m b e r of leading zeros (page 1, section A). • • All native files (page 1, section B). Excel spreadsheets must be either: 1) produced natively w i t h a placeholder Tiff image, 2) converted t o Tiff images w i t h rows, columns, and sheets unhidden (page 1, section B). • One OCR text file per record. If no OCR exists for the record , include a placeholder text file stating, " N o Text Available" (page 1 , section C).

Revised 12.09.2011

Department of Justice, Criminal Division Litigation Support Specifications
1/28/2013 This document describes in general terms the DOJ Criminal Division's requirements for Searchable Image and Native Database production deliveries of electronic data, that is data processed from an electronic state, and scanned paper documents. The following requirements are geared toward a review environment based on Lexis Nexis Concordance or Concordance compatible review platforms such as Relativity. Searchable Image Database Productions of ESI Searchable Image Database productions of Electronically Stored Information (ESI) require the data to be produced as images and text files, with an additional requirement that the files also be produced in their Native Format with a NATIVEFILE field. Native Format shall mean the data files in the form "as kept in the ordinary course of business." For example, a Native Format means that Excel spreadsheets are produced as Excel spreadsheets, Microsoft Word documents are produced as Microsoft Word Documents, etc. The responding party is required to produce the following: A. Document Images are to be produced. All documents or files are to be printed to CCITT Group IV, 300 DPI resolution, single-page, Tiff images. Each container file, such as an email PST or NSF or file container such as a ZIP file or RAR file shall be extracted. Each container item is to be considered a separate document. The parent/child relationship between the container and container item is to be maintained. Each email attachment is to be extracted from the parent email as a separate document. The parent/child relationship between email and attachment is to be maintained. Each image is to be endorsed, in Arial 10 point font, in the lower right hand corner with a unique serial ("BATES") number. The BATES number shall not obscure any information in the image. The BATES number shall be no more than 30 characters consisting of an alphanumeric prefix, leading zeros and the sequential number. For example PROD0000001, PROD0000002, etc. B. Native electronic files are to be produced. Native electronic files are to be produced in addition to the Tiff images. The native file is to be named for the BATES number of first page o f t h e document. If a file cannot be rendered to tiff then a slipsheet image is to be produced, endorsed with the next available sequential BATES number, containing the following information: Original Filename, Original File Extension, below which should be printed the legend "UNPRINTABLE FILE". For each such file, the native electronic file is to be produced in addition to the slipsheet image. The native file is to be named for the sequential BATES number that is endorsed on the slipsheet image. C. Text files are to be produced. For each document produced, Optical Character Recognition (OCR) software should be applied. A single (i.e., multi-page) plain ASCII text file is to be produced (unless there is a prior agreement among the parties to produce UTF-8 (Unicode) or other text formats). In the case of files where the text of the document is electronically extractable, the text file should contain the electronically extracted text. For files where the text of the document is not electronically extractable, the file should be imaged then OCR'd and the text file should contain the text obtained from the OCR process. For files without electronically extractable text and that cannot be imaged and OCR'd the text file should contain language such as "No Text Available." An exception report in Page | 1

Microsoft Excel format or .CSV format listing all files that do not contain electronically extractable text and which could not be imaged and ocr'd will be produced listing the BEGDOC number of each such file. The text files will be named for the BEGDOC of the document and will have a .txt extension. D. A Concordance compatible data file is to be produced. Each file produced will have a corresponding record (row) in the data file. The data file will contain the following fields: FIELD
BEGDOC

NO
1

FORMAT
Text

DESCRIPTION
The BEGDOC field contains the unique sequential BATES number of the first page of the document. BEGDOC shall be no more than 30 characters and shall consist of an alphanumeric prefix, leading zeros, and the unique number assigned to the document. For example: PROD0000001. BEGDOC is to be designated the Image Key. The ENDDOC field contains the unique sequential BATES number of the last page ofthe document. BEGATT is used for Emails/attachments. BEGATT is the BEGDOC for the parent Email of each attachment. This field is populated for each attachment as well as the parent Email. ENDATT is used for Emails/attachments. ENDATT is the unique sequential BATES number of the last page of the last attachment to the parent Email. This field is populated for each attachment as well as the parent Email. Range of the family group in the format: BEGATT - ENDATT. This field is populated for each attachment as well as the parent Email. Date Sent o f t h e top-level parent Email. This field is populated for as well as the parent Email. This data shall be standardized otherwise agreed upon. Time Sent of the top-level parent Email. This field is populated for as well as the parent Email. This data shall be standardized otherwise agreed upon. PGCOUNT is the page count ofthe document as rendered to Tiff. Owner of data, if available. Source ofthe data, if available (eg. Smith's Office Laptop, hard drive label, etc.). Email "From" data. Email "To" data. Email "CC" data. Email "BCC" data. Email "Subject: line data. Email date sent. Application-generated record time sent. Author name metadata from electronic files if available. Title metadata from electronic files if available. Subject metadata from electronic files if available. Data Source Email Folder data for Emails and attachments. Application-generated record creation date. This data shall be standardized to EST, unless otherwise agreed upon. Application-generated record time created. This data shall be standardized to EST, unless otherwise agreed upon. Application-generated record last modified date. This data shall be standardized to EST, unless otherwise agreed upon. Application-generated record time last modified. This data shall be standardized to EST, unless otherwise agreed upon. Application-generated record last printed date. This data shall be standardized to EST, unless otherwise agreed upon. Original file path of a native document showing where the document was kept in the "ordinary course of business." For Emails: Mail subject. each attachment to EST, unless each attachment to EST, unless

2 3

ENDDOC BEGATT

Text Text

4

ENDATT

Text

5

FAMILY-RANGE

Text

6

FAMILY-DATE

MM/DD/YYYY

7

FAMILY-TIME

HH:MM:SS

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

PGCOUNT CUSTODIAN SOURCE FROM TO CC BCC SUBJECT DATESENT TIMESENT AUTHOR TITLE DOCSUBJECT FOLDER DATECREATED TIMECREATED DATELASTMOD TIMELASTMOD DATELASTPRNT FILE_PATH FILENAME

Numerical Text Text Text Text Text Text Text MM/DD/YYYY HH:MM:SS Text Text Text Text MM/DD/YYYY HH:MM:SS MM/DD/YYYY HH:MM:SS MM/DD/YYYY Text Text

Page | 2

For attachments and E-files: Original File name from source media. 29 30 31 32 33 34 35 36 DOC_EXT NATIVELINK MD5HASH SHAHASH CONVERJNDEX ENTRYID INTMSGID DOCTYPE Text Text Text Text Text Text Text Text File Extension of the document. The hyperlink path to the produced native file. MD5 Hash value ofthe document. SHA1 Hash value of the document if available. Conversation thread ID/Index value. Cannot exceed 450 characters. EntrylD value ofthe Email. IntMsgID value ofthe Email. Populate with the type of the document: E-Mail, Attachment, E-Doc, or Hardcopy. Note that embedded messages should be populated as Attachment; only the parent e-mail is populated as E-Mail.

The delimiters to be used f o r t h e data file are: Field Separator Text Qualifier Row (record) terminator Return or New Line H or Code 020 p or Code 254 ® or Code 174

For example (not all required fields represented): pBEGDOCpt/pENDDOCpflbBEGATTbt/bENDATTbt/bFAMILY-RANGEb E. A Concordance Image (Opticon) compatible Image Load File is to be produced. An Opticon .OPT or .LOG text file is to be produced in with the following comma delimited fields: BATES NUMBER, VOLUME, IMAGE PATH, DOCUMENT DELIMITER, N/A, N/A, N/A Opticon Sample Format: PROD0000001,VOL001,D:\VOL001\IMAGES\001\PROD0000001.TIF,Y„, PROD0000002,VOL001,D:\VOL001\IMAGES\001\PROD0000002.TIF„„ PROD0000003,VOL001,D:\VOL001\IMAGES\001\PROD0000003.TIF„„ PROD0000004,VOL001,D:\VOL001\IMAGES\001\PROD0000004.TIF,Y„, PROD0000005,VOL001,D:\VOL001\IMAGES\001\PROD0000005.TIF„„

Each production will be delivered on media whether CD, DVD, or Hard Drive appropriately sized for the production. Each Production will contain a Volume Folder named for the sequential production volume starting with VOL001 and incrementing with each subsequent production. The Volume Folder will contain a folder named IMAGES containing the Tiff image files, The IMAGES folder will contain sub-folders starting with, folder 001. Each sub-folder will contain no more than 5000 image files. The Volume folder will contain a folder named NATIVES containing the native electronic files. The NATIVES folder will contain sub-folders starting with folder 001. Each sub-folder will contain no more than 5000 files. The Volume Folder will Page | 3

contain a folder named TEXT containing the text files. The TEXT folder will contain sub-folders starting with folder 001. Each sub-folder will contain no more than 5000 text files. The Volume folder will contain the data file. The data file will be named f o r t h e production volume (eg. VOL001.DAT) and will have the .DAT file extension. The volume folder will contain a Concordance Image (Opticon) image load file with either the .opt or .log file extension. The image load file will be named for the production volume (eg. VOLOOl.opt). Searchable Image Database Productions of Scanned Paper Documents Searchable Image Database productions of Scanned Paper Documents consist of Image files, OCR text of the images, a data file and an image load file. The scanned images are to be produced. Document images are to be scanned "color for color." Black and white documents are to be scanned and produced as CCITT Group IV, 300 dpi resolution, single page Tiff images. Color documents and color photographs are to be scanned and produced as single page JPG images. The parent/child relationship between documents and attachments shall be maintained. Each page will be electronically endorsed in the same manner as specified for Searchable Image Databases of ESI. For example "PROD0000001." Text files are to be produced. Scanned documents will be OCR'd to produce a multi-page text file. For each document produced, a single (i.e., multi-page) plain ASCII text file is to be produced (unless there is a prior agreement among the parties to produce UTF-8 (Unicode) or other text formats). The text files will be named for the BEGDOC of the document and will have a .txt extension. A Concordance compatible data file will be produced. The Concordance compatible data file will be of the same format, with the same delimiters as the Concordance data files specified for Searchable Image Databases of ESI. The minimum required fields to be produced with scanned paper documents are: BEGDOC, ENDDOC, BEGATT, ENDATT, PGCOUNT, CUSTODIAN, DOCTYPE A Concordance Image (Opticon) compatible image load file is to be produced. Searchable Image Databases of ESI. The Concordance

compatible .opt or .log image load file to be produced will be of the same format as specified for

Page | 4

Addenda Productions of Structured Data (e.g.- Databases) Structured data (e.g., Oracle, SQL, MySQL, QuickBooks, etc.) shall be produced in its unprocessed "as kept in the ordinary course of business" state (i.e. in its Native Format). Structured data that requires export to text delimited formats shall be the subject of discussion and agreement between the parties before production. Productions of Structured Data from Proprietary Applications Structured data from proprietary applications (e.g., proprietary timekeeping, accounting, etc.) shall be produced in text delimited formats (i.e., flat "tables" with field names identified in the first "record," or as fixed-length flat files with appropriate record layout), that is, formats capable of being loaded into MS Access 2007, Concordance, or in reports or views able to accessed and used by such software. Any fieldlevel documentation shall also be provided. Other proprietary database file formats which do not conform to the just-discussed parameters shall be deemed unacceptable production, unless upon discussion and agreement between the parties before production. Production of ESI from Non-PC or Windows-based Systems Production of ESI from non-PC pr Windows based Systems (e.g. Apple, IBM mainframes and UNIX machines) shall be the subject of further discussion and agreement between the parties before production. Media Formats for Storage and Delivery of Production Data Electronic documents and data shall be delivered on any of the following media: • • CD-ROMs and DVD-R (+/-) formatted to ISO/IEC 13346 and Universal Disk Format specifications External hard drives, USB 2.0 or eSATA, formatted to NTFS format specifications. 1.02

Virus Protection and Security for Delivery of Production Data Production data shall be free of computer viruses. Any files found to include a virus shall be quarantined by the producing party and noted in a log. Such log shall then be provided. Password protected or encrypted files or media shall be provided with corresponding passwords and specific decryption instructions, as well as any software required for same shall be the subject of discussion and agreement between the parties before production. Privilege Logs a. Unless otherwise agreed upon between the parties and prior to productions of data, it is required that Privilege Log(s) shall be the subject of discussion and agreement between the parties before production.

Page | 5

b.

The recommended formats for producing Privilege Logs are MS Excel or MS Access. All documents determined to be privileged by the producing party shall be identified in a manner agreed upon by the parties.

Compliance and Adherence to Generally Accepted Technical Standards Production should be in conformance with standards and practices established by the National Institute of Standards and Technology ("NIST" at www.nist.gov), U.S. National Archives & Records Administration ("NARA" at www.archives.gov), American Records Management Association ("ARMA International" at www.arma.org), organizations. Transmittal Letter to Identify Productions of Data Unless otherwise agreed upon between the parties, it is requested that all productions be accompanied by a transmittal letter including all o f t h e following: volume name, electronic Bates number (document id or control numbering) ranges referenced to custodian names, total number of records, total number of images/pages or files, mapping of fields to plainly identify field names, types, lengths, formats and also indicating the field name intended to be linked to for image viewing, date and time format, and confirmation that the number of files in load files match the numberof files produced. An Exception Log shall also be included documenting any production anomalies utilizing by the electronic Bates number (document id or control numbering) assigned during the collection, processing and production phases. American National Standards Institute ("ANSI" at www.ansi.org), International Organization for Standardization ("ISO" at www.iso.org), and/or other US Government or professional

Page | 6

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