471
105th Congress, 2d Session-----
--
INVESTIGATION OF POLITICAL
FUNDRAISING IMPROPRIETIES AND
POSSIBLE VIOLATIONS OF LAW
INTERIM REPORT
SIXTH REPORT
BY THE
COMMITTEE ON GOVERNMENT
REFORM AND OVERSIGHT
together with
ADDITIONAL AND MINORITY VIEWS
Volume 3 of 4
WASHINGTON : 1998
MINORITY STAFF
Parliamentarian
MICHAEL Bopp, Senior Investigative Counsel
Counsel
KRISTI L. REMINGTON, Senior Investigative
Counsel
ELLIOT S. BERKE, Investigative Counsel
ROBERT J. DOLD, Investigative Counsel
JASON HOPFER, Investigative Counsel
JoHN IRVING, Investigative Counsel
RAE OLIVER, Investigative Counsel
JIM SCHUMANN, Investigative Counsel
MICHELLE E. WHITE, Investigative Counsel
DUDLEY HODGSON, Chief Investigator
MILT COPULOS, Investigator
KEVIN DAVIS, Investigator
G. ANDREW MACKLIN, Investigator
JOHN T. MASTRANADI, Investigator
MATT TALLMER, Investigator
THOMAs P. BOSSERT, Assistant to Chief
Counsel
JASON FOSTER, Assistant Systems
Administrator
LAUREL GROVER, Staff Assistant
KENNETH FENG, GAO Detailee
ROGER STOLTZ, GAO Detailee
RICHARD D. BENNETT, Special Counsel to the
Committee
Investigative Counsel
PHILIP S. BARNETT, Minority Chief Counsel
Staff Member
CHRISTOPHER P. Lu, Minority Counsel
MICHAEL J. RAPHAEL, Minority Counsel
ELLEN P. RAYNER, Minority Chief Clerk
JESSICA R. ROBINSON, Minority Staff
Assistant
DAVID SADKIN, Minority Counsel
PHILIP M. SCHILIRO, Minority Staff Director
Assistant
MICHAEL T. YANG, Minority Counsel
MICHAEL J. YEAGER, Minority Counsel
LETTER OF TRANSMITTAL
HOUSE OF REPRESENTATIVES,
Chairman.
CONTENTS
Preface ............................................................................................................
.......
Chapter I: Introduction ...........................................................................................
Chapter II: Unprecedented Obstacles to the Committee's Investigation ............
Chapter III: The Democrats' Failure to Return Illegal Campaign
C on tribution s ........................................................................................................
Chapter IV: Unprecedented Infusion of Foreign Money Into the American
Political System ........................................................................
Part A: The Riady Family and John Huang: Access and Influence with
the Clinton White House
.................................
Part B: Yah Lin "Charlie" Trie and His Relationship with the Clinton
Adm inistration ..............................................................................................
Part C: Johnny Chung: His Unusual Access to the White House and
His Political Donations
........................................
Part D: The Sioeng Family's Contributions and Foreign Ties ......................
Chapter V: The Failure of Government Agencies to Vigorously Pursue Campaign V iolations ....................................................................................................
Part A: Jorge Castro's Illegal Campaign Contributions, and Why They
Were Never Prosecuted
.....................................
Part B: FEC Enforcement Practices and the Case Against Foreign National Thomas Kramer:. .Did
Prominent DNC Fundraisers Receive
Spe. . . .. . .. . .. . .. . .. . .. . .. . .
.. .. ..... ... ..... .
cial Treatment?
Chapter VI: The Hudson Casino Rejection ............................................................
Chapter VII: Procedural Background of the Campaign Finance Investigation ..
Page
5
47
149
1185
1185
1347
1671
2131
2933
2933
2983
3111
3863
VIEWS
...............................
Additional views of Hon. Dan Burton
.........
.....................
Additional views of Hon. Pete Sessions
Minority views of Hon. Henry A. Waxman, Hon. Tom Lantos, Hon. Robert
E. Wise, Jr., Hon. Major R. Owens, Hon. Edolphus Towns, Hon. Paul
E. Kanjorski, Hon. Gary A. Condit, Hon. Bernard Sanders, Hon. Carolyn
B. Maloney, Hon. Eleanor Holmes Norton, Hon. Chaka Fattah, Hon. Elijah
E. Cummings, Hon. Dennis J. Kucinich, Hon. Rod R. Blagojevich, Hon.
Danny K Davis, Hon. Thomas H. Allen, and Hon. Harold E. Ford, Jr ..........
Additional views of Hon. Thomas M . Barrett ........................................................
3881
3920
3923
4878
REPr. 105-829
VOL. 3 OF 4
SIXTH REPORT
together with
ADDITIONAL AND MINORITY VIEWS
On October 8, 1998, the Committee on Government Reform and
CHAPTER V, PART A
THE FAILURE OF GOVERNMENT AGENCIES TO
VIGOROUSLY PURSUE CAMPAIGN VIOLATIONS
JORGE CASTRO'S ILLEGAL CAMPAIGN CONTRIBUTIONS,
AND WHY THEY WERE NEVER PROSECUTED
In the course of the Committee's investigation, we learned of another source of foreign money-South America. The Committee
learned that the New York District Attorney's Office conducted an
investigation into the banking activities of the Castro family of
Venezuela, and had uncovered evidence of illegal campaign activities by that family. The District Attorney's Office turned this investigation over to the Justice Department, which failed to pursue any
charges against the key individuals involved. The Committee followed up on the New York District Attorney's investigation, and
brought to light the facts of the Castro case.
I.
2936
seek6
7
Alert newsletter. In addition, Castro Llanes was reportedly
Venezuela.
to
ambassador
U.S.
ing to have Intriago appointed
Progreso matIntriago also organized a defense team for the Banco
the acrelease
to
Customs
U.S.
ultimately convinced
ter which
counts. 8
sysIn 1994, following the collapse of the Venezuelan banking
VenMiami.
in
settled
and
States
United
the
to
fled
tem, Castro
ezuelan banking regulators seized Banco Progreso that December.
embezzleCastro was later charged in absentia with bank fraud,
9
government.
Venezuelan
the
by
ment, and conspiracy
On April 4, 1996, Castro Llanes was indicted in New York along
in
with his son and grandson on charges of a scheme to defraud on
the first degree. He was convicted on grand larceny charges
February 19, 1997, and in April of that year sentenced to a term
of 1 to 3 years in prison. The larceny involved defrauding depositors of the Banco Progreso International de Puerto Rico of as much
as $55 million. His crime also cost the government of Venezuela
more than $8 million.
B. ORLANDO CASTRO CASTRO
The U.S.-educated son of Castro Llanes, and uncle of Jorge Castro Barredo, Orlando Castro Castro was president of the Banco
Progreso in Caracas, Venezuela. He was convicted along with his
father and nephew by the Manhattan District Attorney on charges
of bank fraud involving the theft of millions of dollars from a Puerto Rican bank the family controlled. He was sentenced to a term
of 23 to 7 years in prison. 10
C. JORGE CASTRO BARREDO
1d
75 Interview
1d.
9Id.
lo Id.
"Id.
12Id.
13 Id.
of James Kindler and Joseph Dawson, Dec. 26, 1997 ("Kindler-Dawson Interview").
2937
cerning his knowledge of illegal foreign conduit campaign contributions and his testimony was corroborated independently by documentary
evidence obtained by the New York District Attorney's Office. 1 '
Notwithstanding documentary and testimonial evidence, the Justice Department chose not to bring any charges related to the Castro conduit contributions.'1 On February 19, 1997, Castro Barredo
was convicted on the unrelated bank fraud and larceny charges. On
December 15, 1997, he was sentenced to a term of 32 to 102
years in prison.1 6
D. MARIA SIRE CASTRO
2938
After being subpoenaed to appear before an executive session of
invoking
this Committee, Intriago declined to answer questions,
23
the Fifth Amendment to virtually all questions posed. Intriago's
attorney, did, however, submit a letter on behalf of Intriago to the
Committee, stating in part:
Mr. Intriago is not a government official. He has never
held a high elected or appointive government position. He
has never been an employee of, or consultant to, the Democratic National Committee. He is not a "friend" or "associate" of the President, the Vice President, or any other high
ranking Democratic Party official. He has not applied for,
been interviewed for or considered for a government job.
He has never had or sought a government contract. Mr.
Intriago simply is a respected private lawyer with a previously unblemished record of conduct. 24
This statement, is at best, misleading. According to DNC documents obtained by the Committee, Intriago is listed as an "applicant" for a Federal appointment. The documents indicate that he
was involved in the 1992 Florida Presidential campaign, and that
the recommendation was forwarded on December 16, 1992.25 It indicates his "JOB PREF./AREA OF INTEREST" as "LEGL," likely
indicating a legal job preference. It indicates his "AGENCY/DEPARTMENT PREFERENCE" as "Just," likely indicating the Department of Justice. 26 The notation also indicates under the title
"Job Level", the initials "SL," indicating a senior level position.2 7
Similarly, the contention that Intriago has never been a "high
government official" understates his actual employment history. He
was a senior congressional staff member early in his career, and
served as a Special Assistant to the Governor of Florida, playing
a major role in the development of that state's racketeering laws.
He also served as an Assistant U.S. Attorney in Florida.
Mr. Intriago's name also is listed in another DNC document
which is a compilation of recommendations for a delegation to attend the 1994 Salvadoran election. Intriago's name is first on the
list which also includes such dignitaries as Secretary of Energy Bill
Richardson, then mayor of Albuquerque Martin Chavez, and prominent DNC donor Walter Kaye. 28 The Committee also obtained a
letter dated December 2, 1992, from Intriago to then DNC Chairman Ron Brown addressed "Dear Ron," and stating:
Just a brief note to tell you that I enjoyed meeting you
during the campaign in Little Rock and Middleburg. Apparently, I am now a "trustee" of the DNC and am looking
forward to assisting you in any way I can.
So that you will know a little more about me, I enclose a
couple of recent issues of my publication, Money Launder23
2939
ing Alert, together with some background information. I
think this is an issue on which President Clinton can
make some headway in dealing with the drug and white
collar crime problems. 29
II. CASTRO'S ILLEGAL CONTRIBUTIONS
"Id.; see Checks of Jorge Castro Barredo to Ohio Victory Fund, DNC Victory Fund '92, and
Democratic party (Exhibit 5).
Kentucky
35 Id.; see Check of Maria Sire Castro to DNC Victory Fund (Exhibit 6); Check of Maria Sire
Castro to Maryland Victory Fund (Exhibit 7).
36 Id.
"Id.
"See Committee Exhibit of fax cover sheet (Exhibit 8); see also Fax Message from Charles
Intriago to Jorge Castro, Sept. 16, 1992 (original) (Exhibit 9).
3Castro Hearing at 12-13 (Testimony of Jorge Castro Barredo).
40 Castro Hearing at 12.
41Castro Hearing at 12-13.
2940
the $5,000 check Castro Barredo had written to the Ohio state
a new $5,000
party, and instead, asked Castro Barredo to 4write
check to the Kentucky State Democratic party. 2 On September 29,
Castro Barredo did so, and sent the check to Intriago. However,
days later, Intriago called again, and told Castro Barredo that he
would not use the Kentucky check, and instead, asked Castro
Barredo to draft a $5,000 check to the Florida Democratic party.43
Castro Barredo, exasperated, asked why he had to keep writing
new checks.4 Intriago responded "that's the way they want it."45
Castro Barredo did not ask for any further explanation, and sent
the requested check to Intriago.
On September 24, 1992, Castro Barredo received a wire transfer
to his account for $24,990.46 Records indicate that the wire transfer
came from Inversiones Latinfin, a company owned by Orlando Castro Llanes. 47 Castro Barredo testified that Inversiones Latinfin
does no business in the United States.
A. THE CASTROS' RED CARPET TREATMENT
2941
of the Castro family and the various allegations that had been leveled against the family about money laundering.5 4
B. INTRIAGO'S TIES TO THE DEMOCRATIC PARTY
54 Id.
2942
Later, upon their return to New York, the District Attorney's Office subpoenaed a number of bank records including those of Jorge
Castro Barredo and Maria Sire Castro. The bank records showed
that both of the $20,000 checks to the DNC Victory Fund 1992 Federal Account had been cashed, but that Castro Barredo's first two
state party checks had not been cashed. They did confirm, though,
that Castro Barredo's $5,000 check made out to the Florida Democratic party had been cashed.6s More importantly, the records
showed that on September 24, 1992-just 8 days after the faxboth Jorge Castro Barredo and Maria Sire Castro received wire
transfers to each of their accounts in the amount of $24,990.64
Taken together, these documents support the assertion that an illicit transaction consisting of a conduit contribution reimbursed by
a non-U.S. entity took place.
IV. THE JUSTICE DEPARTMENT'S HANDLING OF THE CASTRO CASE
The New York District Attorney's Office had uncovered convincing evidence of a serious violation of Federal campaign law, and
they decided to refer the matter to Federal prosecutors. Since most
of the criminal acts involved in the case had occurred in Miami, the
District Attorney's Office referred the matter to the Federal prosecutors in the Southern District of Florida. In the referral letter,
Assistant District Attorney John Moscow wrote to Richard
Gregorie, Senior Litigation Counsel in the U.S. Attorney's Office in
Miami, to inform him of what had been discovered:
[T]he checks and wire transfer relate to a series of violations of the laws relating to campaign financing. That is,
two people sent $25,000 each to a political party and received reimbursement for those political contributions from
an off-shore company. 6 5
Mr. Moscow also forwarded copies of the documents which had
been obtained in the course of the bank fraud investigation. At this
same point in time, the District Attorney's Office also referred another aspect of the Castro investigation, involving customs law violations, to Federal prosecutors in the Southern District of New
York.
Mr. Moscow followed up on the letter by meeting with Gregorie
in Miami on October 17, 1996.66 Further follow-up to this meeting
took the form of two letters sent to the Miami Assistant U.S. Attorney on October 28, 1996, and October 29, 1996.67 On February
1997, two additional packets of documents were forwarded 24,
to
Miami by the New York District Attorney. These packets included:
* The fax from Alert International discovered in Santo Domingo.
* Copies of checks issued by Jorge Castro Barredo and
Maria Sire Castro to DNC "Victory Funds."
"See Exhibit 10.
"See Wire transfer documents (Exhibits 13-14).
"Letter from John W. Moscow to Richard Georie, Oct. 9, 1996 (Exhibit 18)
66 7 Castro Hearing at 77 (Testimony of Joseph
Dawson).
Letters from Jon W. Moscow to Richard Gregorie,
Oct. 28, 1996 (Exhibit 19) and Oct. 29,
1996 (Exhibit 20).
2943
* A wire transfer document showing that on September 13,
1994, Castro Barredo sent Intriago $100,000.
* Two canceled checks issued by Castro Barredo, one for
$20,000 to the DNC Victory Fund '92 Federal Account and
for $5,000 to the Florida Democratic party Federal Account. one
* Account statements from the International Bank of
Miami
N.A. for the account of Jorge Castro Barredo showing
the
checks were cashed.
* Two canceled checks issued by Maria Castro, one in the
amount of $20,000 to the "DNC Victory Fund 1992 Federal
Account" and one for $5,000 to the Maryland Democratic party
Federal Account.
* The NationsBank account statements for Maria Sire Castro showing that the check was cashed.
* Wire transfer documents showing that $25,000 was wired
to both Jorge Castro Barredo and Maria Sire Castro
from
Banco Latino by order of Inversiones Latinfin on September
24, 1996.
* Shareholder documents showing that Inversiones Latinfin
was owned by Castro Llanes. 68
On March 11, 1997, Joseph Dawson of the New York District Attorney's Office spoke with a Miami Federal prosecutor and discussed
the issue of the statute of limitations for prosecuting the campaign
law case against Castro. The prosecutors agreed that since the fax
transmission occurred and the checks were written in the fall of
1992, the statute would expire in the fall of 1997.69
A. CASTRO COOPERATES
At the same time that the New York District Attorney's Office
was discussing the conduit contributions case with the Miami U.S.
Attorney's Office, they were also holding discussions about obtaining Jorge Castro Barredo's cooperation. Castro Barredo had been
convicted, along with his grandfather and uncle, on February 19,
1997. An agreement was ultimately reached, and Jorge Castro
Barredo agreed to be debriefed by the New York District Attorney's
Office.70
The debriefings took place on March 20, 1997 and April 3, 1997.
In the course of the debriefings, Castro Barredo stated that he
made contributions of $20,000 to the DNC, and $5,000 to a state
Democratic party at Intriago's instructions, and that he was reimbursed for the contribution by one of his grandfather's companies. 7 1
According to Castro Barredo, Maria Sire Castro also made a
$20,000 contribution to the DNC and a $5,000 contribution to a
state Democratic party at Charles Intriago's direction, and was
similarly reimbursed by Castro Llanes.72 Castro shared with the
prosecutors the entire story of how he had come to contribute to
the Democratic party, how he had been reimbursed, and what the
family had received for the contributions. The testimony given by
Castro to the prosecutors was the same that he gave the Commit-Letter from John W. Moscow to Richard Gregory Esq. [sic], Feb. 24, 1997 (Exhibit 21).
69 Id.
77o Id.
1 d.
72
Id.
2944
73
tee in interviews, and in its hearing. In the Committee's hearing,
case confirmed that Castro
the
on
working
the District Attorney
was truthful throughout interviews and debriefings with their office:
COUNSEL. Has Mr. Castro ever told you anything about
conduit contributions that has later proven to be false?
Mr. PRESS. No. 74
Following the debriefing of Castro Barredo by the New York
prosecutors, they arranged for Castro Barredo to meet with Federal
prosecutors on May 28, 1997.7r Just prior to the meeting, Preiss
spoke with Assistant U.S. Attorney Bruce Udolf from the U.S. Attorney's Office in the Southern District of Florida and again expressed his concern over the potential statute of limitations problem.7 6 They agreed that the likely statute of limitations for a prosecution relating to the Castro contribution expired on September
16, 1997, or 5 years from the date of Intriago's fax to Castro
Barredo.7 7 Roughly 1 week after Castro Barredo talked with the
Federal prosecutors, a Federal prosecutor in Miami called Preiss,
thanking him for the cooperation and courtesy provided by the New
York District Attorney's Office.78 He also stated that his office intended to pursue the matter, and that its investigation could be
completed before the statute of limitations expired.79
In late June or early July 1997, Preiss received a phone call from
Castro Barredo's attorney, Marc Nurik, stating that the Justice Department's Public Integrity Section had taken the Castro case away
from the prosecutors in the Southern District of Florida.80 Nurik
said that he had spoken with the head of the Justice Department's
Public Integrity Section, Lee Radek, and was concerned that Radek
had nothing substantive to say about the Justice Department's
plans for the case.ex Nurik feared that the Justice Department
would allow the statute of limitations to expire, leaving his client
with nothing to show for his cooperation. 82
After confirming that the case had been transferred, Preiss attempted to speak to Lee Radek. Preiss spoke with Radek's assistant, but the assistant refused to put Preiss through unless he had
a "referral number" for the case.88 Preiss then asked that whoever
was handling the case contact him.8 ' An exchange between the
Committee Counsel and Mr. Preiss concerning his attempts to contact Radek raises serious questions about the responsiveness of the
73
74
7 5 1d.
Id.
76
of Richard Preiss and Joseph Dawson, Jan. 19, 1998 ("Preiss-Dawson Interview")
at7.Interview
7
Castro Hearing at pp. 79-80.
791d.
so1 Preiss-Dawson Interview.
ld.
82 Id.
3
8 Id.
2945
Justice Department to the apparent violation of law which
was connected to a DNC trustee:
COUNSEL. Now, Mr. Preiss, did you try and have a conversation with Mr. Radek?
Mr. PREISs. Yes.
2946
C. THE CASTRO CASE DIES
2947
Jorge Castro Barredo is currently scheduled to be sentenced on October 20, 1997. We referred a matter to the
Department of Justice in late 1996 and Castro Barredo is
a witness who has been interviewed by representatives of
the Department of Justice in connection with an investigation of Charles A. Intriago.9 9
*
Please advise us whether the Department of Justice intends to make any submissions regarding Castro Barredo's
cooperation or lack of cooperation in your investigation and
send us a copy before October 20, 1997. If you wish us to
request a delay in the sentencing of Castro Barredo, please
advise us immediately how long a delay you would like us
to request and the basis for the delay in order that we may
convey that information to the court. 0 0
A week later, Castro Barredo's attorney called Preiss, stating
that he had received a copy of a letter from Lee Radek, chief of the
Justice Department's Public Integrity Section to Preiss advising
him that the Department would neither be asking for a further
postponement of Castro Barredo's sentence, nor submitting a letter
on his behalf. In the letter, Radek stated:
[W]e have concluded that there is at this time no further
role for him [Castro Barredo] to play in matters under investigation by the Task Force.101
2948
versations between Assistant District Attorneys in our office, and the question whether to basically take back a
matter that had already been referred is sort of a touchy
area. 103
CONCLUSION
2949
* Why, for more than 2 months, the Attorney General has
denied the request of the Committee to interview Richard
Gregorie, the Assistant U.S. Attorney involved in the investigation of the Castro case before it was taken away by the Public
Integrity Section. Gregorie likely has detailed information
about the reasons that the Castro case was taken to Public Integrity, but the Attorney general has never responded to multiple requests made by the chairman to interview Mr. Gregorie.
It is the opinion of the Committee that the Public Integrity Section of the Department of Justice was derelict in its duty to pursue
clear evidence of crimes including wire fraud, mail fraud, conspiracy and campaign finance violations related to the Castro case. The
Justice Department's failure to act on this case prevented the
American people from learning the truth about illegal campaign
fundraising activities going back to the 1992 presidential election.
The Committee was able to uncover only part of the truth, the
story of how Jorge Castro and his aunt made $50,000 in illegal contributions to the DNC. However, there are two more critical questions that the Committee has been unable to answer: why did the
Castro family make the contributions, and who was telling Charles
Intriago how to direct these contributions? These are facts that
could have been discovered by a timely prosecution of Charles
Intriago. However, because of the Justice Department's malfeasance in the Castro case, the truth may never be discovered.
[Supporting documentation follows:]
2950
U. S. Department of Justice
Wasame.l
D.C 20510
GT1
7 1997
EXH[B
2951
2
Thank you, again, for having brought this matter to our
attention.
We continue to value this type. of productive
coordination between your office and the Justice Department, and
look forward to working together again in the future.
Sincerely
Lee J. Radek
Chief
Public Integrity Section
Criminal Division
cc:
2952
APPLICANT:DAER
s athleen C. Noyt
DT!
12/18/
12/18/92
COMMENTS:
APPLICANT:
Swanse
Mr.
ZBQL. Mr.
DATE
Eunt
BOB NELSON
WILL SPONSOR: T
CANEAGIeL FI
JOB PREP. /AREA OF INTEREST: ADMN
JOB LEVEL: SL
: STAT
WANTS AMBASSADOR TO ITALY.
Hr. Andrew D.
FRLOM Ms.
SQURCEL
12/22/
Eli Segal
SOURCEL
COMENTS:
DATA
12/22/92
SDATE2299
1/9
Susan Thomases
DAWN FRIEDKIN
WILL SPOSOR: T RECOMMEND:
CG
JOB PREP. /AREA OF INTEREST: LEGL
SL
AGENCYIDEPARTMENT PREFERENCE:
JUST HLHS
CAMPAlGN:
JOB LEVEL
COMMENTS:
APPLICANT:
Mr. Charles A.
EROK
Intriago
2/69
12/16/
SOURCE
PAUL TOBACK
WILLQSONOR T RECOMMEND:
FI
JOB PREF. AREA OF INTEREST: LEGL
JOB LEVEL: SL
AGENCY/DEPARTMT PREFERENCE: JUST
.CAMPAIGN
COMMENTS:
Mr.
Robert C. Jamissewaki
FBON.
Mr.
91=1u. VP
JOB LEVEL: SC
Page 33
DT
12/16/
Craig Smith
COMMENTS:
RD
12/16/92
PRE. /AREA OF
AGENCY/DEPATMEN PREFERENCE:
00
T
T
BUD
ECOMNEND: HR
STAT
EXHIBIT
2
IlfilfllilfllflllmiifilfilDHC 0764400
2953
DsmdWdhebb.Ch.
MEMORANDUM
TO:
DANA WYCKOFF
FROM:
MARTHA PHIPPS
DATE:
RE:
Per you request, I lave comped our recommdaons for the delegtin to aud the
Salvadora Elcm on March 20th.
All but one of the following names appear on the February 4th memo dat I snt to you
regarding our secommnWdations for the Marc 11th ChIlean Imaguadon Delegation.
Please call me at 8634121 if nam from our original Ist hae been selected for the Qilean
delegation. In that
we will forward additional names to you for this Salvadora delegation.
1. Mr. Charles Intriago
Presid
Alert Publicadons Partners
1401 Brickell Avenue
Suite 570
Miami, FL 33131
305-5304500 w
305-530-9434 f
2. Congressman ill Richa
204 CROB
Washington. DC 20515
3. Martin Chavez
Mayor of Albuquerque
505-786-2040
ma
-49-
IUEEINE
W DNC 0311808
1NEI
2954
4. Marl Cam- Ap"~t
AM.9u0u. Oeb& ApOM
8601 Georgia AVeouS
sumvo Spring, MD 20910
S. WrPar Lewis 00 NEW NAME
Otairun of die Board
th Poeise CaorafmwO
MM
Porklad mkuo
alevelmi OH 44101
216461-SODD
6. Jon. Phen
rafts Of Olicmn Stuie
TeUnIfenity of Ariinei
130 Wedi Coness
I11th Floor
TuCauS, AZ
602-7404126 w
7. Mr. Waliat Kaye
475 Pakh Avene
New Yor. NY 10022
212-338-2290 w
2124167-97
2955
10. On=c Napltu.
12009 Eau Firemme
Norwalk. CA 90650
916-445-096
DHC 0311810
IEUIIMUEEIUUEE DNC 0311810
INNEEN
2956
-ALERT
International, Inc.
2, 1992
December
Mr. RonaldBrown
Chairman
Committee
Deorcratic National
430SouthCapitalStree,SE
D.C 20003
Washington
DearRon:
meetingyou during the campaign
Just a brief notetotell you thatI enjoyed
in Little Rockand Middleburg. Apparently,Iam now a "trsee of the DNC. and
can.
I
way
I amlooking forwardto assistingin any
Sothatyou will know a little more aboutme, I enclosea coupleof recent
Alerr, togetherwith some background
MoneyLaundering
issues of mypublication,
information. I think this is an issue on which PresidentClinton canmakesome
cmimeproblems.
collar
white
and
drug
the
with
in
dealing
hevdway
to seeing younoon. Best regardsI lookforward
Sner
ChdeA
rs,
npo Eq..
Publeshe
SLw570
A3313,
Mon 1
Fr-odd-nu
fo
c 305
0,EXHIBIT
30330Qd34
4
Illiflllilllllifillllillll DNC
1359488
2957
JORGE F. CASTRO
OR GREZIA MATOS DE CASTRO
.... FLOn
JORGE F. CASTRO
OR GREZIA MATOS DE CASTRO
lI 1
104A
THE INTERNATIONAL
U
hc
f--&?
o co
.AMI FLORIDA
LLl
'-4
Ic
I~~~~~~~
S THE
- AGC
DrW
r,
-.
-T
...
iICIZI
...
E CAS~rau
LI.IA
1.'
~,.cIo
3
.NA
-I
2958
1,7SW 1 9THAVE.
MIAP4.
FL
~c~js.u.C~at~::~.,
3t?5325
-
elySy
=T4
2959
bb
EXHIBrf
2960
FA
57dModig
AFVILUATION
coveh~tt
sbra
-(=uID~b~
DATE:F/
_____________________
FROM:
COMM'EmT
ZD,
S--41110
f-
/9MR Y4ZFNh
- a A4.0"
?AlAge
-. /.o
A-
-6AW
At,
Oenz
........................................... .......
...................................
..................................................................
.......... ....
............
......
...............
..............
................................
Ou.iW............
::.w an.! ...
.......................
..................
...
...........
..........
eig A.0
Ext'.# .
.....
......
..
.............
..........
......................
..................
MIBIT
8
2961
- - -- - - -
- - - - - -
Phone: 305S30-0500
FAX #;
DATE:
TO:
AFFILIATION:
5z/
9 /
3137
I =n
Number of Page,
(including cover sheet)
2962
mm
-~
OHIB
10
2963
1**
jaJ.i
irI
0'
l-1
a.f1
.LIUI.
n~I iIIC
0MU
I~C1cl
PRIAIfiV
U Al
2;I
l l
~y ~-O.0a
i 128
CI
*Ou l ..
59*01
0iil"
l~
S~ ILCI
0
1..90..
ir i
I D as, 1~lI~
:111" Mll~ a
a ri
C
'altCY6.9
Ci9_i
0lli
M~
I-
10G G64
2964
.1.0.0
MIT
W
WIWSMetIMlw
WN~~
I101
AW
IM AD0D'~2
Ow
SII
25.00.00
I=I
~Y
1"
o e
'
I GOU
W~GO
.SY.UI
21
ISNICSGS
Iwv
.AS:
1o D Gem h W IN
'WNW LOID C A
Ar, 1211ijJoii
jj
2
0
MOOw10
9=14
rPU
JI.P I
0
LJASAIVSAlA
BUI
lJM
va MIMIC
I 404.'ff
-II
A06IS
Aawvi
wm Ja
IAwe
ff81555
sle.
2965
m~j
LO; Pls3
M"i
.11U
3vlomS3Xv%4,..
I IPYISI
lUU
IRM
MCR
~1"
S3IU
VIKIK
Wr MCI
1W
coSWU
PO52W??, U
roow
1.3111
LRTiICow-c
.10
....... .... ..
WW@
LAYIPo. C..
.004,0011S
.SP
U .
..
...
a3
I71
INISI3
.....5.....5
.t
i......
IRMc.
a m
,7 1
21.00C.i
oTIP
S .
C ,J1
)c
SiT
Jew-
.1MILiE
U
,11no
527TEX
Do
K
OrU~
WIiILTtl
Ci 7m
MOMJ-f
2966
IMI
orM,"
1111
4O
flOom
PRIORTY.O1
ow
T159?
136 C: . 5059
.91
.
.9599
.~ l
1311 I
M
.
3,39
.1.91
. .71
. I .3 .
Vr!.. I33
74
A W R mum5
Il 134,
61633
IUICI
Ta
-orl
"I'M .
0.36
we%,.
10P .463
M*
.90C .*,P
,173w
Do,
. .........
W.91S
553
1315993
Do1
3C Tm5I9533
..
p
1f,
644
2.44.'
.0.5
59W5
.4
Ix-
ml
LI
-4
2968
June 21, 1995
Mr Charles Intriago
Publisher
Alert Pulbication Partners
1401 Brickell Street
Suite 570
Miami, FL 33131
Dear Charlie:
Recently, I discovered several photographs of Orlando Castro and you that were taken at past
DNC events Although these pictures were taken some time ago. I knew both you and Orlando
would sill enjoy having these copies. I would be very appreciative if you would forward to
Orlando the photos that I have enclosed for him
As always,
Sincerely,
Enc Sildon
Director
National Membership Services
lll
know
2969
urMANDUM
TO:
FROM:
Team Florida
DATE:
May 7, 1993
RE:
Florida donors
iE
g 8
EXHIBIT
17
2970
TRUSTEE (raised at least $50,000)
Marvin Rosen
Jerry Berlin
Mitchell Berger
Howard Glicken
Russ Barakat Austin Forman
Monte Friedkin
Bud Stack
BLF ($10,000
contribution)
Michael Adler
Bell South (Danny Murray)
Gladys Cofrin
Arthur Courshon
Florida Medical Center - Eddie Dauer
e Herman)
a
s
U
Richard Machado
Steve Scott (Nevco Partners)
Jorge Bolanos
Jim Pugh
Sel Maduro
Hugh Westbrrok (Vitas Health Care)
Dr. Sandy Ziff
Environmental Sal (David Block)
Hamilton Forman
ggg il
ill
DNC 4025934
2971
DISTRICT
ATTORNEY
or
rws
COUNTY OF NEW YOmN
ONE MOGAN PLACE
Na
N.Y.
Yome
0ol
33190-0
212)
gOeassm M MORGENTMAU
October 9, 1996
II
EXH4Ifl
18
2972
DISTRICr
ATTo
Ner
CoUNry
of
iw
Voam
urs
Jo
.
scow
Assistaht District Attorney
Enclosures
2973
DISTRICT ATTORNEY
nossart~
A0N
smokGrNVsu
RACE
Oct:ber
24 1996
October
17,
1995.
REDACTED
Thank you again far the tvee and attention that was extended
to Andrew Finan and myself an o.Ar visat to Miami.
e
ru
yours,
iofn. M~oscow
2974
DISTRICT
OF
ATTORNEY
T-E
MMAN0
FLCk
Z2I23 335000
0o0ER
P
MOnA0NTu
October 29,
1996
meeting on October
from files
of
17,
1996.
REDACTED
Thank you again for the ti-e and attention that was
extended
to Andrew Finan and myself cn cur visit to Miami.
Very truly yours,
John W. Moscow
Assistant District Attorney
Ends.
EXHIBIT
20
2975
DISTRICT ATCRmE
cOUNTY 0' RiSV.)
Newv"n.. N.V.
1Snas
(212) 33S.9000
Ne5Ma
#a monGsumAU
EHIBrr
21
2976
(2) Account statements from the International
Bank of Miami N.A. account of Jorge Castro,
showing that the two above-mentioned checks
were cashed, and the account debited;
(3) The front and back of a check issued by Maria
Sire Castro to the DNC "Victory Fund- for
$20,000.00; the check was cashed;
(4) NationsBank account statements for Maria
Castro showing that her account was debited
when the above-mentioned check was cashed;
(5) Wire transfer documents showing that
$25,000.00 was wired to both Jorge Castro and
Maria Castro from Banco Latino by order of
("B/O") Inversiones Latinfin on September
24, 1992;
(6) Shareholder documents showing that
Inversiones Latinfin is owned by Orlando
Castro Llanes, which illustrates that
Jorge and Maria may have received
reimbursement for their campaign
contributions by Orlando Castro Llanes,
because they received money from a Castroowned, non-American company whose amount is
equivalent to the amounts requested by
Charles Intriago on September 16, 1992.
These documents were received from the Attorney-General of
Venezuela. The "Bates" stamp numbers on all documents were
stamped by members of the District Attorney's Office.
Very truly yours,
John W. Moscow
2977
DISTRICT ATTORNEY
09
'.g
RODENT M. MORSENTMAU
September 4, 1997
BY EXPRESS MAIL
Peter Ainsworth, Esquire
Trial Attorney
United States Department of Justice
Public Integrity Section
Campaign Financing Task Force
1001 G Street, N.W.
Washington, D.C. 20530
Re:
Charles Intriago
EXHIBIT
22
2978
OF
THE
ROBERT M MORGENTHAU
October 10,
1997
BY EXPRESS MAIL
Peter Ainsworth, Esquire
Trial Attorney
United States Department of Justice
Public Integrity Section
Campaign Financing Task Force
1001 G Street, N.W.
Washington, D.C. 20530
Re:
Richard T. Preiss
Assistant District Attorney
Senior Investigative Counsel
(212) 335-4210
se-,--.
"
EXHI1ff
23
2979
MARC S. NUR
ATIORn
ONE FDANCIAL
MARC ENLTE
R.A2
POWsLAUDEMDLL FLORI
RI!ILBENNETTZ
PA.
AT LAw
33MARD: (9W 4.10t
m3M
DADLcam)s4ssw
TAX 3Mg 7U4g
MEMORANDUM
TO
FROM
Carolyn William
DATE:
RE
Mr. Pris:
Mr. Nwik asked me to inform you that he has no objection to your
presenong the Judge with a copy of the foregoing c
aespondence
from Lee J. Radek.
Thank you.
Carolyn Williams
EHIBIT24
OCT-17-197?
10:49
P.e0z
2980
U. S. Deparmme of Josee
D.C 2M
OCT 1
7ore
Castro Barredo
10/17/97
OCT-17-1997
10:50
09:29
TX/RI NO.9246
P.002
2981
2
Thank you. again, ror hawing bzuught this matter to our
a
type of productive
We continue te value
attention.
Justice Department. and
coordination between you Office mad
the future.
look award
to working together again
Ls
. Radek
Pub Ic integrity Section
.LX-I*
l Divialon
ce:
10/17/S7
OCT-17-1997
19:59
35 7
4421
49528
TX/IK ND.9246
P.003
CHAPTER V, PART B
THE FAILURE OF GOVERNMENT AGENCIES TO
VIGOROUSLY PURSUE CAMPAIGN VIOLATIONS:
FEC ENFORCEMENT PRACTICES AND THE CASE
AGAINST FOREIGN NATIONAL THOMAS KRAMER: DID
PROMINENT DNC FUNDRAISERS RECEIVE SPECIAL
TREATMENT?
Another foreign contributor who came to the Committee's attention was Thomas Kramer. Mr. Kramer, a German citizen with considerable real estate holdings in the South Beach area of Miami,
illegally contributed over $322,600 to national, state, and local candidates of both the Democratic and Republican parties.' The
Tampa Tribune noted the donations and published an article in
September 1994 questioning whether or not Kramer was eligible to
make political contributions. 2 The following week, Kramer "voluntarily" disclosed his illegal activity, claiming ignorance as to the illegality of his campaign contributions.
Upon learning that Kramer's contributions might not be legal, almost all of the contributed money was returned to Kramer by the
parties involved.3 The FEC ultimately fined Kramer, his secretary
(Terri Bradley), the law firm of Greenberg Traurig Hoffman Lipoff
Rosen & Quentel, P.A. ("Greenberg Traurig"), and the Republican
Party of Florida ("RPF") for giving or receiving Kramer's contributions. The penalties associated with the Kramer contributions totaled $503,000. Mr. Kramer was individually fined 4 $323,000-the
largest penalty of its kind ever assessed by the FEC.
The two individuals most closely identified with soliciting Kramer's contributions were Marvin Rosen, the former Finance Chairman of the Democratic National Committee ("DNC"), and Howard
Glicken, a former Vice Finance Chairman of the DNC and close political associate of Vice President Gore. Mr. Glicken was charged on
July 9, 1998, by the Department of Justice's Campaign Financing
Task Force and pled guilty to two misdemeanor5 violations stemming from his role in the Kramer solicitations. The FEC fined
Greenberg Traurig-the law firm hired by Kramer to handle immigration matters and which counts Marvin Rosen as a partner$77,000 for soliciting illegal contributions from Kramer with knowledge of his foreign national status. When asked who at the firm be1
The Committee's investigation focused only on the state and national contributions.
2Louis Lavelle, "Developer's donations questioned," Tampa Trib., Sept. 28, 1994, at Florida/
Metro
1.
3
The Republican Party of Florida [RPF] did not return $95,000 of the $205,000 it received.
The RPF successfully argued that the money had been placed in a redistricting account that
it was legally permitted both to receive and spend money contributed by foreign nationals. The
FEC agreed with the RPFs position. Conciliation Agreement, In the Matter of Republican Party
of Florida (federal/non-federal accounts) and James H. Stelling, as treasurer,MUR 4398, Feb.
20,4 1997, at 1.3 (Exhibit 1).
Robert Jackson, "German Given Record Fine in Campaign Donation Case," L.A. Times, July
19, 1997, at A16.
GJane Bussey, "Political money probe nabs Miamian," Miami Herald, July 10, 1998, at 9A.
(2985)
2986
sides Rosen solicited contributions from Kramer, the FEC reported
that:
The only Greenberg-Traurig individual specifically identicontributions in the file
fied as a solicitor of Mr. Kramer's
of this matter is Marvin Rosen.6
During the course of the Committee's investigation, the explanations given by FEC staff members only served to raise further
skepticism as to the conviction with which the FEC pursued the
Rosen and Glicken investigations. Indeed, the FEC has never adequately explained why it failed to bring a case against Rosen individually, or why it initially failed to pursue a case against Glicken.
Notwithstanding the fact that neither Rosen nor Glicken was fined
by the FEC-despite evidence demonstrating that these two individuals were the only solicitors who had reason to know that Kramer was ineligible to make contributions-FEC General Counsel
Noble stated on March 31, 1998, that no one at7the FEC ever even
called Rosen or Glicken about the contributions. It should be further noted that Kramer was not contacted by the FEC until a year
and a half after first disclosing his illegal contributions to the commission. Yet, in announcing that it would not conduct enforcement
proceedings against Glicken, the FEC made the following statement in December 1997:
[Blecause of Mr. Glicken's high profile as a prominent
Democratic fundraiser, including his potential fundraising
involvement in support of Vice President Gore's expected
presidential campaign, it is unclear that this individual
would agree to settle this matter short of litigation.8
FEC counsels and Commissioners, in both the FEC conciliation
agreement and in subsequent testimony before the Committee, argued that this statement referred to a statute of limitations that
was about to expire at the time Glicken's name was discovered in
conjunction with his solicitation of Kramer.9 They argued that discovering Glicken's name at such a late point made bringing a case
against Glicken difficult for the Commission and would complicate
the settlement process for the other involved parties.' 0 This position, however, cannot explain away the fact that Kramer submitted
an affidavit in December 1994-approximately 4 years before the
statute of limitations would expire-which put the FEC on notice
that a key fundraiser for the Democratic party may have knowingly
solicited his illegal contributions." Furthermore, the FEC's statement linking Glicken to Vice President Gore as an apparent reason
6
2987
for not pursuing the matter appears to be a particularly ill-considered message that the FEC does not prosecute cases when met
with resolve and political connections. Notwithstanding the fact
that many of the recipients of Kramer's donations had no knowledge of his foreign national status, the Thomas Kramer matter demands vigorous attention for two reasons:
(1) Kramer's first and third federal contributions were conduit contributions made at the request of, and with the knowledge of, very prominent Democratic fundraisers; and
(2) the FEC appears to have missed the mark entirelyprominent national fundraisers should be penalized heavily if
they encourage others to break the law.
An analysis of FEC practices and procedures relevant to the
Thomas Kramer matter follows this chapter as Appendix 1.
II. THOMAS KRAMER: HIGH PROFILE GERMAN DEVELOPER
A. BACKGROUND
2988
and Howard Glicken clearly had knowledge that Kramer was ineligible to make political contributions. The sections of this chapter
discussing the roles played by Rosen and Glicken in the Kramer solicitations will explore such evidence in detail.
The DNC and Kramer's QuestionableImmigration Status
The Committee uncovered additional evidence demonstrating
that the DNC was on, at a minimum, constructive notice of Kramer's questionable immigration status. Notwithstanding the aforementioned newspaper articles describing Kramer's foreign national
status, documents show that the DNC conducted background
NEXIS research on the Miami-based developer which turned up a
Forbes magazine article describing Kramer as a "German investor." 17 The DNC's own "Event Form" for Chairman David Wilhelm
for a June 10, 1993, Vice Presidential dinner described Kramer as
being bornon in Germany." 8 The form did not mention Kramer's
exact immigration status, leaving the legality of his ability to make
political contributions a matter of uncertainty.
Despite his questionable status, Kramer earned a DNC Business
Leadership Forum position due to the fundraising efforts he undertook for an April 29, 1993, dinner for Vice President Gore.19 A
DNC memo dated May 7, 1993, to party finance directors demonstrated why Kramer was considered an attractive target for campaign funds:
Tom Kramer-Gave $25,000 to the event. Is the developer
who will build much of South Miami Beach and is worth
tens of millions. Make him a Trustee and stroke him and
he'll do more than $50,000 for the program. 20
Other employees at the DNC also targeted Kramer directly. Eric
Sildon, Director of Membership Services for the DNC, included
Kramer on a list of potential invitees to a Florida event for President Clinton "because thin s like this might get him jazzed-up to
start writing those big check k." 2 Mr. Kramer's name appeared on
call sheets for both Laura Hartigan, Director of the DNC's Trustee
Program, and for David Wilhelm, the then-DNC Chairman. 22 Mr.
Wilhelm also drafted a letter to Kramer and his wife on May 27,
1994, inviting them to a June 1994 DNC National Presidential
Dinner. 23 National Finance Chairman Terry McAulliffe also invited
Kramer to the DNC's 1994 Business Leadership Forum's Issue
Conference and to the DNC's National Presidential Dinner. 24 As a
result of such targeted solicitation, Kramer eventually attained
DNC Managing Trustee status. 2 5 Along with his numerous con7
Form for Olympus Holdings, Inc. and corresponding background
Screening
Mor Donor
i
(Exhibit
DN ioration
5).
"sEvent
Form for Chairman Wilhelm, June 10, 1993 (Exhibit 6).
9
2 Charles Intriago another South Florida Democratic Fundraiser and DNC Trustee was also
in attendance. See "6harles Intriago and Illegal
Political Contributions from Venezuela" section
of this report).
220
1Florida Donors Memorandum, May 7, 1993, at 7.5 (Exhibit 7).
Clinton in Florida Memorandum, Sept. 20, 1993 (Exhibit 8).
22
LauaHtgan Calls (Exhibit 9); see also Call Sheet for Chairman David
Wilhelm, Nov.
16 1993 (Exhibit 10).
1) Chairman David Wilhelm Letter to Mr. and Mrs. Tom Kramer, dated
May 27, 1994 (Exhibit
11).
24
Invittion to Thomas Kramer to the 1994 Business
Leadership
Forum's
Issue Conference
(Exhibit 12).
' Invoice Dates DNC Managing Trustees, at 13.7 (Exhibit 13).
2989
tributions and invitations to various DNC causes and events, Kramer also began to gain access to both the Vice President and the
First Lady: Mr. Kramer likely attended a private dinner with the
Vice President on June 10, 1993, at the Four Seasons Hotel in
Georgetown 26 and was also scheduled to be seated at the First
Lady's table at another DNC event. 27
B. CONTRIBUTIONS
Recipient
Mitchell for Senate
DSCC
..............................................
Amount
Returned?
$
0..............$1,
Yes ..............
$20,000 Yes ..............
Solicitor
32
Marvin Rosen
33
Howard Glicken
=radley
is nolongeremployed
bythe Portofino
Gmup.
Sandler
Letter
to Rodriguez,
Sept.3, 1997,at 18.3,18.11
(Exhibit18).
ODSCC
Finance
Division
Check
Tracking
Memorandum
(Exhibit
19).
26NMR Event Brief, June 10, 1993 (Exhibit 14). Kramer was slated to sit at Chairman Wilhelm's table. Table Diagram (Exhibit 15).
"The First Lady's Table (Exhibit 16). Mark Jimenez, who is also currently under investigation for campaign fundraising abuses, was also listed on the diagram. Id.
"Affidavit, supra note 11.
"Conciliation Agreement, In the Matter of Thomas Kramer et al. MUR 4398, Aug. 5, 1996
(Exhibit 17).
"'See Affidavit, supra note 11 at 3.3.
2990
Kramer focused on these two contributions in his December 1994
affidavit. The contributions are distinct from his other illegal contributions in that they involve violations of two Federal election
law provisions-2 U.S.C. 441e, making illegal contributions by a
foreign national and 441f, making illegal contributions in the
name of another. This chapter will show that both Rosen and
Glicken sought contributions from Kramer knowing he was a foreign national and that Glicken encouraged him to make contributions through a conduit. Anyone soliciting a contribution from Kramer knowing he was a foreign national or encouraging him to
make the contribution through a conduit would thus be conspiring
to violate Federal election law provisions.
C. THE CASE AGAINST THOMAS KRAMER
2991
FEC's management of this case. Indeed, FEC Commissioner Joan
Aikens acknowledged a problem during one of the MUR hearings:
My first objection to this was to the length of time this
was sitting around for a sua sponte complaint.3 9
Commissioner Aikens further noted:
I understand the misfortunes that befell the matter, but I
do find it distressing to have a sua sponte matter involving
both corporate and foreign national contributions delayed
this long. It would seem that something like this should be
flagged to be sure that it doesn't fall between the cracks. 40
The FEC ultimately discussed the cases in Executive Session on
four occasions,4 1 and handed down the following fines: Terri Bradley was fined $21,000 in July 1996; Kramer $323,000 in August
1996; the Republican Party of Florida $82,000 in March 1997; and
the law firm Greenberg Traurig $77,000 in February 1998. At the
time, Kramer's fine was the largest ever assessed by the FEC for
an illegal campaign contribution by an individual. 4 2 The FEC decided to concentrate its case against these four entities in order to
maximize the possibility of entering into conciliation agreements.
For various other reasons-reasons which will be examined and explored in this chapter-the FEC decided not to pursue a case
against Marvin Rosen or Howard Glicken, both closely involved
with the Kramer conduit contributions. (The personal involvement
of these individuals will be discussed in detail in the "Marvin
Rosen, Howard Glicken and Their Solicitations of Thomas Kramer"
section of this chapter).
D. THE CASE AGAINST THE REPUBLICAN PARTY OF FLORIDA ("RPF")
On February 20, 1997, the RPF voluntarily entered into a Conciliation Agreement with the FEC for contributions it accepted from
Kramer. The agreement noted that the party accepted the following
contributions from Kramer: (1) Separate contributions of $100,000
and $5,000 from the Kramer-owned Portofino Group on June 4,
1994; and (2) $100,000 from Kramer on March 3, 1994, $5,000 of
which was deposited into the party's Federal account with the balance being transferred into a non-Federal account and then transferred into a segregated redistricting account. The RPF argued, and
the FEC later agreed, that it did not need to return $95,000 of the
$205,000 it received because it had been legally placed into a redistricting account. The FEC noted in the agreement that funds used
solely for non-campaign related redistricting issues are exempt
from the foreign national prohibition at 2 U.S.C. 441.43 The
$95,000 transferred by the party was thus, according to the FEC,
legally permissible under campaign finance law. Nothing in this
agreement pointed to any evidence whatsoever that anyone within
or related to the RPF knowingly solicited contributions from the
4398, supra note 35.
2992
foreign national or had direct knowledge of Kramer's status as a
foreign national.
E. THE CASE AGAINST GREENBERG TRAURIG
Because of the FEC's inability to reach a settlement with Greenberg Traurig as part of the broader Kramer-related MUR 4398and so as to not adversely prejudice the successfully completed portion of MUR 4398-the Commission severed the activity concerning
Greenberg Traurig into a separate matter and launched an investigation into the law firm's involvement in Kramer's contributions.44 The investigation into Greenberg Traurig's actions was assigned the MUR number 4638.
The FEC's case against Kramer from the outset, according to
FEC Associate General Counsel Lois Lerner, targeted Greenberg
Traurig:
Our focus .
the law firm. Ordinarily in the past, we had not really proceeded against solicitors in these kinds of cases, but here
very specific information regarding the law
we had
firm[.] 45
According to Lerner, "Mr. Kramer had said that it was individuals
in the law firm that had solicited him and that was how we had
proceeded." 46 Kramer's secretary, Terri Bradley informed the FEC
that a named partner at Greenberg Traurig had solicited Kramer
for illegal contributions. (Fora discussion of the FEC's case against
Rosen-whom the Committee suspects may be the "named partner"
in question-see the "Marvin Rosen" portion of the following section.)
The FEC has not been clear about the frequency with which it
proceeds against the solicitors of illegal foreign or conduit contributions. In an exchange before this Committee, FEC Associate General Counsel Lerner suggested that it was virtually unprecedented
for the FEC to target the solicitors:
Mr. BURTON. Let me just follow up, if I might. You have
gone after individuals who illegally or unethically solicited
contributions that were not legal, have you not?
Ms. LERNER. Foreign national contributions, I believe
there's only been one other instance where we have pursued a solicitor.
Mr. BURTON. Is that right? Only one other?
Ms. LERNER. I believe so.
Yet according to arguments made by FEC Staff Attorney Jose
Rodriguez to the Commissioners during the FEC's MUR hearing:
There is a violation for someone who solicits the foreign national contributions, but not for the conduit. And having
looked at some of our past practice through the MURS, I
don't believe we've actually held anyone in violation of the
4 General Counsel's Report, In the Matter of Greenberg, Traurig, Hoffman, Lipoff, Rosen &
PA, MUR 4638, Oct. 27, 1997, at 23.2 (Exhibit 23).
Quentel,
45
Federal Election Commission Enforcement Actions, supra note 6 at 39 (statement of FEC
Associate General Counsel).
4 Id.
2993
foreign national prohibition for simply being a conduit. We
have held people certainly for soliciting funds on behalf of
the [political] committee, but not for being a conduit.4 7
Greenberg Traurig was presumably targeted because of its particular and indisputable knowledge of Kramer's foreign national
status. Yet it was Marvin Rosen-the DNC Finance Chairman, the
lawyer who held Kramer as a client, and the actual solicitor of
some of Kramer's contributions-who was in a unique and significant position. These factors make the reality that the FEC targeted
Greenberg Traurig, rather than Rosen individually, even more difficult to comprehend.
Greenberg Traurig eventually expressed a desire to settle the
matter, and did so based on the $91,000 the firm admitted soliciting from Kramer.4 8 The agreement noted that the firm lawyers
working on the immigration matters were aware of Kramer's foreign national status.' 9 The agreement did not detail which contributions the respondent solicited or which specific lawyers at the
firm were aware of his immigration status.
It should be noted, however, that the FEC may have actually
given Greenberg Traurig (and Marvin Rosen) an unfair advantage
when it decided to split the case into two investigations. By splitting the case, the FEC was allowed to place into the public domain
all of the facts involving all of the parties except Greenberg
Traurig. The law firm, with which Kramer had placed his trust to
advise him of the laws of this country and which in turn advised
him to break the law by making illegal contributions, was thus
given a chance to further distance itself from Kramer by splitting
itself off into a far less public investigation.
It should be further noted that Kramer's attorney objected to
splitting off the Greenberg Traurig case. In a letter written to the
FEC on June 20, 1997, Kramer's counsel wrote:
We are advised that the Commission has taken the very
rare, if not unprecedented, action of severing the above-referenced MUR [MUR 43981 to create a new MUR for one
respondent that has failed to reach a conciliation agreement with the Commission.
We have been told that in severing this matter into two
separate MURs, the Commission will redact from the public record of MUR 4398 certain facts that are essential to
a fair understanding of the case as it concerns our client,
Thomas Kramer. Specifically, we understand that references in our December 27, 1994 voluntary disclosure letter and in Mr. Kramer's accompanying affidavit to his having made contributions at the suggestion and with the ad-
2994
omissions will obscure the fact that Mr. Kramer had every
reason to believe he was acting within the law when he
made campaign contributions, the public's understanding
be skewed in a manner grossly unfair to
of the facts 5will
Mr. Kramer. 0
Kramer's counsel further pointed out that at no time did Kramer
ever advocate selectively publishing the facts surrounding his contributions. On the contrary, Kramer advocated full disclosure.
Whether by intention or by accident, the splitting of the case into
two separate MURs may have placed Kramer-who voluntarily
came forward and disclosed all his improprieties completely and accurately-at a disadvantage, while placing Greenberg Traurig in a
more favorable position.
III. MARVIN ROSEN, HOWARD GLICKEN, AND THEIR SOLICITATIONS
OF THOMAS KRAMER
A. MARVIN ROSEN'S INVOLVEMENT
1. Background
Marvin S. Rosen is a shareholder in the Miami-based law firm
Greenberg Traurig. He has a long history of political fundraising.
He personally raised more than $300,000 for Walter Mondale's prenomination campaign in 1984.51 Mr. Rosen also served as chairman
of Michael Dukakis' national finance board of directors in 1988 and
was one of former Florida Governor Reubin Askew's chief fundraisers.5 2 He has also raised money for a number of Democratic
Senators. He was elevated by the DNC to trustee status after raising more than $50,000 for an April 1993 dinner in Miami honoring
Vice President Gore. 53 He served as a fundraiser for the Summit
of the Americas conference in Miami and as head of the DNC Business Council.
Mr. Rosen became Finance Chairman of the DNC in September
1995. He did not, however, take a leave of absence from his private
practice upon assuming the chairmanship-resulting in criticism
from some of his colleagues for mixing personal and party business.5 4 As Finance Chairman, Rosen oversaw a staff of 110 people-setting broad strategy for raising funds, deciding where to
hold Clinton fundraisers, and soliciting money from donors. He has
since sought to distance himself from the investigation of campaign
finance violations, stressing his chairmanship position was voluntary and claiming that others had day-to-day management responsibilities.55 Press accounts have reported that the DNC is paying his legal bills. 56
so Letter from Roger M. Witten and Margaret L. Ackerley to General Counsel Noble, June 20,
1997
51 (Exhibit 25).
Jackson, Brooks, "Dukakis Nears a Fund-Raising Record With Big Boost From Greek-Americans,"
Wall Street Journal, Sept. 21, 1987 at Al.
52
Kenneth S. Allen, "Costly decision: Askew pays price for leaving race," St. Pete. Times, May
12, 31988, at 1B.
6 Florida Donors Memorandum, supra note 20.
" Michael Weissko f and Susan Schmidt, "Some Clouds Over a Rainmaker; Aa Democratic
pagT Finance Role Grew, So Did Lobbying Firm," the Washington Post, Jan. 26, 1998, at A8.
66Susan Schmidt, "Democrats Renew Attacks on House Panel After Staff Turmoil in Political
Funds Probe," the Washington Post, July 3, 1997, at A4.
2995
2996
called Rosen twice in the autumn of 1995 before Huang was finally hired. 65 Former DNC Finance Director Richard Sullivan,
before the Senate Governmental Affairs Committee, testified
that: "My sense of it at the time was that Harold had called
Marvin on-twice about it over the period of a couple of weeks,
and that is when Marvin acted on it."66 Rosen was prompted
to hire Huang after President Clinton approached him on November 8, 1995, at an event held at the Historic Car Barn:
Rosen, in a deposition before the Senate Committee on Governmental Affairs, stated that "I believe as part of the conversation, [the President said] something along the lines that he
believe that
came highly recommended or something, but I did
it was an approving comment at the time." 6 7 Rosen and
Fowler soon thereafter gave Huang the title of Vice Finance
Chairman, the No. 2 or No. 3 position at the DNC (according
to Sullivan). 68
* Rosen reportedly approved of the inclusion of Wang Jun,
head of a Chinese arms-trading company under investigation
for alleged involvement in weapons smuggling, at a February
6, 1996, coffee because now-indicted fundraiser Charlie Trie
and Ernie Green, a friend of the President's and a Managing
Trustee of the DNC, were6 9helping Huang raise money for a
then-upcoming fundraiser. Rosen also gave John Huang the
the Jefferson Hotel
go ahead for the July 30, 1996, dinner at
which raised $488,000 for the President.70
* Rosen's firm was also hired by Roger Tamraz, an Egyptian-American oil financier wanted in Lebanon on embezzlement charges. Tamraz hired Greenberg Traurig and donated
money to the Democratic party to promote himself and his proposal to build a $2.5 billion oil pipeline from the Caspian Sea
region of Central Asia to Western markets. Tamraz contributed
about $300,000 to Democrats in 1995 and 1996. A Federal
grand jury is seeking to determine if anyone tried to bribe or
pressure any Clinton7 1administration officials into supporting
Tamraz and his plan.
Tamraz claimed that the firm was hired for legal advice on
regaining some of his properties seized in Lebanon. The connection evidently came through Tamraz' hiring of Greenberg
Traurig lawyer Victoria Kennedy, wife of Senator Ted Kennedy. 72 Rosen and Sullivan met with Tamraz at the Four Seasons Hotel in Washington, DC on October 6, 1995. Tamraz
complained that he had been frozen out from the White House.
5
Don Van Natta, Jr., "President Linked to Urgent Enlisting of Top Fundraiser," New York
Times, July 7, 1997, at Al.
66Investigation on Illegal or Improper Activities in Connection with the 1996 Federal Election
Campaign Part I Before the Senate Committee on Governmental Affairs, S. Hrg. 105-BOO 92
(statement of Richard Sullivan).
(1997)
6
1d. at 1663 (statement of Marvin Rosen).
" Id. at 99 (statement of Richard Sullivan).
July
C. Miller and Glenn F. Bunting, Ex-DNC Official May Pose Biggest Party Threat,
9,699
70
See generally Tom Squitieri, "Democrats knew Huang might be trouble," USA Today, Feb.
19, 1997, at 09A.
7 David B. Ottaway and Dan Morgan, "Senate panel to study saga
of access and oil," Austin
American-Statesman,
Sept. 9, 1997, AS.
72
Edward Walsh, "Tamraz Defends Political Donations; Access
Top Officials Was 'Only
Reason' Pipeline Promoter Testifies," the Washington Post, Sept. 19, to
1997, at Al.
2997
Rosen promised to look into it. Tamraz was later admitted to
four White House functions. 7 3
Tamraz testified before the Senate Committee on Governmental Affairs during its campaign finance inquiry. When
asked by Senator Joseph Lieberman whether he thought he got
his "money's worth" for the $300,000 he gave, Tamraz replied,
"I think next time I'll give $600,000."74
* The DNC assumed $25,000 in bills incurred at Chicago's
Four Seasons Hotel during the 1996 Democratic Convention.
Greg Cortes, an attorney from Puerto Rico, had picked up the
tab for Rosen's $3,000-a-night suite, as well as part of the tab
for treasurer Scott Pastrick, after the hotel refused to provide
free rooms. Much of the bill was paid through wire transfers.
The DNC was concerned that the wire transfer may have come
from Cortes's South American business associates and thus decided to pick up the tab. The DNC also failed to report Cortes'
payment as an in-kind contribution to the party in its FEC filings. 75
3. Marvin Rosen and the Kramer Solicitations
Terri Bradley told the FEC she was able to identify the Greenberg Traurig partner who solicited contributions from Kramer, and
was aware of both telephone and fax solicitations evidencing such
solicitation. 76 This information was conveyed during a telephone
conversation between her lawyer and Jose Rodriguez, the staff attorney assigned to the case, in September 1997. Rodriguez was
asked about this information during a Committee hearing:
A: We had some discussion about the language that we
could include. Of course, what they wanted was some language showing that the client relied on, uhm, legal advice
from the law firm. If I understand correctly, we told them
that we would provide some of this language. We would
not identify the law firm of course. Nor would we include
language showing that the law firm solicited a number of
the contributions. But we would allow some language
showing the client's reliance on legal advice.7 7
Q: And I guess my question is up until 1997, what was
done to try to deal with this very clear, specific request
and, obviously a violation of the law because Ms. Bradley
did, in fact, make a $20,000 conduit payment, didn't she?
A: Yes she did.
Q: OK. And what steps did you take to try to find out
who this person was?
73
34. 4
Gregory Vistica and Michael Issikof, "A Shadowy Scandal," Newsweek, Mar. 31, 1997, at
7 Investigation on Illegal or Improper Activities in Connection with the 1996 Federal Election
Campaign Part VII Before the Senate Committee on Governmental Affairs, S. Hrg. 105-300 184
(statement of Roger Tamraz).
(1997)
75
Charles Babcock, "DNC Assumes Hotel Bills First Paid by Business Consultant," the WashPost, Jan. 8, 1997, at A14.
ington
7
Office of the General Counsel Memorandum of Telephone Call or Visit, Sept. 11, 1997 (Exhibit
77 26).
FEC Pre-MUR 307/MUR 4398, supra note 35.
2998
A: The steps that were taken were taken during the conciliation process, and I can't go into detail because it's confidential information.
Q: I understand.
A: We sought to gain further information on this transaction during the negotiations for conciliation. We did
not-the conciliation negotiations went quickly incidentally, settlement was reached quickly. Later on in the investigation when we could not find settlement or reach settlement with the law firm, we inquired further, and that
brings us to the conversation you saw earlier on the
other information that you have in your posTelecon 7 and
session. 8
Associate General Counsel Lerner testified before this Committee
during the same hearing that "there's also information that there
who were also involved in the
were other people in the law firm
solicitations, not just Mr. Rosen." 79 Yet in a statement provided to
the Committee after its March 31, 1998, hearing, the FEC reported
that:
The only Greenberg-Traurig individual specifically identicontributions in the file
fied as a solicitor of Mr. Kramer's
of this matter is Marvin Rosen.8 0
Based on evidence provided to the Committee by the FEC itself, it
thus appears that Rosen was the "named partner" to whom Bradley was referring. Unfortunately, the Committee was not able to
learn the identity of the "named partner" directly from Bradley because she asserted her Fifth Amendment rights before this Committee.
The Committee also discovered that Rosen solicited $60,000 from
Kramer at an event in March 1994 and another $65,000 from Kracompanies. Both of the contributions violated 2
mer through 8his
U.S.C. 441e. 1
B. HOWARD GLICKEN'S INVOLVEMENT
1. Background
Howard M. Glicken was born on November 16, 1943, in Miami.
He serves as the Chairman of the Board of the Americas 8Group
and is the former chairman of the Commonwealth Group, 2 the
College Democrats of America, and Jillian's Entertainment Corporation.8 3 He was fired from a Miami bank in 1983 after accepting
7'
soId. at 114.
eiDNC Check Tracking Form for 35 Star Island Inc. (Exhibit 27); Executive Summary for Mr.
Tom Kramer (Exhibit 28); DNC Finance System report on Tom Kramer (Exhibit 29); DNC Response to Committee Interrogatories, Mar. 30, 1998 at 30.3 (Exhibit 30); see also Karpel, Craig,
"Al 2Gore's Ties to Dirty Money in Miami," Apr. 4, 1994, at 1.
8 The business addresses are: Alhambra Plaza, Suite 620, Coral Gables, FL 33134; 1 Massachusetts Ave. NW, Suite 850, Washington, DC 20001; One Boston Street, 30th Floor, Boston,
MA 02108.
to Jillian's owns a chain of billiard parlor/restaurants in Miami, Seattle, Cleveland, and Boston. Jillian's was formerly known as Cam. Carom was one of two Miami companies indicted
by an Atlanta based grand jury on charges of money laundering as part of Operation Polar Cap.
Polar Cap was a nationwide attack on the financial end of the Medellin cocaine cartel. David
Sedore, "Carom and Analysts Say Indictment Misses the Mark," S. Fla. Bus. J., Dec. 2, 1991,
at 1. Falk and Duvan Arboleda, former chairman of the Orezana Corp. (another company in.
2999
a commission that his boss considered to be a kickback. 8 ' Mr.
Glicken also once headed MetalBanc Corp.,85 a precious-metals
3000
by Ambassador James Cheek and twice stayed as a guest of U.S.
Ambassador to Chile Gabriel Guerra Mondragon at the official residence.97 Mr. Glicken even accompanied the late Commerce Secretary Ron Brown on a 1994 export promotion tour through Latin
America. His mere presence troubled some delegation members:
squeamMr. Glicken's "wheeling and dealing" reportedly "evoked
ishness among a number of officials at Commerce." 9 8 His inclusion
thus raised the specter of political considerations possibly affecting
Commerce Department decisionmaking.9 9 Despite such controversy, Glicken prepared a memo for the Vice President upon returning from the trip. This memo appeared to raise some concerns
by staff members based on handwritten notes written on the letter's face.o10
The Miami businessman has also been considered for administration appointments. Mr. Glicken's nomination to the President's Export Council was approved by President Clinton in a March 1994
memo.1 0 1 After additional FBI information on Glicken arrived,
however, his candidacy was withdrawn. No reason was listed for
the application's withdrawal. 102 Mr. Glicken was also considered a
"strong candidate" and a "good fit" for the Delegation to the Inauguration of the new Colombian President. 0 3 The recommendation
memo noted that "Howard is on the Executive Board . . . of the
Maimi (sic) Coalition for a Drug Free Community-a famous international drug interdiction and prevention program. He served in
this organization with Janet Reno until she was appointed Attorney General."10 4 Mr. Glicken was also considered a priority for
participation in the Miami Hemispheric Conference, according to a
DNC memo.'O
Mr. Glicken has also been an active party fundraiser. He helped
raise money for the Democrats in 1992 and raised $2 million for
the party in 1996. He was elevated to trustee status (along with
Rosen) after raising more than $50,000 for the April 29, 1993,
Miami dinner honoring Vice President Gore.10 6 He served as CoChairman of the December 1994 Miami-based Summit of the Americas' business contingent.' 0 7 He attended coffees with both the
President and the Vice President, flew on Air Force One, and visited the White House on at least 70 occasions-staying overnight
in the Lincoln Bedroom at least once. 10 8 He co-chaired a March
the Western Hemisphere of the House Committee on InternationalRelations, 103d Cong., 2d sess.
(1994).
97 Kuntz, supra note 87 at As.
"Paul Blustein, "A Cloud Over Commerce; Politics May Have Tainted Choices, Policy," the
Washington Post, Dec. 22, 1996, at Al.
9100Id.
Glicken Letter and Memorandum to Vice President Gore, May 10, 1994 (Exhibit 32). Two
notations, which appear to be written in different handwriting, read "David-We Better Discuss
In Person-Thanks J.Q.", and "Jack/David: Will you p1s. Handle this-politics of whether we
mention this to Secy. Brown. Beth."
01 Candidate for Presidential Appointment Memorandum, Mar. 22, 1994 (Exhibit 33).
10 2
Individual Information Sheet on Prospective Presidential Appointees, May 5, 1997 (Exhibit
34).
103 Delegation to Columbia [sic] Memorandum, July 28, 1994 (Exhibit 35).
104Id.
105Hemispheric Conference Memorandum to Laura Hartigan, Aug. 16, 1994 (Exhibit 36).
Marvin Rosen was also considered a priority. Id. Mark Jimenez was also asuested part iant
and Thomas Kramer and Neal Harrington were considered as general priority d.
10oFlorida Donors Memorandum, supra note 20 at 7.2.
107 M. Delal Boer, "Latin American Free Trade Stumbles,"
Wall Street Journal, Asia, Nov.
2, 1994, at 6.
10'Howard Glicken: Democratic Events Attended (Exhibit 37).
3001
1994 Miami dinner honoring the President and Mrs. Clinton, which
raised $3.4 million. Senator and DNC Chairman Chris Dodd wrote
Glicken a letter on February 27, 1995, expressing his pleasure at
seeing him at a White House dinner and appreciating his "diligence
10 9
and hard work as a Managing Trustee of the Democratic party."
President Clinton thanked Glicken personally-who was seated in
the front row-during his opening remarks at the fundraiser. President Clinton also thanked Glicken in his remarks given at an April
1996 Miami fundraising event. In total, Glicken raised $2 million
for the 1996 Clinton-Gore team. Vice President Gore thanked him
personally for his role in a Miami fundraiser which raised $3.4 million.
Apart from his role as a fundraiser, Glicken appears to have
combined his political activities with his business ventures. In
1996, he founded the Americas Group (which counts former Senator George Mitchell as a board member) as a vehicle to encourage
business deals between the United States and Latin America. 1 0
Mr. Glicken reportedly took a group of South American businessmen and politicians to meet President Clinton at a December 1996
reception at Miami's Biltmore Hotel."" He also met with officials
the NSC, and the
from the personnel and political affairs offices,
Presidential and Vice Presidential staffs.11 2 On another occasion in
1996, Glicken brought a client from Brazil to meet Ronald Klain,
Vice President Gore's Chief of Staff". 3
3. The Case Against Howard Glicken
Mr. Kramer's secretary, Terri Bradley, made a $20,000 contribution to the Democratic Senatorial Campaign Committee ("DSCC")
after someone unknown to Bradley-later revealed to be Glickenapproached Kramer. According to Staff Attorney Rodriguez, in testimony before this Committee and in documents produced by the
FEC, Bradley overheard a conversation between Kramer and another individual who asked Kramer if there was "anyone else who
could make the contribution in your place." 114 The solicitor promised that the "requested contribution would make Mr. Kramer a
member of the 'inner circle' with various accompanying perks."
Bradley told the FEC that she would divulge the name of the
Democratic fundraiser suggesting 5 the illegal scheme in exchange
for immunity from prosecution."1 The Committee attempted to
interview Bradley but, as previously noted, she asserted her Fifth
Amendment rights before the Committee. The plea agreement
Glicken entered into focused on Bradley's DSCC contribution-the
questionable contribution referenced along with the "prominent
fundraiser" language that resulted in tremendous public criticism
109Dodd
1996, with
110 The SEC objected to the merger of Americas Group which Glicken founded in
to 18 prcnt
Advanced Electronic support Products in 1996. A group oi shareholders amount
of the fund are suing Americas Group for 'blatant self-interest.' see S. Fla. Bus. J., De.2,
1991,1 at 1.
M Kuntz, supra note 87.
Scores of Times,"
1Kuntz' "Democratic Fund-Raiser Glicken Visited White House Officials
Wall Street Journal, May 5, 1997, at A20.
11sId
Office of the General Counsel Memorandum of Telephone Call or Visit, supra note 76.
n^m
11
Tamara Lytle, supra note 90.
3002
and which played a significant part in the Committee's March 31,
1998, hearing.
Despite all of the controversy surrounding this Democratic party
insider, the FEC decided in December 1997 not to pursue a case
against Glicken. This decision was made in the face of strong evidence demonstrating that Glicken had knowingly solicited an ilegal contribution from a German national through a conduit straw
onor. In an unusual announcement, the FEC cited "Mr. Glicken's
high profile as a prominent Democratic fundraiser" and "potential
fundraising involvement in support of Vice President Gore's expected presidential campaign" as reasons not to pursue a case
against Glicken. 116 During testimony before this Committee, the
FEC General Counsel stated that his office first learned Glicken's
name only a few months before the statute of limitations governing
the case would expire. Yet, as previously noted, the FEC was first
provided with information by Kramer himself that someone within
the Democratic party knowingly solicited the illegal contribution as
early as December 1994.
When asked during the Committee's March 1998 hearing why
the FEC did not pursue a case against Glicken more aggressively,
FEC General Counsel Lawrence Noble stated:
We did not pursue the investigation of Mr. Glicken because it was-most of the activity at issue was 1993 activity; some was 1994. We have a 5-year statute of limitations. Mr. Glicken's name came up late in the process. We
have not found reason to believe against Mr. Glicken. We
would have had to start from the beginning with Mr.
Glicken. The statute of limitations on the main part of a
solicitation runs this April. 117
*
What we were interested in with Mr. Glicken was the suggestion that he may have suggested to somebody that they
make a contribution in the name of another. And that took
it up to another level which is why we held on to that part
of the case, thinking that we might be able to do something about it. But by the time that-that was in the
DSCC information. We did not find Mr. Glicken's name
until July 1997, and that particular contribution, where
there was a suggestion that it was a contribution in the
name of another, or solicited as a contribution in the name
of another, the statute of limitations would have run at the
end of April of this year. 1 8
It should be noted that the FEC did not "find Mr. Glicken's name
until July 1997" because, in actuality, it did not send a subpoena
to the DSCC until June 10, 1997.119 Documents produced in response to this subpoena revealed that Glicken had solicited the
Bradley contribution. No explanation given by the commission has
adequately addressed why the FEC waited until 2Y2 years after re116
3003
ceiving Kramer's affidavit (which highlighted the DSCC contribution)1 2 0 to send interrogatories to the DSCC. It is thus the Committee's opinion that this explanation-given the amount of money
involved, the fact that the case was brought sua sponte, and the
involvement of two of the most prominent Democratic fundraisers-is simply incomprehensible.
IV.
121"Bradley
3004
of the matter and the already successful resolution concerning all principles in this case, this Office does not recommend further proceedings concerning these two DNC
contributions either. Instead, this Office recommends closing of the entire file in MUR 4638.125
Once the conclusion about Glicken and his association was reported in a major newspaper, the interest of the Department of
Justice in the matter was notably increased. Such interest is obvious in an e-mail sent by Lois Lerner to Lawrence Noble on February 12, 1998:
Donsanto just called. They've seen the "offending language." While he was sure there must be more to the story
than this was Gore's friend, he wanted to know why this
hadn't been referred to DOJ. He said that Task Force
would be revving up an investigation unless he could provide them with something clarifying this. While I have no
problem with them investigating, I thought it would be
useful to provide them with whatever statement we make
to the press. 126
Despite the Justice Department's previous lack of interest in
these matters, the Task Force did indeed 'rev up' an investigation
and entered into a factual proffer and plea agreement with Glicken
on July 9, 1998-3 months after this Committee held its hearing
reviewing the FEC's management of the Kramer matter-in which
Glicken admitted to criminal violations of FECA by soliciting political contributions from a foreign national and by causing a political
contribution to be made in the name of another.12 7 Based on the
agreement, Glicken potentially faces up to 2 years in prison and a
fine of $200,000. The Justice Department recommended a fine of
$80,000 and a minimum of 500 community service hours. Mr.
Glicken also "expressed a desire to provide substantial assistance
to the Government in the investigation and prosecution of others
after entering his guilty plea"1 28 and that he "shall cooperate fully
with federal law enforcement authorities."1 2 9 Mr. Glicken also
promised to "make himself available to all Government
agencies[.]" 3 0 If Glicken's guilty plea agreement is accepted by the
Court, and Glicken fulfills each of the terms within the agreement,
then:
[T]he Government agrees that it will not further prosecute
defendant for his conduct that is the subject of this plea
agreement or for any other election code-related conduct
known to the Government as of the date of defendant's
guilty plea pursuant to this agreement, or which becomes
known as a result of his cooperation pursuant to this
agreement.131
25
13oId. at 44.11.
la Id. at 44.4-44.5.
3005
Taking into account the weight of the evidence against Glicken,
it appears as if the Miami businessman entered into what potentially could be an overly favorable plea agreement. Mr. Glicken's
role in soliciting contributions from other Florida-based campaign
contributors on behalf of the DNC and other Democratic causes has
yet to be fully investigated by this Committee. However, the Committee has uncovered evidence showing that Glicken also solicited
contributions from Neal Harrington and Calvin Grigsby's company,
Fiscal Funding 13 2-contributions which led to the indictment of
both Harrington and Grigsby, along with Carmen Lunetta, in the
June 1998 Port of Miami conduit contribution scandal.13 3 Whether
or not such evidence was available to the Department of Justice at
the time it entered into the plea agreement with Glicken, which
would determine whether or not such action would fall within the
aforementioned immunity agreement, is not known by the Committee. Glicken asserted his Fifth Amendment rights before the Committee unless granted immunity.
Because Glicken has exercised his Fifth Amendment rights in regards to the Committee's inquiry, the Committee's investigation
into further misfeasance on Glicken's part has been impeded. This
is not the cooperation that Glicken promised upon signing his plea
agreement. The Committee has not been able to explore why the
two additional illegal Kramer contributions solicited by Glickena $25,000 contribution at Vice President Gore event and $40,000
contribution at a President Clinton fundraiser-were passed over
by both the FEC and the Department of Justice.13 4 The Committee
is also not privy to information the Department of Justice may
have in its possession regarding any additional campaign fundraising improprieties that may have been committed by Glicken. The
Committee is thus not aware of which improprieties would be covered by the immunity agreement if it were to be upheld by the U.S.
District Court for the District of Columbia.
V. CONCLUSION
FEC's handling of the Kramer matter brings into serious question the Commission's goals and effectiveness. Several points need
to be emphasized. Notwithstanding the knowledge that a high-profile Democratic party fundraiser was allegedly involved, the case
received little attention by the FEC for nearly 1/ years after Kramer first disclosed his improprieties. In actuality, the FEC did not
send an inquiry to the DSCC regarding the contribution until 2
years after receiving Kramer's affidavit. Perhaps more important,
the FEC appears to have done nothing to pursue the allegations of
wrongdoing against Marvin Rosen. Although the Committee recognizes that the FEC must prioritize its many cases, few things
would rival in importance the possibility that one of the titular
heads of either the Democratic or Republican parties is involved in
132 1994 Florida Presidential Dinner Donors, at 45.3 (Exhibit 45).
13 3
United States of America v. Carmen Lunetta, Calvin Grigsby and Neal Harrington (So. D.
FL June 3, 1998) (Exhibit 46). Messrs. Glicken and Harrington, along with Charles Intriago and
Mark Jimenez (both of whom have asserted their fifth amendment rights before our Committee)
were noted guests at a December 1994 Brickell Key dinner hosted by Vice President Gore. Vice
President's Guest List, Dec. 11, 1994 (Exhibit 47).
mDNC Response to Committee Interrogatories, Mar. 30, 1998 at 30.3 (Exhibit 30).
3006
criminal conduct that cannot be explained away by "fuzzy" or "complicated" election laws.
In addition, the case ultimately resulted in over $500,000 in
fines, including the largest personal fine of its type. Such fines,
however, barely totaled more than the contributions themselves (all
of which were returned to the contributors).
Finally, the FEC made a public statement in which it seemingly
admitted that it was not pursuing a case against Glicken because
of his prominence and strong ties with Vice President Gore. Prominent national fundraisers should face the same consequences as
any other citizen if they encourage others to break the law. The
FEC, in neglecting to investigate and pursue such blatant violations of campaign fundraising laws, appears to have been derelict
in its mandated statutory responsibilities.
APPENDIX 1
FEC PRACTICES AND PROCEDURES RELEVANT TO THE KRAMER MATTER
In the early 1990s, the FEC began to reinvigorate its case management system. In 1992, the Commission adopted a criteria worksheet, or "rating sheet," that provides numerical ratings for its
cases. 2 The following year, the FEC "launched substantial enforcement reform by adopting a comprehensive prioritization system designed to produce timely resolution of major cases." 3 Known as the
Enforcement Prioritization System ("EPS"), the specific elements of
the system included:
* Creating a detailed and objective method for ranking
cases that allow the Commission to identify those which
best warrant the use of the FEC's limited resources.
* Determining, based on resources, the total number of
cases the enforcement staff can actively and efficiently
pursue at one time.
* Establishing realistic time goals for resolving targeted
cases (preferably within an election cycle or less).
* Managing and tracking cases through periodic priority
evaluations so that staff assignments can be adjusted as
LCase Disposition by Fiscal Year: Cases Involving Conduit Payments under Section 44if (Exhibit A-i) and Case Disposition by Fiscal Year- Cases involving Foreign National
Contributions
Under
Section 44ie (Exhibit A-2).
2
Introduction to the Enforcement Prioritization System (Exhibit A-3).
FEC Press Release, Dec. 13, 1993 (Exhibit A-4).
3007
needed and cases that warrant no further resources can be
identified for closing.
* Creating a center enforcement docket system ("CED") to
process incoming cases and assign them as staff become
available.4
The FEC based its prioritization procedures mostly on confidential standards, some of which include: whether there was knowing
and willful intent to violate the law; the apparent impact of the alleged violation on the election process; the amount of money involved; the age and timing of the violation; and whether a particular area of the law that needs attention is involved. 5
General Counsel Noble told Committee investigators that the
focus of the EPS has changed over the years. According to Noble,
things like the $25,000 contribution limit used to be a "big deal"
to the FEC, but now things like contributions made by a foreign
national are given higher priority. 6 While the Committee recognizes the FEC's limited resources, the fact that the Commission periodically changes the degrees of priority for violations of campaign
laws inevitably forces oversight bodies, such as this Committee, to
question the Commission's enforcement objectivity. In controversial
cases such as the Kramer matter, the FEC can thus argue that
seemingly flagrant violations of law were not considered as a priority by the Commission based on standards and criteria which remain confidential to everyone outside of the FEC staff.
B. CASE MANAGEMENT
Any action by the FEC generally begins upon the filing of a complaint alleging violations of Federal election campaign laws. Within
5 days of receiving a complaint, the Commission notifies any person alleged in the complaint to have committed such a violation.
Before the FEC votes on the complaint, other than a vote to dismiss, any notified person has the opportunity to demonstrate to the
Commission that no action should be taken against such person on
the basis of the complaint.
If the Commission, by an affirmative vote of four of its commissioners, finds that it has reason to believe ("RTB") that a person
has committed, or is about to commit, a violation of Federal campaign laws, the Commission shall, through the chairman or vice
chairman, notify the person of the alleged violation. The FEC then
conducts an investigation of the alleged violation. If the Commission determines, by an affirmative vote of four of its commissioners,
that there is probable cause to believe ("PCTB") that any person
has committed, or is about to commit, a violation of Federal campaign laws, the Commission attempts, for a period of at least 30
days, to correct or prevent such violation by informal methods of
conference, conciliation, and persuasion, and to enter into a conciliation agreement with any person involved. Any attempt to correct
or prevent any violations may continue for a period of not more
than 90 days. The Commission may not enter into a conciliation
4
1d.
5
Remarks by Scott E. Thomas, Chairman of the Federal Election Commission, Dec. 13, 1993
A-5).
(Exhibit
i
nterview with Lawrence Noble, General Counsel of the Federal Election Commission, in
Washington, DC (July 2, 1998).
3008
agreement unless pursuant to an affirmative vote of four of its
members. A conciliation agreement, unless violated, is a complete
bar to any further action by the Commission.
C. FINES, PENALTIES, DEFENSES, AND MITIGATION OF OFFENSES
3009
tribution or expenditure involved in such violation. In the case of
a knowing and willful violation of 441b(b)(3), the penalties shall
apply to a violation involving an amount aggregating $250 or more
during a calendar year. Such violation of 441b(bX3) may incorporate a violation of 441c(b), 441f, or 441g.
In any criminal action, a defendant may evidence their lack of
knowledge or intent to commit the alleged violation by introducing
as evidence a conciliation agreement entered into between the defendant and the FEC which specifically deals with the act or failure to act constituting such violation and which is still in effect.
The court shall take into account, in weighing the seriousness of
the violation and in considering the appropriateness of the penalty
to be imposed if the defendant is found guilty, whether the specific
act or failure to act which constitutes the violation for which the
action was brought is the subject of a conciliation agreement entered into between the defendant and the Commission, the conciliation agreement is in effect and the defendant is, with respect to the
violation involved, in compliance with the conciliation agreement.
[Supporting documentation follows:]
3010
Exhibit 1
MUR 4398
44 1c.
437g(a)(4)(A)(i).
II. Respondents have had a reasonable opportunity to demonstrate that no action should
be taken in this matter.
III. Respondents enter voluntarily into this agreement with the Commission.
IV. The pertinent facts in this matter are as follows:
1. The Republican Party of Florida is a political committee within the meaning of
2 U.S.C. 431(4)(C).
3011
2
2. James H. Stelling is the treasurer of the Republican Party of Flonda.
3. The Republican Party of Florida, a party comminee as defined under
II C.F.R.
100.5(e)(4),
102.5(a)(1)(i)
to establish separate
federal and non-federal accounts from which to conduct its federal and non-federal activities.
The Republican Party of Florida has registered its federal account with the Commission under
the name the "Republican Party of Florida Federation Campaign," and submits its state filings
under the name the "Republican State Executive Committee of Florida."
4. Thomas Kramer is a foreign national as defined at 2 U.S.C.
II C.F.R.
441e(b)
and
110.4(a).
5. The Portofino Group, Inc. is a domestic incorporated entity owned and controlled
by Thomas Kramer.
6. On June 4, 1993, Respondents received and accepted two separate contributions
of $100,000 and $5,000 from the Portofino Group, Inc. which were deposited into the
Republican Party of Florida's non-federal account. These contributions were made under
Thomas Kramer's control and at his direction.
7. On March 3, 1994, Respondents received and accepted a $100,000 contribution
from Thomas Kramer. Respondents deposited $5,000 of this contribution into the Republican
Party of Florida's federal account, with the remaining $95,000 going into the non-federal
accounts and then transferred into a segregated redistricting account.
8. Respondents contend that they accepted the contributions from Thomas Kramer
and the Portofino Group in good faith and without any knowledge that Mr. Kramer was a foreign
national or that the Portofino Group was controlled by a foreign national.
3012
3-.
or through
9. It is unlawful for any foreign national to make a contribution directly
any local, State or Federal political office, or
any other person in connection with an election to
or indirectly participate in the
for any foreign national to direct, dictate, control, or directly
corporations, with regard to
decision-making process of any person, including domestic
elections for any local,
decisions concerning the making of contributions in connection with
State or Federal office. 2 U.S.C.
441e(a);
11 C.F.R.
110.4(a).
10. Further, it is unlawful for any person, including political committees. to accept or
receive any such contribution from a foreign national. 2 U.S.C.
44le(a);
II C.F.R.
110.4(a).
11. The Commission has held that funds used solely for non-campaign related
redistricting issues are exempt from the foreign national prohibition at 2 U.S.C.
441e.
See AO
1982-14, 2 Fed. Election Camp. Fin. Guide (CCH) 15655 (April 9, 1982); see also, AO
1981-35, 2 Fed. Election Camp. Fin. Guide (CCH) 15619 (Sept. 28, 1981).
V. Respondents accepted and received a total SI 10,000 in contributions from a foreign
national, in violation of 2 U.S.C.
441e.
VI. Respondents will pay a civil penalty to the Federal Election Commission in the
amount of Eighty-Two Thousand Dollars ($82,000), pursuant to 2 U.S.C.
437g(aX5XA).
437g(aXI)
concerning the matters at issue herein or on its own motion, may review compliance with this
agreement If the Commission believes that this agreement or any requirement thereof has been
violated, it may institute a civil action for relief in the United States District Court for the District
of Columbia.
3013
4
VIII. This agreement shall become effective as of the date that all parties hereto have
executed same and the Commission has approved the entire agreement.
IX. Respondents shall have no more than 30 days from the date this agreement becomes
effective to comply with and implement the requirement contained in this agreement and to so
notify the Commission.
X. This Conciliation Agreement constitutes the entire agreement between the parties on
the matters raised herein, and no other statement, promise, or agreement, either written or oral,
made by either party or by agents of either party, that is not contained in this written agreement
shall be enforceable.
wrence M.Noble
General Counsel
FOR
RESPO
L. Ginsberg
Co
Date
Date
3014
Exhibit 2
'0
In the Manerof
MUR 4638
1.
INTRODUCTION
On October 30.1997. the Commission me
Thomas Kramer a foreign nmional. to FederaL. sate and local elections during the 1993-1994
election cycle.1 At the same time Respondem was provided with the Commissions proposed
conciliation agreement. Seethe General Comuers Report in this matter ("CR')
dated
Additionally.
this report analyzes the remaining issues and participants involved in Mr. Krumer's contributions
and recommends closing the matter without further proceedings.
M Krner*s contnbutomt
erre
addrned a predecono
MUR 4)91
3015
4
EL
Remaining Pardcipsaft
As noted in previous reports in this maner and in predecessor MUR 4398. in his sue
spomre submission Mr. Kramer suggest that antuamd individual associated with the
lDemocrtic Senatorial Campaign Committee ("DSCC") had instructed him to make his S20.000
April 28. 1993 contribution in the name of his secretary. in violation of2 U.S.C. 44I f. During
the course of the mater, this Office sought information concerning this transaction. including the
identity of the individual involved. While this Office has discovered information identifying an
individual credited for soliciting four of Mr. Kramer's contributions to the Democratic Party (two
each to the DSCC and the Democratic National Committee CDNC")). including the contribution
made in the name of his secretary. the available evidence is inconclusive as to this individuals
actual involvement in suggesting that the contribution be made in the name of another.'
Specifically, the available evidence obtained from the DSCC suggests that Howard
Glicken, a south Florida findraiser, was responsible for both of Mr. Kramer's contributions to
the DSCC. including the $20,000 contribution made in the name of his secretary. However, this
information is not conclusive. In its response to the Commission's interrogatories. the DSCC
notes that it is -without any specific information responsive to this request other than to state its
C.belief that Howard Glicken may have been involved in soliciting these contributions." DSCC
response dated July 16. 1997. at 4. Accompanying this response are documents relating to the
contributions: however, these documents do not confirm Mr. Glicken asthe solicitor, instead
litce conuibutioms
includeMr. Kramer's Aril 21. 199)520.000 contribution (made Indiename ofhn
wsretary andSeptember
17.1993$3.000 contributions
to thef)5CC andMr. Krar's Apni 14.1993$25.000
cnmtraihumn
(madethroughPauim Group, liaI and Much I t. 1994540.000 contritushon
te theDemocratc
%.tsNAl (ommitarc
3016
5
they show two uidentifled entries under the fundraising heading-"Cooper" for the S20.000
contribution and MJV" for the S3.000 cotrition.
Moreover, there is only limited evidence reading the Section 441f scheme. Mr. Kramer
in his ua sponse submission.while suggesting that the he was instructed by a D5CC fundraiser
to make lis S20.000 contribution in the name of his secretary - Terri Bradley, fails to identify
this individual or provide details of the conversatiot. Similarly. in conversations with this
Office, counsel for Ms. Bradley, while noting that his client recalls the suggestion being nade to
Mr. Kramer. refuses to provide further information or the identity of the fundaiser without a
grant of inunuity from criminal prosecution. While further inquiry of the DSCC may clarify the
apparent inconsistency concerning Mr. Glicken's attribution as the solicitor, because of the
a
discovery complications concerning the Section 441fissue, this Office does not believe that
sufficient time remains within the statute of limitations period to adequately investigate the more
substantial April 1993 contribution made in the name of another.
While this Office would generally recommend a reason to believe finding against
Mr. Glicken and conduct an investigation into the two DSCC contributions, because of the
discovery complications and time constraints addressed above. and the fact that the transctions
as issue took place during the 1993-1994 election cycle, this Office does not now recommend
proceeding against this identified individual or the DSCC.
Similarly. this OMce does not recommend further proceedings concerning the
two DNC
contributions apparently solicited by Mr. Glicken. Unlike the DSCC contributions,
the larger of
these two contributions would not betime barred until March of 1999 - approximately
a year
and lour months from now. however because of Mr. Glicken's high
profile as a promInent
3017
6
Democratic fudraiser. including his potential fundraising involvement in support ofVice
President Gore's expected presidential campaign. it is ner
settle this m
Unspecified period in pursuit ofone participant and because ofthe low prospect for timely
resolution, the age of the matter and the already successful resolion concerning all principals in
this case, this Office does not recommend further proceedings concerning these two DNC
contributions either. Instead, this Office recommends dosing the entire file in MUR 4638
Therefore, this Office recommends that should the Commission agree with the above
assessment concerning further proceedings in this maner, it close MUR 4638. Should the
Commission not agree with this assessment. this Office recommends that the Commission close
the matter only as to Greenberg and Traurig.
Ill.
COMMENDATIONS
1. Accept the attached conciliation agreement with Greenberg, Traurig, Hoffman, Lipoff
Rosen & Quentel, PA. in settlement ofMUR 4638 and dose the matter as to this
Respondnt.
2. Close MUR 4638
3. Approve the
appropriate letter(s).
Lawrence M. Noble
General Counsel
Date
'y
Lois G. Lerner
Associate General Counsel
3018
7
- Am
3019
Exhibit 3
1.
is
My name
Thomas Kramer.
in
I am a real estate
The donor companies
under the laws of the state of Florida and are wholly owned by
me.
am a Cerman citizen and am in the United States
2.
on an E-2 visa.
: rad.
od
also personally
:.1s period.
I was
u.S.C.
not
including
I speaO
Engt1sh
know
with
w* realize I am German.
e saus: ny
3020
-2-
6.
Greenberg,
Traurig.
Lipoff.
The Greenberg.
Hart.
including
Traurig
Principals at
request electicn
Mirars.
However.
Traurig to
were
:he law.
aware
any .ssue as to
::
were
at:.re-gn
y '.egal
rateens..
ability
-**e
contributions.
7.
prettlatlc.
: wee
Af:er consultaticn
: requested refund
compnes
0!
article
in
the
ry contributions may be
with co..sel
3021
.3-
8.
7erri Bradley.
I have req-uested
in
I reimbursed Ms.
I do
b.
recollection,
(*DSCC")
on April 28,
1993.
To the best of my
if
any.
explana::t:
S.
citizens.
DSCC
would
I do no: recall
In any event. I
did not understand at the time that I was being advised that it
waS unlawful for the DSCC (or any one else)
c:ntributions free
because.
to
the
crei;n na:enals.
I proceeded as I did
y recollection.
best of
c.e
to accept political
I have
involved.
S.
chart of contributions
the accompanying
3022
The &s
:&s
Jj
Ader
as
identificaticn
Notary Public.
Print Name:
Cnrmission
Com-mission
State of Florida
trAv
A.
1JA4
Number:
Expires:
(SEAL)
or01.0
NUMBEA
UaCOMMSS altp
AUC. 15lead9I
3023
Beachwalk
Development Corp.
new Fiesta. Inc.
Corp.
Holding
Oly:pus
Playa Del Sol. Ltd.
Portofino Group. Inc.
Sandpoint Financial, Ltd.
Santorini Isle, Inc.
SBE. 'Inc.
Seagull Development Corp.
South Beach Creative Group.
S:. Tropez R/B Fund. Ltd.
Sun & Pun. Inc.
2 Star Island, Inc.
3024
-cow
--
S.I.LI
C-
Too B.d.y
DS=
Tb-
Ty.DSCS
Mv.M Di.._
f.lb
G,.w t-a.
-.
W17M9
%D
T.
3D.U9"VOW
T.
3wmm
4mW"
P..LdCI
X-
40M&
SIWM
2.inh
S.WA
T.
tWOi.W
Y.
1S.in 00.
tod
s~noW
lam
1=.00
i2100
v.0.
Thooo Ka-o
FicdCn
Ttam X-to
FkdM..
MoO
12fl03
tJ.SW
Y.
Fr.o.f tafO
121163
tJ.0.
Y.
too. sk C-o.CF~
1 2993
stw m
7-193
5W.A
C-o
Ioo-
4111"3
SM.00
C-
7b-.
ft.dl
O yP o.
p .
Ponorm
G-oP. to.
S-A F-
-%a-b
T.
JAM
U.S.
r-o
__
MAM114
wmGolz
20A12
Rpbb lq.ItPo .1
WAM. SM
APIN19
ft
MA AAA
-__
10-d a" A
K.
-4m
-..
--
P.-
T.
MAW~
MOM5A
3025
.
-M.
-M-
An&-
12,11wma
.-
Cbav
Shy.
C.."6 b.
N. a-
b.
3i F
T. a
own
ND-9,rn.
FR
SY Ebb
414m
lo.w
T.
4IFPS
mm
T.
4/rZM
3mm
~
Sy
Shy.
f~ P.
yS3
nN mm
Fod
S..._____
612:m
______
Moo
5.5/. F-.
G .2.
L."
5/Nm
5*2/5
Y.
4114/S93
R..t2
5Mm..12MM/W
mom
-.
(-Ya
Y.q..u3FA
_____wbdS
6/22/93~
3y
3" Y
inD-
cwir-
T.
t22/n
m
TSWmI2
&'d.
_______
Fi
S2.
Eb._______
_______
SdpFW-L
SM.. WIn
va
sm Ebia
2.&F-W
&
Do-t
Ta
a___
unD1Miy
3026
Ammed
-
guard
5.Tum
-m
nd
ams
Lwry
l.
#I.an -
sum
L&
3.
j___m
If
5.
Trope
sLs.
s.
- FL
L3
Kmld
Mt
massafedM
Ye
Y.
-e
S-
3121M
itv
I-w
gma
lnw
393
T.
Ys
SWI9M
S.
tIW~19
SW
Ye
was
sea3es
c.._...-..
uSO.
2=
.*,
Karpd
Mike Empel
sun& Funin
Mm
Phy Dd So LaL
Lad
B!.491h
MikenLpd
anciW
7a&3
eUN
Sa
SO
L .d
anw-"'.
1 Empin
I~
Nw
4a-
L.p-an
MrEme
d;
--
Smm
WIll
sham
--
MikeEspel
D samria Miease
Sdpin=mail d9
Mi arpel
tl.
Campipped
SHEI..
Mike Eapd
cF-d
Inm.dha
Mi
Immhar
Lpd
Mkr
al
mmu
30119.9
sM"
tim
2w
iWW
T.
WM SO
119193
Y.
Yom
SIDE
01f91
Yes
.M
Yes
_
102.93
IGL21M9
sWZ
SW.W
cah)
Thasa K
-Ked Lai
campalpm ad
4-3-3
Inrains
Nia.as.di
AprB 93
S.0
Esc
Unknown.
Yes
5135.0
3nSW13
(feminons enlia
3027
DOL
am Pod
k1.
r."
4___
I
F~.
N-.D
TP
3d- b-~
aAE
-
SM
-b
__wo
SOLO_
___-
S~3~
-d
Mm Lft
fiU
%-TLa-
amm~
% .g.-
W-
t.6
SL
&i"
WWY
iE
a d
lM
G-L-
T.
sm
T.
mm
so"_
____m
GML..a
5mm
_.
izUm
SM0
T.
Izem~
SInAD
Y.
I2zmm
9"f
Y.
jC.00
V.
C-___
S.a A.
CAY.
ba Na
M L..b
C.g
L-N i
G-
Gaq.
_______________.
SO____
C-_
-"I
C-MO"
I.d
li2.m
100.00
1 y"
I SIOOAC11OLM
3028
a
--
oC.8"
-
SM bkL1
lS .
(I.-
SLTwo.WE F.O
R.
a-O . 1m.
.w.
me L-
L-
M.olo.
CWp
f-
C.."
qmmw~
f.
Aril
mom
difim
SOL
MUM.9
X0m0
T.
-w
T.
man
1
Y.
IM
MRS~
3a
3mm
C--i s
s.m
A io
D..do-
Co.
Lid,
C-.W h,
C
fo.
C
h f
a.. P.
1h
Vkoy
imv
3AU
SOm
To.
sm
3mla
asm- tan,
. SNO
]hVk S-i
S-90.f
Crp.
,--
-3121MG
mum
l2r,"
3029
3030
Exhibit 5
aN.7o
DONo
Group:
To:
From:
Re:
Data
PO
SCRt!RQ-
Xent*
Joe_
Nancy_
Kiki
you
a
nelow is information about the above-reerenred donor.
ONC-s
to the
inlformation and/or Objectionls with
3*e0v anyadiona
comments,
send this for,
receipt Of this contribution, please
to Kent arkus by close of business,
of Donor:
_ Nam
a Mr,
5 000
Amount of contribution:
as-q 0 Address:
-^ CL S
-TV% a
'
.0
(v-
Car
n f- W.
Employer:
Ponr
La-
Donation:
sent
to
Research:
of
e y.>
IL.4 -S
yee:
NEXIS SZARl:
FE OKLINE SEARCH:
(Attach Susary
DC
Akat*FS
_
l*e
Ve
No
'41Urq/ 3,
Date:
No
No
Findlngs)
Deposit
Return to Donor
Com:itee CmenteS:
C-e? Or Staf
LeIs:
Disposition.
2)
Date
Chisf
by close of business
Deposit
Of Notification to Legal
Return_
Dept.
of Statt:
or
3031
Copyright 1993 Canads NewsWise Ltd.
Canada NewsWire
AprD A. 1993, 7bursday
SECTION: Fiandal News
DISTRUTION: Anim Busine
Editors
LENGTR- 27 wor
READLIL VANCOUVER STOCK EXCHANGE - COMPANY MEETING DATES NMET
FROM APRIL
10. 1993 TO MAY 10. 1993
DATE
KEYWORD
VANCOUVER Aprg I
C-vanm
onugasm
Mar 25 Apr 30 A
Mar 9 Apr 15 A
Mar 26 May 7 AG
UEWWUWEWUWEW
DNC O62t598
3032
Copyright 1993 FForbes
,~Inc.
March 1. 1993
SECTION: MONEY & DvESVMhG; Pg. 58
LENGTH: %EA words
EALDL-
BYLINE: By Phyllis mg
HIGHLIGHT:
?.Czan Bcach's South Beach hasbecme the nsew Moca of Eu2owash Meet Thomras;
Lrawc
BODY:
SOUTH BEACH. hOA)M REACH. South Batcsi ts l way is hone than Saint-Troe
waback in the l7IM. Thnm s n Brigitt Bardat. butl gorgeous male and
female models amin Plenftiu supply. Lawe
afteouoosss and atiry evenings.
Ocafrn c i wich rich Euiorash. wholater reair to cendy clubs
where they drink; and duce until the next Florida siuiin.
Thomas X-ar us the bie of t South Beach party. He is flamboyant eve
by Etwicb standards 1TseOmeui-bam Liamos. 35, educated at a fancy Gerrnan
boadig school, is dashingly handammandanupnt.
The Florida pmn h-v t mo w ama. Lasu summer he tr down a house on
exclusive Indian Crick Iland Is make Mnth(o a new mansion. But he never
built the mnansion. WSeg his i
, alpo . 'I don't want tW live surrounded by
Old Peple -oa *si C-P as iae a&andssd lu budding plans after powadsd
1114bm
1 th Oe u11068
gol dub hired a pnsa= invstgator to track him. Hr
III= threatened as bwld a auriing &sense aus I an
4ma
a In P-'$m
WW oa anArcL. - for which he paid S 2.9
inson. HebugsUlu he" -aCOICUCI
- buy Chnxana Onssis chalet in
Saint Mona- aNWals cIla 10" Oncs., wfa CIUAMsj~e Lady GhsLaine*
Robar Raialls oWd YICLL
He made the Paes 46" a UNrw%
macuilar Hallosccn-ugst bash
fewhis ruigtclub. alW aL
Tive1 were- f~rywks anda naked womaun
lysng an
atable wihapa
f-ia-9
el
ms were invited to dtp
snwbena in **se"U 62"M101
Wn n
&C-iaeci. Lamer istruedM the
"tl Th6 I&ane Pameeand by pLassersin Naz emblems
drepe s bar' ho
- his 2948 Mcrede ond 0,e cant
Iug~rfgguuais~~iDNC 06283-~q
3033
AlDvery decadent.
ButS y~rAmehas a busmsei de. Loo He has spent over S 40 million buying
ml~ waznein South Beach: 5 rsenti~al properces on Star Island, 2
properties ansIndian Creek IWand and 20 aparaninsin in ocenfront Sout Pointe
According to a Miami Beach ma] esate agent, be pa top dollar for
Touc
skim pwoperoen. Ansd in evay cm. hepaid cash.
cm all thal mah! Apparently much of it from German deomibillionasre
WVhece
Siegfried QO. 73. onie of the words b~ige Prosier of cency (w box).
About Two yeas agoOnio named fLabini, a glamnorous woman in her 50s. after a
long relatiotship. Her dauighuer from a previous manage. Cadkuine. is nmred
to 71somas Kramser. Kamer bags that his wjfe, whatsbe was going with
sost Yorck. introudm her mother to the old gentlemnan. At any
Stegfried Qow's
rame. 0wapparently helped sake lus nlew sapson-iis-law's Florida foray.
linoughs to cu a rift bawm= Qtto and his
Now much has Otto pain Kaim?
two sont. Tdlman and Yasek. In Ckwber Siegfried Quo Heew both aons out of
the business where they hadworked for ycm. nthy were trying to poison
thar fatha's mund aaunsa mc.' says Xsanr. Otte rr has it that fth 3mn
vied to have QOe -'ared mestlly, unempoosL Nolilser Siegfied Otto. his
lawyer wo palmBeam nor natihes or his cornpany's supevisory bmdwere willing
to alk about the relaasrtup.
It's an Odd relanmuuP. an apng andailing consrowv German busainessman
and APlaYboy wts AdseY MePumDnEven Xs lfum's friends admit he ii a
craP~wer. Ouc ef the'. Last Ranr, a Swws banker. says of Knamer- *He's a
rel gmanr.4 y marAmt nn= he was a tecager. and
has alia crap Lacom
K~ramer
thu's -he ste reg of his uatse may tiaw cme froms. He had speculated in
sutch things as told, grains andeweese. tcpaLem, tialng and losing large
his &=Inv 10South Beach early last yer. aftcr being
-smHe 171411071d
He had set up a blind pool io
-IC=EIn Ger"MnV trane wAgo
vutujay
g belove thee -as a ruling asn who auiy
uwC11 in Easl Cwman rel mnse
OWewdmu
omaP~-t=n negative publicity -- Ase his
XrAwC
MOTS
awe IL
wvush He minedmcvr usFlo,-d&.
bLnk to oil f! n, s
~Law
ISBN=ft2I~JUWIWif
DI4C
O623
fLfl-
3034
But things amIt so good with him right now. APPVxU00Y his
Clearly short Of Cash'
=pfthehisin-law hasALinorawlUMl OnCh~kwriifi.
IinCludIng the
hasin the past month dismiisd at leas 68 s
yLaWe
welliisT=W develope Kay Scam Hie also shuttered his nightclub. Bell. Biut
building a S 250 million apartmnt complex as a playground for
ll
he UW
the Eugoich in newly glarnocis Muami Beach, lie envisions a new luxury hotel
il 1212r the money. 'Now I sin a
he
and Eurpent~yle vilage V onl
poiter withoutarms,' he reans. *Im nat a developgr, but I have a vision of a
whie the rich, the osmopolitan. the peple with idss can gther here in
ptmoc
~eof
IUUEiln~jI~ilgI~u~DNC
062ci0
3035
F, -t .
marchi 1. 1993
FOCUS
wards
HEADLR4M TheBYLNL P. R.
BODY:
MUNICH's Gicli & Deau GmbH prints cueies pssports. traveler's
Is shares thes inwnadcaail markets
checis. and nock and bond ccr%%A--.
with New York's U.S. bankntc. Landon-hueid Dela Rue, Paris-bascd
frariois-'aric; Obaithur. vai others.
tow the irm prior to World
G&Dbegan ia Lcipzi in 1052. Siegfried Ocani
-War 1 as a prm u-ninc and gained convo1 afk marryig the daughter of
the Nazi war marine, it rtfuisid
an of the founder. Though ft company 'si
in print countefeit mkoh bLnk mowwhoi the Nazis demianded it:
as integity. The plats were 80% destroyed in
maoeratng would cmpu
a 19-LA
bombing. and in 1945 On was tan prisoner by the Russians. In 1949 he
in Mooceh.
eped and began the fim jw
In his 50s he dj~mx his wife and in his 70s marice Ranbi. Thomas
teary) Thus beian the Knhner-OmD zeiaconshrp.
Xnrner's ntnemwma-c
With Ons's sats mnr of sh buums and his health failing. Onto has put his
company amthe block. It --W bring S S00 millsom. Which could be good ne-s
for Thomas XKnm. &fhe can my an good urnis with his mother-in-law, who.
by Gamatun law, ua enotd o wzhas 1".5% of the -- ul.
GRAP4OC. Pienn. Sabmi a Sqftmid COt. Thomas Xmmcr'z angels' Munsich
Press
Fat . March 1. 1993
DNC 0629QQ--d--
3036
Intfmauonz l Henld Tribum, Novgmber 12, 1992
FOCUS
SECrION: FEATUPtE
227 words
LEWOT:
Matzsc Is Sold For SIl I MilliHEADLWh&E
DATEm.D4E: NEW YORK
BODY:
- The portrait of a womm. *LAse.*
beensoald atSodeysfor S II aflson.
aatm eshbition at ft
The pitue one of t saas or &4 cusas
Withdrawn from the Show ID beincluded in the
Miasmof Modie Ass. Was
Soathby's viewuig before the sale Tuesday eweaing. It will bereuned to the
in Foan
ciuibition uml Jan. 12and will then pu t ft Kimbell Art Museum
Worth. Texas, whach bought cha wurL
haLf -n.sfW. Of ft 66 lam, 31 woe!
The S35.6 million sak wason~ly
unsold. mAbng a 35 percent failue~ rn by vulue- A prominent role was played
by Ameican buyes. who acrwmni 21 of 35 works. 'Fmnuea dans um Fauteah."
prunud in 1932 by Piasso. sold for S2.86 millsont. 25 permst below the low
cmffwz. SOthebys aid ft bue was Thomas Kimar .T Florida.
110
tMllE
IJFJ111WJINiulI DNC
069D-L
3037
Copyright 1992 The New York .TMCSCZmpany: Abwa=
AUTH: BY DON FDWYRC)K
In~rnauu1rvI~fIDNC OGqr
3038
mairaer
awilpyofls betwe
amas
198S-199.
IIMUMI~UShIMnffINXIM6
DNqC 06SD..
3039
Exhibit 6
Event Form for Chairrman WIlheirm
Date of the Event:
Sponsor.
Location:
Event begins:
Cm~cis 6:30 pm
Dinner. 7:00 pm
Lasts until:
8:30 (approx)
DW arrives:
7:45 pm
depert:
8: 15 pmr.
(posuble) program:
Emm
ae todanor.
2-25 pel
3040
Exhibit 7
TO:
FROM:
Team Florida
DATE:
May 7,
RE:
Florida donors
1993
l* fl gl 3 l l3 DNC 4025933
3041
TRUSTEE (raised at least $50,000)
Marvin Rosen
Jerry Berlin
Mitchell Berger
Howard Glicken
Russ Barakat
Austin Forman
Monte Friedkin
Bud Stack
BLF ($10,000
contribution)
Michael Adler
Bell South (Danny Murray)
Gladys Cofrin
Arthur Courshon
Florida Medical Center
Eddie Dauer
U.S. Generate (Steve Herman)
Charles Intriago
Tom Kramer
Richard Machado
Steve Scott (Nevco Partners)
Jorge Bolanos
Jim Pugh
Sel Maduro
Hugh Westbrrok (Vitas Health Care)
Dr. Sandy Ziff
Environmental Sal (David Block)
Hamilton Forman
agglASjflhI
DNC 4025934
3042
NFC (S5,000 contribution)
Harold Altschuler
William Amlong
Dan Ashland
Alan Becker
Abel Holtz
Mickey Arison (Carnival Cruise)
Michael Chizner
Bucky Clarkson
Michele Cohen
Larry Hawkins
Bill Crotty
Fred Estrada
Max Salas
Ada Fiedkin
Shawn Friedkin
Lisa Friedkin
Arnold Friedman
Joseph Gehl
Sherman Podolsky (Gold Star Medical)
Ira Leesfield
Dennis Ross
Bob Kagan
Harvey Kaltsas
Albert Knoll
3043
Mickie Leonard
Fernando Alvarez (Mercy Lu Enterprises)
Mark Michaels (Vitreo-Retinal Consultants)
Soloman Melgan (Vitreo-Retinal Consultants)
Montenay Power Corp/Montenay-Dade, Ltd.
Carol Moody
William Rand
Janet Robbie
Nelsn Rodriguez
Diane Sepler
Special Committee for Health Care Reform (David Schiering)
Larry Stewart
Morris Stoltz
Parker Thompson
-Maria Elana Torano
Norm Tripp (Alamo Rental Car)
Windmere Corporation
Louis Wolfson
Richard Zelman
Armando Munoz
Mike Pecora
Bret Berlin
Pat Bickford
Belin Saborido
HONORABLE MENTION
Tom Daly raised $20,000,
including $5,000 personally
written.
He should be considered . Trustee, and certainly
will write and raise more than enough by the end of the
* A
year to qualify for the program.
Bud Chiles
Raised over $30,000 as of this memo, with
additional money likely to "come in"
during the next few
weeks.
Linda Murphy McCool - Wrote $30,000.
We have listed her as
a BLF member, but if
"teed-up" properly, could write or
raise an additional $20,000 to be a Trustee.
Simon Ferro - Raised $30,000.
a BLF member.
Igg Il1ilHl
DNC
4025936
3044
He wants to
Joe Chapman - Wrote $20,000 and raised $5,000.
the
the ability to write
and has
remain a trustee
remainder. We recommend his Trustee status be renewed.
Jack Bendhein - Wrote $25,000 and gave check to Monte
He did so under the assumption that $25,000 was
Friedkin.
the membership cost to be a Trustee, as indicated to him by
Monte.
President of Blockbuster Video, which wrote a
Jim Blosser
We need to find an event for
$10,000 check for dinner.
them to write the remaining $5,000 to allow them to join
the BLF.
Paul Cejas - Wrote $25,000 and has committeed to write or
raise at least $25,000 more,
although he is aiming for
Managing Trustee status and hopes to raise the additional
$75,000 necessary for that program.
Larry Hawkins
Raised $40,000 in
3 days!
Wrote $5,000
himself.
As a County Commissioner, he has the ability to
raise hundreds of thousands of additional dollars in Miami.
We should get him fully engaged by asking him to be a
Trustee and commit to raise an additional "chunk" of money.
Doc Cullison
As Presideht of MEBA, he controls several
labor groups contributions nad has the potential of giving
hundreds of thousands of dollars.
He gave $15,000 to our
event while also giving $15,000 to the Labor Council.
His
Trustee status should be renewed.
He'll certainly give
another $20,000 prior to year's end.
Tom Kramer
Gave $25,000 to the event.
Is the developer
who will build much of South Miami Beach and is worth tens
of millions.
Make him a Trustee and stroke him and~heoll
do more than $50,000 for the program.
Maria Elana Torano
Raised $42,000, including $5,000 she
wrote.
At minimum, she will do remaining $8,000 in. the
near future and should be listed as a Trustee at this
time.
0gglill*lll
DNC 4025937
3045
Exhibit 8
MEMORANDUM
TO.
Nancy
cc: Pater, Jay
FROM:
Eric
DATE:
RE:
Clinmonin Florida
As you know. the POTUS is traveling at Florida this week. The itinerary Is fluld and will be fmnalized
Later today. Current plan calls for a lae afternoon departure from Washington on Tharaday. Thursday
night appearance on the ABC News epenal. A Health Cae Town Hall Meeing. This will occur in
Tampa. A Friday event somewhere to the am on aime.
Josh King. who is scheduling the trip. has Iadicaed there will be no time for a 'supportsers event' on this
Inp. However. I asked if he could give us some uaee for our top Floridians and he said be thought he
could work it into the trip. He asked for a priorkited list of our top 15 people, with no guarantes that he
could take care of ALL of thEm He thinks mre will be a watch room' aet up at the sit of the Town
Hall, and the President will spend
asis there as a holding room either prior to, or immedistely after,
the show. That, he thinks is the bea shot for us with the President. FYI. the trip is tight, because they
want the President to have massuaum speech prep ame before his address to the UN at the end of the
weekend
As 1asrs requested. I have taken a fim sab a mames for the pnionry lst. PLEASE GIVE ME YOUR
PROMPT REACTION. SO WE CAN QUICKLY FINALIZE OUR LIST. THEY ARE NOT
PRORTTIZED. L's firt deermusne who should be added or dropped front this list before we pnortize.
I have mned to combise key trusam from Flonda wab health care people from Florida. I also have added
Tom Kramer because things like this umts go ha janed-up to start writing those big checks, as I
previously emptsased masmeo
Mtchell Derger 2
PhitalFrost (health) Ierr
Ceyaatbsirb)
Kramer
'S Deuens Roes (Tampa) jI)
George Sheldon (Tampa) 21
Hugh Westbrook (health) If
Arthur Couraboo (be was the one who da not
gi
vtied to Miami dutch and was vwy ups
fl
N1I8RAAINIIIIRIINIMWIl
DHC 1102040
3046
Exhibit 9
Laura Hartigan Calls
Ms. Merle C. Chambers
President & CEO
Axem Resources. Inc.
Denver Technological Center
7800 E. Union Ave., Suite I 100
Denver, CO 80237-2757
Office Phone: 303-740-9000
Home Phone: 303-770-2183
303-488-0206
Far
Spouse Name: Hugh Grant
Status: Z
Mr Lester Crown
222 North La Salle Street
Chicago, IL60601-1003
Office Phone: 312-236-6300
312-899-5039
Fax:
Spouse Name: Renee Crown
Statu: Z
Mr Tom Kramer
Owner
The Portofino Group
446 Collins Avenue
Mar Beach, FL 33139
Office Phone 305-532-2519
Home Phone 305-532-2519
305-538-1020
Fax:
Notes: Gave 100K during Inauguration
Spouse Name: Catherine Burda Kramer
Wntten Total:
25,000.00
1993 Contribution Total: 25,000 00
Invoice Date: 4/29/93
Event AG.Miani(25K)
Status W
Confidential Informatim
IlliHh1111
402623
3047
Exhibit 10
Call Sheet for
CHAIRMAN DAVID WUDHlM
las
TITLE.*
ORGANIZATION.
(Home 1)
(90532-7519
CONTACT:
PHONL
PURPOSE OF CALL To e
tte Inugural
ACTVITY/FOL.OW4LP:
CaLuheet prres
by If," C wew
MIiaJillJWIS~gfDI~ilNUifilhIfllDNC
1121910
3048
Exhibit 11
David Wilhelm
Chairman
Enclosure
3049
Exhibit 12
Thomas Kramer
President
Olympus Holdings, Inc.
446 Collins Avenue
Miami Beach, FL 33139-5146
Dear Tom,
On behalf of Chairman David Wilhelm and
the Democratic National Comnunce (DNC).
Leaderslup Forum's Issue Conference
in Washington on June 21st and 22nd
1994 Business
3050
Washington on June 21st.
Sincerely.
Terry McAuliff
3051
PAGE 5
REPORT DATE06/14/94
REPORT TIME 01:30PH
GATELIST
(POSTPONEDTO JUNE 21) Business Leadership Forum * April 19. 1994
Contact Social Office 167136
ACCEPTANDNO RESPONSE
NAME
NAME
Iberra.Ken (Hr.)
Ickes. Harold (Hon.)
In:riago. Charles (Mr.)
Jacks. Echan (Hr.)
Jackson. Ira A. (Hr.)
Jacobs. Harry (Mr.)
Jacobsen. Ken (Mr.)
James. 11, Charles (Mr.)
Jankovsky, Joel (Mr.)
Jarvis, Scott (Mr.)
Jayne. Endard (Dr.)
Jetli. -s,111m (r.)
Joffe. Robert (Mr.)
Jaff. Virginia (Hs.)
Jo.,son. Rob.r: L. (Mr.)
Johnson. Sheila (R.)
Jones. Arthany (Hr.)
Jon.. David (Mr.)
Jones C Douglas (Mr.)
Jones. Kirby (Mr.)
Jones
;r.. Robert Trent (Hr.)
Jordan. Carolyn (Hs.)
Jordan. Robert (r.)
Joseph. Peter (Mr.)
Josh.Z. Ernest P (r.)
Joyce Gene (Dr.)
Kande.l. Alice (Dr.)
Kantor. Mickey (Hon. (Amb.))
Kapsr. Lsaeh (Mr.)
Karcher. David (Hr.)
Lasa. Masehiko (Mr.)
Loup. Robert (Mr.)
Keetan. .'rank (Mr.)
Kelly. (athy (Mo.)
Kelly. *aes P. (Dr.)
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
IlifliR~lilfW/llflZ~l#DHC 11 03289
A
A
A
A
A
A
A
A
A
A
A
3052
Exhibit 13
Invoice Dates
Managing Trustees
Mr. Ian M. Cummangs
March 15, 1994
Payment on Pledge:
100,000.00
1994 Written:
Mr.
Richard A. Hayward
Chairman
Mashantucket Pequot Nation
March 14, 1994
Payment on Pledge:
Written
100,000.00
1994 Written:
100,000.00
1993:
Mr. Mark Jiminez
Future Tech International Inc.
March 10, 1994
Payment on Pledge:
1994 Written:
100, 000.00
Mr. Alfred Estrada
Payment on Pledge: February 15, 1994
Written 1993:
100,000.00
1994 Written:
5,000.00
Mr. Harold Nix
Harold NiX a Associates
Payment on Pledge: February 10,
100,000.00
1994 Written:
1994
Mr.
Truman Arnold
President, Chairman of the Board and CEO
Truman Arnold Companies
Payment on Pledge: February 9, 1994
1994 Written:
100, 000.00
Mr. Oscar Wyatt
CEO
The Coastal Corporation
Payment on Pledge: February 9, 1994
100,00I.0C
1994 Written:
Mr. Paul Montrone
Fisher Scientific International
Payment on Pledge: February 9, 1994
1994 Written:
120.5o.00
Written 1993:
40,000.00
Mr. Robert L. Healy
Manager of Federal Goverrment
ARCO
Payment on Pledge: February
1994
Written:
100,250.00
Relations
. 19.94
3053
Mr. Wayne Reaud
Senior Partner
Reaud, Morgan, and Quinn
February
Payment on Pledge:
1994
100,000.00
Written:
8, 1994
4,
1994
January 22,
1994
1994
. John J. Moores
resident
MI Incorporated
Payment on Pledge:
1994 Written:
100,000.00
1993
1993
Dr. Bob
Elkins
CEO
Integrated Health Services
1, 1993
December
Payment on Pledge:
Written 1993:
115,000.00
Mr. Carl H. Lindner
President
American Financial Corporatic.
Payment on Pledge:
December
1. 1993
Written 1993:
250,000.CZ
Mr. Phil Stout
Stout
Group Limited
Payment on Pledge:
1994 Written:
December 1. 1992
Wr:tten 1'3:
100,000.00
3054
Written 1993:
100,000.00
Written 1993:
104,950.44
1993
Written 1993:
80,000.00
1'.993
Mr. Ron
Burkle
Managing Partner
Yucaipa Companies
Payment on Pledge:
July 13. 1993
Written 1993:
105,000.00
3055
Mr. David Geffen
July 13, 1993
payment on Pledge:
100,000.00
Written 1993:
Mr. William S. Lerach
Milberg, Weiss, Bershad, Spechtrie,
and Lerach
July 13, 1993
Payment on Pledge:
Written 1993:
150,000.00
1993
100,000.00
105,000.00
3056
May 5,
payment on Pledge:
100,000.00
Written 1993:
Mr. William D. Rollnick
Ms. Nancy Ellison
May 7,
Payment on Pledge:
109,000.00
Written 1993:
Mr. Jeffrey
Hirshberg
Director of Government Relations
Ernst & young PAC
January 12,
Payment on pledge:
250.00
1994 Written:
115,000.00
Written 1993:
$50,000-599,999 Donors
David F. Muller Ph.D.
President
Susmit Technology Inc.
Payment on Pledge:
March 17, 1994
50,000.00
1994 Written:
Mr. Paul Tudor Jones
Tudor Investment Corporation
March 7,
Payment on Pledge:
1994
50,000.00
1994 Written:
written 1993:
40,000.00
Written 1993:
25,000.00
Samuel
6, 1994
50,000.00
Klagsbrun
3057
DNC Florida Managing Trustees,
Managing Trustee
Mitchell Berger
Berger,
Shapiro A Davis
100 N.E. 3rd Avenue
Suite 400
Ft.
W-
Ian Cumming
Chairman, Leucadia National
Corporation
529 East South Temple
Salt Lake City, UT 84102
W801/521-1001
F 801/539-0722
Fred Estrada
Chairman, Hispanic
Publishing Corporation
999 Ponce deLeon Blvd.
Suite 600
Coral Gables, FL 33134
V 305/442-2462
F 305/443-7650
Alfonso Fangul
President - Flo-Sun Inc.
316 Royal Poinciana Plaza
Palm Beach, FL. 33430
v 407/655-6303
Monte Friedkin
Frxedkin Industries
7900 Glades Rd.
Boca Raton. FL. 33431
V - 407/479-1882
Nouard Glicken
Chairman - The CoMnonwealth Group
8400 Old Cutler Rd.
Coral
Gables. FL 33134
V - 305/446-0023 or 202/799-40404
F
305/662-2647 or 202/709-4Z42
H - 305/669-1063 Honorable Larry Na-kins
Board of County Commissioners
111 Nt 1st Street
Suite 220
Miami, FL. 33120
V - 305/375-5123
Carlos Herrera
President
2-C Properties Inc.
3058
2900 West 40th Street
8201
Hialesh, FL 33016
W - 305/362-1664
Mark Jimenez
Future Tech Int'l
3000 NW 72nd Avenue
Miami nL. 33122
305/477-6406
F - 305/477-3473
Thomas Kramer
Portofino Group, Inc.
43 Star Island
Miami Beach FL. 33139
W - 305/538-4422
F305-538-1020
Jorge Perez
President - Related Group of Florida
2820 Coral Way
Penthouse 1
Miami, FL. 33145
V - 305/460-9900
F305/445-1725
H - 305/663-9121
Marvin Rosen
Greenberg, Traurig, Hoffman, Lipoff
1221 Brickell Avenue
22nd Floor
Miami, FL.
33131
v - 305/579-0535
Dr. Steven Scott
2828 Croasdaile Dr.
Durham. NC 27705
F 919-382-3287
Rosen
919-383-0355
305/443-3329
F - 305/443-0850
H - 305/661-1025
Maria Elena Torano
1000 Brickell Avenue
Miami, FL. 33131
V 305/579-2180
F
305/579-2156
Trustees
3059
Michael Adler
President - Adler Group
8181 NW 14th Street
Miami, FL. 33126-1899
W 305/590-1100
F
305/590-1194
Russ Barrakat
Broward County Housing Coaission
1773 N. State Rd. 7
Lauderhill, FL 33133
w 305/739-1114
F
305/484-5650
Jerome C. Berlin
Chairman, Deux Michel, Inc.
12725 S.W. 122nd Avenue
Miami, FL 33186
W 305/251-5000
F 305/251-7723
Guy Bostick
President & CEO, Comerce Carrier
P.O. Box 67
Auburndale, FL. 33823
v 600/524-1101
F 813/965-1093
H 305/443-2587
Paul
Ce)as
Chairman/CEO - Care Florida
7950 NW 53rd Street
Third Floor
Miami, FL. 33166
V 305/591-3311
F 305/470-2936
Joe Chapman
President, Royal American Managment
1002 W. 23rd Street
Suite 400
Panama City, FL. 32405
W 904/769-8961
F 904/769-5506
Arnold Friedman
CEO - St. Johns Home Health Agency
15500 Ne- Barn Rd.
Miami Lakes, FL. 33014
V 305/558-0101
F 305/550-5118
Willie Gary
Gary,
Williams, Parenti, Finney 6 Lewis
Waterside Professional Building
221 East Osceola St.
Stuart, FL. 34994-2175
3060
N 407/283-8260
F
407/220-3343
Hatt Gohd
Whale Securities
650 5th Avenue
New York, New York 10019
W 212/484-3672
F 212/404-3675
N 212/873-8227
Abraham D. Gosman
Chairman & CEO, Mediplex
15 walnut Street
Wellesley, NA 02181
V 617/446-6900
F 617/446-6908
Calvin Grigsby
President, Grigsby Branford a Co. Inc.
230 California St.
Suite 601
San Fransico, CA 94111
W415/392-4800
F 415/398-5548
Neil Harrington
Chairman, Harrington and Company.
899 S. America Way
Miami, FL 33132
V 305/358-1511
F 305/358-0611
H 305/576-4742
Inc.
Stephanie
Kerr
Cruise Line Executive
901 S. America Way
Miai, FL 33132
0 305/358-5122 x5371
F 305/358-4807
N 305/371-5533
Ira Leesield
2350 South Dixie Hwy.
Miami. FL. 33133
V 305/854-4900
F 305/854-8266
Boyd B. Lewis
S.B. Lewis 6 Company
1747 Pennsylvania Avenue,
NW
suite 1150
Washington, D.C.
W 202/429-6949
F 202/293-2068
Don A. Madden Sr.
-2* Mooney Pa.
Fort Walton Beach, FL. 3254W
904/244-3196
3061
H/W 407/367-7291
F 407/367-0656
David Block
President, Environmental salvage Team
1538 NW 24th Avenue
Miami, FL 33125
V 305/633-3000
F
305/633-8301
James J. Blosser, Esq.
Assistant to the Chairman
Blockbuster Entertainment,
I Blockbuste Plaza
Ft. Lauderdale, FL
33301
V 305/032-3051
F 305/832-3925
Corp.
William B. Bond
Private Invester
225 Water street
Suite 230
Jacksonville, FL 32202-5141
0904/356-9100
F - 904/358-9147
904/646-1548
H
Joe Boren
President, South Region Air and Water Technologies Corp.
400 Sawgrass Pkwy.
Sunrise, FL. 33325
Tom Burr
CEO, Anesthesia P.A., Inc.
Suite 204
5300 NW 33rd Avenue
Ft. Lauderdale, FL 33309
W 305/495-5666
Honorable
Hugh Carey
Vice Presidtnt
W.R. Grace Co.
919 18th Street NW
Suite 400
Washington. D.C. 20006
W202/452-6704
F 202/452-0597
Art Collins
President, Public Private Partners..p
520 East Park Avenue
Tallahassee, FL. 32301
W 904/561-0762
F 904/561-0397
Arthur Courshon
Chairman
& President
3062
Jefferson Bancorp, Inc.
301-41st street
Miami Beach FL 33140
W 305/535-9574
Jim Eaton
President, Capital Strategies
P.O. Box
1713
Tallahasseee, FL 32302
W 904/224-6789
F 904/222-6981
Milton m. Ferrell, Jr.
201 S. Biscayne Blvd, Suite 1920 Miami,
W
305/371-8585
F 305/371-5732
J. Carey Gleason
1039 N. Pitt St.
Alexandria, VA 22314
W703/683-3970
Cathy Kelly
Assistant Executive
Director
ETP - NEA
FL, 33131
3063
McClendon, Counts
1 Midtown Paza
1350 Peachtree St., NE, Suite 850
Atlanta, GA. 30309
w 404/875-1545
Manny Medina
Terremark, Inc.
2601 S.
Bayshore Dr.
PH 1-B
coconut Grove, FL 33133
w 305/856-2626
F 305/856-8190
Dr. Salomen Melgen, M.D.
Vitreo-Retinal Consultants
2521
Metrocentre Blvd.
West Palm Beach, FL 33407
W 407/607-0007
F 407/609-0431
Linda Murphy McCool
7425 SW 42nd Street
Miami. FL. 33155
N
305/661-8195
Larry Overton
Larry J. Overton A Assoc.
101 east College Avenue
Suite 302
Tallahassee, FL. 32301
V 904/224-2859
F
904/561-6311
H 904/893-1241
Edward Porter
President. International Fine Arts College
1737 North Sayshore Drive
Miam, FL 33132
H
305/373-4884
F 305/374-7946
James H. Pugh
359 Carolina Avenue
winter Park, FL. 32789
W 407/644-9055 F 407/644-9845
Steve Naclerio
Senior
VP 4 General Council
Bacardi Imports, Inc.
2100 Biscayne Blvd
Miami, FL. 33137
H 305/573-8511
F 305/573-2730
Chip Reid
President. Current
Builders
3064
2251 Blount Rd.
Pompano Beach, FL. 33069
w 305/945-1358
F 305/978-8646
Israel Roizman
President, Roisman & AssOc. Inc.
801 East
Germantown Pike
Suite M-3
Norristown, PA 19401
W 215/278-1733
F 215/276-1734
Pat Tornillo Jr.
President, FEA - United
118 North Monroe St.
Tallahassee, FL 32399-1700
W 904/224-1161
F 904/681-2905
Kerry A. Walsh Skelly
Assistant Vice President/Director of Government
Relations
Brown Forman Corp.
P.O. Box 100
Louisville, KY 40201-1080
W502/774-7552
F 502/774-7188
Nelson Fairbanks
President & CEO, U.S.
Sugar
P.O. Box 1207
Clevistown, FL
Armando J. Yanez President. Financial Contracting
Sevices, Inc.
3211 Pleasant Lake Dr.
Tampa, FL
33618
813/264-2656
F 813/264-5556
3065
Exhibit 14
mmst Brief
Ainded a pdvam A-
wh
sm
-A-d OWP
Scm
-nfe
RaW.L Gowginwu
-em fo ri
mors Uaw
NiM
bd
Kom
Uds
Tom idl
L um am~
~It Rub
The Ve
a meam=)
humamL
Marna
U WIOIEEEMIDDHC 1040251
V*
3066
Exhibit 15
5
TABLI
1.
5
2.
4.
7.
4.
---O I.MREA
..
DNC 11 0222
3067
Exhibit 16
THE
1)Bud Stack
2) Barbara Stack
3) Tom Kramer
4) Katherine Kamner
5) Fred Estrada
6) Team Estada
7) Mark imcrer
8) %Ardlie Gary
9) Gloria Gary
10) Rbca~ Sw
3068
Exhibit 17
MUR 4398
The Commission also found reason to believe that 35 Star Island. Inc.;
Portofino Group, Inc.; Olympus Holding Corporation; Sun & Fun. Inc.; Playa Del Sol, Ltd.; New
Fiesta, Inc.; St. Tropez R/E Fund, Ltd.; Beachwalk Development Corporation; Santorini Isle,
Inc.; 7th & 5th Deco Corporation; Sandpoint Financial, Ltd.; SBE, Inc.; South Beach Creative
Group. Inc.; 5 Star Island, Inc.; 2 Star Island. Inc.; Seagull Development Corporation; Azure
Coast Development, Ltd., ("Respondents") and Thomas Kramer as owner and Chief Executive
Officer of these corporations, violated 2 U.S.C. 441e.
NOW, THEREFORE, the Commission and the Respondents, having participated in
informal methods of conciliation, prior to a finding of probable cause to believe, do hereby agree
as follows:
1.
The Commission has jurisdiction over the Respondents and the subject matter of
this proceeding, and this agreement has the effect of an agreement entered pursuant to 2 U.S.C.
437g(a)(4)(A)(i).
II. Respondents have had a reasonable opportunity to demonsrate that no action should
be taken in this matter.
3069
2
Ill.
110.4(a).
2. 35 Star Island, Inc.; Portofino Group. Inc.; Olympus Holding Corporation; Sun
& Fun. Inc.; Playa Del Sol, Ltd.; New Fiesta, Inc.; St Tropez RIE Fund, Ltd.; Beachwalk
Development Corporation; Santorini Isle, Inc.; 7th & Sth Deco Corporation; Sandpoint Financial,
Ltd.; SBE, Inc.; South Beach Creative Group, Inc.; 5 Star Island, Inc.; 2 Star Island, Inc.; Seagull
Development Corporation and Azure Coast Development, Ltd. are domestic incorporated entities
owned and controlled by Thomas Kramer.
3. Terri Bradley was employed as Thomas Kramer's secretary during the period of
the transactions at issue.
4. A. Thomas Kramer made direct contributions to various local, State and Federal
political committees used in connection with elections for local, State and Federal office during
the 1993-1994 election cycle, totaling $13,000.
B. Thomas Kramer further made a direct 595,000 contribution to the Republican
Party of Florida which was deposited into its redistricting account.
5. Thomas Kramer asked his secretary Terri Bradley to make to contributions in her
name, totaling $21,000, for which he subsequently reimbursed her. Accordingly, Thomas
Kramer made contributions to Federal political committees in the name of his secretary Terri
Bradley during the 1993-1994 election cycle, totaling S21,000.
3070
3
6. Thomas Kramer made contributions through unknown intermediaries to local
and State political committees during the 1993-1994 election cycle, totaling $1,000.
7. Thomas Kramer as a corporate officer directed the making of contributions by
his seventeen corporations to various local, State and Federal political committees used in
connection with elections for local, State and Federal office during the 1993-1994 election cycle.
totaling S287,600.
8. It is unlawful for any foreign national to make acontribution directly or through
any other person in connection with an election to any local, State or Federal political office.
2 U.S.C. 44 1c(a); 11 C.F.R. 110.4(a).
10. It isunlawful for any person to make a contribution in the name of another
person. 2 U.S.C. 441f.
V.
3071
4
Sandpoint Financial, Ltd.; SBE, Inc.; South Beach Creative Group, Inc.; S Star Island. Inc.,
2 Star Island, Inc.; Seagull Development Corporation and Azure Coast Development. Ltd.. at
Thomas Kramer's direction, made contributions totaling S287,600, in violation of 2 U.S.C.
441e.
VI.
Respondents will pay a civil penalty to the Federal Election Commission in the
437g(a)(5XA).
VII. The Commission, on request of anyone filing a complaint under 2 U.S.C.
437g(a)(1) concerning the matters at issue herein or on its own motion, may review compliance
with this agreement. If the Commission believes that this agreement or any requirement thereof
has been violated, it may institute a civil action for relief in the United States District Court for
the District of Columbia.
VIII. This agreement shall become effective as of the date that all parties hereto have
executed same and the Commission has approved the entire agreement.
IX. Respondents shall have no more than 30 days from the date this agreement becomes
effective to comply with and implement the requirement contained in this agreement and to so
notify the Commission.
X.
This Conciliation Agreement constitutes the entire agreement between the parties on
the matters raised herein, and no other statement, promise, or agreement, either written or oral,
made by either party or by agents of either party, that is not contained in this written agreement
shall be enforceable.
3072
5
XI. The terms of this agreement, including any admissions herein, are applicable solely
to this proceeding and are not an admission of fact or liability or conclusion of law for any other
proceeding, suit or action except by the Federal Election Commission.
FOR THE COMMISSION:
Da
Lawrence M. Noble
General Counsel
//a8/5/96
A
ividully)Date
8/5/96
Date
3073
rDenm%
stea
Exhibit 18
C&e
C Nao
Chair
Sepner 3, 1997
Federal action Commiselon
office ofrthe Gmn..l Coused
999 E SrM. N.W.
Washinpon. D.C. 20463
ME
IM
MUR.
We have ideld
bAt inve
been o
le
to
and copy an
sruieve
Sim
l yours.
eo Bse. Sandlr
General Counsel
I4'-14
11,P.1.l. I
sI.
. ...
...
Itol.
is....
...
legI
%1
li11
111
.MOIl*
11.M
IW
3074
Cre~t
=
N.~C
-C. Ah
.
L-
A.-
nr
A .di
* .a-. dse
se
.
W .
1 C.
.
Ay..
se
aem.
Ott. .C...
Q
a~sum
- mU,
A J..
c
r
&. Ca.
.- I Ccb
Con
PA
Mam
. .L
..
..
P A .
-. m
.L. ....d*
.
.pC .An.
J~b..
M
...
a
..
rs
- L
deAd
Chaing...d.TI..
.
A
W-4 C.-a
C CR U.
L CL-
IL...
er
3... .
C.144r..
a..
L-.. J...
C.. A.
.
N
S-..
VIA EXPRESFEDRA
mbe
Rr
HP-
A.d
." J.
NI
3.W.
nL
A
Lq.
b.
bh.
..
C . X
S an
MaC
ambe 3,.
. t
am C
.
...
I-
Ad
Id
w
a-
L& Sa-
6 .
PA
. Spt..
I-
**
M.
...
Msm
2-. J.-?
Q u A m ..
P.Llah.Mu
d. IL
.. ueRul.,*.ha.iAdr.
g
Al- IL RAia
Sh....
L.
...NR 1.SAiF
1
A.
I... JL 0U..
C r. LA
a_ L. CPA
L K-..
L O...
P-...
R..d C LA...
SAW.
L Sk...
P- A. a6.1.. Sd.
t-
L
.f
L
RU.
Enclosed please find checks totalling 374,000.00 collected in conjunction with the
outstanding checks, which had to
remaining
March 22nd cocktail
be returned and recut and others to be collected. I wil forward them to you as soon as
Marvin S. Rosen
H. V.3. LA
Sincerely,
.-
d C-
__a
possible.
e
s
W6.
1.
1.
V. Wome
WI
JesseMk
iit
j.
A..C
Re.en
Ms
Ah. 2U P
N. *N....Li....r.
N.-J... Md3..WI
L
L R.
M3lh
1
1I
L.a.
..
mb e
Dbut L assesd
Aise
MSRvlm
&.
C-..
ar
5.-
*****
p
aNN..L d...
M
asr
M
LCanic..
.
a-A C.AAA,
t-..
&I S Cj..q
C...AL.
. A.* = =
CAmoNJ
mt
. . . .
N.
Lm...
. Leb
p Ct ag..N..
N ***S 6 .-***
&.
$-..U
S
Wt
N.61.. L IA.-
L 0.1...
5--0M
-&
..
W.
a-4-1
LT Law
C.C -
3...
-O-6.
M.
W. -
d C-..,
3075
SENATOR GEORGE MITCHEU.
March 22, 1993
ALVAREZ, CESAR
3reenberg Traurig
Attorney
3ASS, HILARIE
31mnberg, Trurig
Brickde Avenue
AiI, Florida 33131
Attorney
30&579450
GER, JAMES L
Alrney
Aut 400
ld
,dW
IFlorda 33301
;RADLEY, TERRI E.
371 NW 1st Sbet
Intation, Florida 33324
Exeuive
MAstat
38-4422
BROWN, IUANA
Real Estat
1,000.
APLAN, SHEILA
.2 Polndan Drive
Interior Designer
2,000.
7801 NW 1t Street
nnbrokePines, Florida 3302
3076
Senator George Mitchell, March 22nd, Biltmore Hotel
page 2
CEJAS, PAUL L
Care Florida
7950 NW 53rd Avenue
Suite 300
Miami, Florida 33168
305-370-1950
CUNNINGHAM, ALLEN A.
O 68 East 3rd Street, No. 23
New York, New York 10003
CRUZ, GLORIA
Eldorado Trading Co.
Chairman
1,000.
Real Estate
Executive
1,000.
C.F.O.
250.
Houswifte
1,000.
DALY, STACY
811 Brookwood Place
Ann Arbor, Michigan 48104
Student
2,000.
Student
DALY, TRUDY
32 Simpson Road
Housewife
2,000.
3077
Sert.ator Geote Mitchell March 22- Bitmore Hotel
page 3
ENGEL., FAITH
13258 S.W. 114 Terrace
Man, F~lod 33186
Accounltanlt
1,000.
FERNANDZ MIGUIEL
125 Gavlan
Coral Gables. Florida 33143
Heath Insurance
Executive
1,000.
7PLETCHER, PATRICIA
,,Shapo, Freedmnan & Fletcher
Suite 4750
'4120 South Biscayne Blvd.
Florida 33131
,gri
Attorney
1,000
.GARCIA, ANTONIO
2 25
- B SW 112th AveweA
_Wmrd, Pwoide 33165
Developer
1,000.
GORSON, MATTHEW IL
Greenberg, Truawig
1221 Sticel Avento
Mlamif, Florida 33131
3~059-
Attorney
2,000.
Attorney
1,000.
3078
Senator George Mitchell. March 22nd, Biltmore Hotel
page 4
GUZMAN, LEO
Guzman &Guzrnan
701 Brickell Avenue
Miami, Florida 33131
Investment
Banker
250.
Attorney
1,000.
ISAZA, LUIS
Eldorado Trading Co.
720 NW 43rd SWeet
a'Miami, Florida
President
250.
-KALB, MARTIN
Greenberg Traurig
$1221 Brickel Avenue
Miami, Florida 33131
3CS579-500
Attorney
1,000.
KRIES, LAWRENCE
Care Florida
7950 NW 53rd Avenue
Suite 300
Miami, Florida 33168
305-470-1950
President
1,000..
LANNES, ANGELA P.
350 Alcazar
Coral Gables, Florida 33134
Land Survoyor
HOFFMAN, LARRY J.
Greenberg, Traurig
1221 Brickell Avenue
. Miami, Florida 33180
305-5790500
1,000.
3079
Senator George Mitchell March 22nd. Bihtmore Hotel
page 5
MARTINEZ, MANUEL
43 Madeira Avenue, No. 2
Coral Gables, Florida 33134
Bookk eep
MARTINEZ, OSVALDO
14548 Balgowan Road
Miami Lakes, Fl 33016
Health Care
Execu tive
1,000.
McALPINE, M.E.
3410 Creekbriar
Houston, Texas 77068
1,000
McDONALD, THOMAS M
8833 NW 70th Court
Pariland, Florida 33067
-305739-6400
PresidenTh
-MEDINA, LISETTE
5 Star Island
Miami Beach, Florida 33139
House wife
2,000.
MEDINA, MANUEL
Terremark
44 West Street, Suite 1275
Miami, Florida 33131
Develcoper
2,000.
MONTERO, HILDA
1605 Bay Road, Apt. 507
Miami Beach, Florida 33139
Execu tive
Ass ant
1,000.
Krave nThomas
Engin eers
500.
3080
Senator George Mitchll. March 22nd. BSltme Hotel
=age 6
IMURPHY, LINDA F.
200 Leucadefidra Drive
Coral Gables, Plo~r4ida 33156
Developer
1,000
Developer
1,000.
Health Care
1,000.
RELATED
GROUP OF FLORIDA
Afttorney0
SCHNAPP, MARK(P.
Greenberg. Trwlg
1221 Idiell Avenue
MIaMI, Florida 33131
305-57905W)
Attorney
SHAPO, RONALD A.
Shapo, Freedmmn, Fletcher000
200 Soith BWacyne Blvd.
Mlaml, Flor~a 33131
305-35-4440
Atre
Soo.
8081
Senator George Mitchell, March 22nd. Biltmore Hotel
page 7
Attorney
1,000.
President
2,000.
Attorney
1,000.
WALLACE, MILTON
Cenust Financial Center
100 S.E. 2nd Stiet
Suite 2100
Miami, Florida 33131
30-371-2223
Attorney
1.000.
WEINSTEIN, MARK
Government Affrs
VIACOM
1515 Broedway
Now York NewYork 10026
212*2584110
Senior V.P.
1,000.
WILLIAMS, JAMES
5441 Buchanan Street
Holywod, FlorIda 33021
Printer
2,000.
305-443-3329
TAPLIN, MARTIN W
-
3082
Senator George Mitchell, March 22nd, Biltmore Hotel
page 8
WILLIAMS, JOSEPH
5441 Buchanan Street
Hollywood, Florida 33021
Printer
2,000.
Investcr
1,000.
'05-1a00
3083
TEH
*PvI
MITuCmLL
Wonsenw
AND NOft*****************..****.*
alMED
INTERCO N
...
0 DL
eat
M-. L BANK
commI WToN
'~4. fll~d
IOK'
emewasC
3084
Exhibit 19
au&
hener (uth.)
FundiserC
PAC/Contributor N=:n
Business Address:
Aci
Contact_
Fax
Business Phone:
71
Hose Address:
//i
1/i
.FL Trr2!p
- Spouse.
Fax--
Home Phone.
Emnployer
Atribute the following program and event code:
-L/kajoriry Trus-M
- Leadership Circle-_
_
-Business RoundtableFall/Spring Dinner__Road Show_
Tally: Credit Senator/Chaluener
Raised by
'*
UMNM920244
"LZV
mM
m_
Lehner(autL)_0_
Through
-Women's Council_
Labor Council
-Miscellaneous
Building Fund
Ezp
_Other
HA
3085
Exhibit 20
Pciwa-
5IzJ'94~
ANi
U---.
October 4,
1994
-~me-.
-a.--
5.5 -5.5
e-- M
UR ~Q7
'General counsel
,deral Election Commission
S99 E Street,
Washington,
N.W.
D.C.
20463
Re:
Thmas Ereaer
Dear Larry:
I an writing to follow up an our brief phone call last
Friday. As I explained, we represent Thomas Eramer and wish to
disclose voluntarily to the Cammisin)-rEamers recent
violated provisions of
discovery that he may have inadverttly
the Federal Election Campaign Act Jby making or- causing
contributions in connection with candidate elections
At the time
notwithstanding his status as a fcig'naticnal.
' he was not aware
Mr. Eramer made or caused these cnib;ti
in
connection
ana
that foreign nationals may not
E'Oaes. M.- Kramer -is .
with candidate elections in the It
.ion an 'its 'staff 'in
willing to cooperate fully with the
connection with this matter. We zaere Vieting Hr.E ramer's
y'-raise'questions under
records to identify which contritioim
Commissian of any such
we will promptly advisethe FECA.
If we conclude that'imy contributions were
contributions.
questionable, Mr. Kramer will promptly seek refunds of the
contributions in question.
We would appreciate it if you would forward this letter
Thank you
to the appropriate person on your enforcement staff.
for your cooperation.
Very truly yours,
Roger M. Witten
cc:
Mr.
Kramer
3086
Exhibit 21
WILMER, CUTLER & PICKERING
....
A .-
w.sA.A.O
oC
.
EEl
\LA
W.
-oo7-2
.-
Sixth Floor
Washington, D.C.
Re:
20463
Pre-MUR 307
We include Mr.
3087
any other contributions that we may learn of after this
disclosure.
Mr. Kramer did not intend to violate Section 441e, and
he is quite sorry that it appears that he has done so.
He was
a foreign
national in
In addition,
and
3088
As reflected on the enclosed chart, Mr.
Kramer or his
candidates for
companies made or caused six contributions to
on the
candidates
to
contributions
federal office and numerous
state and local level.
Kramer that it
the
had
directed the bulk of his donation to its state account for "noncampaign,
$5,000.
1'
An exception is Mr. Kramer's $1,000 contribution to Ms.
Ileana Roa-Lehtinen, which the candidate refunded before Mr.
Kramer made a request.
a,
The letters exchanged by the Republican Party of
Florida and Mr. Kramer are attached.
-3
3089
no longer have open campaign accounts or funds from which to
refund his contributions.
In addition to his personal and corporate
contributions, Mr. Kramer also made some contributions through
other people.
federal level,
Terri Bradley.
his secretary,
We
We
enclosed chart.
to the Commission,
as the
Mr.
F
We were guided in our approach to this issue by the
First General Counsel's Report in the Sports Shinko matter, dated
June 4, 1993, in which the General Counsel took the position that
violations of 2 U.S.C. S 441f involving contributions to state
and local candidates were more properly the business of state
authorities than the FEC. (Report at 17-18).
3090
Kramer voluntarily brought this matter to the Commission's
attention, and he has cooperated fully in facilitating an
investigation into his contributions.
We would appreciate an opportunity to meet with you
regarding this matter at your convenience to explore the
possibility of pre-probable cause conciliation.
In the interim,
Roger M. Witten
Margaret L. Ackerley
N
Enclosures
C-
C'.
-5-
3091
Exhibit 22
FEDERAL ELECTION COMMISSION
WASHINCTONDC .MY-b9
MAY- 4 1995
Lawrence M. Noble
General Counsel
SUBJECT:
1.
3092
Memo to the Commission
Page 2
Commissioner Aikens objected to the length of time this
Office required to present a report to the Commission in a
im m.nzs matter involving both corporate and foreign national
contributions.
Additionally, citing language in the report
which suggested that some of the contributions made by Mr.
Kramer to the Republican Party of Florida "... may be exempt
from 441e,' she raised questions regarding-cur pursuit of the
RPF and regarding the conciliation agreement which was being
Her comments with-respect to the
proposed for Mr. Kramer.
proposed conciliation agreement (tape locations 43-44)
should be exempted from disclosure pursuant 2 to 2 U.S.C.
5437g(A) (4)(B)(i) and 5 U.S.C. 5552b(c) (3).
Commissioner McGarry indicated that he would require the
RPF to properly document any assertion that contributions made
to it were exempt from the foreign national prohibition. He
also had questions regarding the liability of individuals
who acted as conduits of improper contributions.
2.
1996.
3093
Memo to the Commission
Page 3
Counsel and Staff Attorney Jose Rodriguez responded.
(21-44).
(126) .
3. Meeting
of October 29,
1996.
3094
Memo to the Commission
Page 4
Accordingly, the October 16, 1996, GC Report did not
address substantive issues. It contained only a brief
background description of Greenberg, Traurig s involvement
in the matter; a report on several telephone conversations
between this Office and counsel for the respondent which
explored possible terms of conciliation; and a recommendation
that the Commission enter into pre-probable cause to believe
conciliation with the law firm. A proposed conciliation
agreement was attached.
Commissioner Thomas initiated a discussion which made
reference both to the proposed conciliation agreement and to
the Commission's past practice with reference to pursuing the
solicitors of improper contributions.
(15-77) .
His remarks,
and those of Staff Attorney Rodriguez in response, which
touched upon the proposed conciliation, (17-18; 22-28; 33-36;
43-45; 47-49; 63-77), should be exempted.
Commissioner Elliott raised questions as to the involvement
of individual members of the law firm, the participation of
corporations in the activities in issue, and the return of
improper contributions. Staff Attorney Rodriguez responded.
(78-139).
3095
Memo to the Commission
Page 5
of the cases.
The June 23, 1997, GC Report discussed those motions
and recommended against granting them. Discussion at the
June 23, 1997, meeting contained no exempt material.
RECOMMENDATION;
Disclose to the Office of Reprbsentative Stephen Horn, to the
Center for Responsive Politics, and to any other interested
party tape recordings of the Executive Session discussions
of Pre-MUR 307, MUR 4398 and MUR 4638 which were conducted on
June 25, 1996; October 22, 1996; October 29, 1996; and June 24,
1997, with the exception of those portions cited above as being
exempt from disclosure pursuant to 2 U.S.C. 5437g(A) (4) (B)(i)
and 5 U.S.C. 5552b(c)(3).
3096
Exhibit 23
Inthe Matter of
Greenberg, Traurig. Hoffian.
Lipoff. Rosen & Quentel. P.A.
MUR 4638
S V
The present matter addresses the severed portion of MUR 4398. MUR 4398 was
generated by asua sponge submission filed by counsel for ITonas Kramer noting that, as a
foreign national, Mr. Kramer made extensive contributions to Federal, state and local elections
during the 1993-1994 election cycle. The sua sponge also disclosed that Greenburg, Traurig,
Hoffian, Lipoff. Rosen &Quentel ("Greenberg &Traurig" or Respondent"), a law firm
retained by Mr. Kramer to handle his immigration matters, had solicited an undisclosed portion
of the contributions at issue. Based on this information, on June 25, 1996, the Commission
found reason to believe against Mr. Kramer, his assistant Ms. Terni Bradicy, his wife
Mrs. Catherine Burda Kramer, several corporations under his control, various Federal, state and
local recipients and the present respondent, Greenberg & Traurig. The Commission took no
funher action against all respondents except for Mr. Kramer, Ms. Bradley. one recipient
committee - the Republican Party of Florida - and Greenberg & Traurig.'
aancIaed wI
iternhe
Iung
3097
All above remaining respondents requested pre-probable cause conciliation, and the
Commission successfully settled MUR 4398 as to all tuspomierts. except for Greenberg &
Traurig - obtaining atotal of S426.000 in civil penalty payments.
Report (GCRO) in MUR 4393. dated May 9.1997. at 3-5. Because of the inability to reach
settlement with Greenberg & Traurig. and so as to not adversely prejudice the successfully
completed portion of MUR 4398. the Commission severed the activity concerning Greenberg &
Traurig into the present mater. closed MUR 4398 and lunched an investigation into the law
firm's involvement in Mr. Kramer s contributions. Seeid
Recently. rather than respond to the requested discovery. Respondent expressed a
3
renewed interest in settling this matter at the present stage. Based on the available evidence
from the various recipient sources contacted during the investigation, it now appears that
Greenberg & Traurig solicited approximately S91000 from Mr. Kramer. This report
recommends entering into conciliation with Greenberg & Traurig and presents for the
Commission's approval a proposed conciliation agreement.
-
1.
UIte
Comminsn alsorecrteJ a fotalU.I11 tu
i dlprgernean
efo
aiiiuni sir
urn arlien
3098
9
IV.
RErMMFENDATTONS
1.
2.
Lawrence N Noble
General Counsel
Dae/0
4S
BY:
Associate General Counsel
3099
PTC;Sfia W ;:AFfl
a,~N Cw oil
m vTs 6)
WIT I
IN4
NHI-
icv a BZN lj
Eel
3100
Exhibit 24
BEFORE TEE FEDERAL ELECTION COMMISSION
In
the Matter of
MUR 4638
1 Al.
CERTIFICATION
I, Mkrjorie W. Emmons,
1997,
the
2.
3.
as
Approve the appropriate letter,
recommended in the General Counsel's Report
dated December 19, 1997.
Commissioners
affirmatively
Elliott,
McDonald,
McGarry,
cast a vote.
Attest:
Date
Marjorie W. Emmons
S cretary of the Commission
10:52 a.m.
4:00 p.m.
4:00 p.m.
3101
BEFORE THE FEDERAL ELECTION COMMISSION
In the Matter of
MUR 4638
441e.
The Commission has jurisdiction over the Respondent and the subject matter of
this proceeding. and this agreement has the effect of an agreement entered pursuant to 2 U.S.C.
437g(a)(4)(A)(i).
II.
IV.
2.
110.4(a)(4).
441e(b)
and
3102
3.
on
irnMigration matters and other legal matters. The firm lawyers working
on the immigration matters were aware of Mr. Kramer's foreign national
status.
4.
5.
The
from making
11 C.F.R.
3103
110.4(a). the term person includes a partnership, association, corporation
or.any other organization or group of persons. See 2 U.S.C. 431(11)
and 11 C.F.R. 100.10.
V.
For purposes of
resolving this matter. Respondent admits that this was in violation of 2 U.S.C. 441e.
VI.
Respondent contends that any violation of the law was inadvertent and that it did
Respondent will pay a civil penalty to the Federal Election Commission in the
437g(a)(1) concerning the matters at issue herein or on its own motion. may review compliance
with this agreement. If the Commission believes that this agreement or any requirement thereof
has been violated, it may institute a civil action for relief in the United States District Court for
the District of Columbia.
IX.
This agreement shall become effective as of the date that all parties hereto have
executed same and the Commission has approved the entire agreement.
X.
Respondents shall have no more than 30 days from the date this agreement
3104
becomes effective to comply with and implement the requirement contained in this agreement
and to so notify the Commission.
XI.
This Conciliation Agreement constitutes the entire agreement between the parties
on the matters raised herein, and no other statement, promise, or agreement. either written or
oral, made by either party or by agents of either party, that is not contained in this written
agreement shall be enforceable.
XII.
The terms of this agreement, including any admissions herein, are applicable
solely to this proceeding and are not an admission of fact or liability or conclusion of law for
any other proceeding, suit or action except by the Federal Election Commission.
FOR THE COMMISSION:
Lawrence M. Noble
General Counsel
By:
Lois G. Lrner
Associate General Counsel
Date
By:
Leslie J. Kerman
Counsel for the Respondent
Date
3105
Exhibit 25
WILMER. CUTLER & PI
OS
Snag.
,
&
a.
HQ37-
M-HUM
Federal Election Commission
999 E Street. N.W.
Washington, D.C. 20463
Re:
MUR 4398 -
Thomas Kramer
al.
Honorable Commissioners:
we are advised that the Commission has taken the very
rare, if not unprecedented, action of severing the abovereferenced MUR to create a new MUR for one respondent that has
failed to reach a conciliation agreement with the Commission.
We
also understand you may revisit this decision, and we ask that
While limited time
3106
accompanying affidavit to his having made contributions at the
suggestion and with the advice of counsel will be omitted.
AttachmentA.
(aft,
were
is made public, we
CO
the
years earlier) .
Even if it
(5=, Attachment C,
the
3107
believes otherwise,
not an
Surely this is
it
is
justified and
Alternatively,
as we
the
3108
pinally. we ask that the Commission notify us of how it
intends
Sincerely,
Roger M. Witten
Margaret L. Ackerley
Counsel for Respondent,
Thomas Kramer
3109
Exhibit 26
OFFICE OF THE GENERAL COUNSEL MEMORANDUM
OF TELEPHONE CALL OR VISIT
DATE 9/11/97
MUR 4638
3110
Because of its legal representation of Mr. Kramer and his corps, the fim had full knowledge that
Kramer was foreign, and knowledge re: his interest in the corps.
CHAPTER VI
THE HUDSON CASINO REJECTION
This section of the report focuses on the rejection by the Department of the Interior (DOI) of an application to take a 55 acre parcel
of land into trust with the ultimate objective of establishin an offreservation gaming facility. This application was made by three impoverished Wisconsin Indian tribes who anticipated going into
partnership with the owner of an already existing class III gaming
facility. After complying with all of the requirements placed upon
the tribes by the Department of the Interior, the Bureau of Indian
Affairs (BIA) regional office in Ashland, Wisconsin, and the area office in Minneapolis, Minnesota, both recommended that the application be approved. After those closest to the proposed site recommended the approval of the application on November 14, 1994,
a 32 page report was sent to Interior's central office in Washington,
DC for final review.'
For the three tribes this was a day to celebrate because, as DOI
spokeswoman Stephanie Hanna noted, the DOI has never overturned an Area Office recommendation to take land into trust for
gaming purposes.2 The 32 page report from the Minnesota area ofce discussed a number of factors supporting approval of the application. These included: an agreement for government services, consultation with the city of Hudson, public response to the proposal,
impact on the neighboring tribes, environmental impact, and impact on the infrastructure including traffic, lighting, and water.
Nevertheless, on July 14, 1995, the Department decided against
the recommendation of both the regional and area offices and rejected the tribes' application.3
In the weeks and months following the rejection, it became apparent that it was possible that campaign donations and political
considerations may have influenced the Department of the Interior's decision. As the Committee reviewed various campaign finance
issues, an investigation into the decisionmaking process was commenced. During the investigation, the Committee deposed and/or
interviewed officials from the White House, the Department of the
Interior, lobbyists on both sides of the application and representatives from the three applicant Wisconsin Indian tribes. The Committee also subpoenaed documents from various sources includin
the Department of the Interior, law firms, and lobbyists involved
with the application, and a number of individuals close to the case.
Additionally, the Committee received relevant documents from the
1
1).2
See Denise Homer's Recommendation to the Assistant Secretary for Indian Affairs (Exhibit
See Cary SpiVak, Did White House Kill a Casino?, Milwaukee Journal Sentinel, Sept. 14,
1997.
3
Letter from Michael Anderson to Rose Gurnoe, Alfred Trepania, and Arlyn Ackley, Sr., July
14, 1995 (Exhibit 2).
(3113)
3114
ongoing Federal and state litigation surrounding the Department's
decision.
On January 21, 22, 28, and 29, 1998, the Committee held public
hearings on the issue of whether undue political influence led to
the rejection of the application. The Committee heard from witnesses including: the Chairmen of the three adversely affected
tribes, Patrick O'Connor (a lobbyist opposed to the application),
Secretary of the Interior Bruce Babbitt and a number of officials
from the Department of the Interior. These hearings focused on the
process by which the Department of the Interior came to reject the
recommendations of its area office and the influence of outside entities on the process.
EVENTS LEADING TO THE DENIAL
3115
the President, White House staff, Members of Congress, and the
Department of the Interior.
On February 8, 1995, O'Connor set-up a meeting in Minnesota
Congressman Jim Oberstar's office with members of the Minnesota
Congressional delegation, John Duffy, who served as Counselor to
Secretary of the Interior Babbitt, and George Skibine, the head of
the Indian Gaming Management Staff (IGMS).7 The meeting resulted in a great benefit to the tribes opposed to the application because Duffy agreed to extend the comment period which the Area
Director had closed prior to sending her recommendation to Washington. Duffy would later set an April 30, deadline for the comment
period. However, he failed to notify the applicant tribes of this special extension, thereby giving the opponents of the application an
unfair advantage. 8 Given that the Department was required to
treat all parties evenhandedly, this was a troubling decision.
The February 8, 1995, meeting in Representative Oberstar's office was followed 5 weeks later by another high level contact between the lobbyists against the application and representatives
from Secretary Babbitt's office. On March 15, 1995, Patrick O'Connor and former Congressman Thomas Corcoran (a law partner of
O'Connor) met with Tom Collier, Secretary Babbitt's Chief of Staff,
and Heather Sibbison, Special Assistant to Secretary Babbitt's
Counselor John Duffy.9 One of the matters discussed at this meeting was "the politics of the project." Collier also told O'Connor and
Corcoran that "the final decision would be made by him or Secretary Babbitt 'depending on the level of controversy this application generates.'" 10
The President is asked for assistance
As early as April 1995, Patrick O'Connor tried to contact Loretta
Avent, Special Assistant to the President for Intergovernmental Affairs, the person in the White House who handled Native American
issues." He faxed material to the White House which discussed his
client's opposition to the Hudson application and asked that Avent
intervene with Secretary Babbitt on the Hudson application.12 According to Avent, she did not return O'Connor's call or answer his
fax because of legal advice she had received and thus "would not
speak with him or any lobbyist or lawyer" about these issues.13 Although his initial calls appear not to have been returned, O'Connor
capitalized on an opportunity to speak directly with President Clinton when he met with the President, Bruce Lindsey and Linda
7
Memorandum from Larry Kitto to Lewis Taylor, Feb. 6, 1995 (Exhibit 67). This memorandum states: "Pat (YConnor of our firm is working with Secretary Babbitt's office to confirm his
fatcipation in the meetmy that will be held on Wednesday, February 8, 1995 at 1:30 p.m. in
congressman Oberstar's omce."
sAn undated letter to Secretary Babbitt from the applicants indicates that they were never
informed bythe Department of Interior about the extension of the comment period (Exhibit 3).
John DufSecretary Babbitt's Solicitor, later notified the tribes in a Mar. 27, 1995, letter to
Arlyn AeSr.,
almost 7 weeks after the period was opened (Exhibit 4). In fact, this notification might never have occurred if Ackley hlad not found out about the extension from other
sources. Once this came to light, the Department had no choice but to let both sides respond.
*Memorandum from Thomas Corcoran to Larry Kitto, Mar. 17, 1995 (Exhibit 68).
"xSee Patrick O'Connor's Datebook, Apr. 10 and 17, 1995 (Exhibit 5).
12OBrndmfrom
Michael T. Schmidt to cheryl Mills, Apr. 24, 1995 (Exhibit 6).
1
a Memorandum from Loretta Avent to Harold Ickes, Apr. 24, 1995 (Exhibit 7).
3116
Moore at a small fundraising reception in Minneapolis on April 24,
1995.14
President] said, "Bruce, talk to O'Connor about his concerns about tribes that he represents." That was it.17
Ann Jablonski, a lobbyist for the St. Croix Tribe, confirmed
through Tom Corcoran, O'Connor's partner, that O'Connor began to
"launch into the matter and Clinton called Lindsay [sic] over to
script the story and operationalize a response or resolution. He was
apparently the one who decided it was a problem Ickes would/
could/should take care of." '8 Jablonski also received confirmation
that the President was aware of the Hudson situation: anotherhr
partner in the O'Connor and Hannan firm, Tom Schneider, allegedly an FOB [Friend of Bill] who socializes with Bill and Hillary,
has confirmed in a conversation with Clinton that Clinton is aware
of the Hudson dog track issue." 19
Once the President became involved, the White House reacted
with a flurry of activity. Lindsey called back to the White House
once he returned to Air Force One in order to determine what was
happening with the former DNC Treasurer's problem, and why
Avent had not returned his calls. 2 0 O'Connor testified:
I told Bruce the concern we had . . . And I said, "I'm try-
i16 Id.
Patrick O'Connor's deposition was taken in a civil law suit filed by the applicant tribes after
DOI rejected the application.
"State
Court Deposition of Patrick O'Connor, Apr. 18, 1997, p. 61 (Exhibit 8).
1
8Memorandum from Ann Jablonski to Brady Williamson, May 23, 1995 (Exhibit 9).
1o Id.
2201See
Memorandum from Michael T. Schmidt to Cheryl Mills, Apr. 24, 1995 (Exhibit 6).
State Court Deposition of Patrick O'Connor, Apr. 18, 1997,
p. 61 (Exhibit 8).
3117
that Lindsey contacted Ickes shortly before or after his call to
Avent because Ickes placed a call to O'Connor that same day. 2 2
Warning of illegal and improper involvement
It appears that the conversation between Lindsey and the White
House staff on April 24 made an impression, prompting the two
key White House staffers on Indian issues, Loretta Avent (Special
Assistant to the President for Intergovernmental Affairs) and Michael Schmidt (Senior Policy Analyst in the White House Office of
Policy Development) to prepare memoranda on the issue. Both
memoranda outlined legal, ethical, and political reasons that the
White House could not get involved and intervene in the application before the Department of the Interior. It appeared that these
memoranda were attempts to explain why the White House should
not get involved in the decisionmaking process at Interior. The only
reasonable explanation for such quick and forceful opposition to
White House involvement was that Lindsey may have suggested
such involvement.
Ms. Avent's memorandum to Harold Ickes explains the improper
nature of White House intervention in an Interior decision. Avent
relied upon advice of the White House counsel's office to arrive at
the conclusion that involvement by the White House was improper
and illegal:
I just got a call from Bruce in reference to a person named
Pat O'Connor, whom I don't know, who has called me on
numerous occasions. . . . Following the legal advice we
3118
date. The press is just waiting
for this kind of story. We
don't need to give it to them.2 '
Michael Schmidt also drafted a memorandum in response to
Lindsey's call. He sent his memo to Cheryl Mills in the White
House Counsel's office:
This e-mail is to fill you in more detail about a call that
Loretta and I were on with a Lobbyist/Fundraiser named
Pat O'Connor . . . Pat called Loretta last week on this
in this issue! . . . As you know, we legally cannot intervene with the Secretary of Interior on this issue. Please
have Harold call Don Fowler and explain that there are no
secrets in Indian Country, that word of this conversation
is already getting out and it would be political poison for
the President or his staff to be anywhere near this issue. 25
Although these two memoranda indicate that the White House
staffers understood that they should not get involved in the Hudson issue, the sentiments contrast with an overlooked sentence in
Loretta Avent's memorandum, where she stated: "I am on my way
into a meeting with five of our strongest tribal leaders (because of
their significant voter turnout)[.]" 26 It is somewhat curious that
Avent would react so negatively to the Hudson issue and, at the
same time, single out Native American leaders-based on partisan
political concerns-for special White House treatment. The concern
regarding "secrets in Indian country," referred to by Schmidt, appears to have been overridden in this political situation.
As the following pages make clear, others at the White House did
not follow the course suggested by Avent. There were numerous
subsequent contacts between the Secretary of the Interior's office
and White House Deputy Chief of Staff Harold Ickes' office.
The DNC becomes involved
After meeting with the President, O'Connor moved to increase
the pressure on the Department of the Interior by involving the
DNC. As early as March 1995, O'Connor was attempting to meet
with people at the DNC and Interior. 2 7 On April 23, 1995, David
Mercer called O'Connor to notify him that a meeting with DNC
Chairman Fowler was set for a time after his [O'Connor's] meeting
with the Department of the Interior's Chief of Staff Tom Collier.2 8
On April 28, 1995, Patrick O'Connor and representatives of tribes
opposed to the Hudson project met with Don Fowler, White House
staff, and staff from various Senate offices. 29 Speculating on why
lobbyists would meet with the money raising wing of the Democratic party, Judge Barbara Crabb of the U.S. District Court for the
Western District of Wisconsin stated in a published opinion: "I can" Memorandum from Loretta Avent to Harold Ickes, Apr. 24, 1995 (Exhibit 7).
2Memorandum from Michael Schmidt to Cheryl Mills, Apr. 24, 1995 (Exhibit 6).
2Memorandum
from Loretta Avent to Harold Ickes, Apr. 24, 1995 (Exhibit 7).
27
Patrick O'Connor Datebook, Mar. 15, 1995 (Exhibit 5).
2Fax from O'Connor & Hannan to Patrick O'Connor, Apr. 23, 1995 (Exhibit 10).
*'SokaogonChippewa Community v. Bruce Babbitt, 961 F. Supp, 1276, 1282 (W.D. Wis.
1997).
3119
not assume that Fowler met with these tribes merely to socialize.
They must have expected that Fowler had some ability to affect the
decision on plaintiffs' application." 3 0
As it turned out, Judge Crabb appears to have correctly articulated the purpose of the meeting. As one lobbyist who also attended
the April 28, 1995, meeting with Don Fowler explained:
The purpose for this meeting is to discuss our position on
the Wisconsin Dog Track Fee to Trust proposal with influential democrats in Washington. The people we are meeting with are very close to President Clinton and can get
the job done.3 1
The purpose of the April 28, 1995, meeting with the DNC Chairman was also clearly outlined in a memoranda from lobbyist Larry
Kitto to the opposing tribes.
The purpose of the meeting was to request the DNC and
the Committee to re-elect the President, to help communicate with the White House and the President about why
the Department of the Interior should not approve the feeto-trust land transfer for the Hudson Dog Track. The message was quite simple: all of the people against the project
both Indian and non-Indian are Democrats who have a
substantially large block of votes and who contribute heavily to the Democratic party. In contrast, all of the people
for this project are Republican. Fowler assured the group
that he would take this issue up with high ranking officials in the White House[.] 3 2
Both Chairman Fowler and David Mercer, the Deputy Finance Director of the DNC, understood the potential of helping people who
"contribute heavily to the Democratic party." Lewis Taylor, head of
the St. Croix tribe, mentioned in a State Court Deposition that contributions to the DNC were discussed. Taylor commented: "I told
Mr. Fowler that, you know, that we've got a number of heavy-duty
issues that we needed help on and our friends are the Democrats
and therefore I think we should donate to assist in some of these
causes." 3 3 Tom Krajewski, a lobbyist working on behalf of the Hudson opponents, passed on information from Kitto, O'Connor's partner and a principal lobbyist for the tribes, that Fowler listened,
took notes, asked questions and got the message: "It's politics and
the Democrats are against it and the people for it are Republicans." 34 When asked about any discussion of campaign contributions, Fowler did not recall and defended himself by saying that he
had "no memory."3 5
It is difficult to believe that Fowler would have a different perception of this meeting. After all, the message was as Larry Kitto
said, "quite simple." After the discussions of campaign contributions, Fowler not only promised to contact the White House, but
30 Id.
a1 Memorandum from John McCarthy to all tribal leaders, Apr 25 1995 (Exhibit 11).
"Minnesota Legislative Update Apr. 24-28, 1995 (Exhibit 12). This lobbying report prepared
by Larry Kitto mistakenly notes the meeting as Apr. 18, 1995.
" State Court Deposition of Lewis Taylor, Dec. 17, 1996, p. 71 (Exhibit 13).
"Memorandum from Tom Krajewski to JoAnn Jones, May 3, 1995 (Exhibit 14).
-Testimony of DNC Chairman Don Fowler before the Senate Committee on Governmental
Affairs, Sept. 9, 1997, p. 108.
3120
also promised to urge Harold Ickes, White House Deputy Chief of
Staff, to press Secretary Babbitt to "make a closer examination of
impact of the [Hudson casino]." 3 6 The above excerpts clearly show
a belief on the part of the lobbyists that campaign donations were
to be exchanged for policy decisions.
In a document obtained by the Committee from the Democratic
National Committee, it seems clear that both Chairman Fowler
and David Mercer understood the possible fundraising potential of
opponents of the Hudson application. Mercer outlined calls for
Chairman Fowler, and under the heading "Pat & Evelyn "Evie"
O'Connor" stated:
The O'Connors are on the hook with Peter Knight to raise
$50k for the re-election. I'm meeting with them tonight to
talk to them about bringing in the American Indian money
of $50k for the Gala[.] . .. Pat is certain to inquire about
76).
Sept. 9, 1997,
p. 39
107.
Memorandum from Joe Sandler and Neil Reiff to the DNC Finance Staff, Nov. 11, 1995 (Exhibit 16).
40 Senate Deposition of Don Fowler, May 21, 1997, pp. 260-261.
41 Memorandum from Don Fowler to Harold Ickes, May 5, 1995 (Exhibit
17).
3121
Below is an outline of the issues raised during my meeting
with several tribal leaders and DNC supporters who oppose the project. I've also attached a Peat Marwick impact
study forwarded by our supporters. Please let me know
how we might proceed.
. .
3122
of gaming
POTUS [President of the United States] re 5expansion
0
and the dog track and opposition to so doing."
Harold Ickes' staff contacts the Departmentof the Interior
Harold Ickes, apparently, did keep his promise. Indeed, Ickes and
his staff kept a close eye on the application from the White House.
On May 18, 1995, Ickes' assistant, Jennifer O'Connor,5 1 prepared
a memorandum for Ickes updating him on the information received
the Department of Interior was
from Patrick O'Connor and where
in the decisionmaking process. 52 It is clear from this memorandum
that Jennifer O'Connor was in contact with staff familiar with the
application at the Department of the Interior. Jennifer O'Connor
also was privy to information that Interior was looking to reject the
the information "is not public
application and advised Ickes that
and is confidential at this point." 53
This would not be the last time the White House would contact
Interior to receive confidential information kept from the applicant
tribes. On June 6, 1995, David Meyers, an employee in Ickes' office,
indicated that he had spoken with Heather Sibbison, Special Assistant to Secretary Babbitt, and that Interior planned to "make an
announcement in the next two weeks."54 Sibbison relayed confidential information that Interior was "95% certain that the application
will be turned down. . . . [and] they will probably decline because
3123
effort to distance himself from the application, testified that he was
"peripherally involved" and "Jennifer O'Connor on my staff was the
primary person on [the Hudson application]." 5 7 Heather Sibbison
and Jennifer O'Connor continued communications between the Department of the Interior and the White House, even though O'Connor did indicate that she prefaced all of her conversations with Interior stating "I'm making a status inquiry, don't want to influence
anything, don't tell me anything you're not supposed to tell me."5 8
In addition, Jennifer O'Connor was also in contact with John Duffy's office. At the time, Duffy was Counselor to the Secretary and
one of the top political appointees involved in the decisionmaking
process. O'Connor called Duffy's office on at least two occasions
known to the Committee. One conversation was in response to a
call from Duffy. The message sli received from Duffy's office
records reads returned your call."59 Additionally, it is important
to note that the "disposition" column read "done" which most likely
means that Duffy returned O'Connor's call. 60
On June 26, 1995, Jennifer O'Connor faxed a letter to Sibbison
inquiring about the Chippewas' application. The next day, Sibbison
faxed back two responses--one indicating that the Department
would reject the Chippewa application and the other indicating
that the Department was reviewing the matter.6 1 This raised
strong suspicions of political impropriety in the eyes of Judge
Crabb, who stated:
[T]he fact that [Sibbison] sent two letters to the White
House with different messages implies that the White
House had been involved in the matter already. Also, the
mere fact that Sibbison sent two somewhat contradictory
letters suggests that the department was aware of the
need for some subterfuge in the process to allow Ickes to
advance political ends. The letters seem almost to allow
Ickes to choose which direction he wanted the Department
to take. The more troubling aspect of Sibbison's June 27
response is that it means the Department had reached a
decision on plaintiffs' application by that date. This undermines the departments assertion that Deputy Assistant
Secretary Anderson was the one making the decision on
plaintiffs' application. 6 2
Judge Crabb's remarks appear particularly well-founded considering what was happening at the staff level. For example, on July
5-just 2 weeks after the "subterfuge" of the diametrically opposed
letters-Troy Woodward, a lawyer in the Solicitor's office, sent the
following e-mail:
Tom [Hartman], George [Skibine] said you were working
on an analysis of the Hudson Dog Track proposal and
whether the proposed gaming would be in the best interests of the Tribes and not detrimental to the surrounding
57
Testimony of Harold Ickes before the Senate Committee on Governmental Affairs, Oct. 8,
1997, pp. 46-47.
5Deposition of Jennifer O'Connor, Sept. 15, 1997, pp. 96-97.
59
Department of the Interior telephone record, May 25, 1995 (Exhibit 21).
60
6 1Id.
to Jennifer O'Connor, June 27, 1995 (Exhibit 22).
2 Letter from Heather Sibbison
6 Sokaogon Chippewa Comm., 961 F. Supp, at 1283.
3124
community. Can you please send me an electronic copy of
your analysis before 1:30? 63
This communication is remarkable for two reasons. First, it shows
that 9 days before the decision was made, the key non-political
staff had not reached a conclusion about the fate of the application. 6 ' Second, and perhaps more important, it shows that there
was still no analysis that indicated the application was detrimental
to the surrounding community. Nevertheless, 9 days later a political appointee rejected the application, stating: "Because of our concerns over detrimental affects on the surrounding community, we
are not in a position, on this record, to substitute our judgment for
that of local communities directly impacted by the proposed off-reservation gaming acquisition."65 Given the extraordinarily arbitrary
nature of the decision, Judge Crabb was certainly justified when
she speculated that "the Department was aware of the need for
some subterfuge in the process to allow Ickes to advance political
ends."66
Ultimately, communication between the White House and Interior reached a level where according to David Meyers, Sibbison
for any "feedback" she
went so far as to ask Jennifer O'Connor
might have had on the application. 67 In an extraordinary memorandum from one Ickes staffer to another Ickes staffer, David Meyers writes to Jennifer O'Connor: "[Sibbison] stated that they will
probably decline without offering much explanation, because of
their 'discretion' in this matter. She asked that if you have any
feedback please call her with your thoughts."68 As already discussed, the use of quotation marks for "discretion" is curious. More
important, the fact that the Secretary of the Interior's Special Assistant was telling Harold Ickes' staff that Interior would reject the
application "without offering much explanation" cannot be given an
innocent explanation. Given the weight of all the evidence before
this Committee, the real reason that the rejection would be made
"without offering much explanation" is that there was no evidence
to offer. Mere incompetence cannot explain why the government
would reject an application without properly justifying its decision.
Not only is such action the definition of "arbitrary and capricious,"
it is also, given the almost-certainty of litigation when a decision
is not supported by valid reasoning, contemptuous of the taxpayer
who must pay for the agency's misfeasance in court.
The communication which has received the most speculation and
attention, however, appears to have been from Harold Ickes to Secretary Babbitt himself.
63E-mail from Troy Woodward to Tom Hartman, July 5, 1995 (Exhibit 65).
6A.l produced copies of memoranda prepared by Tom Hartman show that far from finding
that the application was a detriment to the surrounding community, he concluded the oppositethat the application was not a detriment to the surrounding community. See, e.g., Memorandum
from Indian Gaming Management Staff to Director, Indian Gaming Management Staff, June 8,
1995 (Exhibit 44); see also Memorandum from George Skibine to Assistant Secretary-Indian
Affairs, undated (Exhibit 45). Both of these memoranda are marked "draft." However, no other
memoranda were produced as final work product, and there are no other staff memoranda to
the65contrary prior to the rejection letter.
Letter from Michael Anderson to Rose Gurnoe, Alfred Trepania, and Arlyn Ackley, Sr., July
14, 1995 (Exhibit 2).
66Sokaogon
Chippewa Comm., 961 F. Supp, at 1283.
6
Memorandum from David Meyers to Jennifer O'Connor, June 6, 1995 (Exhibit 20).
68 Id.
3125
Additional significant communicationsprior to the denial
Although evidence shows frequent communication between the
White House and the Department indicating the application would
be denied, there was no such communication with the applicant
tribes. The applicants had a number of contacts with Interior officials and were not informed of any significant-let alone fatal--defects in their application. Indeed, in May 1995, Paul Eckstein 69 a
lawyer and friend of Secretary Babbitt's who worked on behalf of
the Chippewas, had a conversation with Secretary Babbitt during
which Babbitt reportedly promised to meet personally with the
tribal Chairmen and Eckstein if a problem with the application
arose. 7 0
On May 17, 1995, tribal representatives, Fred Havenick, and
Paul Eckstein met with John Duffy. In this meeting Duffy did not
identify any specific problem with the application. Nevertheless, he
did convey that he did not believe the application would be a "slam
dunk." 7 1 This was one of the only comments made by Duffy in the
meeting. In an effort to look deeper into the matter, the group met
with George Skibine and Thomas Hartman that same day. In this
meeting the group discussed the technical aspects of the application and no problems were identified. 72 That night, however, staff
at Interior met and reported to the White House that a preliminary
decision to reject the application had been reached.73 Not only was
this not communicated to the applicant tribes, they had not even
been given a clear understanding of what they needed to do to correct any perceived defects in the application. Given the Department's previous efforts to work with applicant tribes to perfect applications-including in one situation hiring mediators to broker
applicant/community harmony-there has yet to be advanced a reasonable explanation for the Department's approach to this application. If the decision was made under appropriate circumstances, as
Secretary Babbitt has repeatedly argued, there would have been no
reason to withhold critical information from the applicants, while
at the same time favoring the opponents.
George Skibine and Thomas Hartman had the opportunity to articulate any perceived problems when they met again with Paul
Eckstein and Fred Havenick on May 31, 1995. Interestingly, there
were no problems identified and Eckstein and Havenick left believing the application was on its way to approval. 74 Either Skibine
and Hartman did not know that a decision had been made, or they
refused to help the applicant tribes. Hartman, however, may not
69Paul Eckstein is a ln time friend of Secretary Babbitt. The two met at Harvard Law
School in 1962 and returned to Arizona to practice law. In 1967 Babbitt was hired by a small
law firm in Phoenix where Eckstein was working. In 1974, Babbitt left the firm when he was
elected Arizona Attorney General. In 1978 Babbitt was elected Governor of Arizona. Throughout
Babbitt's political career, Paul Eckstein has been a part of his inner circle of advisors. For example, Eckstein ran Babbitt's re-election for Governor in 1982. Needless to say Eckstein and Babbitt were close friends. (Committee Staff Interview with Paul Eckstein; see also Senate testimony of Paul Eckstein, Oct. 30, 1997, pp. 13-14).
estimo of Paul Eckstein before the Senate Committee on Governmental Affairs, Oct. 30,
1997 p. 18; see also Senate Deposition of Paul Eckstein, Sept. 30, 1997, p. 29.
"S~enate Deposition of Paul Eckstein, Sept. 30, 1997, p. 88. In his deposition before this Committee, John
remembered the phrase "not a slam dunk," but did not recall having had
any discussions about problems with the application with "the applicant tribes or any other representatives."
Deposition of John Dufy,, Jan. 26, 1998, pp. 40-41.
72
7 3Id. at 35-36.
See Memorandum from Jennifer O'Connor to Harold Ickes, May 18, 1995 (Exhibit 19).
74
Comnmittee Staff interview with Fred Havenick.
3126
have known about the preliminary decision, because as late as
June 16, 1995, he relayed to Eckstein that the staff report was just
passed to Skibine and there were no problems that could not be
cured.7 5 Eckstein later called George Skibine on June 26, 1995,
seeking an additional status report. To Eckstein's surprise, Skibine
refused to talk about the application for fear that he would lose his
job.76 Again, this adds to the concern that the Hudson decision was
not made on the merits.
Inconsistencies in Secretary Babbitt's statements
There is substantial evidence that Ickes called Secretary Babbitt
in order to influence the Department's decision on the Chippewa's
application. Paul Eckstein testified in a sworn affidavit:
Later that day, on July 14, 1995, I met with Secretary
Babbitt. I asked the Secretary if he would delay the release of the decision of the Tribes' application until the following Monday to allow time for the Tribes to attempt to
respond to the political pressure being exerted against the
application. Secretary Babbitt said that the decision could
not be delayed because Presidential Deputy Chief of Staff
Harold Ickes had called the Secretary and told him that
the decision had to be issued that day.7 7
When word of Eckstein's assertion was disseminated, Secretary
Babbitt denied the account. Babbitt immediately denied any contact with Ickes or that Ickes played any role in the decision. Secretary Babbitt even denied ever using Ickes' name in front of
Eckstein. In an August 30, 1996, letter to Senator John McCain,
Secretary Babbitt stated:
I must regretfully dispute Mr. Eckstein's assertion that I
told him that Mr. Ickes instructed me to issue a decision
in this matter without delay. I never discussed the matter
with Mr. Ickes; he never gave me any instruction as to
what the Department's
decision should be, nor when it
should be made.7 8
Judge Crabb, in the Federal law suit filed in Wisconsin against
the Department of the Interior, correctly noted: "[ilt would be improper to dismiss Eckstein's assertion just because Babbitt denies
it."79 Indeed, Secretary Babbitt, upon further reflection, gave Senate Governmental Affairs Committee Chairman Fred Thompson
another contradictory statement about what happened:
[W]hile I did meet with Mr. Eckstein on this matter shortly before the Department made a decision on the application, I have never discussed the matter with Mr. Ickes or
anyone else in the White House. Mr. Ickes never gave me
instructions as to what this Department's decision should
be, nor when it should be made. I do believe that Mr.
Eckstein's recollection that I said something to the effect
75
77 Id.
3127
that Mr. Ickes wanted a decision is correct. Mr. Eckstein
was extremely persistent in our meeting, and I used this
phrase simply as a means of terminating the discussion
and getting him out the door.80
In testimony before the Committee on Government Reform and
Oversight and the Committee on Governmental Affairs, Babbitt indicated that his statements were not only truthful but consistent.8 1
A simple reading, however, would lead to the opposite conclusion.
One of the most damaging and troubling pieces of Eckstein testimony revolved around the alleged rhetorical question asked of
Eckstein by Secretary Babbitt. The question involved campaign
contributions given to the Democratic party. 82 Secretary Babbitt is
said to have indicated that "these tribes [donated] on the order of
half a million dollars, something like that."8 3 This statement, if
true, constitutes an illegal sale of government policy for campaign
contributions. Secretary Babbitt has said he has "no recollection" of
mentioning contributions with anyone from the White House, the
DNC, or anyone else. 8 ' However, the difference between his correspondence to Senator McCain and then to Senator Thompsoncombined with direct evidence of White House contacts with the
Secretary's office and direct and circumstantial evidence relating to
improper decisionmaking at the Department of the Interior-make
the Secretary's statement less than credible. Furthermore, Secretary Babbitt's willingness to make misrepresentations about
smaller matters-for example, Governor Thompson's position on
the application or whether the decision was based solely on Section
20 of the Indian Gaming Regulatory Act-adds to the sense that
he has not been candid about his involvement in the Hudson matter.
"PossibleDOJ involvement"
In a document produced to the Committee pursuant to subpoena,
Scott Keep, an employee in the Solicitor's office, sent the following
e-mail to Heather Sibbison, Hilda Manuel, Michael Anderson, Tom
Hartman, Paula Hart, George Skibine and Troy Woodward:
DOJ [Department of Justice] has found a reference in one
of the documents or testimony to possible DOJ involvement in the Hudson dog track matter. Are any of you
aware of any involvement by anyone at DOJ in the Hudson dog track matter prior to the decision on July 14? . . .
If anyone has any recollection of a contact from DOJ,
please advise me.**
Apart from this one reference, the Committee is not aware of any
Department of Justice involvement with the Hudson application
so Letter from Secretary Bruce Babbitt to Senator Fred Thompson, Oct. 10, 1997 (Exhibit 25).
asTestimony of Secretary Bruce Babbitt before the Committee on Government Reform and
Oversight, Jan. 29, 1998, p. 797; see also Testimony of Secretary Bruce Babbitt before the Committee on Governmental Affairs, Oct. 30, 1997.
"Senate Deposition of Paul Eckstein, Sept. 30, 1997, p. 53.
" Id.
"Testimony of Secretary Bruce Babbitt before the Committee on Government Reform and
Oversight, Jan. 29, 1998, p. 791; see also Testimony of Secretary Bruce Babbitt before the Committee on Governmental Affairs, Oct. 30, 1997.
"E-mail from Scott Keep to Heather Sibbison, Hilda Manuel, Michael Anderson, Tom Hartman, Paula Hart, George Skibine, Troy Woodward, Nov. 17, 1997 (Exhibit 72).
3128
prior to the rejection of the application on July 14, 1995. It is entirely possible, however, that such a contact would have relevance
to the Committee's investigation.
PROBLEMATIC ASPECTS OF THE HUDSON DECISION
3129
on the Chippewas' application. 93 Patrick O'Connor also testified
that he met with David Mercer, the Deputy Finance Director of the
DNC, several times after his April 28 meeting with Chairman
Fowler to discuss "how many Indians we could get to attend the
presidential gala" ($1,000 or $1,500 donation required) in June.9 4
Patrick O'Connor had a goal to raise $25,000 from the Tribes for
that fundraiser,9 5 and he also recalled that he and Larry Kitto met
with Terry McAuliffe, the National Finance Chairman of the Clinton/Gore '96 Committee, and was asked for more $1,000 donations
from members of tribes opposed to the application.9 6 O'Connor was
also responsible for a fundraiser on October 23, 1996, in Minneapolis, Minnesota, honoring Vice President Gore, in which 17 of the 20
attendees were members of tribes opposed to the Hudson casino, or
their lobbyists.9 7 Thus, the Vice President went to a fundraiser
that was-with the exception of only three attendees-composed
exclusively of beneficiaries of the Hudson decision.
In testimony before the Senate Governmental Affairs Committee,
when asked about the contact Patrick O'Connor had with Deputy
Finance Director David Mercer while the Hudson application was
under consideration at the Department of the Interior, Fowler
could not remember anything about Mercer's contacts with those
opposed to the application.9 8 However, Chairman Fowler admitted
that "one could infer that the casino matter was discussed[.]"99 Although O'Connor has denied any link between DNC solicitations
and his clients' donations, a review of his daybook would reasonably lead to a different conclusion. Because O'Connor billed his Native American clients for the time he spent discussing and coordinating campaign donations with the DNC and Clinton/Gore '96
staffo100 it is reasonable to conclude that Patrick O'Connor believed
that these contributions were intertwined with defeat of the Chippewas' application before the Department of the Interior.
A review of O'Connor's calendar is one of the clearest indications
that campaign dollars were exchanged for influence in the decisionmaking process at the Department of the Interior. On the day the
application was denied, Patrick O'Connor wrote in his daily planner: "need to follow up with Harold Ickes at the White House,
[Don] Fowler at the DNC and Terry Mac [Auliffe] at the Committee
to reelect-outlining fundraising strategies."1 0 1 In addition to the
entry in O'Connor's calendar he also billed the St. Croix tribe for
the fundraising discussions with Ickes, Fowler, and McAuliffe.1 0 2
The fact that O'Connor was engaged in "follow up" discussions on
the very day the Hudson application was denied indicates that
fundraising dollars played a larger role in the decision than anyone
is willing to admit.
Given the direct and circumstantial evidence indicating a political decision, it is hardly surprising that O'Connor's clients and the
93State
4
95 Id.
Court Deposition of Patrick O'Connor, Apr. 18, 1997, pp. 71-72 (Exhibit 8).
9 Id.
9 7 Id. at 87-88.
9 5VPOTUS Reception
3130
after
lobbyists against the Hudson application began contributing
cehad
O'Connor
and
denied,
was
the Chippewas' application
mented the "fundraising strategy" with the White House, DNC and
Clinton/Gore '96. Furthermore, 2 months later, on September 14,
1995, Patrick O'Connor and Larry Kitto sent out personal invitations encouraging opposition tribe members to attend0 3$1,000 per
In the inperson Presidential and Vice Presidential fundraisers.
President
that
belief
their
vitation, O'Connor and Kitto reiterated
tribes:
opposing
the
of
behalf
on
intervened
staff
his
and
Clinton
"As witnessed in the fight to stop the Hudson Dog Track proposal,
the Office of the President can and will work on our behalf when
asked to do so." 104 This feeling was also shared by at least one of
the tribes who wrote to thank both the President and the DNC
Chairman. The President of the Ho-Chunk Nation wrote to Chairman Don Fowler:
On behalf of the Ho-Chunk Nation, I want to thank you
for your help in the successful effort to defeat the Hudson
casino. Numerous people contributed to the Department of
Interior decision. You were particularly instrumental in
the significance and
helping the Department understand
importance of their decision.10 5
President Clinton's efforts also did not go unappreciated: "On behalf of the Ho-Chunk Nation, I want to thank you for your role in
the decision to deny the request to approve the Hudson casino."106
Shortly before the decision to reject the application was made, at
the time that the White House was getting involved in the Hudson
application, Chairman Fowler received a memorandum from one of
his staffers. This memorandum states: "Craig Smith, White House
Assistant to Political Affairs, and Judy DeAtley, DNC Western Porepresentatives to discuss
litical Desk, met this week with Indian
political and campaign strategies." ' 0 7 This memorandum indicates
much greater coordination with Native Americans than previously
known. It also includes material from Kevin Gover-then a lawyer/
lobbyist in the private sector and now the Assistant Secretary for
the Bureau of Indian Affairs-stating that: "[t]he tribes can be
Minnesota, Wisconsin, Flormajor financial players in California,
10 8
ida, New Mexico, and Washington."
It appears to be far from coincidental that this flurry of political
activity involving Native Americans was taking place as the Department of the Interior was deciding to reject the advice of its own
area and regional offices.
The applicant tribes were not given the opportunity to cure any of
the application'salleged defects
While the opponents celebrated their victory and sent letters of
appreciation to the President, the decision to reject the application
took the applicant tribes by surprise. The applicant tribes have
'Letter
10 Id.
from Patrick O'Connor and Larry Kitto, Sept. 14, 1995 (Exhibit 32).
Letter from JoAnn Jones to Don Fowler, Aug. 3, 1995 (Exhibit 33).
..
o Letter from JoAnn Jones to President Clinton, Aug. 3, 1995 (Exhibit 34).
107 Memorandum from Alejandra Castillo to Don Fowler, June 23, 1995 (Exhibit 35).
"o'Memorandum from Kevin Gover and Cate Stetson to Craig Smith and Judy DeAtley, June
19, 1995 (Exhibit 36).
105
3131
consistently complained that they were never consulted in advance
about the alleged problems the Department of the Interior found in
the application. This is a critical point, and the record supports this
position.
The statutory language of Section 20, reads: "[land may be placed
into trust if] the Secretary, after consultation with the Indian tribe
... determines that a gaming establishment ... would be in the
best interest of the Indian tribe and its members, and would not
be detrimental to the surrounding community[." 0 9 It is true that
members of the Interior Department met with tribal leaders, but
the tribal leaders were not consulted about any problem which
would have jeopardized the application. Indeed, the consultation
that did take place resulted in both the Area and Regional office
approving the application. There was no subsequent consultation
that put the applicants on notice that the Secretary's office had
identified problems that had not already been addressed or solved
at the Area and Regional levels. Furthermore, there was no indication that the Department was going to change its policy just for the
Hudson application and discard the standard that opposition, to be
considered, had to be supported by "factual documentation."110
Given the Department's role in the Sault Ste. Marie and Pequot
applications to help facilitate accommodations with the local communities, there are strong indications that the decision may have
been driven by political motives.
The conclusion appears to be inescapable: where contributors of
large amounts of money were involved, the Secretary's office appears to have helped the contributors. In the Hudson application,
the Secretary's office again helped the large contributors-this time
by failing to notify the applicants that the comment period had
been reopened and then denying the application without informing
the applicants of defects or providing a chance to cure the alleged
defects.
David Jones, the Assistant U.S. Attorney representing the Department of the Interior in the ongoing law suit regarding this
matter, identified the problem that the Department would face
when it became clear that the applicant tribes had not been consulted about potential problems with the application. Jones wrote:
Now that we have reviewed the administrative record in
greater depth, we have determined that the alleged problems with the 2719 [Section 20 of IGRA] process are significant. We are primarily concerned about our ability to
show that the plaintiffs were told about and given an opportunity to remedy the problems which the Department
ultimately found were outcome-determinative. Area Directors are told to give applicants an opportunity to cure
problems, and it will be hard to argue persuasively that
109 Section 20 of the Indian Gaming Regulatory Act has been codified at 25 U.S.C.
(emphasis added).
2719(bX1XA)
1 0
Hilda Manuel, in a letter to Representative Gunderson, stated that "any opposition should
factual documentation." Letter from Hilda Manuel to Representative Steve
by
be supported
Gunderson, Mar. 2, 1995 (Exhibit 38). This issue is discussed fully in the next section of this
chapter.
3132
applicants lose this opportunity once the Central Office begins its review.1 11
Jones goes even further to note:
The administrative record, as far as we can tell, contains
no record of Department meeting or communications with
Department's concerns
the applicant tribes in which the
were expressed to the plaintiffs.1 12
The reason that there was nothing in the record is that the Department simply failed to identify such problems in advance. Had there
been a problem that would appropriately have led to the rejection
of the application, the Department of the Interior would have had
some record of the problem. Furthermore, it is likely that at least
one employee of the Department of the Interior would have told the
applicants that there was a problem that would prove fatal unless
cured.
The following exchange from George Skibine's deposition confirms David Jones' conclusion that the applicants were not given an
opportunity to cure defects:
Q: To clarify the meaning of my question, here were
three poor tribes that had presented an application to the
Department of the Interior, and you were making a determination as to whether to aprove the application or deny
the application. If you, as the director of the IGMS staff,
identified a particular problem that might lead to the rejection of the application, did you consider it important to
communicate that directly to the applicant tribes to give
them an opportunity to cure the problem?
A: Good question. I don't think that I did that on this
application, the first application I considered as head of
the gaming office. If I were to do that again different now,
you know, it might be different, it might be something I
would consider doing, but at that time, I didn't do it. In
other words, we did not[.] 113
Skibine elaborated further in the following exchange during his
deposition:
Q: Now if you had shared the June 29 draft with the applicants, is it possible they might have come back and offered accommodations to the problems you identified?
A: If we had done more consultation with them and told
them, yes, it's possible. We didn't do that in this instance. 114
If the Department of the Interior was acting in good faith, it
would have given the tribes an opportunity to cure the alleged defects. Because Interior acts as a middleman-the collector of information supporting or opposing the application-it has historically
been responsible for keeping the tribes informed of problems. In
other situations where political considerations were not driving the
11 Letter from David Jones to Scott Keep, Feb. 14, 1996 (Exhibit 37).
H2 Id.
113Deposition of George Skibine, Jan. 13, 1998, p. 61 (Exhibit 69).
114
Id. at 121.
3133
decision, Interior kept the applicants informed of the issues. In one
case they even hired a mediator to solve the problems between the
applicants and the local opponents.115 Particularly given the fact
that George Skibine recognized that the local opposition was "largely generated" by lobbyists opposed to the application,11 6 it is legitimate to ask why a mediator would be hired in one case and not
in another. One answer that naturally suggests itself is that to hire
a mediator for the Mashantucket Pequots benefited Democratic
contributors, and to hire a mediator for the three Chippewa applicants would have worked against Democratic contributors.
In the Hudson application, no one from DOI's central office even
visited the proposed site in Hudson, Wisconsin, to see any of the
alleged problems first hand. As for the central tenet of the rejection-opposition by the surrounding communities-the Department
of the Interior went so far as to misrepresent to this Committee
and to a Federal judge the facts pertaining to support for the application. 117
The Department changed its policy regarding off-reservation applications just before deciding Hudson
It is clear that the Department would have acted appropriately
if it made a finding, supported by fact, that the proposed Hudson
casino would have been a "detriment to the surrounding community." Because the record did not support such a finding, the Secretary's office changed the approach to evaluating off-reservation
gaming applications, and decided that unsupported opposition
within the community would be enough for a finding that the proposal would be a detriment to the surrounding community. In its
rejection of the application, the Department has morphed the Section 20 "detrimental to the surrounding community" standard into
a policy that the existence of opposition to an application is a "detriment to the surrounding community."
The Department of the Interior has not publicly discussed this
policy change. In communications obtained by this Committee pursuant to subpoena, however, Department officials have admitted
that a new policy was used to decide the Hudson application. Furthermore, it is clear that the applicants were not informed of the
new ground rules for deciding their application.
One clear statement that a new policy was used to decide the
Hudson application is found in an internal communication between
Secretary Babbitt's Special Assistant Heather Sibbison, and Michael Gauldin, a Department spokesman responsible for answering
questions about the Hudson decision. Almost 22 years after the
ecision was made, Sibbison-who was also the go-between with
1u1
16See
3134
the White House for the Hudson matter-made the following statement in a confidential internal e-mail:
[I]t has been our position, first articulatedin Hudson, that
officials essentially
expressed opposition from local elected
1 18
is prima facie evidence of detriment.
David Jones, the Department of the Interior's own attorney in
the civil litigation in Wisconsin, adds to our understanding of
Sibbison's statement:
The second, and related, problem is that the Department
appears to have changed its past policy of requiring "hard"
evidence of detriment to the community. The plaintiffs will
therefore argue that they had no notice, either through
past policy or through direct Departmental communicaby local officials
tion, that the "soft" concerns expressed
would jeopardize their application. 119
Even more enlightening is George Skibine's explanation of the
role of Counselor to the Secretary John Duffy. Skibine noted:
The Department (Duffy) made a decision that the opposition of the local communities was evidence per se of detriment, and that the Department was not going to require
the communities for detailed evidence to back up their opposition. 120
This was a departure from Department practice and established a
new standard to assess trust applications. It is certainly a departure from Acting Deputy Commissioner of Indian Affairs Hilda
Manuel's letter to Representative Gunderson-drafted just 4
months before the rejection-which pointed out that "any opposition should be supported by factual documentation." 1 2 1 Thus, in
the Hudson case, Babbitt's counsel established a new policy--one
not articulated anywhere or shared with any of the applicants.
Further illustrating the departure from what was standard practice up until the Hudson application, Kevin Meisner, an attorney
at the Department of the Interior, disagreed with Duffy's decision
and wrote a memorandum to a number of Department employees
involved in the Hudson decision (Troy Woodward, George Skibine,
Paula Hart, Tom Hartman, and Larry Scrivner). Meisner stated:
nIE-Mail from Heather Sibbison to Michael Gauldin, Dec. 16, 1997 (emphasis added) (Exhibit
54).
11 Memorandum from David Jones to Scott Keep, Feb. 14, 1996 (emphasis added) (Exhibit
37).
120 Memorandum from George Skibine to Scott Keep, Assistant Solicitor, Aug. 5, 1996 (Exhibit
51). Heather Sibbison characterizes Duffy as the person "most centrally involved" in the decision. Although he did not have the actual decisionmaking authority, Sibbison answered in the
affirmative when asked if Duffy "was much more involved in meetings and deliberations about
this particular application than Mr. Anderson." Deposition of Heather Sibbison, Senate Committee on Governmental Affairs, Sept. 26, 1997, p. 118-119. In a memorandum prepared by Troy
Woodward, Duffy's role is further explained: "Duffy thinks that the local communities may veto
off-reservation Indian gaming by objecting during the consultation process of Section 20. I expressed the opinion, advocated by George [Skibine] and which we have used to evaluate objections in the past, that the consultation process does not provide for an absolute veto by a mere
objection, but requires that the objection be accompanied by evidence that the gaming establishment will actually have a detrimental impact (economic, social, developmental, etc.). Memorandum
12 1by TMW [Troy Woodward], July 6, 1995 (Exhibit 77).
Letter from Hilda Manuel to Representative Steve Gunderson, Mar. 2, 1995 (Exhibit 38).
3135
My view on this matter is that the bald objections of surrounding communities including Indian tribes are not
enough evidence of detriment to the surrounding communities to find under Section 20 of IGRA that the acquisition for gaming will be detrimental to the surrounding
communities.
Specific examples of detriment must be presented by the
communities during the consultation period in order for us
to determine that there will be actual detriment. A finding
of detriment to surrounding communities will not hold up
in court without some actual evidence of detriment. In this
case the gaming office did not think that the information
obtained during the consultation period was enough to
show actual detriment to the surrounding community.122
In addition to making the point about unsupported objections not
being sufficient to establish detriment to the community, Meisner
provides a clear window into what actually happened prior to the
revisions and political cover-up following the decision. By pointing
that the "gaming office did not think that the information obtained
during the consultation period was enough to show actual detriment to the surrounding communities," a dispassionate observer
can only wonder what Secretary Babbitt meant when he told this
Committee that "the Department based its decision solely on the
criteria set forth in Section 20 of the Indian Gaming Regulatory
Act."1 2 3 If Section 20 requires a finding that an application not be
a detriment to the surrounding community, and Secretary Babbitt
maintains that the decision was based on Section 20 of IGRA, and
his own staff stated 8 days before the rejection that the gaming office did not have evidence of actual detriment, there should be little
surprise that this Committee has a significant problem with the
following language from the rejection letter: "Because of our concerns over detrimental effects on the surrounding community, we
are not in a position, on this record, to substitute our judgment for
that of the local communities directly impacted by this proposed
off-reservation gaming acquisition."1 2 4
Two significant problems flow from this policy change: (1) the applicants were not informed that new rules were being invented for,
and applied to, their application; and (2) the abrupt shift in policy
defied a valid Presidential directive prohibiting the Department
from changing policy without providing advance notification to the
tribes.12 5 Indeed, the change of policy conflicts with Section 20 of
=Memorandum from Kevin Meisner to Troy Woodward, George Skibine, Paula Hart, Tom
Hartman, and Larry Scrivner, July 6, 1995 (Exhibit 52).
- Testimony of Secretary of the Interior Bruce Babbitt, Jan. 29, 1998, p. 776.
=4 Letter from Michael Anderson to Rose Gurnoe, Alfred Trepania and Arlyn Ackley, Sr., July
14, 1995 (Exhibit 2).
125 President's Memorandum for the Heads of Executive Departments and Agencies: Government-to-Government Relations With Native American Tribal Governments, 59 Fed. Reg. 22951
(1994). In pertinent part, this Memorandum states: "In order to ensure that the rights of sovereign tribal governments are fully respected, executive branch activities shall be guided by the
following ... (b) Each executive department and agency shall consult, to the greatest extent
practical and to the extent permitted by law, with tribal governments prior to taking actions
that affect federally recognized tribal governments. All audh consultations are to be open and
candid so that all interested parties may evaluate for themselves the potential impact of relevant proposals" (Exhibit 66).
3136
IGRA, which requires "consultation with the Indian tribe" 12 6 prior
to a determination that the proposal would be a detriment to the
surrounding community. It can hardly be argued that the Secretary
consulted with the applicants if they were unaware that a new policy was being used to consider the application.
George Skibine, allegedly the key decisionmaker in the rejection
of the application, lends support to a statement by Sibbison that
the Department had changed its policy. In an e-mail to Hilda
Manuel, Bob Anderson, Heather Sibbison, Michael Anderson, Scott
Keep, Dave Etheridge, Tom Hartman, and Nancy Pierskalla, dated
March 17, 1997, he states:
Plaintiffs informed us that a pivotal question in their decision to resubmit an application is whether the Department
again stand by its position that the "naked" political opposition of the surrounding communities without factual support is enough for the Secretary to refuse to make a finding that the proposed acquisition is not detrimental to the
surrounding community.
. .
them know the outcome. .7 . . I think that it is a fair question for plaintiffs to ask.12
It is significant that Skibine does not take issue with the fundamental premise of the question. This admission that "factual
support" was absent from the decision goes directly to the question
of whether the decision was improperly made, and whether the Department has tried to cover up this fact. The Committee is left with
a significant question: Why would "naked" political opposition without factual support ever be a legitimate reason to deny an application? Prior to Hudson, it was not a sufficient reason and nowhere
in the record is there a discussion of why the Department felt compelled to change the policy without even notifying the parties that
there had been a change. Again, the circumstantial evidence points
to an improper motive.
Secretary Babbitt made his position clear in a statement to the
New York Times: "This department does2 8 not force off-reservation
casinos upon unwilling communities." 1 However, prior to the
Hudson decision, mere opposition was not enough-there had to be
an objective showing of detriment. For example, in her letter to
Representative Gunderson, Hilda Manuel stated:
You request clarification on whether or not the Bureau of
Indian Affairs (BIA) considers the views of parties opposing a fee-to-trust acquisition by a tribe for gaming purposes. Because of the contentious nature of fee-to-trust acquisitions for gaming purposes, public sentiment and concerns of the negative impacts of casino gambling are two
of the several issues that are common. The Department of
the Interior (Department) is sensitive to these issues. Consequently, we want to take this opportunity to assure you
that comments opposing fee-to-trust acquisition receive the
3137
highest consideration during the review process. However,
it is important to point out that any opposition should be
supported by factual documentation. If the opposing parties
do not furnish any documented evidence to support their
position, it is difficult, if not impossible, to make a finding
that the acquisition is not detrimental to the surrounding
community as required by the Indian Gaming Regulatory
The commonsense rationale for this standard is obvious: opposition based on racism, for example, would hardly be an acceptable
reason for rejecting an application. Thus, to be a part of the decisionmaking process, "factual documentation" of opposition was always required prior to Hudson. George Skibine, during his deposition, understood this concept. When asked whether he would accept
a claim of opposition and a claim of harm "without any research,"
he replied:
No; I think that we would need to look at what justification you submit.' 3 0
The weakness of the Department's position regarding the Hudson
application is illustrated by an exchange between Committee counsel and Mr. Skibine during his deposition:
Q: [A] longtime Hudson business person wrote in support [of the application] and states that the opposition to
the acquisition is receiving money from opposing Indian
tribes. Is this an observation that you investigated at the
time you were analyzing whether to approve or reject the
application?
Skibine: No, it was not an allegation we investigated.
Q: Do you know whether it is correct or incorrect?
Skibine: No, I don't know whether it is correct or incorrect.
Q: Would it make a difference if it was correct?
Skibine: I think that if it was correct, it would make a
difference, yes.13 1
Given that the Department of the Interior was basing its rejection-at least according to the Department-on opposition from the
local community, it would seem that fundamental fairness would
have required an inquiry into whether it was true that people were
receiving money for their opposition to the application. Forced to
admit that it would have made a difference if the allegation were
true, Skibine has essentially conceded the Department's case-the
Department failed to examine a potentially dispositive factor,
which makes it well-nigh impossible to argue that 'the right decision was made in the right way and for the right reasons."132
Indeed, the Department's intellectual position is even worse. By
changing the policy to allow opposition to constitute a prima face
case of detriment to the community, as Sibbison stated in her emlUtter from Hilda Manuel, Acting Depu
Gunderson, Mar. 2, 1995 (emphasis added)(E
1a1Id. at p. 133.
2 Testimony of
3138
mail to Michael Gauldin, 3 3 the Department is conceding that it
would be acceptable in future cases if the opposition was bought by
a special interest or, in the extreme, the opposition was grounded
on a racist reaction to the applicant. In the final analysis, the failure of the decisionmakers to look beneath the surface of the opposition makes it appear that they were less interested in a fair decision than in arriving at a predetermined goal, by whatever means
necessary.
In the Hudson application, there was certainly opposition. There
was also, however, support for the application, and it appears that
quantitatively there was more support than opposition. Perhaps
more important to the making of a principled decision, there is
hardly any "factual documentation" to back up the opposition. Furthermore, to return to the point emphasized in the previous section, there was no opposition that was beyond cure if the applicants
had been informed of the basis for the opposition. In addition, as
will be discussed later, the Department misrepresented the amount
of support for the application before this Committee and a Federal
court. Given the importance placed on community opposition, this
leads to a serious concern that the quantity of support and opposition was manipulated in order to validate the pre-determined outcome of the Hudson application denial.
The reasons advanced for the rejection of the applicationare contradicted by information obtained by this Committee
A review of the recommendations prepared by the career professionals working for the Department of the Interior gives insight
into not only what the career civil servants were thinking, but also
what the applicant tribes were expecting from their meetings with
Interior officials. The Finding of No Significant Impact
("FONSI"),134 the first Area Office recommendation,13 5 the second
Area Office recommendation, 1 3 6 the recommendation from the Indian Gaming Management Staff (IGMS), signed by Thomas Hartman (the IGMS economic specialist) ' 3 7 and George Skibine's redraft of the IGMS memorandum, 3 8 all support the conclusion that
the application was on its way to being approved by the career professionals at the Department of the Interior. The only letter or
memorandum to the contrary is Michael Anderson's three page rejection letter written on July 14, 1995.139 Indeed, it is particularly
troubling that there are no memoranda recommending that the application be rejected. One reasonable conclusion as to why no such
memoranda were prepared is that the facts, as developed, did not
support such a position being committed to paper.
1saE-mail from Heather Sibbison to Michael Gauldin, Dec. 16, 1997 (Exhibit 54).
'Finding of No Significant Impact, Sept. 14, 1994 (Exhibit 41).
13
5 Memorandum from Denise
omer, Area Director to Ada Deer, Assistant Secretary-Indian
Affairs, Nov. 15, 1994 (Exhibit 42).
136 Memorandum from Denise Homer, Area Director to Ada Deer, Assistant Secretary-Indian
Affairs, Apr. 20 1995 (Exhibit 43).
1' Memorandum from Indian Gaming Management Staff to the Director
of the Indian Gaming Management Staff, June 8, 1995 (Exhibit 44). Although it was marked "draft" it was signed
by Thomas Hartman.
isaMemorandum from George Skibine to Assistant Secretary-Indian Affairs, undated (Exhibit
45). Skibine denies that he had any input into this memorandum.
13
oLetter from Michael Anderson to Rose Gurnoe, Alfred Trepania, and Arlyn Ackley, Sr.,
July 14, 1995 (Exhibit 2).
3139
The three page rejection letter signed by Michael Anderson
points to "detriment to the surrounding community" as the reason
for the denial. However, George Skibine, allegedly the most important of the decisionmakers, made the following statement in an internal memorandum after the decision was made:
It is true that extensive factual findings supporting the
local communities' objections are nowhere to be found. 14 0
This is a crucial point considering that Skibine acknowledges: "The
point here, and a very crucial one, is that the Department has to
rely on the record, and the opposition of the local communities in
the record is the evidence relied upon." 14 1
Supporting Skibine's after-the-fact recognition that "extensive
factual findings supporting the local communities' objections are
nowhere to be found,"1 4 2 is an acknowledgment by him that as of
June 30, 1995, just 2 weeks before the rejection, the IGMS had tentatively reached the conclusion that the application would not be
detrimental to the surrounding community:
Tom Hartman of my staff also prepared a memo regarding
the section 20 "not detrimental" analysis. Unfortunately, I
have not been able to finish the review because of computer difficulties. Our tentative conclusion is that the
record permits us to make a finding that a gaming establishment at that location will not be detrimental to the
surrounding community." 3
Of particular interest to the Committee is the timing of this e-mail
when compared to other correspondence from the Secretary's office.
On June 6, 1995, before Skibine stated that the record indicated
that the proposal would not be detrimental to the surrounding community, Heather Sibbison, Special Assistant to Secretary Babbitt,
relayed to the White House that Interior was "95% certain that the
application [would] be turned down.""'4 On June 27, 1995,
Sibbison wrote to the White House indicating that the application
would be denied, and the decision "may be made public at the end
of the week."145 This leads to a fundamental question: how could
the decision based on Section 20 have followed the recommendations of career officials if 3 days after Ms. Sibbison had confirmed
the application's denial to the White House, Skibine indicated that
the IGMS position was that the application would 'not be detrimental to the surrounding community."
Skibine's statement about "our tentative conclusion" is consistent
with representations made in the record about impact on the community. For example, the Indian Gaming Management Staff
(IGMS) made the following observations about "detriment to the
community":
Staff finds that detrimental impacts are appropriately
mitigated through the proposed actions of the Tribes and
14
Memorandum from George Skibine to Scott Keep, Aug. 5, 1996 (Exhibit 51).
141Id.
142Id.
13E-mail from George Skibine to Heather Sibbison, June 30, 1995 (emphasis added) (Exhibit
46).
'"Memorandum from David Meyers to Jennifer O'Connor, June 6, 1995 (Exhibit 20).
'-Memorandum from Heather Sibbison to Jennifer O'Connor, June 27, 1995 (Exhibit 22).
3140
the Agreement for Governmental Services. It finds that
gaming at the St. Croix Meadows Greyhound Racing Park
that adds slot machines and blackjack to the existing Class
III pari-mutuel wagering would not be detrimental to the
surrounding community[.] 146
Inconsistencies such as the one between this statement and Michael Anderson's rejection letter lead to the justifiable suspicion
that the decision was made for reasons other than those publicly
advanced. Furthermore, how could the applicants have addressed
the perceived "defect" if the record did not support an argument
that the "defect" existed?
Another clear contradiction of the rationale advanced in the July
14, 1995, rejection is found in an e-mail from George Skibine to
Heather Sibbison, Paula Hart, Tom Hartman, Troy Woodward, and
Kevin Meisner. Skibine states:
I also sense that even if the Town of Hudson and the Town
of Troy embrace the proposal, we may still not change our
position because of political opposition on the Hill, largely
generated by the Minnesota and Wisconsin Tribes who oppose this acquisition.' 4 7
This admission makes a mockery of Secretary Babbitt's assertion
that the decision was "the right decision made in the right way and
for the right reasons." 14 8 After spending so much effort in attempts
to convince Congress that the decision was predicated on local opposition, this e-mail shows that Skibine understood that the Department of the Interior was prepared to disregard the views of
both Hudson and the closest neighboring town. Indeed, even the
Governor of Wisconsin understood that there was support for the
application. When asked if the December 1992 referendum
in Hud49
son indicated local support, Thompson replied "Yes." 1
Heather Sibbison also expressed concerns that it might not be
wise to include references to other Native American opposition to
the Hudson application. In an e-mail 2 weeks before the rejection,
she stated:
[W]e may not want to include in our rationale the opposition of the other tribes, because I think it is possible that
if the three Tribes came back with stellar support from
their local towns and Congressman, we might look at the
proposition in a new light-but even in that case, the Minnesota tribes will still be against it. And also, I agree with
Collier's uneasiness about some tribes getting all of the
146Memorandum from the Indian Gaming Management Staff to the Director of the Indian
Gaming Management Staff (George Skibine), June 8, 1995. (Exhibit 44) The memo was signed
by Mr. Hartman even though there is a stamp located on the bottom of the document indicating
"Draft." Additionally, Mr. Hartman in his deposition indicated that the memo was a compilation
of views from a number of the staff. See Deposition of Thomas Hartman, Dec. 8, 1997, pp. 8182.
147 E-mail from George Skibine to Heather Sibbison, Paula Hart, Tom Hartman, Troy Woodward and Kevin Meisner, June 30, 1995 (Exhibit 46).
us Testimony of Secretary of the Interior Bruce Babbitt, Jan. 29, 1998, p. 769.
149 Doug Stohlberg, Thompson Says He "Won't Stop" Casino at Dog Trmck, Hudson Star Observer, Feb. 10, 1994 (Exhibit 71).
3141
goodies at the expense of other tribes-theoretically they
all should have equal opportunities.15 0
Sibbison's observation is curious because it stresses political factors
and not legal factors. Her concern that there would be a problem
with the perception of certain tribes "getting all the goodies" appears to have no place in a principled decision, made on the merits.
The record provides no indication of what came to light between
June 30-when Skibine stated that "our tentative conclusion is
that the record permits us to make a finding that a gaming establishment at that location will not be detrimental to the surrounding
community"-and July 14, when Anderson rejected the application.
Because there is no indication in the record of what could have
changed the minds of the staff, it is reasonable to conclude that
"detriment to the surrounding community" was the pretext for the
rejection, and that the failure to announce that the Department
was changing its policy in this case was necessary because the debate would have become infinitely more complicated, and the
grounds for appeal to Federal court would have been strengthened.
Political considerationsappear to have influenced the decision
Secretary Babbitt has said publicly that the Hudson decision was
the "right decision made in the right way for the right reasons."' 5 1
A review of the above material does not support this statement. It
is simply inexplicable for the Department to have made a decision
without support in the record for that decision. Furthermore, but
for political considerations, it seems the Department could have delayed the final decision in order to provide the applicants a chance
to remedy any alleged defects.
In addition, lobbyists' notes of meetings with Interior staff call
into question the integrity of Interior's decisionmaking process. In
a May 25, 1995, memo lobbyist Scott Dacey discussed meetings
with Mike Anderson, George Skibine, and Thomas Hartman. In
these meetings the process or reviewing the application under section 20 of IGRA was discussed. As of this meeting Michael Anderson apparently not only did not want to establish a precedent
against tribes wishing to bring land into trust into the future, he
also acknowledged that the law was not on their side.152
Dacey went on to explain that reachingig the 'detrimental'
standard is difficult [to establish]. According to Tom Hartman, all
of the economic impact statements are of no value in this assessment. The addition of a new Indian gaming establishment to the
market area brings 'normal competitive pressures.' " 3 When
asked about competitive pressure and the role it played in finding
"detriment," Hartman had the following response:
The only policy I was aware of, and it was articulated verbally by the Deputy Commissioner of Indian Affairs, was
that economic competition was "not detrimental," that we
couldn't pick one tribe out over another. And even from a
business standpoint, the reason you have a McDonald's on
1
5sE-mail from Heather Sibbison to George Skibine and Troy Woodward, June 30, 1995 (Exhibit 75).
151 Testimony of Secretary Bruce Babbitt Jan. 29, 1998, 769.
152 Memorandum from Scott Dacey to Debbie Doxtator, May 25, 1995 (Exhibit 53).
15ad.
3142
one corner and a Burger King on another and a Wendy's
on the third corner is because there are synergisms in a
lot of these, so you can't-it is very difficult from an econometric standpoint to say, when you add another casino
that it ruins everybody else's business. If that was the
case, then the second person moving into Las Vegas would
have ruined it for everybody, and I think we know that
that is not the case. 154
4Deposition
1a5Memorandum from Scott Dacey to Debbie Doxtator, May 25, 1995 (Exhibit 53).
16
157
Id.
Id.
r
158E-mail
from Kevin Meisner to George Skibine and Troy Woodward, July 11, 1995 (Exhibit
55).
159 Testimony of Secretary of the Interior Bruce Babbitt, Jan. 29, 1998, p. 776.
3143
Perhaps even more revealing, the Department of the Interior was
prepared to reject the Chippewas' application even if the local officials were uniformly behind the application. George Skibine, in an
e-mail to Sibbison, Hart, Hartman, Woodward, and Meisner stated:
"I also sense that even if the Town of Hudson and the Town of Troy
embrace the proposal, we may still not change our position because
of political opposition on the Hill, largely generated by the Minnesota and Wisconsin Tribes who oppose this acquisition."160 This
is a curious conclusion in that the question of congressional participation had already been addressed by the Department's solicitors
office. Kevin Meisner, an attorney for the Department, stated prior
to the final resolution: "I think the question of whether a Congressman can participate in the state consultation process for taking
land into trust for gaming under IGRA (25 U.S.C. 2719(b)(1)(a))
should be answered in the negative. . . . My feeling is that it
would not be appropriate or Federal Congresspersons to
comment[.]" 16 1 Skibine's statement that the application would be
rejected even if there was complete support from the affected
towns, shows the transparency of the Secretary's claim that the Department made the right decision for the right reasons.
Thomas Hartman stated under oath that Interior was concerned
about the political ramifications of Interior approving the application and a Republican Governor rejecting it. Haman had the following to say:
In the meetings I had been in, the negatives of taking the
land into trust had certainly been discussed. A concept
that had been tossed out was that in a Democratic administration and a Republican governor, to ignore the local
input and impose a casino on an unwilling community and
then have the Republican governor say, well, look at those
ridiculous Democrats doing this again, was not viewed as
being the best position to be in. So I know when they say
"probably a bad idea to create a land trust," there were
plenty of ideas thrown out to indicate that some people in
those meetings thought it was a bad idea to create a land
trust in this case.162
Whether Democrats would suffer political consequences for following the law and past Department of the Interior practice should
never have even been considered as a factor in the decisionmaking
process.
Michael Anderson---decisionmakeror politicalpuppet?
When asked whether he was the decisionmaker in the Hudson
case, Michael Anderson, the Deputy Assistant Secretary for Indian
Affairs, stated "That is correct." -6 Despite this assertion, evidence
reviewed by the Committee showed that Anderson appeared to play
160E-mail
from George Skibine to Heather Sibbison, June 30, 1995 (Exhibit 46).
2 E-mail from Kevin Meisner to Heather Sibbison, Mar. 23, 1995 (Exhibit 56). It is somewhat
ironic that discussion of this matter during Committee hearings often that such opposition by
elected leaders. Meisner's position that such opposition was not relevant is the only expression
of Department policy produced by the Department pursuant to the Committee's document request and subpoena, and it is curious that many argued such opposition was relevant when the
Solicitor's office at Interior indicated that it was not.
162 Deposition of Thomas Hartman, Dec. 8, 1997, p. 54.
1e3 Deposition of Michael Anderson, Jan. 14, 1998, p. 38.
3144
little or no role in the actual decision. Anderson admitted that he
spent only 4-5 hours on the Chippewas' application and that he did
not read or review the 32 page recommendation to approve the application provided by the Department's area office.164
Anderson did, however, express a concern about the detrimental
impact that the casino would have on the nearby St. Croix Chippewa. When asked about this, he had the following exchange:
A: I believe the nature of the concern was that they had
developed a market for the casino in that area, and that
they felt that there would be a detrimental impact to their
market if another casino was located nearby. I believe they
also may have provided studies to that effect as well.
Q: So correct me if I'm wrong, it is a valid opposition for
an opposing tribe to object on economic grounds?
A: Yes, and the letter states that as a factor. 165
After Committee lawyers pressed Anderson, he admitted that he
was aware that the St. Croix tribe gaming operation was "very
profitable."16 6 Although Anderson was aware of the general financial status of the St. Croix tribe he testified that he did not review
any of the market information provided to the Department regarding the impact of the Hudson application and relied solely on the
staff for this information.
A: I didn't review specific market information. I was informed by the staff, the Indian Gaming Management Staff,
that there was an impact and that was also contained in
the letter, the decision letter as well. There may have been
discussions about the location and the market area that
was developed by St. Croix, but I don't recall any specifics.
Q: Do you recall who on the Indian Gaming Management Staff told you that, or communicated that to you?
A: I don't remember who the major staff advisors on the
would have been. George Skibine and Tom
market impact
Hartman.16 7
This testimony is of particular interest because Hartman, the economic specialist for the Indian Gaming Management Staff, has testified that a casino in Hudson would not have had a detrimental
impact on the surrounding community. Hartman also signed a
memorandum compiled by the Indian Gaming Management Staff to
this effect and included an analysis of the detriment on surrounding tribes. 6 8 Michael Anderson, however, had never seen or been
told of this analysis before he signed the rejection letter on July 14,
1995.169 If Anderson was not aware of the analysis compiled by the
staff responsible for reviewing these applications, he must have received direction from another source.
There are numerous additional examples of Anderson being unaware of significant information. For example, he was not aware of
164Senate Deposition of Michael Anderson, Sept. 26, 1997, pp. 66-67.
165 Deposition of Michael Anderson, Jan. 14, 1998, pp. 24-25.
166
16 7 Id.
16 Id. at 28.
8See memorandum from Indian Gaming Management Staff to Director Indian Gaming Management Staff, June 8, 1995 (Exhibit 44).
69 Deposition of Michael Anderson, Jan. 14, 1998, p. 29.
3145
a contract for services signed by the applicant tribes and the community authorities in Hudson, Wisconsin, which would have mitigated a number of the7 0concerns and objections mentioned in the actual rejection letter.'
Anderson also was unaware that Heather
Sibbison had sent letters to the White House indicating how the
decision would be made.' 7 ' This is critical because Sibbison sent
these letters to the White House before George Skibine had prepared his first draft of the denial letter on June 29, 1995. Anderson
testified that not only did Heather Sibbison not consult him on
these letters, but he was unaware that the Department of the Interior's position had ever been communicated to the White House.172
Notwithstanding his representations to the contrary, it appears
that Anderson's role in the decisionmaking process was limited. His
conduct in this matter is consistent with that of someone who was
going along with a decision already made, and his failure to inquire
about any of the salient facts, and his obvious concern for the
wealthy Democratic contributors opposed to the application, raise
serious questions about his involvement.
CONTRADICTIONS AND CHANGING STORIES
In addition to the major contradictions already discussed, including the contradiction between Secretary Babbitt and Paul Eckstein
regarding contacts with Harold Ickes, whether the Secretary mentioned political contributions by the opposing tribes to Democratic
organizations, Secretary Babbitt's belief that his letters to Senator
McCain and Senator Thompson were consistent, and Babbitt's
statement that the decision was based solely on section 20 of IGRA,
there are a number of other contradictions which require further
explanation.
Was the President contacted about the Hudson applicationafter the
initial meeting with Patrick O'Connor?
There is contradictory testimony over whether Tom Schneider, a
lobbyist at O'Connor & Hannan and good friend of the President's,
communicated with the President about the Hudson dog track application. O'Connor & Hannan billed a total of $4,000 to their clients for Tom Schneider's time on the dog track matter, a fact that
was initially withheld from this Committee.' 7 3 In fact, the billing
entry unambiguously reads: "meeting with senior White House
staff and POTUS [President of the United States] re. Expansion of
gaming and the dog track and opposition to doing so."1 74
Schneider has testified that O'Connor asked him to stop by an
event at the Mayflower hotel because the President was there for
an event.175 Schneider did stop by the event: "I talked to [the
President] for a few minutes, did not say anything about the Hud170d. at 70-71. See also Agreement for Government Services (Exhibit 70). Attached to the
Agreement is a letter from the Mayor of Hudson stating: "I think you will find, as you review
the attached material, that the City of Hudson has a strong vision and planning effort for the
future and that this proposed Casino can apparently be accommodated with minimal overall impact, just as any other development of this size." Also attached is a referendum showing that
a majority of those who cast ballots were supportive of the proposed casino.
171 Senate Deposition of Michael Anderson, Sept. 26, 1997, p. 29.
7
1 2 Id. at 29-31.
73
1 See O'Connor & Hannan billing records (Exhibit 31).
17
4Id.
175 Deposition of Thomas Schneider, Dec. 10, 1997, p. 15.
3146
son Dog Track, and saw Harold Ickes there. Ickes said "that he had
told Pat that he was going to look into it. I said to Harold that I
thought that it deserved looking into and I would appreciate it if
he would. 176 He further clarified his communication with the President by stating: "I absolutely did not talk to the President then or
ever about the dog track and the Indians.1 77
Schneider's story is contradicted by Thomas Corcoran, a former
member of Congress and fellow partner of Schneider's at O'Connor
& Hannan. Corcoran noted:
The only other contact that I know of with respect to anybody from O'Connor & Hannan with the President was a
casual contact, not really a lobbying contact, that Tom
Schneider told me about, as I recall a day or so after it
happened. Mr. Schneider is a good friend of the President.
He was attending a reception, I believe at the White
House, and they were just chatting. And in the course of
that chat the President indicated that Pat O'Connor had
mentioned this dog track to him. They both had a pretty
good laugh about the fact that the President of the United
States had been informed about a dog track in Wisconsin,
and I must say that Tom and I had a pretty good laugh
about it as well.1 78
This version of events is supported by Schneider's billing records
at O'Connor & Hannan. The billing entry reads as follows: "Indian
matter regarding racetrack gaming and Hudson dog track. Telephone discussion and meeting with senior White House staff and
of gaming and the
POTUS [The President] re[garding] expansion
dog track and opposition to so doing."179
Fred Havenick was told that the DNC and Clinton/Gore '96 played
a significant role in the Hudson rejection
Fred Havenick, the owner of the existing dog track in Hudson,
Wisconsin, attended a Democratic fundraiser in Florida on August
15, 1995. At this fundraiser, Havenick spoke with Terry McAuliffe,
the Clinton/Gore '96 Finance Chairman. The following is Fred
Havenick's sworn testimony before the Committee on Government
Reform and Oversight:
[Just a month after the rejection. I was at a fund-raising
event in Florida where I ran into Terry McAuliffe, chairman of the finance committee for the President's re-election campaign. After the meeting, I went to say hello to
Terry. I've known Terry for quite some time, mostly
through his political activities. At the same time, Terry approached me with a large smile on his face and said,
what's doing in doggiedom? I said that we were having an
enormous problem with an Indian gaming project in northern Wisconsin. He said, oh, I know all about that; to which
I responded, come into my office, a private corner of the
meeting room. I recall that Terry said, I took care of that
176 Id.
177Id.
at 19.
of Thomas Corcoran, Dec. 10, 1997, p. 30.
90'Connor&Hannan Billing records, Oct. 2, 1995 (Exhibit 31).
178
Deposition
17
3147
problem for you. I was baffled and asked him what he
meant. I recall that he said, I got Delaware North's Indian
casino project killed, the one that would have competed
with you.I set up the meeting with Fowler and others and
turned it around. I told Terry that was my project and I
was the one who owns the track in Hudson. His face
dropped. He was clearly in shock and said little else.18 0
McAuliffe clearly thought he was helping a Democratic contributor
when he helped "kill" the application. Terry McAuliffe had known
Havenick for quite some time through his activity as a Democratic
contributor. This relationship began in the mid-1980s when
Havenick and McAuliffe were both members of the Democratic Senatorial Campaign Committee. Havenick also came into contact with
McAuliffe at numerous Democratic fundraising events. 181
A meeting at Lac Courte Oreilles produced diametrically opposed
affidavits from the Department of the Interiorand the applicant
tribes
On December 3, 1996, George Skibine went to a meeting at the
La Courte Oreilles reservation to meet with members of the applicant tribes. This meeting was set up because of a potential settlement arrangement with the law suit filed by the tribes against the
Department of the Interior. According to a number of people who
attended the December 3, 1996, meeting the following exchange occurred:
Q: How did [the application] not get approved the first
time?
A- We approved it, but when it got to the Secretary's office politics took over.182
Frederick R. Roach, Fred Havenick, Mary Ann Polar, Peter A.
Liptack, J.W. Cadotte, Arlyn Ackley, Sr., and DuWayne Derrickson
all signed affidavits to this effect. In response to these sworn affidavits, the Department of the Interior produced affidavits from individuals with a differing recollection of events.xsa Skibine in his
testimony had this to say about the meeting:
We were contacted by the Lac Courte Oreilles tribe to
come to Wisconsin to discuss with them the problems that
the Wisconsin tribes had with the upcoming renegotiation
of their Class III gaming contracts with the State of Wisconsin. And we agreed to come there to make a presentation about compact negotiation. At the same time, the
tribes asked us to come and discuss with them, the three
tribes, either the day before, to discuss with them and give
technical advice on placing land in trust, in general. We
clarified to them that we could not and would not discuss
the Hudson-the litigation involving the Hudson Dog
'eTestimony of Fred Havenick, Jan. 21, 1998, pp. 117-118 (emphasis added). Terry McAuliffe
was not deposed by this Committee. He did, however, dispute the accuracy of Havenick's account.
iax Id.
12
8 See Affidavits of Frederick R. Roach, Fred Havenick Mary Ann Polar, Peter A. Liptack,
J.W. Cadotte, Arlyn Ackley, Sr., and DuWayne Derrickson (Exhibit 58).
8sSee Affidavits of Nancy Pierskalla, Troy Woodward, Tim LaPointe, Paula Hart, and Robin
Jaeger (Exhibit 59).
3148
Track at this meeting . . . we made that absolutely clear
to the Lac Courte Oreilles tribe that this was not going to
happen. And they told us that they would inform the other
two tribes there that the litigation and whatever happened
during the litigation of the Hudson Dog Track would not
be discussed.1sa
Skibine's explanation before the Committee is undermined by a letter from Ray Wolf, the Vice-Chairman of the LCO Governing
Board. Wolf wrote:
George Skabine [sic], the Director of the BIA Office of Indian Gaming Management and Nancy Pierskella, Land Acquisition Specialist for his office, have suggested they come
to Wisconsin on Tuesday, December 3 to meet only with
the Chippewa tribes interested in acquiring off reservation
land for the purposes of establishing a casino, specifically,
Hudson.
The purpose of the BIA meeting is to provide technical assistance to Mole Lake, Red Cliff, and Lac Courte Oreilles.
Mr. Skabine [sic] is aware of the need for discretion as his
office is scheduled to meet the next day with all of the
Wisconsin tribes to provide technical assistance on gaming
compact negotiations. 8 5
In interviews with Mark Goff, lobbyist for the applicant tribes, and
J.W. Cadotte, a member of the Lac Courte Oreilles tribe, Committee investigators learned that there were two meetings held on December 3, 1996. The first meeting was a smaller meeting held at
the council headquarters, and the second was a large meeting held
at the LCO bingo hall. This is an important fact which can explain
why the two sets of affidavits are diametrically opposed. Most of
the Interior officials who signed affidavits regarding a December 3,
1996, meeting did not attend the initial meeting at the tribal headquarters.186 This is a fact that should have been known to the attorneys preparing the affidavits, and to Mr. Skibine, who apparently attended both meetings and failed to reflect this fact in his
affidavit.
Shannon Swanstrom, attorney for the Red Cliff tribe, took notes
at the December 3, 1996, meeting with George Skibine. In these
notes, Ms. Swanstrom wrote a quote from Skibine as follows: "I
find that [Hudson] in best interests of tribes and not to detriment
of surrounding community, will send letter to governor." ' 8 7 This
information places Skibine's testimony before this Committee in
question.
"a'Testimony of George Skibine before the Committee on Government Reform and Oversight,
Jan. 22, 1998.
185 Letter from Raymond Wolf to Arlyn Ackley, Sr., and Rose Gurnoe, Nov. 7, 1996 (Exhibit
60).
11o Committee interview with Mark Goff and J.W. Cadotte, Dec. 15, 1997.
187 See Notes taken by Shannon Swanstrom, Dec. 3, 1996 (quotation in the original) (Exhibit
61).
3149
The Department of the Interior misled the Committee and a Federal
district court in Wisconsin with the information contained in
the administrativerecord
The administrative record detailing this case was compiled by
the Department of the Interior for the ongoing litigation over this
matter in Wisconsin. The Committee reviewed the material and believes that Interior officials may have tried to mislead those who
received the record. First, the record does not adequately reflect
support for the application to take land into trust. A review of the
material received by the Committee pursuant to its subpoena revealed the following support: a petition totaling 114 pages of signatures, 188 another petition of 38 full or partial pages, 189 207
cards,19 0 and 127 letters.
The record prepared for the litigation, however, reflects a lesser
amount of support and inaccurately indicates that there was more
opposition than support. The Department's Solicitor took affirmative steps at a hearing conducted by this Committee to provide misleading information about the extent of the support for the application. The following exchange occurred before this Committee:
Mr. HORN. Mr. Secretary, your counsel, to be charitable
about it, misrepresented the record in terms of that document when he said it was referred to the court. We got the
document finally and what is in the court's binder is not
that document. Here is the difference: 797 cards, letters
and petition signatures are on that computerized document to which your counsel, the Solicitor of Interior, I
think, referred, and we have in the original document,
which is not in the court record, 1,413 petition signatures.
In other words, counsel is saying it was all the same and
it is just some were typed and Xeroxed and what not and
some were in hand, and that means 616 people were left
out. And I don't particularly appreciate that misrepresentation . . .
Mr. LESHY. I am told by staff that Mr. Hartman, who
3150
of how much support there was for the application. The record,
read at face value, misrepresents the facts and support associated
with this application. The 38 page petition alone would probably
have had more than 797 signatures. Because the full 38 pages have
not been included in either the record compiled for litigation, or the
material produced to this committee, it is not possible to determine
the precise number. The figure of support rises when the additional
114 page petition and other forms of support are included. Although it is curious that the Department appears to have actively
misrepresented the lack of support for the application, it is consistent with the need to make this point so as to support the theory
of the rejection.
The Department of the Interior provided misleading information to
Conress prior to the decision to reject the application was
made
At least one representative who came out in opposition to the application a parently received false information from Secretary
Babbitt's ofice, perhaps in an effort to "educate" individuals in
order to encourage them to oppose the application. In a letter to
Secretary of the Interior Bruce Babbitt, Representative Steve
Gunderson stated: "According to your office, since Congress passed
the IGRA in 1988, the Secretary of Interior has never approved the
acquisition of off-reservation land to be used for casino gambling."1 93 The information provided to Representative Gundersonthat "the Secretary of the Interior has never approved the acquisition of off-reservation land to be used for casino gambling"-is
false. Hilda Manuel, Deputy Commissioner at BIA, when asked
about Congressman Gunderson's assertion stated "It's not correct." 194
Once again, the veracity of Department of the Interior representations about the Hudson decision is called into question when one
considers that false information was provided to Congress even before the application was rejected. There certainly appears to be a
self-fulfilling aspect to the Secretary's office response to Congressthe information provided appears now to have helped pave the way
for the decision to reject.
The role of Section 20 in the decision
In the rejection letter, Michael Anderson also informed the applicants that even if the Section 20 problems were satisfied, the Secretary would reject the application under another statutory provision known as Section 151. There is no indication in the record,
however, that the Department ever analyzed the application according to the provisions of Section 151. Furthermore, Secretary
Babbitt told this Committee: "[Tlhe Department based its decision
solely on the criteria set forth in Section 20 of the Indian Gaming
Regulatory Act." 19 5
On review, however, this statement does not appear to be entirely correct. Perhaps the most direct indication is from George
193 Letter from the Honorable Steve Gunderson to Secretary Bruce Babbitt, Apr. 28, 1995 (emphasis
in the original) (Exhibit 47).
4
19 Deposition of Hilda Manuel, Jan. 6, 1998, p. 50.
195 Testimony of Secretary of the Interior Bruce Babbitt, Jan. 29, 1998, p. 776.
3151
3152
The Department of the Interior mischaracterized Governor Thompson's public position againstthe expansion of gambling
Notwithstanding representations from a number of Department
officials that Governor Thompson was opposed to the Hudson application, he stated: "I will not promote and I will not block. I'm on
the tail end of the process, and if everyone else, including the local
people, approves it before me, I won't stop it."200 Although there
is nothing in the record to indicate anything to support his position, Babbitt has stated that the Governor opposed the dog
track. 20 1
Governor Thompson did make statements about opposition to the
spread of gambling. However, in this case, he had apparently discussed a deal where the tribes would each give up their rights to
a second casino if the Governor would approve the Hudson casino.
Thus, there would be fewer -casinos allowed in Wisconsin if the
Hudson application were approved. Fred Havenick explained the
proposal before the Committee:
If you wanted to say that you were against the expansion
of gambling, there are currently 17 casinos operating in
Wisconsin. This really would have reduced that number by
3 . . . it would be almost a 20 percent reduction in the
total number of casinos[.] 2 0 2
The record contains no indication that the Department made an
effort to obtain Governor Thompson's views on the Hudson application. Therefore, it seems inappropriate that it would make representations about whether he would, or would not support the application.
DEPARTMENT OF THE INTERIOR COMPLIANCE WITH DOCUMENT
REQUESTS
2o Doug Stohlberg, "Thompson Says he "Won't Stop" Casino at Dog Track," Hudson Star Observer,
2/10/94.
20 1
See Testimony of Secretary Bruce Babbitt before the Government Reform and Oversight
Committee, Jan. 29, 1998, p. 946.
202 Testimony of Fred Havenick before the Government Reform and
Oversight Committee,
Jan. 29, 1998.
3153
A. Yesterday.203
This revelation prompted the Committee to take the unusual step
of issuing a subpoena to a government agency. On December 12,
1997, Interior received a subpoena to produce all documents related
to the Hudson matter. The compliance date for this subpoena was
January 2, 1998.
The following is a list of dates and productions received from the
Department of the Interior after it received this Committee's subpoena:
December 17, 1997: One file containing records.
January 2, 1998: Six boxes of records.
January 13, 1998: One fie containing records. Information included records related to Ada Deer, whose deposition was taken that day.
January 16, 1998: One file containing records.
January 17, 1998: One file containing records.
February 13, 1998: Copies of e-mails.
But for the deposition of Robin Jaeger, and the belated discovery
that the Department of the Interior had failed to produce all relevant documents, the Committee would have been denied significant, probative material.
WHITE HOUSE CLAIMS OF PRIVILEGE DELAYED THE COMMITTEE'S
INVESTIGATION
BC
The author of this note is the President, and the White House argued that Congress should not receive this document. Both this
Committee and the Congressional Research Service 205 disagreed
with the Counsel to the President's legal analysis that executive
privilege applied to this document, and to the other documents
withheld for a considerable period of time.
CONCLUSION
3154
made makes Secretary Babbitt's alleged comments to Paul
Eckstein about Harold Ickes' role in the decision and the importance of Native American political contributions seem an accurate
reflection of the facts. Secretary Babbitt's protestation that he did
not make the statement about contributions and that he did not
mean the statement about Ickes ring hollow in the face of the candid statements of his staff about what was really going on in the
Department's decisionmaking process.
[Supporting documentation follows:]
3155
IwND
11 sotT
AVENLIE
MML'.AOLI MINNESOTA
IWI012141
Exhibit I
Tribal operations
MEMORANDUM
TO:
FROM:
SUBJECT:
On March 4, 1994, the Sokaogon Chippewa Community of Wisconsin, the Lac Course
Oreilles Band of Lake Superior Chippewa Indians of Wisconsin andthe Red Cliff Band of
Lake Superior Chippewa Indians of Wisconsin (collectively referred to as the "Tribes'),
together, pursuant to Section 2719(b) of the Indian Gaming Regulatory Act, 25 U.S.C. 3'
2701-2721 (1988). filed an application with the Minneapolis Area Director requesting that the
United States take a certain parcel of real property located in Hudson, Wisconsin, into rust
for the benefit of the Tribes for gaming purposes. The Tribes do not currently own the
property, but they have an agreement to purchase the land if and when the Secretary of the
Interior makes the findings necessary under Section 2719, the Governor concurs in the
Secretary's findings. the steps necessary to place the land into oust have been completed, the
National Indian Gaming Commission approves the management contact and collateral
agreements and the Tribes have amended their gaming compacts of 1991 to permit the
operation of pari-mutuel greyhound racing.
This memorandum outlines the Minneapolis Arta Office's review and analysis of the Tribes
application and trasmits; (1) the Area Director's Findings and Recommendations, (2) the
comments of the Field Solicitor. Twin Cities, and (3) the Doctumntary Support required for
the Secretary's Determination concerning the request for off-reservation gaming on proposed
Trust Acquisition of the Tribes.
. APPUCATION INFORMATION
A. Sokaogon Tribe: The Sokaogon Chippewa Community of Wisconsin occupy a small
reservation in Forest County. Wisconsin with the central community in Mole Lake. There
EOP 064500
3156
are 1.528 persons enrolled in the Tribe. 512 members live on or near the reservation
According to figures provided by the Tribe. 42% areunemployed and actively seeking
employmenlt
The Sokaogon Chippewa Community Tribal Council is authorized by Article VII. Section
(e), to manage all economic affairs and enterprises of the Community. The Sokaogon
Chippewa Community Tribal Council included two resolutions as pan of the Tribes
application package. Resolution No. 9-11A-93 requested the assistance of the Bureau of
Indian Affairs to place the St. Croix Meadows property into undivided trust status.
Resolution No. 2-4A-94 approved the St. Croix Meadows-Joint Operating Agreement and
authorized the Tribal Chairman to sign the agreement.
B. Lac Course Oreilles Tribe: The Lac Coure Oreilles Band of Lake Supenor Chippewa
bad a reported enrollment of 5,431 people in 1991. In 1991, 1.923 of these people lived on
the reservation and another 1,126 lived within 150 miles of the reservation.
The Lac Course Oreilles Tribal Governing Board is empowered by Article V, Section 1(f) of
the Lac Course Oreilles Constitution to purchase lands within or without the boundary of the
Tribe's reservation. The Tribal Governing Board is empowered by Article V, section 1(h) to
engage in any business that will further the social or economic well-being of members of the
Band. The Lac Coune Oreilles Governing Board submitted three resolutions as part of the
Tnbes application package. Resolution No. 93-82 requested the assistance of the Bureau of
Indian Affairs to place the St. Croix Meadows property into undivided trust status.
Resolution No. 94-08 approved the Joint Operating Agreement and directed the Tribal
of
Lake
Band
Oreilles
Chairman to execute the agreement on behalf of the Lac Courte
Superior Chippewa. Resolution 94-09 created the Lac Courte Oreilles Economic
Development Commission to act on behalf of Lac Courte Oreilles.
C. Red Cliff Tribe: The Red Cliff Band of Lake Superior Chippewa occupy a small
reservation in Bayfield County. Wisconsin, on the shores of Lake Superior. There are 3.180
persons enrolled in the band. 1,651 members live on or near the reservation.
The Red Cliff Tribal Council is authorized by the Red Cliff Constitution Article VI, Section
1(e) to manage all economic affairs and enterprises of the Tribe. The Red Cliff Tribal
Council included two resolutions as part of the Tribes application package. Resolution
9/23/93C requests the assistance of the Bureau of Indian Affairs to place the St. Croix
Meadows property into undivided mrst. Resolution 2/7/94A authorized the Tribal
Chairperson to sign the Joint Operating Agreement on behalf of the Red Cliff Band of Lake
Superior Chippewa and also authorized the Chairperson to take such other actions necessary
to effectuate the agreement.
These Tribes continue to have high rates of unemployment and poverty in spite of having
developed gaming facilities on their reservations. We agree with the Tribes determination
that this is true largely because they are located at great distances away from urban markets.
EOP 064501
3157
Tribes also have relatively small populanons and land holdings. The Hudson
Each of Lbese
location will provide the msbes with access to an urban market for the gaming facility,
However. since it is unlikely that many of the residents of these three communities will chose
to relocate to be employed at this location, the benefits which will aceue to each of these
communities will come not from direct employment in the gaming facility, but. rather, from
employment and the goods and services which would be generated by the spending of each
community's share of the net income.
The average amount estimated to be received by each of the three Tribes over the next five
years from the operation of the Hudson Gaming Facility is approximately S10 million per
year. This money would be used by the Tribes to improve health care facilities on thesr
reservations, purchase land, improve housing facilities. improve community and elderly
programs. improve educational facilities and as educational grans, and to invest in economic
development in the communities.
1.
Description of Land:
The Tribes have requested that land located in the City of Hudson, County of St. Croix and
State of Wisconsin. be taken into trss pursuant to 25 C.F.R. Parts 151 and 25 U.S.C. j 465
and 2719. The land is currently owned by Croixland Properties Limited Parmership.
This request is for a parcel of land located in the fractional NE'A of the NE '. and SEi' of
the NEA. Section 6. T28N, RI9W. City of Hudson, Saint Croix County. Wisconsin,
described as follows:
The fractional NEV- of the NEIA of said Section 6, EXCEPT that pars of the right-of-way of
Carmichael Road which is located in said fractional NE;4 of the NEA of said Section 6.
ALSO, that part of the SEIA of the NE'4 of said Section 6 described as follows:
Commencing at the NE corner of said Section 6: thence S02*49'01"W 1,891.74 feet along
the East line of the fractional NEIA of said Section 6 to the NE corner of a parcel Imown as
the 'Quarry Parcel* and the point of beginning of this description; thence N88'40'24"W,
1.327.55 feet along the North line and the extension of the North line of said *Quarry
Parcel' to a point on the West line of the SEA of the NEM of said Section 6; thence
N02'48'30*E along the west line of said SE' of the NEMIto the NW corner thereof; theoce
Easterly along the North line of said SE'A of the NEI' to the NE corner thereof; thence
S02'49'01'W, along the East line of said SEIA of the NEIA to the point of beginning.
The properties listed above encompass an area of approximately 55.82 acres currently
consisting of the St. Croix Meadows Greyhound Racing Facility. The site is served by all
necessary utilities and a highway system which includes lIterstate Highway 94.
EOP 064502
3158
The Tribes have entered into a Joint Operating Agreement with Galaxy Gaming and Racing
Limited Partnership. an affiliate of Croxand, in order to provide management of the
proposed gaming facility. We have informed the Tribes that we view this agreement as a
management agreement subject to approval by the National Indian Gaming Association. The
National Indian Gaming Commission concurred in our determination and the Tribes have
requested their approval.
IL GOVERNMENTAL ACTIONS REOUIRED
The process of taking Off-Reservation land into trust requires a tribal applicant to meet the
requirements of 25 C.F.R. Part 151- Land Acquisition, and Section 2719 of the Indian
Gaming Regulatory Act, 25 U.S.C. I 2701-2721 (1988). Section 2719(b)(1)(A)requires the
following two part determination:
*The Secretary, after consultation with the Indian tribe and appropriate State
and local officials. including officials of other marby Indian tribes, determines
that a gaming establishment on newly acquired lands would be in the best
interest of the Indian tribe and its members, and would not be detrimental to
the surrounding community. but only if the Governor of the State in which the
gaming activity is to be conducted concurs in the Secretary's Determination;'
This report docs DotContain information wrinen specifically to meet the requirements of 25
C.F.R. Part 151, Land Acquisition. This report only outlines the Minneapolis Area Office's
review and analysis of the Tribe's proposal to meet the two part determination required by
the Indian Gaming Regulatory Act. 25 C.F.R. Par 151 requires specific actions within real
estate services that exceeds Section 2719 action under the Indian Gaming Regulatory Act. If
and when it becomes necessary, the requirements of 25 C.F.R. Parn 151 will be addressed by
the Area Office in a separate document.
The Indian Gaming Regulatory Act has several requirements that have been met by the
Tribes; first, all three Tribes have successfully negotiated Class M Gaming Compacts with
the State of Wisconsin as required by Section 2710(dXIXC) of the Indian Gaming Regulatory
Act and the Secretary of Interior published the Approval Notice of the Gaming Compacts in
the Federal Register. second, in accordance with 2710(d)(1)(A), each Tribe has adopted
tribal gaming ordinances that have been approved by the Chairman of the National Indian
Gaming Commission.
Il CONSULTATION PROCESS
The Bureau of Indian Affairs consultations with the City of Hudson. Local Officials, and
Tribal Officials are described in detail in the Recommended Findings of Fact and
4
EOP 064503
3159
Conclusions. As the Recommended Findings of Fact andConclusions indicate. the Tribes
applicauon hasreceived mixed support from the Community and nearby Tribes.
TV DOCUMENTARY RECORD
The Minneapolis Area Office has prepared four volumes of documentary suppon required for
the Secretary's determination. The documentary suppon consists of documents the Tribes
have submitted in support of their application and documents the Area Office has compiled
during the course of the review andanalysis of this application. The documentary record
contains a complete index of documents.
Volume I contains proprietary information that is privileged commercial and financial
information, which is confidential and exempt from disclosure pursuant to 5 U.S.C. 552
(b)4.
V
Based upon the documentary support that was prepared during the course of the review and
analysis of the Tribes' Application, the Area Office has prepared the attached Recommended
Findings of Fact and Conclusions.
Based upon the Tribes' application, the documentary support and the consultations between
the Great Lakes Agency Superintendent, the City of Hudson, St. Croix County, and otherfederally acknowledged Indian Tribes located in Wisconsin and Minnesota, the
Recommended Findings of Fact and Conclusions conclude that allowing gaming on the
proposed trust property is in the best interests of the Tribe and its members and would not be
detrimental to the surrounding community.
V1 RECOMMENDATION
Because the establishment of a gaming facility on the proposed tust land is in the best
interest of the Tribe and its members and would not bedetrimenal to the surrounding
commuruty, I recommend that the Secretary determine that the proposed trust property be
acquired by the Lac Courte Oreifles, Red Cliff andSokaogon Tribes for Gaming purposes.
Area Director
Attachments
EOP 064504
3160
RECOMMENDED FINDINGS OF
FACT
AND
CONCLUSIONS
November 15,
1994
EOP 064505
3161
INDEX
Paoe
Introduction
Part I.
A.
B.
..
...
Table
...................................
.......
1.
2.
3.
4.
5.
9.
C.
D.
10
E.
F.
11
G.
12
H.
12
I.
13
13
J.
Part II.
A.
15
Consultation .........................................
15
1.
Governor of Wisconsin
15
2.
City of Hudson
..
..
.........................
...
..........
15
EOP 064506
3162
3.
C.
Mayor
b.
Common Council
c.
School District
.5
....
15
..
............................
..........................
4.
Town of Troy
S.
6.
B.
a.
15
.16
................................
a.
Public Opposition
b.
Public Support
.........................
...............
16
17
......... 17
..........................
18
19
a.
St.
b.
c.
20
d.
20
e.
Prairie
21
f.
g.
h.
i.
j.
22
k.
23
Economic
2.
Political
................
Indians ........... 19
......................
...........
........
20
21
21
22
..............................
23
........................................
23
...................................
24
24
1.
Environmental Considerations
24
2.
.................
.................
25
EOP 064507
3163
a.
Land Resources
b.
Water Resources
C.
Air Quality
d.
26
e.
27
........
25
........
.......
26
..............................
26
D.
27
E.
Impact on the
27
Infrastructure
.......................
1.
Utilities ............................
2.
Zoning .................................
3.
Water ...............................
4.
28
5.
Lighting ........................................
28
6.
Roads ...........................................
29.
a.
29
b.
29
30
G.
30
H.
31
31
I.
Part II.
Recomendationm
..........
27
........ 28
...........
.............................
28
32
EOP 064508
3164
RECOMMENDED FINDINGS
OF FACT AND CONCLUSIONS
INTRODUCTION:
3165
million, with the proposed Hudson Casino share projected to be
S80 million (excluding the dog track) (Tab 3, pages 21 & 22).
AA
projects Total Revenues for the first year to be 588,367,000.
The Net Income is projected to be $30,910,000 in the first year
of operation. Pursuant to the Joint Operating Agreement (Tab 7D,
page 8) each tribe would receive 25t of the net revenue. Thus,
under this study, each tribe is projected to receive $7,727,000
in the first year of operation and $11,506,000 by the fifth year
(V-I, Tab 3, page 30).
Dr. Murphy estimates the total gaming revenues in the primary
market to be currently at $406,906,108 a year (Tab 4, page 15)
He estimates the proposed Hudson Casino take (including income
from the dog track) would be $104.1 million in the first year of
operation and $131.4 million by the fifth year (Tab 4, page 18)
He projects Net Revenues to be $31.1 million in the first year
and 48.8 million by the fifth year (Tab 5, page 1).
Dr. Murphy
did not provide an estimate of the total market gaming revenues.
However, we note that his estimate of total revenues of
$511,124,739 (Tab 4, page 15) is consistent with the estimate
made by the Arthur Andersen study.
The two reports differ notably
projected and the total amount
incurred by the Hudson Venture
this report). As a result, we
calculate a best case scenario
EOP 064510
3166
Table 1
Arthur Andersen:
$70,000,000
11,367,000
7,000,000
88r367,000
104,100,000
Expenses:
Casino
20,300,000
Dog Track
7,131,000
5,600,000
17,673,000
Operating Expenses
60,000,000
Depreciation
3,111,000
Interest
3,641,000
13,000,000
57.456.000
73,000,000
$30,911,000
$31,100,000
EOP 064511
3167
provide each Tribe a source of income which it
and
EOP 064512
3168
fifth full year of the operation (Tab 7D,
The Tribes have not provided the dollar amount of the obligations
these assumed liabilities will total. However, we do note the
Tribes have estimated a yearly total expenditure in both market
studies which includes these expenses.
Croixland will continue to own and pay taxes only on 6.96 acres
of land next to the Hudson proposal (Tab 7B). The remaining land
will be transferred to the Land Venture and leased to the Tribe's
EDCs (Tab 7E) . The EDCs will pay all taxes, assessments, water
and sewer rents, rates and charges, charges for public utilities,
2 The interest rate on this loan is equal to the prime
commercial lending rate of First Union plus 1% (Tab 7D, page 9, 5
2.27)
5
EOP 064513
3169
and maintenance
4)
2.
(Tab 7E,
page
7,
Article
Croixland and the Tribes have also agreed to form a joint venture
partnership (Tab 7F).
It will be called the Meadows Parking Lot
Joint Venture and is not scheduled to terminate until December
31, 2045 (Tab 7F, page 6, Article 3) . The purpose of this
agreement is to transfer ownership of the parking lot to the
partnership. To accomplish this, Croixland has agreed to sell
the parking lot land to the Joint Venture at closing (Tab 7, page
27, 5 9.03(g)).
The property shall be deemed to be owned by the
Venture as an entity and no Venturer will own the parking lot
individually (Tab 7F, page 6, Article 2).
Under the Asset Purchase Agreement, Croixland will transfer the
parking lot land to the venture for $10.00 and the portion of the
First Union Debt equal to the fair market value of the parking
lot land (Tab 7, page 11, Article III) . The venture will then
lease the parking lot to the Tribe's EDCs.
Thus, the Meadows
Parking Lot Joint Venture will be the landlord and the Tribal
EDCs will be the tenants under terms of the Parking Lot Lease
(Tab 7E).
Rent payable by the EDCs under the Net Lease will
initially be 'a sum equal to 110 percent of the aggregate of the
monthly debt service payable over the initial Lease Year with
respect to the portion of the... (First Union Debt) allocable to
the Demised Premises, (Tab 7E, page 4, Article 3) . The annual
base rent after the initial lease year will be determined by
multiplying the annual base rent for the preceding year by a
fraction (adjustment level divided by the base level) Id. The
lease is to terminate in the year 2018 (Tab 7E, page 2).
We have advised the Tribes of the troublesome aspects of this
arrangement. Specifically, we informed the Tribes that the
ownership arrangement does not appear to be beneficial to the
Tribes and seems likely to cause friction in the future.
However, it is our determination that this arrangement, by
itself, is not a basis to reject the application.
3.
The three Tribes, City of Hudson and the County of St. Croix
entered into an Agreement for Government Services on April 18,
1994 (Tab 9).
Under this agreement, the City and County will
provide general government services to the proposed gaming
facility.
The services to be provided include, without
limitation, police, fire, ambulance, rescue and emergency medical
protection, road maintenance, education and access to water,
sanitary sewer and storm sewer facilities, and other services
that are under the control of the City or County or are
6
EOP 064514
3170
customarily provided to other commercial
city
or County (Tab 9, page 2).
properties
within the
1999,
ana
Year:
dMING NO ADJUSTMENT
Future Value of 1,10 000:'
B
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
..........
1,207,500
..........
.
.
.
.
..........
. .
.
.
.
.
.
..
.
.
1,267,875
1,331,269
1,397,832
1,467,724
1,541,110
1,618,166
1,699,074
1,784,028
1,873,229
10 YEAR TOTALS
2025
..........
...
15,187,807
4,293,477
..........
..........
1,240,850
1,338,877
1,444,649
1,558,776
1,681,919
1,814,791
1,958,159
2,112,854
2,279,769
2,459,871
..........
..........
1,195,425
1,242,644
1,291,729
1,342,752
1,395,791
1,450, 925
1,508,236
1,567,811
1,629,740
1,694,115
17,890,515
14,319,168
8,959,357
3,273,099
For Column A:
For Column B:
EOP 064515
3171
calendar year" (Tab 9, page 4).
However, this does not apply to
taxes paid by Croixland for improvements or special assessments
14. The Tribes will also receive a total reimbursement from
Galaxy Gaming and Racing Limited Partnership in the amount of
$297,500 in years 1995, 1996 and 1997 (Tab 9, page 18).
This
amount represents the difference in the Tribes proposal and the
city's proposal for payment of government services.
The Agreement for Government Services states that the Tribes will
cause Croixland to pay the delinquent and overdue real estate
taxes and assessments and personal property taxes due through
1993 (Tab 9, page 4) . Thus, all encumbrances on the land will be
removed prior to placing the land into trust. However, to verify
this, we have requested the Tribes submit title
evidence prior to
beginning the 25 C.F.R. Part 151 process.
The Tribes responded
by providing a copy of the Title Insurance Commitment (Tab 10).
Also see the Tribe's letter to the Minneapolis Area Office dated
October 14, 1994 (Volume II, Tab 4).
4.
Ground Lease:
in any
6
EOP 064516
3172
rent of $12 a year and all costs expenses and other payments
The EDCs will also be
which the EDCs assume or agree to pay.
required to pay to the Tribes rent from the net revenue pursuant
The EDCs also
to the terms of the Joint Operating Agreement.
agree to pay all real estate taxes, assessments, water and sewer
rents, and other governmental charges imposed against the
facility, or imposed against any personal property or any Rent or
Additional Rent (Tab 7C, page 4, Article 3).
The tenant may construct any building on the land after obtaining
The tenant is
approval of the Landlord (Tab 7C, Article 4)
obligated to provide indemnification for any work on the
facility, any use, non-use, possession, occupation, condition,
operation, maintenance or management of the facility, any
negligence on the part of the Tenant or their agents,
contractors, employees, invitee or tenants, and any injury or
death to any person or damage to or loss of property occurring
Galaxy Gaming is not required to
in, on or about the facility.
The tenant is also required to
provide any indemnification.
provide insurance, Galaxy is not required to pay for any of it
(Tab 7C, Articles '7 & 8)
5.
Activities Loan:
3173
The Las Vegas office of Arthur Andersen & Co., an international
*Big 6, accounting firm performed a market demand and feasibility
study. Dr. James M. Murray, PhD. performed an analysis of the
market for the addition of casino games to the existing greyhound
track and an analysis of the economic impact of the proposed
Venture on the Tribal Reservations and the communities where the
proposed facility would be located. We relied heavily on both
studies to reach our recommendations and findings.
Our review of the market studies indicates that there was a
substantial amount of time involved in accumulating the data in
The
the studies. We find the sources of data to be reliable.
Arthur Andersen & Co. study contains pro forma financials which
were reviewed and found to be acceptable by the Minneapolis Area
Branch of Credit (Volume II, Tab 5).
D.
page 22).
Each of the three Tribes have stated that due to the location of
their reservations, they do not anticipate many Tribal members
who are currently living on the reservations to move to Hudson
for employment in the casino (Tab 1, page 4) . Since the Lac
Courte Oreilles Reservation is located approximately 117 road
miles from Hudson, the Red Cliff Reservation is located
approximately 221 road miles away and the Sokaogon Reservation is
located approximately 290 road miles away from Hudson, we have no
The Tribes do
reason to dispute the Band's assessment.
anticipate 10 - 20 percent of the 1,600 positions at the Hudson
Venture to be filled by Tribal members already living near the
Hudson, Wisconsin area (Tab 1, page 5).
The three Tribes expect to receive an average of $10 million
annually over the next five years as their share of the profits
They have identified areas of "high priority*"
(Tab 5, S-1).
We have
for which this money will be spent at each reservation.
advised each Tribe that if they are going to provide a per capita
payment from their gaming proceed, a Revenue Allocation Plan must
be submitted and approved under the December 21, 1992, Guidelines
5
Activities Identified as High Priorities by all three
Bands: improved health care facilities, educational facilities and
grants, housing, economic and community development, programs for
the elderly, land purchases and community programs.
10
EOP 0645I8
3174
to Govern the Review and Approval of Per Capita Distribution
Plans and Section 2710 of the Indian Gaming Regulatory Act.
Currently, only the Sokaogon Community has indicated that per
capita payments will be made. The Sokaogon Community did submit
a Revenue Allocation Plan. We returned the plan to the Community
and recommended minor changes. We expect to approve the plan
when these changes are made.
Each Band anticipates increased employment on the reservations
due directly to the spending of their share of the net income
generated by the Hudson Venture. In his analysis of the economic
impact of the proposed Hudson Gaming Facility on the three
Tribes, Dr. Murray estimates the creation of 150 new jobs on each
Although the
reservation over the next five years (Tab S, S-1).
Tribes may have to recruit non-Indians to fill many of the new
positions due to a lack of training, the Tribes anticipate that
the majority of these jobs will eventually be held by Tribal
members.
E.
(Tab 5):
TOTAL
ENROLLMENT:
TRIBE
NUMBER LIVING ON
THE RESERVATION:
LABOR
FORCE:
UNEMPLOYMENT
RATE:
3,180
1,651
821
39%
(321)
Oreilles:
5,431
1,923
1,362
58%
(800)
Sokaogon:
1,528
512
198
42%
(83)
Red Cliff:
Lac Courte
Since each Tribe has a high unemployment rate, the jobs created
on the reservation will provide incentive to Tribal members to
work on the reservation rather than moving to Hudson for
employment. Tribal members living off the reservation would also
have incentive to move back.
F.
the
facility
annually
(Tab 4,
11
EOP 064519
3175
page 1S). Of that number, 95t are expected to come from the Twin
cities area and are expected to drop $199,399,166; St of the
visitors will come from outside the Twin Cities Area and are
expected to add $5 million to the net profit of the facility 1d
PROJECT TRAINING BENEFITSi
G.
In their cover letter, the three Tribes stated that the Hudson
Venture will 'provide both jobs and training at the supervisory
and managerial levels for our people, (Tab 1, page 5)
They plan
to implement a cross training internship program to accomplish
this goal. The Tribe's representative has stated that the
internship program will last one year and will obligate the
trainee to stay on an additional year to help train other
employees.
Under the Joint Operating Agreement (Tab 7D, S 5.8.2) as
positions in the facility become available, preference in
recruiting, training, and employment in all job categories of the
Enterprise, including management positions, shall be given first
to qualified members of the Tribes and their spouses and
children; second to qualified members of other Tribes and their
spouses and children; third, to residents of the City of Hudson;
fourth, to residents of the Township of Troy;
of the County of St. Croix.
E.
fifth,
to residents
education,
Our data indicates that the three Tribes have high rates of
unemployment and poverty in spite of having developed local
12
EOP 064520
3176
tribal gaming facilities.
located farther away from
Wisconsin and Minnesota.
this problem by providing
market for gaming.
The Tribes have stated that they do not anticipate any adverse
impacts as a result of this proposal.
3177
between some members of the local community and the three Tribes
or the management of the proposed Venture, as grounds to reject
the proposal.
14
EOP 064522
3178
11.
A.
SURROUNDING
COMMUNITY
CONSULTATION:
3179
eventually finalized
(Volume I, Tab 9)
It provides
for a
The
distribution formula for services to be paid by the Tribes.
School District approved the distribution formula in an
intergovernmental agreement with the County on April 12, 1994.
The particular financial aspects of the agreement are discussed
in Part I of this report. The School District then wrote to the
Governor of the State of Wisconsin calling for in-depth
investigations regarding the impact on education (Volume III, Tab
4, page 7).
They expressed their desire for additional funding,
earlier growth escalators and the possible need for a
reversionary clause in the deed. This indicates weak support for
the current proposal.
3.
3180
The town's concern over increased traffic is addressed in the
The concern over a lower
Finding of No Significant Impact.
standard of living as an argument against the proposal is without
merit since the Tribes have indicated that the proposed gaming
facility will require many supervisory and managerial positions
as well as training programs.
Additionally, Dr. James M. Murray
estimates that 85 percent of the employment and payroll in the
expanded operation will accrue to Wisconsin residents and that 90
percent of the spending at the proposed gaming facility will
originate from outside the state of Wisconsin (Volume I, Tab s,
page 12).
The concern of limited housing does have merit.
However, we find that any growth to the community as a result of
gaming facility would not have a detrimental affect on Hudson.
The towns concern over additional cost of services has been
addressed in the Agreement for Government Services.
S.
3181
have been addressed by the Tribe's application, in the Finding of
No significant Impact, by the local governments of Hudson, or I'.
other areas of our findings. Many of the arguments advanced by
people opposed to the proposal are also political in nature and
raise policy issues for the Department of the Interior.
It is
our determination that none of these issues form a basis to
reject the proposal.
(51.2t),
(Volume II, Tab 8) which has been cited by people opposed to the
proposal, asked:
"Do you favor a constitutional amendment that would restrict
gambling casinos in this state?"
St. Croix County results:
(65.4%)
(34.6%)
EOP 064526
3182
in place and the dog track is currently in operation.
At any
rate, it is our determination that the 1993 referendum, standing
alone, does not preclude the Secretary of the Interior from
making a determination the Hudson proposal would not be
detrimental to the surrounding community.
Approximately 800 people signed a petition supporting the Hudson
No
They did not provide any supporting reasons.
proposal.
evidence has been provided to show that these signatures are not
legitimate. However, we have not verified the residency of these
supporters or determined whether or not they are registered
voters in the State of Wisconsin or elsewhere.
S.
3183
casinos currently in operation and may also be working to
purchase the Lake Geneva Dog Track to add a casino.
(b) Wiaconsip Winnebago Nations
The Wisconsin Winnebago
Business Committee responded by stating that they do not want
this proposal to even be considered until the State of Wisconsin
has fulfilled its commitment under the Tribal/State Compact to
agree to a fourth Class III gaming site for the Wisconsin
Winnebago Nation (Volume III, Tab 13).
We find that the conflict over the Gaming Compact between the
Wisconsin Winnebago Nation and the State of Wisconsin provides no
legal basis to reject the Hudson's proposal.
(c) Leech Lake Band of Chirpewa Indiana: The Leech Lake Tribal
Council passed a resolution against the proposal (Volume III, Tab
6).
They stated that numerous problems will arise for the State
and the gaming Tribes in Minnesota if gaming is expanded to offreservation locations.
According to the Tribe, the problems
would not only be a monetary lose to the surrounding Tribes but
also political in nature due to the unfair use of the "special
trust and tax status" of the Tribes. However, they did not
elaborate as to what the political ramifications would be. Nor
did the Leech Lake Band provide any justification for limiting
the expansion of gaming to "off-reservation" locations.
(d) Shakopee Mdewakanton Sioux Community
The Shakopee
Mdewakanton Sioux Community's Business Council passed a
resolution stating their opposition to the proposed Hudson
Their objections were
Venture (Volume III, Tab 11, page 3).
based on loss of income for the surrounding gaming Tribes and the
political ramifications. Specifically, the Business Council
stated the proposed casino would have a *detrimental political
impact in Minnesota since Minnesota Tribes have agreed by formal
tribal/state compacts to not expand Tribal gaming offreservation..."
The Community also argued that the proposed area is actually
As a result, they feel that
Mdewakanton Sioux territory
approval of an off-reservation gaming facility in Hudson should
We have found no
be reserved for the Mdewakanton Sioux Tribe.
Our Fee to Trust review under 25
legal basis for this argument.
C.F.R. Part 151 will identify any interest this Tribe may hold in
the land at Hudson.
ig.
The Chairman and CEO of the Little Six, Inc., also responded on
behalf of the Mdewakanton Dakota Communzity (Volume III, Tab ii,
He stated that the Community "vehemently
11)
pages 8
opposes" the proposal for the following reasons:
1) This is only an off-reservation gaming experiment which
could have devastating impacts on the negotiation process
20
EOP 064528
3184
among the National Indian Gaming Association,
state Governors, and Attorneys General.
Congress.
3185
(h)
Mill@ Lacs Band of Chipewa Indians:
Although the Mille
Lacs Band did not pass a resolution to declare their opposition
to the proposal, the Chief Executive did write a letter stating
the Tribe's opposition and referred to letters written by the
Minnesota Indian Gaming Association (Volume III, Tab 8).
She
also asserted that the Indian Gaming Regulatory Act was designed
to act as a reservation based economic development tool and that
the Hudson proposal is inconsistent with that intent.
She said
that reservation based gaming has allowed Mille Lacs to take a
feels
this
She
zero".
to
*effectively
rate
45% unemployment
number would increase should the proposal go through.
No studies
or data was provided to support these claims.
3186
impact.
1.
Economic:
None of the Tribes who have written to our office to protest this
proposal has provided us with any figures to back up their claim
that the Hudson Venture would be *devastating economically" to
As a result, we must rely heavily
the other casinos in the area.
on the study prepared by Arthur Andersen and Dr. Murphy to
estimate the impact on the other Tribes economically.
Arthur Anderson's study estimates current market revenue for the
six existing casinos in the Minneapolis/St. Paul area to be $510
million with a total estimated market revenue between $550 and
$630 million' (Volume I, Tab 3, page 21)
Since the Hudson Venture's share of the market is estimated to be
580 Million, AA has found that even though the existing casinos
would suffer some economic loss, the "proposed Hudson casino
should not significantly impact aggregate revenues of the
existing casinos, I._ We have particular concern over the
economic impact of those casinos located within 55 road miles
They include the Mystic Lake Casino, Turtle Lake
from Hudson.
Casino and Treasure Island Casino. Each of the Tribes operating
these casinos have voiced strong opposition to the Hudson
However, none of these
Proposal based on economic reasons.
Tribes have provided our office with any hard figures to back up
their claims.
On August 12, 1994, we requested the Lac Courte Oreillee, Red
Cliff, and Sokaogon Tribes provide an analysis which focuses on
the particular economic impact of the proposed casino on the
' The market was estimated by Arthur Andersen & Co. using the
following figure:.
Population within 100 miles ....
MULTIPLIED BY:
3,800,000
3187
Mystic Lake,
The
Tribes
Political:
EVIDENCE OF ENVIRONMENTAL
ADVERSE IMPACTS:
IMPACTS
AND PLANS
The Lac Courte Oreilles and Red Cliff Bands Lake Superior
Chippewa Indians and the Sokaogon Chippewa Community propose to
purchase, and place into federal trust 55.82 acres of land. The
proposed trust site consists of the St. Croix Meadows Greyhound
Racing Facility including the principal structure, track
facilities, paddock and kennel facilities and parking lot to the
north of the principal building, for the purpose of operating a
Class III gaming facility in addition to the existing pari-mutuel
dog track operation.
The main parking lot west of the grandstand
building is not intended for trust acquisition.
The existing grandstand would be remodeled to accommodate gaming
activities, however, most support facilities (kitchen, washrooms,
office space, etc.) would be maintained.
1.
Environmental Considerationes
3188
Mid-State Associates, Inc.. in accordance with the requirements
of the Wisconsin Racing Board Application for License (Volume IV,
Tab 4)
An addendum to the Environmental Assessment was prepared
by Bischof & Vasseur for the proposed trust acquisition (Volume
IV, Tab 3)
Based on the findings of the EA and the Addendum,
the Superintendent, Great Lakes Agency, found that the proposed
action will not have a significant impact on the quality of the
human and/or natural environment, and the preparation of an
Environmental Impact Statement will not be necessary.
The
Finding of No Significant Impact was issued on September 14, 1994
(Volume IV, Tab 1).
A Level I Hazardous Waste Survey has not yet been completed.
However, we do note that a Phase I Environmental Property
Assessment has been prepared by Braun Intertec for the Tribes.
It indicates that there are no documented or observable
environmental concerns associated with asbestos containing
building materials or underground storage tanks.
It also states
that there is no documented evidence indicating any past or
current land-use activities that have had an adverse
environmental impact on the site. We also note that prior to the
United States taking the land into trust, a Level I Hazardous
Waste Survey must be completed and approved at the Area Office.
We will satisfy this requirement under the 25 C.F.R. Part 151
process.
2.
3189
immediate area surrounding the site is
elevation of 840 feet'
with an average
iJ.
26
EOP 064534
3190
Mussel at the site. At any rate, the natural area consisting of
vegetation or wildlife habitat will not be impacted by the
internal construction or additional traffic flow Jd_
(e) Cultural Resourcesi No specific cultural resources or
structures are known to exist on the site.
The state Historical Society of Wisconsin has stated that there
are no buildings in the study area that are listed in the
National Register of Historic places (Volume IV, Tab 2, page 2)
The Mississippi Valley Archaeology Center, Inc., stated that
there are no known archeological sites in the proposed project
area (Volume IV, Tab 2, page 3).
D.
1.
Utilities$
3191
2.
ZoningI
Water;
The City of Hudson stated that the water trunk mains and storage
facilities are adequate for providing water service to the
proposed casino and "ancillary development south of 1-94" (Volume
III, Tab 1, page 3).
4.
Lighting:
The County has stated that although the City of Hudson has
jurisdiction to control and monitor the lighting, the County has
a responsibility to surrounding neighbors in other jurisdictions
As a result, the County expressed
(Volume III, Tab 2, page 2).
that any changes made to the current lighting system take into
28
EOP 064536
3192
They
consideration the larger community which may be affected.
did not express any dissatisfaction with the current system.
The City of Hudson stated that this concern was addressed at the
Specifically, a lighting
time St. Croix Meadows was constructed.
system is already in place which reduces the light spillage at
the property lines *to an amount equivalent to residential
The City also
streets" (Volume III, Tab 1, pages 1 & 2).
acknowledged that the lights may be on for extended periods of
to be open until 2:00
likely
is
time because the casino operation
a.m. or 24 hours per day it.
6.
Roads:
{a) Access: The City of Hudson stated that the current street
system is sufficient enough to accommodate projected traffic
needs based on 40,000 average daily trips (Volume III, Tab 1,
However, development on Carmichael Road north of the
page 4).
proposed casino may be necessary. Specifically, traffic
regulatory signals will likely be needed at the interchange of
Carmichael Road and Hanley Road.
St. Croix County expressed particular concern with increases in
traffic on USH 12, CTH UU, CTH A, and Carmichael Road (Volume
The County stated that even minimal
III, Tab 2, pages 2 & 3).
traffic increases will have a negative impact on these roadways
However, information
since they are already at capacity.
gathered from the Wisconsin Department of Transportation
indicates that any negative impact from additional traffic will
be minimal (Volume IV, Tab 3, pages 38 & 39).
A traffic study was completed and
(b) Traffic Imact Analysis:
is contained in the 1988 Environmental Assessment for the St.
It is based
Croix Meadows dog track (Volume IV, Tab 2, page 18).
Peak traffic estimates
on traffic projections in the year 2011.
of
Transportation
Department
were provided to the Wisconsin
No significant
regarding the proposed Hudson Casino Venture.
problems were identified regarding the proposed traffic increase
on the Interstate 94/Carmichael Road Interchange.
The Finding of No Significant Impact (Volume IV, Tab 1) also
indicates that although no transportation system is likely to be
developed in Hudson that would assure there will be no slow-down
or delays during peak traffic periods, various methods would be
utilized to manage delays should they occur.
These methods
include varying dog track racing times so as not to coincide with
peak casino attendance times, elimination of parking fees and
gates for easy parking lot entry, use of shuttle buses and remote
parking areas, possible adjustment of time delays on traffic
lights during peak attendance times, and installation of traffic
lights.
EOP 064537
3193
F.
IN
TEE SURROUNDING
COMMUNITY:
The City has stated that approximately 25 acres of the site is
developed. The six acres that are zoned as single family
residence have limited development potential; 18.5 acres are
located in an area of the bluff east of the track and are
generally not suited for development, although there may be some
potential; 5.5 acres are suitable for development (Volume III,
Tab 1, page 4).
The City of Hudson has stated that there is sufficient land in
the city that is zoned appropriately or has already been
identified for future commercial land use to accommodate the
potential need for the development of hotels, motels, restaurants
and other service type oriented businesses 14_
0.
IMPACT
3194
S.
In the
agreement, the Tribes, through their EDC's, will pay the City and
County for general government services, including, but not
limited to, the following services: police, fire, water, sewer,
ambulance, rescue, emergency medical and education. These
services will be provided in the same manner and at the same
level of the services provided to residents of the City and
County and other commercial entities located in the city and
county. The agreement will continue for as long as the land is
held in trust or until Class III gaming is no longer operated on
the land.
I.
FOR COMPULSIVE
GAMBLERS
AND
EOP 064539
3195
III.
RECOHMDDATIONS
Area Director
Date
32
rOP 064-540
3196
TAKI
C 2U240
JUL1 4 199
Exhibit 2
the request of nearby Indian tribes, the Secretary extended the period for the submission of
comments concerning the impact of this proposed trust acquisition to April 30. 1995.
The property, located in a commercial area in the southeast corner of the City of Hudson..
Wisconsin, is approximately 85 miles from the boundaries of the 1ac Courte Oreilles
Reservation, 165 miles from the boundaries of the Red Cliff Reservation, and 188 miles from
the boundaries of the Sokaogon Reservation. The St. Croix Band of Chippewa Indians, one of
the eight Wisconsin tribes (not including the three applicant tribes), is located on a reservation
within the 50-mile radius used by the Minneapolis Area Director to determine which tribes can
be considered *nearby* Indian tribes within the meaning of Section 20 of the Indian Gaming
Regulatory Act (IGRA).
3197
Section 20 of the IGRA, 25 U.S.C. I 2719(b)(1)(A), authorizes gaming on off-reservation trust
inds acquired after October 17, 1988, if the Secretary determines, after consultation with
appropriate State and local officials, including officials of other nearby tribes, and the Governor
of the State concurs, that a gaming establishment on such lands would be in the best interest of
the Indian tribe and its members and would not be detrimental to the surrounding community.
The decision to place land in trust status is committed to the sound discretion of the Secretary
rf the Interior. Each case is reviewed and decided on the unique or particular circumstances of
the applicant tribe.
For the following reasons, we regret we are unable to concur with the Minneapolis Area
Director's recommendation and cannot make a finding that the proposed gaming establishment
would not be detrimental to the surrounding community.
The record before us indicates that the surrounding communities are strongly opposed to this
proposed off-reservation trust acquisition. On February 6, 1995, the Common Council of the
Ciiy of Hudson adopted a resolution expressing its opposition to casino gambling at the St. Croix
Meadows Greyhound Park. On December 12. 1994, the Town of Troy adopted a resolution
objecting to this trust acquisition for gaming purposes. In addition, in a March 28, 1995, letter,
a member of elected officials, including the State Representative for Wisconsin's 30th Assembly
District in whose district the St. Croix Meadows Greyhound Track is located, have expressed
sirong opposition to the proposed acquisition. The communities' and State officials' objections
are based on a variety of factors, including increased expenses due to potential growth in traffic
congestion and adverse effect on the communities' future residential, industrial and commercial
development plans. Because of our concerns over detrimental effects on the surrounding
community, we are not in a position, on this record, to substitute our judgment for that of local
communities directly impacted by this proposed off-reservation gaming acquisition.
In addition, the record also indicates that the proposed acquisition is strongly opposed by
neighboring Indian tribes, including the St. Croix Tribe of Wisconsin. Their opposition isbased
on the potential harmful effect of the acquisition on their gaming establishments. The record
indicates that the St. Croix Casino in Turtle Lake, which is located within a 50-mile radius of
the proposed trust acquisition, would be impacted. And, while competition alone would generally
not be enough to conclude that any acquisition would be detrimental, it is a significant factor in
this particular case. The Tribes' reservations are located approximately 85, 165, and 188 miles
respectively from the proposed acquisition. Rather than seek acquisition of land closer to their
own reservations, the Tribes chose to *migrate' to a location in close proximity to another tribe's
market area and casino. Without question. St. Croix will suffer a loss of market share and
revenues. Thus, we believe the proposed acquisition would be detrimental to the St. Croix Tribe
within the meaning of Section 20(b)(1)(A) of the IGRA.
We have also received numerous complaints from individuals because of the proximity of the
proposed Class III gaming establishment to the St. Croix National Scenic Riverway and the
potential harmful impact of a casino located one-half mile from the Riverway. We are concerned
that the potential impact of the proposed casino on the Riverway was not adequately addressed
in environmental documents submitted in connection with the application.
3198
Finally, even if the factors discussed above were insufficient to support our determination under
Section 20(b)(1)(A) of the IGRA, the SecreLsry would still rely on these factors, including the
opposition of the local communities, state elected officials and nearby Indian tribes, to decline
to exercise his discretionary authority, pursuant to Section 5 of the Indian Reorganization Act of
1934. 25 U.S.C. 465, to acquire title to this property in Hudson, Wisconsin, in trust for the
Michael J. Anderson
Deputy Assistant Secretary - Indian Affairs
CC
3199
6.5 o 2-
Exhibit 3
Secretaryv Babbitt
Secretary Babbitt:
On March 3, 1995 at 2:30 in the afternoon, I satin a Senate hearing room and listened to your
brief speech before Senator McCain about your concern for Indians and the Bureau of Indian
Affairs (BIA). I listened to your comments on Ada Deer traveling across the country consulting
with the tribes in govemment-to-govemment relationship according to our treaties and President
Clinton's Apni 29, 1994 Memorandum. An hour and half later in discussions with the Director
of Indian Gaming, Department of Intenor, it was evident that not everyone in the Department of
Intenor is aware of the trust responsibilities of the Federal government and the consultation
process that is to take place between tribes and all Federal agencies
My tribe and two other Wisconsin Tribes have placed an application to put into trust land to be
used for gaming purposes. We (the three tribes) have followed the regulations and responded to
all the requirements of the BIA Minneapolis Area Director including waiting for the required 30
days for comments for all possible affected parties. Minnesota tribes were given opportunity to
comment on our application for trust land in Wisconsin. However, earlier when the Minnesota
tibes built their casinos, the closest and most effected Wisconsin Tribe (Lac Courte Oreilles)
was not given an opportunity to comment Regardless, the time was provided according to
regulation, the application was reviewed and forward. - from the BIA Area office to the
Depanment of Intenor Up to that point the consultation process was working, then it stopped
The Director of Indian Gaming was visited by the Minnesota congressional Delegation and at
that meeting the state of Minnesota was given an exclusive right to comment on our application
that was submitted to your department. Unfortunately the Director felt there was no need to
inform our tribes or the Wisconsin Congressional Delegation. Our tribes were never informed
that anjidditanj comment period was taking place or that we could provide additional
comments which the Director decided is allowed under the law However, we have been unable
to find where this special comment period for only selected citizens is provided for in the
regulation.
Most important is that your Director has decided that there is no need to consult with tnbes in
decisions that affect them Could you and would you please explain this to me as the Tribal
Chairman of my Tribe so that I may explain this type of exclusion of government-to-government
relationship to my tribal members If your Director of Indian Gaming is excluded from
3200
President Clinton s directive. please notify our three Tribes immediately so we may find out if
there are Federal employees that do not have to adhere to a Presidential directise
Since ly,
Arlyn ckIcy. Sr
Tribal Chairman
3201
r\ -
'DI
Exhibit 4
MAR 27 IM
Honorable Arlyn Ackley Sr.
Chairman
Sokaogon Chippewa Community, Inc.
RL 1, Box 625
Crandon, Wisconsin 54520
000' c,
to Co nress
/ '-&
l.
rs
eS pursoant
ISb'SU6,,t
As you may know, on February 8, 1995, Imet with SenatorPaul Wellsosne, Representatives Jim Oberstar,
David Minge, Bill Luther, Bruce Vento and tribal representatives from the Mille Lacs, Bois Forte, Leech
Lake, Shakopee Mdewakanton Sioux, Red Lake and St. Croix Tribes, to discuss their concerns with your
application to place land located in Hudson, Wisconsin, in trust for the Sokoagon Chippewa. Community,
the Lac Courts Oreilles Band of Lake Superior Chippewa Indians and the Red Cliff Band of Lake Superioi
L..ppewa
At this meeting, tribal representatives indicated that they did not believe the Bureau of Indian Affairs (BIA)
had complied with the tribal consultation requirements of Section 20 of the Indian Gaming Regulatory Act,
and that they lacked sufficient information to adequately respond to your proposed acquisition. They
specifically requested that they be granted additional time to submit reports detailing the impact of the
proposed acquisition on nearby tribes. We agreed to this request, but did not set a deadline for the
submission of this information. In order not to unduly delay consideration of this proposed acquisition,
we have advised the parties with whom we met on February 8 that any additional information must be
submitted by April 30, 1995, in order to be considered by the Department of the Interior in making the
Section 20 determination.
Please be assured that our commitment regarding the submission of additional information will not delay
consideration of other aspects of your application by the BIA's Indian Gaming Management Staff. Should
areas of concerns with the application be identified, you will be so notified.
Sincerely,
John J. Duffy
Counselor to the Secretary
bcc: Secy Surname, Secy RF(2). 101-A, Bureau RF, Surname, Chron, Hold
wp:a:ackley.dog
BIA:GSkibine:trw3/16195:2194068
corr per iDuffy:Irw:3127/95
Identical letters sent to:
20.2 2AUAY2.19
FRIDAYY
0fn
ADWORK RECORD
1t
IB-
4:
ix
fm:
__
__
__
__W__
__
__
__
5:
__
2
DIARY AND
Ar'~OI
Er
WORK REcoRD
B~ig
Si
Oc 000
MONDAY
*
FEBRUAnY 6. 1997
A SCHID
APPOINTU
.*
ED
wk
IVET
8 Da, 31.328Lot
MONDAY
FEBRUARY 6, 1995
II
~11
EXPENSE &
REIMUSBlEMENT
nECOfD:
OC 00002
Wk0a,36.321 1
FEBRUARY 7, 1995
DIARY ANU W.ORKRECORD
r"
.70
ReOAOC-f F
wdEF( 0
WEDNESDAY
FE,5UARY a, it
APPOINTMENTS A SCHEDULED EVENTS
4
_t
-.
WEDNESDAY
55*Da0v39.328L.11
FERi.1RY , 199
DIARY AND WORK RECORD
StA
REDvp,Pumpo.
SATURDAY
wA * sy 42.3231n
uwtJC
itm~LdAj~
OSAP
Ic
nECOnO
TO HlE
DONE TODAY (ACTIONLIST)U
&EIUREMENT
nEHNSE
FIECORD:
IjC
0000
Ifeatlni .i
03/IS/95
trri;
qAiM!Pv
DIiscusakenith
at Interto
o~Y-
.ap.
Top'Cerebranl
Me.l
kegarding
meetings
4 rUsoAY
1905
APRIL8.
APPOINTMENT A OCSI EDULED EVENTg
THURSDAY
APRIL O. 1995
DIARY AND WORK RECORD
PAamn
wa ta -D
nn
9ADe
Bigo I
mQcs
El
or nn000AR
I-
AnR
APPOINTMENTS
*
s a
-u~c
e
evnc'---a
*L'
REDACr'
MATEN
loNla
*Dag
"*-
I RYA
DIAR AND
*'**
RRTE
wonK, RECORD
.rsewro
....
"'w.
(reNuST
REDACTED
MATERIAL
REDACI-:)_
MATERI,.1r
C. '*-gr-
*("?**
OC 000047
I.d
APRIL 10, 1
9
AP OIHTUET A BalEflULE
5.
L.AWA
EVVflTS
265 to,
API0,
19g5
AND WVORJRECORD
va
121
MONDAY
111*. D l ol.
2MI UL APRIL 17, 1995
DIARY AND WORK RECORD
~flc) \Q
F\C
oc Of
1~j
IUbU~
&scfiruLtl EVEN1TS
WEDNESUA T
APRIL 10, 1995
APPOINTMENTS A
IWORK
RErORo
r
9-4
oc 000066
22
(
SATURDAY
APRIL 22. 1095
APPOINTMENTS A SCIHEOULED EVENTS
.. ns
flMt
rO
mmIs.*Mrt2.53tl
SAlUHUAv
APnIL22,
DIARY AND WORK RECORD
04c
su-t
m10:
--
we *3M
1:
.**eotc
asumsco
1995
MONDAY
APFlIL 24, 1995
APPOINTMIENTS A SCHEDULED EVENTS
MI-Day114,251 ILh
(ACrToN
U.JB)
NI~
oc 00008
f5
TUESDAY
APnL
gg
25.1
U*
TUESDAY
L.Htl APRIL25,1995
DIAR1 AND WORK RECORD
wat?*Dutis2
.
are
EOFD
U
U
I
I
*I
1
-*
,-Tso
Eo
*
I-c
MONDAY
fo
IAY 1. 1995
JPOINrENTS
A SCHEDULED EVENTS
*AME
Suatef
Day
MUNDAY I
421,244tltMAY
1, 1995
DIARY AND WORK RECORD
NAUE
PECT
q.4
I=I
TO BE DONE TODAY (ACTION
UST)
12~
0 .e::
',-r
r;:
-9
f5n
lai
ympty.wTb
.,
TUESDAY
172.2. L
MAY 2, 19fl5
MIARY AND WORK REOORO
- .
TA
-- TY
* WEDNESDAY
MAY 3. 195
,*APPOINTMENTS
A SCHEDULED EVENTS
---
-f
DIAY
Pa
TO BEDONE
TODAY (AcTION
UST)
p~G~
EXPENSE
Im5l
.InUnSDAY
MAYW4,
APPOI"ET
TIlUnSDAY
1995
A SaIEDULEI, EVENTS
Wke*D0yl24.241all
DIARY AND WORK RECORD
*dUN SUOECT
ni v NAME014
laEC
DESCIPEOe
TO B
a~
7:R
.j...
-SI
~.-
ime:
B
EXPENE & RaMBURSEMENT RECORD:
,...
.::
.. .* .:
...
~I....
.
.~
~
....
......
. ............
..
~
........
~
3.
B
B...............
1121
qEXPFENM
&iM8U~FqEMENT
RECORD:
its
4hl:fl
MONDAY
1995
,MAYO8,
APPOINTENTS & SCHEDULED EVENTS
s
AME
MONDAY
IB*
r120.
1995
DIARY AND WORK RECORD*
osteloECI
LeftMAYS8,
ct
TO BE DONE TODAY
(ACiON
UST)
m
0!
m
it
m
EXPENSE A REIMBURSEMENT RECORD:
OC 000072
TUESDAY
MAY 9, 1995
APPOINTUENTS A SCHEDULED EVENTS
wa19*D.,
TUESDAY
235Latest
MAYO,1995
DIARY AND WORK RECORD.
hfWJE
"-'
IAHON
DESCEMPTO
ST)
.-
~~
OC 000073
IE
10
WEDNESDAYMAY
10. 1995
SI
APPOINTMENTS
&
SCHED
IOEVEN
VEDNESDAY
MAY 10. 1995
10
11'
C4
1l:
1~
____0.
OC 000074
12
nlDAY'
MAY12, 1995
App*-
a aaEubflLdb
t7~ThCct
MDI
EVEiTS
more~
.*SATUnDAY V
MAY 13, 1995
APPOINTMENTS
SATURDAY
MAY13,1995
REDAC'
-N
DEscIPTION
1E
REDACT
MATE-,
REDACTP'
5.:
OC 000052
14
b UNUAV
-r-Y
Day131.231Lett
ITO
MAY
suBECT
RLDACTED
MvlATE F\iAtL
REDACTED
MATERIAL
95
15
.. , MONDAY
* AY 15. 1995
APPOINTMENTS A SCHEDULE
MONDAY
k20*y0115.230L.l
151
1AJET11OP
OC 000076
16
TUESDAY
20*0a135.229
NW
EXPENSA REIUD
EMEN
te11
MAY 10. 1995
DIARY AN fwORK ftECORD
POJECI
M-AInt
ECORD:
00 000077
WEDNESDAY
MAY 17, 1995
APPOINTMENTS A SCIIEDULED EVENTS
?4V
'I
oee-,
OC 000078
FfIDAY
*--
F. RIDAY
MAY 19.19
APPOINTMEIJ9
& SCHIEDULED EVENTS
TS
~f
LC
SUOJECT
Wk
Mag
'
*Darl31,226 L1rt
MAY 10. 1995
DIARY AND WORlK RECORD
,
i-i
TO
23
TUESDAY
MAYOI3TMENTS A SCHEDULED EVENTS
MAY 23.
WJ.j175,
yPOINUENTSDIARY AND WORK RECORD
1995
-ID
CAD
24. WEDNESDAY
MAY
241995
APPOINTMENTS A SCHEDULED EVENTS
.J-
OD
C:
Oc 000000
)_
__
25. 25
HrURSD~fAY f
THURSDAY
lt
y
MAY 25. 1
1k
U
E
U
I
I
U
I
I
EXPENSE & REIMBURSEMENT
RECORD:
oc 000081
WEDNESDAY
MAY 31, 1995
APPOINTMENTS A SCHEDULED EVENTS
___
E2OsI.ILI
. 7')NESOAY
OC 000082
TUESDAY
JUNE 6. 1995
APPOINTMENTS A SCHEDULED EVENTS
l*D.,
NNL
TUESDAY
JUNE 6, 1995
DIARY AND WORK REcOnD
9st.2ontiL~
oeveno~ACt
Dascarton
OC 000083
3MOW1AY~
MONDOAY
2*,
EVENTS
MO
stoe
DIAfY
SC3su02e
-7-i
rUNrS2
19
MONDAY
A25*
APPOINfTIENTS A SCHE
ns'
MONDAY
,..
NCI
MCt
~~I~.J
L~r
a nEsuounSEMENT
NE 19, 1995
CxP rusE
11o.10t L.11
LEO EVENTS
~Star't
y-IW
Poo1
at~pea_
nECOnD:
ICR-
OC000085
29
THURSDAY
JUNE 29. 1995
lb0
JULY
4 1995
APOINTMENTS
& SCHEDUJLrDVVENTS
"
DIARY AND
ORK RECORD
TUESDAY
JULY 18, 1995
AM
-APPQIp
H* A.E
tUESDAY
OC3
Wl"LDTEMTS
W29-Q
1,10L16
U.ECI
JbLY 16,1995
WORK RECORD
1I
Aus on PnFlJc
VSR
~REDACTF
nO 000059
19
WEDNESDAY
29.0.1200.
WEDNESDAY
1
,,
20
L jJ~20. 19 5
APPOINTMENTS
TO BE
29 !
CIEb.~
DONE TODAY
-IHI
(ACTION LIST)
0Y0 1. 1Li
LY2.19
oa
22
cjI-
0oc 000058
w199D
AUGUST
.
OI,
Ico
36AN
DIARY AND WORK
AUGUSU 95
RECORD
I
OC 000089
MONDAY
AUGUST 21, 1995
APPnlTMNT& SCHEDULED EVENTS
Odif.4ntanI Utf
MONDAY
AUGUS23.d995
4iA
OC 000090
21
A12.
T 22 S9
y34 ra L.11'
AUGUS
22,1995
oc 000091
MONDAy
SEPTEMBER
su
L.te
MONDAY
SEPTEMBER II. 1995
we~k rEonD
~No
'~~o
-~
OC 000092
3252
Exhibit 6
24-Apr-199
07:17p=
TO:
Cheryl D. Mills
FROM:
Michael T. Schmidt
Domestic Policy Council
CC:
CC:
CC:
Carol H. Rasco
Loretta T. Avent
Katharine M. Button
SUBJECT:
Chery>,
you in =ore detail about a call that
This e-mail is to fill
Loretta and C were on with a Lobbyist/Fundraiser named Pat
C'Ccr.cr.
It was half-dIctated to me by Loretta via phone,
C acolocize in advance if it is unrweldy at times:
so
3253
stated that Loretta had told the leader of the Red Cliff Tribe
(who Loretta has never met or spoken with) that she would
intervene on their behalf (not true!).
After this fax tame in
Jay on Loretta's staff called Pat's office again asking for tne
letter from the tribal leader. It never came.
In the meantime, Pat bumped into the President today in Minnesota
and mentioned to him that Loretta never returned his calls
(technically true, but her staff did return them several times
because she was travelling) . A call came from AA1 this morning
from Bruce Lindsey to Loretta to find out what had happened.
Loretta reviewed the story I have written so far, and told Bruce
that she would call Pat to explain our process. Loretta called me
(since I do Indian Gaming Policy) and then conferenced me into a
call with Mr. O'connor (her assistant Katy Button was also in on
the call). And then, in Loretta's words, "his story began to
He had to admit to Loretta .that he had
unravel" in two ways: 1)
a return call from Loretta's office; 2) See the attached fax from
him -- he had to back off of the statement about the leader of the
Red Cliff Tribe talking to Loretta about this since it was not
true. He was agitated that Loretta could not meetwith him on
this issue, and he took my name and number and promised to call me
about this issue sometime this week, and that he would also bring
it up in his meeting this Friday with Don Fowler at the DNC. He
abruptly hung up before I could respond.
According to Loretta:
he first mistake Pat O'connor is raking is trying to tie the
President into an issue that he cannot be tied into for legal and
ollitcal reasons. The White House should not be involved in this
.ssue!
!;emust
0
a
3254
give you
EOP 069078
3255
Exhibit 7
THE WHITE HO-SE
AS
MEMRADUM FO
KAROZ:
:1.
ICKES
Loretta Avent
I )ust got a call from Bruce in reference to a person namec
Pat O'Connor, whom I don't know, who has called me on numerous
occasions. Unfortunately, I was on my reservation circuit, so I
asked both Jay Ca-npbell and Katy Button in my office to call anc
advise him I was travelling and that before I could respond
personally, I would neec a letter from one of the tribal leaders
he was representing explaining their situation and/or their
concerns.
Following the legal advice we have received concerning
chese kinds of issues, I have not and would not speak with him,
cr any lobbyist or lawye:.
Irrespective of lawyers and lobbyists say they know
, my first responsibility is to
in the Acministration
:ake care of the pres. because I am aware of the politics and
:he press surrounding this particular situation, it is in our
interest to keep i: totally away from the white house in
ies:
general, and the pres In particular. This is such a hot potato
(like Cabazon) -- too hot to touch. The legal and political
locationsos of our involvement would be disastrous.
I am on my
eay
into a meeting witn five of our strongest tribal leaders
;because of their significant voter turnout), who have already
g.be ballistic about o:ner :ribal governments who have greater
access to the Administration because of their abilityto pay
hired guns (as they call them) and their Delief that this
unfairly gets things to happen.
They believe that when the
President said "Goverrnent-to-Government" and "respect for tribal
consultation" that it meant directly with them. They consider
the lobbyists and lawyers trying to access us as staff they (the
tribal leaders) pay an.: tnat the:: responsibility is to report
an: advise them (the ::iba leaze:s) , anc as tribal leaders
elected by their me7.tership, they will do the business of tribal
governments directly
cur government.
cn.h
Personally
3256
Departmen: of Interior anc justice DepartmenL anC tna:
is
recognized
I explained this
operate and I assured
advise the party that
meeting is over. I'll
press is Just waiting
give it
Each
to them.
Maggie Williams
Cheryl mills
EOP 069071
3257
FADE1
,He,
Exhibit 8
CitboIT
57071OF01610061
57
CULAR1
MM01
10.31
2R
11 2
1w*0.
0150001
61
11t
011 IS.
1957
10
VAD
000111
010181W5-01
7'--l"-
25
V~lt
1-
rtow~t5
95PVQ
let
WOIIC
TI t
W. I.
staNrer-CION
SeTtlo
815-2).
9l5
3 OPETA66
0101E
L808
I1. 0 I I estes.0.O Bet 1312.
l
ribe
Isebrsl
011t .
1111
A0 0,
B Itl.
Is
- b O st 1 - 80 P.
WO28r,111R.in
7 7 6
~~ ~
23
805810,
"'8.
_tete
- 01 9
10l~
95
IS
ts
ass
l
9
001 0
-nolt
O-eee
-.
11M
-L..
.10
tr'fle
trot
Fir
-11
that
1-
ott
TAKEN PInltiefl
ff0 t01l8
LO
vc
1 1 10 S r e
19
25
____
tI1C16CE.
P.t
Mt 13t2.
_MCN.
191
.i
1~
~~ ~ ~ ~
I7
L16E000
AS0
Intet
0 h at
OI.
-r -1
em
re.eArlhe
:1
17
It
to CK-.
o e
80
SIAMe
OILY sta
K.e~
~~~~~
*~
aeL I
C ALL5 t
13
FrlIr
L-IW 5
I-~kL..
53701
hCoel1s
Aeet
1 1es eeettsl.
WtraToth 5 tt
tr
R ItIas
1be ot.e
aO I
se .
resowt -tsf0I1Lit
(BARI
233-BIte
fitter
lobeis
Oi t
voI-.
btI~C
aILL
15esl
elosD
Aro s
Wt IoweO
0 al
It
00-
not
1sie
a.
3258
57 nEEt 15
PAGE
tthtr
u
Stee IC wat it
to
ceer
ttes
nLO c
is
et
tohe
as:o
mte
attt
0 tes The
to
Is
to 2Ot
3
Fiter
uIn
seoo
'
ethe shit
"
tM se
I r
1s
e t
titt
ett
CsOi
tit
is
tri
Tri-cI
-seta
a
srio
lY
to
It
0A
ttretaLL
wrd
ao otsets
veCtal
sOet
h other
re
tte
L
ta ,
os voterd
osrt
ihh
thasthe
stle
a's0
fL t1
ot1
16
tiltst the 1
Of 0
Is
acso al totr
POa
I,
00
v
15
nt I otsm? -L nt
ad -1t.
Dvesat
likeIn
I kotes ttat s tloycrissotut
steso
tte tirm tIat
0, Ao
I-
22
23
a
trta
ha5
t h
- ea
21
tItsm
04
ot
.m
then
na
hoim
yerevsat
-1
ta
dest thitti
Ievea
ti
tn
tra-
oftt
ehal
t him
aaiti.
me
to
to
A I-il
1
t5
to
03
ran itheditase.
2d A Tht's
0
soya-iOc that ute
oni retail, tt
00 ti I
to het thy
Ksitto reterrih
5 to tntreail
reftenoinsheir tes 00ShtlCLntm stratesyt
24
lint
A
reoresentedadut erhtina
ds. tres
osv
0 sht
,id
ot
ahld
to act
ses 1r--t
that
we
is
MidI l.
tn
00 the
her
t Uhd
tevoet
Ai
tie
eer
eet?
Imat sic
th
trn
es
et
tis
he
oing
fr
t50 4eLL.I heieo he t oatthe c ventim ctee
16
smamvenity
h itatieyrS thi
related to
th
nt 8a
at
.
th7coeoes. Bt hat
his?
- e- he
of ot se ai
it - inan
r
t.
d te
rt
"stn
the la
N
ofh in tatrs
.
I'dsot,tento tiftech
21
_
s t?
_ -res
ot
2 0 40 this a
te
te
lt
Ns
t Sta
it hM
m4
he -It tti
L tim.
f
m1ta
Stts
24
25
a s tee
IM of thin
17
SO
19
er
trno
0
t6
*stt
diot
andthat itsit.
satsvert abru.
so the chovestin
te
oth
,a tt
s to
4e1. n
i that oay esa-, dies t yo7
Ite
yes.I Odd
he
set th PrIet
cre dd1 r
tAt
tin
s chs
Mititt
as th
I mt th h slct
7
mt
Iv
BA
th hirs
sinto
ye Int
Pra.Ii
tnJiatt
onk
16t h Ista
-t~ 9 that
tWt I
'
It I evers - ia
I -r 1 reai
Se~a.
tr Ktte.
I
t at treat
Iee to -t h
thihe
I 00-t
old u n00Iniat te1ter
If
I'dctees
PAG 60
tost
O
12
So1
too
3
I
11l -
-1.
that a.
d ol
at
ile
21
2
03
l h
tsht
24th to detahe
heth
1s ett
1 in
you -0 ha -los-t
04 i.
- sel
itot
h_O
att
s
t
tdts
_t. her ot
tal0 to L et too
inats
tall
ate
t11e
"'an
ea
tt
a
o tterttvsIst
to
%ev
i
nt
Idid
I
to
s15
his
.e-
n
lm
l sia
A av'Sat shot the Tribte
LL
a
t3
50
00
er
loe
ule
to
isy
See I hat
that
a
I
SA
It that reney
titto
inthat antS
..c..t'.
O ln- l"
-Js
us tri hrutae tier theo sad Indet
S0 4 het
ih the c ess he
ieveItatcd to es ecr
A
oid haveOn
6ot-s
uo,
Strtev7
rt
W.
at
te
3259
:,2
t-t
So
0
11e11.e
0
A
A
I
o
to
1
A
o 0
o
A
t2
0
A
'
that
ntns
'
20A
ar
vt
oe
ttI
I. I,
e
O SF0of
this issUC 51
L.
1e1
eta
, h
s ie Ith trhe Presoent
c hnceto
nddI d eouhava
trot
i ?
0 th 1
1 ia.
atoo: saetohm
tht6
nrslet
-Or
I 0i0.
0000 heSt torm.
tot
a
that
I rareseh e raoeaew
t-oa
.t II.
In hr
aSSIe emi000in
5oot
thts
*
NO
te
rtat
oro,
ottco Is
cm t7
0
hot-rh
. to satd
ot tha!
23
wIth
or
-d
sta
1 11t late
tt
e L ie
22 0
StrOO
rIt
ste
iS
t
t
-1
m
r
I
t he. toot to he ra tts.*
that
tot trloe
n0
c-t
he
reatte
y L -m t1
ho lth
,
'n
A
0
0
A
13
27
1
16
C-
rticu
thIs
o
-r ,rea.
00 feLt thattu
t
teot
of this
s.
heIfl
trat. tt
rat
1tth
c01l
.
IS Sa
elah
iho
W C
te
Iale
I
ho
1t
to
ticat
11
ateo
e-
to
oat
In e h
t
o
t.
I0
to
I
the
--
1
mLe
that 3
5
A7 oStt
te
to
ella_
toeta -
A
0
of
22
tet
atti
11
t
smia
22
23
u
0
"I
L -
Wtil"
SCWtLa
tie
.
.lI
l .
Smtthsw
BLED --
e a
to.t:..ut
a1t
Mi
to
aL
_ri
te
I
--
t0
17
toe!
sa
.tA
I
0I
---
ri
I...
f:,
If t ho
olt
sh t te
- e that
"rets
L roee to 0.,Wa
thi a Ltretere
21
t
at
Is
23
I-t
-1nt
7le125
dlv
..
Y1no
ino
oteatI
at
en
tt
tetolStt
aOea
s I
rtto
Ls.
tr
rtat
ests hese
63
Le
mS
e at
thI
at
meting7 M
M uar
7cn
aevlh
revend
tMt
M-
wtak
a ua
Old
s I attIt
r
M-M
ha t M
hr
at.mm m
[a
to a her
to
oth
YeM
L -~
raveLs
1i -- =
Sh
"l.
k'
tr
mitr 1
I 0-n
i.
rhm
00 ote!
Al
ax
-t
ti
ulth
24
Li-e,
rse-
a tat
t
are
m
00
t itKto e Ot t i
0
toLd
t Preth t 0r naloh
Illd . tot 1
d
1
te are
o Ia1t
reit
of
ar u t atls
rte?
hes
ttl
r
t 1 i
-or
I
ee
t
-- ulh
. L
di Y
the
19
25
1
tar
ter
m
0
aLiev Tht
te
" a
10 sa
.
loot
NO he
lto
toor ialt
1.
1271.aaE
17
2!
a
a"
A
J Ints
Ott
It 0
00
5
tfI
the6
to
eh alrod
I t
to
e
NO t
asw N
t0
t7
met
tlntad
Atto tta
ram
-N
lta
lt
12
tO
20
toasue
atter.
Omtto
Ye
thatio.et
So tw
said relut
t
ta
Pe OM It dI
tI
Ma
C~Lits
ta
0 .
26
t1
1
2
3
;1 0 toJ oate
ta
t t a 0. I tot hil
It then tt a cma to n
cowew
fetmnitro,
-eeoaem
oelatat h-o
teo
SetIh
.S
smf
ostsrsn
cl
eno
Oht
Its'
hida
12
~~ ~ ~treve~ ~ ~ ~
h tat
mOt atrw
ts
Liee
the
a th
2I 0 I toLa
25 that ha te
S
Ie
Sl
Yte
00
15
hIS0ca
17
2
em
it
cal
toeae
dateco
t3
15
cta
5
7
there a renneo
uas
,~ ,:o-
-1s
Listene
atM
date
Mect
e
t
sn
of
tM
Itlkt
lke
alt
-I
a
-
3260
PAG 69
ot
T le8
05 flye
it
h e
r
hater s
fthr
tn
sare
in
it
it
i t
O O X
file. non
eleae
ma.
5
6l
tl
toittat
'
a2 v
rt
11
12
it
e etit a th t
tie1
site
th
"
f-
hai
ta
1
al,
il.
nitt
15
17
m
m
18
19
N
21tse
ddine
er.
o
Ethe
he.
recalL
Kitto o-t.a
oft to
tn
Wc-7
A
a
"
tea
te a
S o
to
5I..
it
aesr rec t
Aa
tatr
at son eiti
rit
taer
tet
tm
ts
-t
1?n arce
ne
n ateth
ta teete
n et
l
.taid
thet
he aea.t.
it O lat
he
aht
the
atia
the
annet ale
so
teh
00500 he ' Jit
r Sircn he in iJa
te on
se tatiih
to
ti
na
t
set'hoe
a
mye
ihem it
cud
to atth
that esetia
at .a KA w
t3
. a oe metis
ith hia OnThat
e 0 uti. tuaLL. u
I t the
aosete
-t
A
at
tie
51.011
e
71
69I
tiE
uiir
h
ho- t
ho
IT
its
it
r.e. '2:W teth
.i in Ksitt. Mita
2
3
t
A
o
7
A
5
ii
hat --
On hne20t
Dia Ih Aic
the teeitd
te
Nhe rtatie-
o
8
lth
h A
24
the
Ad
vh
rt
tr
s.1tie
attr
slb
iat
tleti
1it
2
3
tan
No urhFor th eaa
Far th sait
As
0
A
o 0
o0
o tnt
-0a arao
I I
it
e ILL
het
DLeauthrtct ?
into
hto
tor
hct.
veit--u
di~this
i.
eth
o 0
nden
h
i
cedthut
8ye
it
8
sortI o
Fheier
n
like
20 A
att
ta
-tim
this ti
m tither
oo
at
ti
5 e
the oiL dOdli8 sii
I Inor?
o hi.
21
Kitto
to
srsitts
i7
s sIth an
tet
PGE72
c irt th n e
At ths - Lehi -i their
I id
heAa trek
attitati
2 0
adisc seo.
a t
that
the5
e ote
liit
Mere
t
*0
*
--
t t
0en.
0
a
1t
On
It
it
to
17
at
he
ti VIttS: hi set ondite t tie
into-- that nte o
1 e it
into
hIx tri.
-t
nil. PD
W.T
Y1.
12
13
t
ee
to
t
eat
h
da
S Vet. Mihotn e
mi.
ho we
i taim
t? es
heA
.-t Kitto" -netimil
IT
GB me tut
s
m
1- I.ena
M. I tIC
w.
- t
16
lef
et tM Si
re ore he
reitnmet meethes ulth Foster ta tey attn.
hatte
oa or atterr-as
done
tmifththosa
etinsthat -- tiat
tim
at day
tan
noetin utn
Faiter
16
ratountlm
ni,
aIL
7
*
sa
Let
hettonieont
',-
s
a
he her
0
A
10
I at
- atitI
coftane Iti
ntr
te
ten a n
desk ds ethen
sent Irat Introa
us sa
atl ' - KittotM
nat :inr
e
theseooe
Thn
n that at no orate h
thim Fosier Left tirst sent sae'n're.
nuen
e
I
any -ts5te
hit
5-
71
on is le
Bt
h
nstre F
it
ILd
he
a
'tC
thit
to
it
taiea insthis
on
DIW
s-
tt
I
h
to
ni--t.
trt
SM.rn
to
- t this
I
re aIu
it
5e
eh
e
ter
trt
tio
t heot
d
Oir ect
t
Matt -itsl
of h-s
LO awe Olt
lt
hiAh-aat an -- It It._
m m o rMmi
at
to
On ihe 28tn. 11otUi
hnt Ott
lin
iat
hord e
ws
ho tm
Otf Aten'
onoorit e
to taik
oNo, I din'
mCooion ~e Le-ls
ta iso
to ho
Fheier MAenit-?
hon~it TELMdIn
-IOha
ho
dais
Wal.
ainate.
direso
ho PhiITELMITCH-- hetaidet
72
Ofnih
Airtotht
3261
1a t
PAx 73
adousedo
rttehee
3
a
5
At
0
A
6
7
VhAe
02
a
A
tit
ecats
to
Fr
waettte
to
Fostar
the
th
Intc
thet
S.
Di
t th
21
At.
tt
25
Le th a
sa
that
25
ot
hto
bneres
ato
Ccctdelo
Is
"W
-e
ic mnt cf a caita
tA A
d 1o l e rete
ra
a
c feet adtd
0
Ataet
se
Daattc
ttod
t
uht
sho 20
tcore-ac
. o Fotr
b Ctar -- c
te-ott
ccIto or tcc teh S
11
nv
tere
eat
21
isc
to
21
ta
at
t
t
0c txistirs hein
Cosco dat~rd rot cc Dot
Tthe
tribe
h
7
Ad
at
te
ette.
ct
Do cc Amo
cc o
itcroc
11
tut
.rtl;
tarre
cc --
t13
an-
thecc
at
crltehi
22 caiii fccr
ar
atie
ct
ICIm
Tt
a
itDadt
t
a
It u
0
A
21
23
25
2k
d
0
19
cta
at,
cha
rtion
keam
da
d0 -tAt ehitDcDaecl
2,? ht7u
-IbbY.ef
id
ah
d ALI Ct
-
the eh
trik1t~
ctere re
M.
ITc
tar
ere
c.ra
n
24
itoe
at
it
avt.
10
fe
- e
e
WAt their
bca
taco b
m.
n
-a
ve
ctf
I.
s
t of
c-rt
e
em
-d
-LL
-Im
thretafeud?
e
i
ks:
ci.
di,
01
m-
tO
1ct
d
A
a9
into
12
3
14
trt
2 0
p-1--t.
at the
tir
A
A
0
ode
I.A
it
s
ihir
1ruit
ietoted
cos.o
,
e
tc re toi h_
asc a recetothL.
- adtm th
Dro t
im
L
ttiest
thv
ts
itroaott
- S .
o
- httacc
- -.
I-odtt W
tc
a air stact t a
to
hoeAoca
om t
ba-cc
ut
t reaL
ALL
Wr.
rlatc
ulth
00c
Tf
tt-
Dt
-1teM
L ai
KItoInkke,
1 11m t
aAtr
t csai
i
rwm e
- te
mi
tos
1.
the
aortv
I
Fwloe?
itta
24
Cosla thet ae c
hee.
1oc?
At
-e
kt.I
mr t
tls
fIoal
utitt
Zhtt'L
a-tm?
otilici
otro
PaIs
c_-.
de
c cted
ct00 to
r22
IL
trs
tMr tha
tct
o t eatte
A a
Nct
aict
to
im
aea-
t-
7t
et
atf
22
10
A
rem So cat
Ae o stf
da
aesoty
Ickes toI
if F
CaDosedc- ik
aiItinN-iot here t e Imt teot
hi
m." .to
fette
t
role
Iae
16 t t
12
-- UtO
lbbe
chetcc fet
9t
cAet,
trr
A
A
Dh
see Ihave
A--c7
15
o'
iot
tribe1
t
PAM 74
5n
IM
ror -
cu-t
m
O4 eti
sm
is
18
are
ntto
Fose
cc
Ant
to
t acafair
I0 ot
cccct 0attioccett atif the rcnootOht
da
4 hec-lbut
ccOltd a tec cc tatO teattm to tfn
trot
23
afre
tryim
taid
tee.
1thathissM
ras
Fato
cc d
thihes
34
At
et
Utt
At
cte
ct.i
ct ot he
to
7 do
cc dIL
-sAm
Da. -t
teiL
Ic to
theist triba thee cc
dCat
thet cte
Da at a c-oe cdiro at
atm
1att e
Dth At
rette
t1
ta
to
tati
Ao
inot
oth Coa
c-raita
tim
Ft . atte
00 taib to canoe, i
Ietie
is.
is
.
tiri
e5
1A
ODtote
c otc, Oat
de c
Ye
tht
da.
artcu~
t thet
oat
a~ thet tts
i dct
s t
th
old l otcc
eo
bt
h
010
h.
i
-- 55 h had Attie
ccdae lb thet tied
13
1e
-oudrecttyc
F-se
date'
ticutr
diel
to
te
-5
PA
25
orcoah e fr
t t
mIne
d
76
tr
e
t
h
it
to
ar
v
At ttf
3262
77 SHEET 2d
P700
000 a 001L,080vat
A
1
1
2
Lea
e11ti
0
0ck
00
l0
c-
,I 0
00,0
fotw-tm
G. 1L001 to
ALLrt00t.
u0n0c~s
a
to
28
On t
toe
an t a
If that -no-vo
-ith c0.
ite a Wlth0
tim ove at toe.1I-,0t 10- d At otirelY a to at
do
to
a 0
a Wt
"l
t'c
k
5na
toot
Mea.
.ettL
mast0
We LL
writ
-e
.:
to
weato
at
a7110
afe
onvoteto aloft
01t00
-w00 70 s
He
ad 0u0
10
it
of
000 t
too 0t0m
my0
19001A teo Y
01. -L.c0es00
0
at
000 00
uith
0r0s 0
af
At
20
.eoI0MAffaIr?
W
I 0000 t00y 007c
that 0
0 Iro t0 0ite
0
20
h
kh at thos 101 .
1that tIr
s00 of 1
77
24
25
ofl 22
loot
I am
e oLd tar. -,T0 at 23
24
0
c7
te a e v0
tt0 000
1s1
.to
t
78
80
PE
1
2
4
A
7
of t
se
t"ir
fCwse.
0de0r70 sl00
of too
Ism,
th te - that at receive0 rotatl
07TY o
e -e
rats.
0
011 that t0 k1tatls
re
-is
at
to 1
rdti
the
istM
Leu0t
000d000
that10
slt.
Wro alto
in
-ae
moran.
m1os
i
0D
la 000in IJut
u00t
s0 o
tattoo
0000
maih
0
tot
00 usistant.
100offtoce 5o I -0011tteaoice.
7L. 0 0 74 ever
ha
e 1o
Z tuaLLY 0
t attn
t0
m)1t?
t0
000
m
tn his oLic
cattM
A 0
at
- d Oa
-MateLY -m t10
10 PRotLWITtt
Or c000t.
T tchse
70 mm0
e
11
talk to?
11
A
1
0,0 70e -111
0f t(m
m
t.
12
0
OldI 0
0 t
kaof
07 0
trk
807 012
VA:
Tata
to. y0.
13
0A
1 7 00(7t
thi00
I 0000
is
n0
-- 13
at10 A
thotwoor ts
00. 0c0e it
000v0 dis
u
ath
14
that i rote that Letter I e cetainoonfrotoon
14
t
ssm
15
that 000010lv toink
t ttot tsm.
-0I recL
15
Q
M7 ooe
v
-1uatt
oCleto uoth
16
n t-letter
ae
_re e to t00 1001that e00 16
001
s Dr 0
at 00
1 0 -.
t hat tm
ot
17
00s7
wer000t0 th
00letter
17
Thats
lect
It 8
0 010wr 70 01 toolsmt
800t0 01 t00
of00
t8
0 t00 DiOt
cm
I-e
.Olate oatt ih tim
h
10
AmIL 20 0etim 00 0
10 Jot 0re
of Wo 000
19
10
1
to talk
to 100010
Ik
- 1
tai?
oWhrs aere
M A 0
21
A
WLL,v
te AL20 -cto
h
La
t 0017 0
M1
0
kar
o
Stim I hWe. 0s t-0
a
22
orton
0870
ofoo
I
late0tLetter. . I -0d
t2
f
liti1
Tm Crc- .
0000
It To
23
saye. that I -- 000ause
1en I ored 0n areftioo
t3
Co-at
relate0
to Tomy
The00 Crk Coor
10
toIn
Ar in
aid
MKluat
to
o,
2S
~t1I
00
r4tatt
ter
2500OrthO WI
0a certain
000
do ttM
Infoadtemh
0000o000
o
00
1
NO000
t
t-t
trnms
so
k1,m
Imodaty
000 000 0t
7in
.t
to0
A
5
ArtL 28
3263
-
1 8SHE 21
2I
0A
YeI
00113
ottt-oto
SA
o
10
11
t
A0
500_
- CoYIfOtY
LI
C -m
00.o
reotlictI 0C 000
n
ent
tY 005
12
03
tI
A
A
My
tO t
.
Co-
15
tOut
16
I
'te
07A
18
23
Q Did
A
0
i
2 Alth 00
10l0
of.
t
otendl.
Is- to 0
o -i t a de itt .
toe
tOt
5
to 0
it
l did t
ye
' r ollever
no-- bt
--
to
yhmD
00
in
Y4
1.
vet
I6
fILLY
00100*
-ei
th
0 Dresen
Ietoet
the
bye been
t
o I
0YuT else
ICoYt
Itlcoventso
a1t
else
mA
1.'e
tM
alit
resent, m10A
y else 00tt
Thes
Free
Ma
oasAitt
00
re.
.t
00y010
eor
19
22
21
to
22
23
21
ult
tM
th
.
e
I
25
a ce
oa
I
se
d
I0rmto
the
In
DICK to
n.te-
s
oe of
it
Yes
relates to
10n
to
10 e
senatwr
11.0
er
1il. Yet trcal. CEO
of
of ti0 e n-a my s-sms
,ne
02 1e
a t
eae
0
semtitA
tt
17
t ey.
It
I 0y
xatLt8 0000 FeI
000 t
YOU
t YO recall
etAt
-fr
507
11
A2
00
To-
lei
I0
Zt
tor
tCt
tnYO
0
r 0 000cr at ten 0
kmt bt 00.
0 m? ow
it
It
It. dm t _t t
21AOrf0te. I ,e0t 0 0
.01t
in wet
a
I et r11.0 If l.
-- 1f
e1
,a
100 0t
0t00
my0
tI I
0o1
bt
it.
I 7 to
A to,
to
t7
50
o
. a n
ic
_
010 0_
In
201
an ,
tY
center'
Y
olt 1ckn..
a 0 tat. n Ost Ic0s ats reLate to
d
cos?
Ct
to
t:
lToar 'tx
Co-' AOe fri000
0 Moscatern
I um toOx
Tatn
Eotlo
.ir
.t
tI
aT
Ye
83
-P
01
64
1 1
...
mythe
toe
01 Is-n
actor
it
S
2
0
IA
stt
I:
0tto
totte
r
es
Act
l . IA 00
Otted
YO tote
I 0000
t t tL
. to
re. Io
2 0 Lto of
0 tot
-1Y
I 1t
0e C t ine -
A
nol
IS
1
I9
22
321
tol
0-
r0r
oy8
21
00
f02
one
s.
A 0,
cesotcfiat
Fl
te
I0
We
te
-ut
, rmef-
ti
re
to
13
14
Oel ntt
a mett
Ick-
tr
lo
ba
that
oa
ttot
t
--
1,
a-
7,
i dIt
25
fat
n ,.
Mn
ofI
u
tu
thIm.
nL
itL
a m
tin e
the
st
tay
fr:m
--
1s
li
17
tao
20
21
19
Le
After
it
eo .ee
mtp-at27
o r
t
-. t ec
1t
aIit
rct
ui
oa ooto.O
nd I'
Y.
--
itat
ta
At t
ILf
reaL1-1to
27
WI
C- I
In
It
trie
ef
at t
iatetYOafter
Kto
te ti
1i ttat Ivol
oe
L0 Lt
of~ tet tot
Let
lt
Itrel
l00
18
151
01 t
too
leet 000
Ye-
M-te
0
1A
YO_ti
id 'M
_=1A0c11r t01515
S did
t h
lft
E Usbit
oet
o
did t-se e
ts Iu=
line Cath
to
lte
ol
rn
IS
tt
5
1.
is
t
Ite""
i?
ng on L 24 n
te
of1
da
-tt
23
21
e in
2s
I km
0 -.-
to
0it 0-- o If
DteLe tha
ate
0 t
redottO -
tcrt
mi0
tr
na
th
3264
PAGE87
05 SHEET22
PAGE
A
ALLright
2
dsn-ista
-5 wre fi n
pertids the first aesil
3
or Sossotis at that w015105, the 27th?
o
Fouter Wason -The
A
0
The 2th.
&
etieve I was In
SoILL oe to see gae I uM
A
7
0
owA.I cmtt recaLL -othe
I oiteced mle
,sW-'a.
ta
a
it'
plInd
ite oCt50r 00 lt
S tot
CaL
A
Listed here. and than I Catted Corcoran 10
11
district.
n
o
A -- a then a Catt to Kito
12
13
t
A This aito be the day after?
0
15
Dar Defore.
0
t8
Dar Defore
A
A
17
that
1TV.
PENTELO;t3c':That's aSssiIng
1: 0
that catendar is for that day uhich --
1 A
0
2
3
4
5
A
Aith
Metino
1
15
t6
17
1,
t1
20
21
22
vd ot
24
25
I -o
18
.
a-a
were dis
lih
the
ere
23
24
25
7PAGE86
0 Ar.
f , K
0'Connor.I
Itto'S
inviteota
attention to
ntiin
asi PgfEOVi~TC
rt
mhy Cool ragM
You
"h
of thatsatiresits
Do
resener
my Oiscussion
Kitto?
Tr'.
of 55. 00o3.
neeayrecoLLection
ont
No
to ReeLect.'
"sdrCmitte
1i5 aLL
this
and we 00 dscuss -- Ad
KittoIth Terry ftouLiff
we diddisc-5
thats inhirS Later a
87
PAGE8
Reeect.
1
contributions
to the Coaittee to
2
0
That was gith
Later on?
3
A
Sem
That's-- it'LLCta
SO ha.
a4 hea
0
Didfa also discuss 25
at 51.5 eMh for the
5
President. 19. 20 in Junec
he
thauat
6
151ASILELWAITCHFor Therecord-7 A No. That isKits's hate'not sihe.
8 0
That 5 rignt.but -A And roUre askinam if I recall talking to Kitto
ate 10
this?
11
5
Yes.
12 A
I talkc
to Kitto its Tarry
5ALilff
M
13
RttiM -- a Kittous
if he cagLd cm s
1
51,000 a Dersn. that this
hordm
r: And
15
recallLhatKittosaid. Now
i 'a talking aout the
16
eetinaWith Terry icAutiff. whichMas notat the
17
w.ItIwMinthe offices of Tm Culetittee
to
tI
Reelect.
19
0
No. when
saythe Coriittee to Reelect.uld
20
that include
both the ClintonlGore ornary '96
A
No An I dont have MY recoLLection anyr
in
21
committee
a the CL.ntonsGore
'96cmittee?
deCiMseo
gith
at the BIt as to M 1st5.
22 A
Sem itsthe mse thiM
Noc. Ion't
recaLL
diaissiMa
c-ts.
23
0
~ ToctaLk Mot
tOGIi
tteeto Reetect. I ktm
0 'oucant recall dissIsino 550.0
to
the D1N With
24
thinking
of 1972and CREEP. Itdoesn't
auaty hwav
Larry Kilto an Friday. noy 5 of 1995'
25
the sme nase. does
06
88
notes
Moati
MA
ftAUliff
MosLe
f-raise.
mT-Z0
uhates
9
mc
At
hes.
M-e
with
wrons
21
22
23
24
25
tr.,
it
20
21
22
I
000
so
A Ite in he wMtr
I hoe
sr
a ole
vo
Aent a then I
t oret
Do-es5
'The President. arise Lisosey. WOLOo
Footer. interior'. seMIs - 50 ONC- Larry it1tC
Mn then DeLou I hae "Comittee to ReeLecI
ITem-"1o Coited is thltI
i cAdt hse styreCO Iectio s to -t that 50
aMY
rag
sots
it?
3265
Ann J.oeo* *
Exhibit 9
To:
Brady WiLliamson
Enclosed piease fnd a letter to Ickes. which is all the written material that
may be floating around the White House that we know about. The meeting
mentioned at the end of the letter has not yet occurred, but we are told by
Tom Corcoran, O'Connor and Hannan, that a letter from several of the
Minnesota congressmen will be sent to Ickes tomorrow requesting a meeting.
As for the meeting in the Twin Cities where O'Connor is alleged to have
huddled with Clinton on Hudson. Corcoran tells us that O'Connor began to
launch into the matter and Clinton called Lindsay over to script the story and
operationalize a response or resolution. He apparently was the one who
decided it was a problem Ickes would/could/should take care of. Another
partner in the O'Connor and Hannan fim, Tom Schneider, allegedly an FOB
who socializes with Bill and Hillary, has confirmed in a casual conversation
with Clinton that Clinton is aware of the Hudson dog track issue.
By the way, representation of the facts is inaccurate in this letter. I guess I
wculd not say Thompson supports this project because he has not publicly
made that statement (far from it). Delaware North does not own St. Croix
Meadows- It owns the Kaukauna track and holds a second mortgage on
Wisconsin Dells Racing. The connector to St. Croix Meadows is Tom Diehl,
who will have a 1.99% share in the Four Feathers project (that's the casino at
Hudson) and who owns the Dells track We also know that Obey. Gunderson,
Roth and Barrett are opposed to the Hudson-Four Feathers project. Kohl,
IGezcka, and Klug have recently affirmed their neutrality.
Manchester
P4'ice
Phone 603-251.0702
,Madison,
Wisconsin 33703
FAX 60S 251.0704
3266
Exhibit 10
OQCONNOR & NANN, L.L.?.
Attorneys at Law
700 Baker Building
706 2nd Avenue South
Minneapolis, MN 55402
(612) 341-3800
FAX (612) 343-1256
coVR, wals
Tw.weOMnnICarrO
PLEASE DELIVER THE FOLLOWING PAGE(S)
NAME:
Pat O'Connor
FAX NUMBER:
871-5449
FROM:
Mary Jo
April 23,
TO:
7
1997
PLEASE
CALL BACK AS
SOON AS
Transmission Ended:
OC 000050
3267
Exhibit I I
TO:
FRONL
)oao WkC(aky
RE.
Met
EArrys Offi.Sc
Scm
ApW 21L99S
DATS.
ceate
i b vy awana
Thm
o u pdb.
roo
auky~lI 3S71
~L2l
77
Y.
oAIM
MO
Me YOUa AUl bA-o PUdaY.
RtL J. "mC-
Lk4JfNS 366
g.~lhl~flUI~l DC 3245324
3268
Minnesota
1995
III.
Exhibit 12
April 24
page 2
)00109
3269
Fowler assured
project are Republican.
the people for this
the group that he would take this issue up with high ranking
officials in the White House and,
minnesota Legislative Update 117
April 24 - 26,
1995
page 3
K9000110
3270
TAYLCI.
15VI
balldt d a d ness.
ba-hfirst a-ty 5dr
ose.
ca
them
taeroath a f~em
in
so vAh
Let
da
Exhibit 13
17. 19
CM
ST COIx COJatT
-
COT
STATEP ISCONSIN CIRCUIT
.------------------
A,.
ha
the
btdt tis
nIhdicate
Wrat
isetalateiho
a o
to
tmo
ttit
ttins
co
beth
teueinay oh Leis Taylor entarea
I art
be
ter.
taa
Lt
Cadnifs.
Ca
PC1H
ga
W iP
ihecatea Tharor
ion
1m.
bar16.
a to a
- st
-i ie
to
is ra
said, did. observed hero others sal
W.TAYLor
that
in aetirat or actuo
Lead
otoih
or
toeolaDaecefutide internal oraeeines,
oh
tio
tra
intrL
o
mai
Intai
A ordceedinh. metiso
the St cr-ox triad
CV-til
lNoi~ti.
-------
---
OPOMITIM
apbTlAO
TAYOO
LEWlS
T . we17. 1eS
, ot
15 Attacrena
to
third drtIes
ad Invodyn
icatdty to awtor astsioh
Oh the State o
a-ta
iired Into at the hirs
a t cltile
meti
trto
acino
rahetiai le
t
orTartor is a
ttis
a-tso
e
-usnthat
a is atheh
isetim K. MCrItta
58
-PAGE4
PAC 2
nt
3
I
ii
Oulh0
&SS
STE-IS.
S.C.. 2 Ent
by dolM
mitin
Stret.
iR
VA .
5pae.
ridso. Visttiem
12
naat?ori the PLairitiffs.
137
MiiaOus.
Cee.
C. dea tedar
10S5 O6
14
orim a
e.
'J
ta 5 O412s by
Mii
IS
behalf ori the Oefftld l
16
207, srted.
I L, P.0
St C11x
1'
S5 . by
A J BIj . e On
10
di
mir
HIB1
bx
lLl
Ultlsa
Talr
tata e
VowL~ant
L ISTe 1tr.
-.
All strt
3
-tilit
7A
0
o
Pintioffs
9 A
re
rio
Intntion fro
71
i3
mo
sl
have o
14
19
24
rtiL
iao tsa
23
Mcwd.
It
4
rmTb i sory.
Maclima Avars
Thr Va
tfit
iusee
1T
to
in
nts
by
hJ
tr
res
1f
Mod
t
JlletoSJI.
IM)233-01.
un
tt
to
fr
to
Joed iF
dL
sti
C
et
if I cm aDte 5
-rst
I
t
I
.
.1-
ntta&Lands9t.
sr:,I
Ioie
aceoa
iat
Snts.
57
E-VIMD
uistm
t-
yoet
his
teMrecord
eass fr
Ilel,
is
16
17
221
23
25
to
ret
o th aa7
i
cS ntc
he Bi l That
st th y. tson
record, e
it
. Ad
chts
15
rna W
Box 55.
o
s
Ave . S-
M ulIttS
asoh
VA5
11
Madt2riso
oji
5ae
his trib
to
3271
P
-PiJ
Is
1testiln
2
mA Jtal
tesiny
SA:
LL7
I i In my by
A
-P-7.
he
to
LL.
In
A
12
A
if
Aol
I nt as
-et e
m
eAf
tis-- bet
. tA
s.
A A
Iheicate seat the cLata Alfhiv ae ALt 100
0
to
al
the
trIbe
12
ti
tieIt
IA the Ietb
tle
heIr esily
bits
tI.IA
ts Al
tier
t
t cA t?
Is
that
13
An A All It te-iLLIo
5b
12
even
luatty
smreenir
10
I-t
remof
Tiet l. Ld s
been after th t
Allaire
a
it
5A
I IIthe It um
-t
I0e
in
Wi to
tt
eet
J.L of19
ltltcmrt really recall
13
iti
dM
t_ilt 1um
Iat-t2
re
ult
Miev
itm
teatt
imi
he
Act'si"
l
br
95l
Ore Arier
thee
tAut
to
ia
um
Afore
heelts
At Athe
ta
liel
Im
h~dt
dbeat
fr
the rhd And
17
An VdMA may. A at leat
bet ams te~I.
-t
CA
lits
n. Bl
I5
16
IA
i
w
21
has mi
1s
tell
An
th
24 re ralAAeein
thatO
atit
taLL of 199
th
Anlevet
be
th
inia
on
I
PAG 6
no
8a
Int
WeLL. i
Ae
itr
lm
il
aA
eti l
li
Anm
edd
the state l
of
h)euat
tM
2
3
to
the
A thy
be l WelintL tb.
to
at
fo
AP,
tbtM
ta
-I 0db
1 12 tAte
to
bI
uhei
I cah
ea
a
bI.
- at
A.te
in5M~n
121
13
14
17
at
18I
D
I:
Iw
ou
se
c'if
I
O r
is
ai
I
I tI
Ice?
I n
.1n
Uc
In
or
-ti
tim
la
S
s'
Of
1,%9
~rAn
iA
of
Ia
tI n
r
tti
all
IMu
D
9
9t
A
A
of
I-l
oLd
=.
. t
thatvemy
3 f
Oen
op
I
tm
n,
naea.
fht
t
to
11after
o of
r-
l 19.
the t
lhv t
bi
.. l.t..
_='to
01.
A
ASt
he
" ii
AnlebtO
ASt
oit
a wreut~
~~IfIdb
MBA
I Onia
-- n
vatim
lt
emie
eL?
sb
17
ist
a e.et
.m
amOff
an
QTr
aLL
a
a_
at
/t.
O,=
isn
ti
It-at
tof
m
Ie
-t
Mi
cis
21
a
.
24
tob
atie ii-Al
Stat
rabc
the
of
At
i
att
70Da
m
m att.a my t
betAtin
he
t~li~r'
tAtnd
IAWel
Iaint
t aAt5eba
IA
ttit
me il
heir tal
9l.
It.
it
senbrat
toben
-dtiAren
A Lt-
Al_IIG
.t t
try to
ihe
DiC An
mAn
eridl
tbete
r ofh
in oa ius,eto
--
tea
al
ryA
"'M
-ai
aihti
.
fle
be"asb
Ao
me.1l1
Ar
th
wite1 . totM
t ri
16
18
I-rcL t.a
Iamificatt
ma
17bl~tonbr
A
Il.
14
antities
vArlm
Wdan
24
An
-ay
to
-a
tlea7
tAn
aitnt a, of ti olin
a TayL-.
tf the ta-Abe
A
--
be
be
bembt
it ' I
-l
re"bLY
cmt tty
si e A e ti
ati.
sn
fAy
-
tn7
t ofa l
Le
3272
ica
tmt
100 Asrlt r5cen
1
2
6
7
st
aits 0wt
la'ists
2
9
3
St
oltr
in
utinsit
A
A
14
Mat
i,
1
A
A
17
1A
A
190 A
A
I
Aner tt
it
astian
ou
t.
at
ulo
t.1
Itr
,t
at
lto
t
A
2 A
12 5A1 no acmstir. It
try
IS A trior IA the
17
amer 2itee.
A
IA
myasti,
eote r
21
81A It
'9.
vatioo
man
mL
aru
Wuit2B. 195.
te?
2
--
IA
meetir.
at thle
e00
le
t File CaSitte. AiA
tis
il
ste
mtyiNAti
L
I
arati
atitc
lt
IA F
eti
54
1A.
Do A
i realty
cmrt
recAlt.
Oat' Al
Larist AiA
PAE 10
01
_et
Ia
is
11
12
13
DIA
Di
A
m-
i3
ilo .l.
oet
at
I-
1.1o smolM
m
s Iat us ret fr
my
tri
. ft
for Doomic ayeicmst Aroiltl
ofother
trAt 000isiti10.
-se
a.
Cs.
l00Ma
It
rF
In 100S- 1h r
wo
IA
ctDeor
A
A
A
18
22
1
16
21
22
24 0
00
mims
rt
Aenwe
1--15.lt
lntertribl~l.5
li a t .
0.13 I-SAnfast
Do00ceai
1
-4
eret54e
mtilo,
srs
vriAVI
ii9
2A
matty11
21fr
everythems
22
MFAA
In
25
tim?
.
C "rr
e at
etim
t11.t
it C 54 mit
ASSA DeltAt.4rea
man
rm Ar
mo
020t0
54 Am.
Isre
5Bl13:
Amsl~ti
lie
i 1U e
13
recaLL
at
I lst Ao
a t
rAA T3
- T
4 AU
A.0 crm A attend
11
17
12
19
fandd
21t
-1te
c
1
at t1.
lA '
A Iyo noe at a Fi-State Intertrlbal
-511.
acton. F
SateAmlLY
15A I -A A to that
a.
0
A
11m
4
Aloe
atre,
to
MAJIt
to t11SF
000
Aoe reAonve 51
AeA51
1 ta in
051 1e
Sa1 e o
.
"ction.
0
00 Am
rf10
1t0 00 ti.0
Um
0r
DCrs I tat
til
A tlI
21 astir
av
tA OsstrticA
I cm0 rsostti
A
Acit. tet s0 t 1
tA 15
W ld
asmtir.
t40Sc 05.
t AisoAat loll
0n00
-
Mao.
Mt
n mi-ave W
yFtim
Ast
frm
tr.5
at
tMe
54 ltt
riot
ra
Iv
reatsim
t
Oatisi
Aas
Mrt
Atoe
sitlmt
lr1
c
wtn
son11en
twA 5
12 emactAro
Tt tribat
1niin
90t
tMt IOat
At it
effectt t 101 F10
riotiti
IA
A
t1.1
have
cA
Sk1bine
Al
it
i5
IA?
an-lns,
intrat,
Ts is 11
As I at At Ibn m I .Lieve
..
'0 .
ti
at
at ull
dia
in 0
De,I cat rtaLL tmar. I -s I -t li
b,
mnio
I 5Ll
1.1 .m In
f
'9.
I at
itea
ite
it- 1c at
Oc1 lit?
4511. I
I-t
fW
21
ao
A
a
AA
t0
mtta
irett
A
A
adid
Itn
f
I
AlA 0
A
M5
-t
sio!t
DoFA re
1 t0S
aetlis
net
In 1954
l t p a tble .
-t
-.A
I't
FAou ma0 Alve
DAilt
A ssioLe tAt
IA -A1
cmia
ort.
it
551 iAat
ac
raste
w e. 220 r Id1 msint rscAee a lise
A
7
knns
..
15
I1
A -- Wil
1- I
At.
A
.310000
00.c5
lts's
aImlas tar i7
Ai tey mist In rar.1l
a
g21id
It
17
c e 31 of
t
0
cir
11
12
I a ALie to 55t5 e astir. In Imteve
Everti
i2
A
tasoLayismAt1y0diA.A13
fcr15
lami
i A
13
Ir,10hA
5A
A
Ell,0
i'154"31
A
IS
ol
trtos'
A
i.
511 i11t
5 Ae
m __
O"es
mBICt.:
A
A
A
00
ot tt
rslecstti
ty
at40
alre~atto
LAC
h
muith
ilm A
Ao
it
3273
13
PM
raofed Ra
OavOntyL 'lntme
RIcOtei
TO
|2
3
4
S
S
read
O
O
cratit
itself
teo
If
a eno
The
ita1
T
Sole
ie
So
th t
tha
cmver0
Did
1.
RT to TteTen
3
O
lA
bet
sOOT
100
like -a111 To
The
I need
to
n ,
I
on t thi
In tOt
00ra. 6 Tir 0
mas0
00
O
Oi.
I W
I In Inl
tut oer ti
atlcO
ite
me-
TneraL5
11to
wlr
0Cott
o0
ITt 5e0 Ae
Those
TO
0
ST
this hetIho on O r. 28'
-- CoiTTe
Lsate LIST of 01 tim0
O
otteied en I D Line OIL Tee
Yuoe
I
TO o
unT
InaTd 0r 11a1 O 01
1
re
-- t
e
1o ILLs
t
eotservice
t
rai
,
f7
1
naim_1
if Tm ie at
eATh SMOf'ROO Te
12
-Like to e at
leOie
e
us- - t 13
tonsa
13
o
mn .ra
T
. T.O loIO
eJT TO TM
I ak
114 eT
OR 105
- r of Is
.s tha
.. u ed -to
14
is
tne
15
The 0uesTomlne ecaeds The acopof O Tme courTs
16
I I1.
I k
id Cae wIze iI
that
.Tl
1
POLE1nt4
dT
17
ad sLl
t
I leOLIkeVeT
TI T
17
tri
ISe F 1r1 IhaT 1did f
Tay
18
I
-1a neea can
19
1 Its fri , a
oml
T
CTO
l
I
f1
9
i
21
tet
21
0
-- kL
1C- .TO
~~ ~ ~ ~
11
at
of1
If
ml
a
24
23
Oh
Ceaily
of i
eth
rit
TO ST o
18
fTtM leT
in~
1.
SPAG
ed to
-1-ve
Oh 1000s0To
my
0011
we
e-
aotT
10t
oo.
)t
im
e
Il
in
tot
=
7
t71. 1
9t
think
1I
cae-I
edit
Iito'
tan, sto amm
to
t
1Svit TeToet TM h
o I.:to."oi
-tn
toklMe of
a
disc
In
re erin
left
tI
1att
-mt
tr
eL
t,
l tt
It5
aa
1 Like to
-i
ht
T-te
17atic,
a
21
22
18
relte
I
Gant
WettI,
testk
to
I It
it
aI in
a
at M
mti
WiLM. IM.
NatimnL Fine
lee.
-W~
-1
-e
-t
seat
-all
Matt
at
-Im
-tLat.
-tin
I
L
-LL. nea.
ii ek,00t
am
t1
a t
te
a
59
frien
St
M
t
L
t-t
11rIM
t?
0m
11
~
0O.
alI-It
tM
ca
TOa nM
did
DL e
tm
1n
CCit
t n a.I io,
ooe
odO
00.1
0on1 01
frIefo
5 0
16
F"n,
13
.
e0IO
ut
12
15
To S
as
0 I TO- 00
0 atll
e
R tTs
T
TOerw
I t
It'5 a Lot
f-t
e.
oe
a
TM eSI? IM5
fs a
002 TO
23
on ee
olx1
15
16
17
A
0
A
0
A
t-- us
ae
Oet into
-0
siti
0e
at1a1That
1-1
T
ld O
Latists
orTi lote -No
Q-- In Thisdilolsi ?
ft
T O 0 0atdid W. FtLe 50 in
r d
to
stiRIt
a
ati0
To
TM t tic
Naditl
21
FIo
e
e as
le
22
A
A lOT00
eye TrlOte.
m0
U.0
TT.
-t be
01 0
t00didas Cole
say ih Orle
to er
05
Soetimthao T ato timT
oolo
ho
5Ioae
18A
raty
two
mitta m01
3274
p
17 S55
ne1.10t~
01
ha
teev tnat
atia
na .ventoi
A Acre noo relat!
O
e Fooler 00 scof
to
th
Iet
onit
Tht
Di0cr
otoot
th
meatif
0
m:
the
am
I
tt
to
tenoo else tn o Ot
Foote te
tmt
to ae c thats a tenet' on no orM
Affairs o0
Unite icoe o tMt au-c of tIMI.
t
de
Secretry ealtt en hay
I -ut ta t recall.
Fo
er toot
to
tthm
DI. W Kittt sen
tt
13
i5
A
0
A
17
o
o
t0
11
A
0
12
it
it
21
2
2
ains
5
-tt
t
mt.
t aTDhaict t
I tnih-6
that 7 etnn
effect
tnt
t umthh to
U hae Fooler sad
tcmf5uL.
etanas
hat
tanre
04
hte
t ccotri
hai F
ntha
trI'I"e
o
o
s
FTo ec I hat
ha B10. I etevetnat -ton
le
t.
to
in
h,
coo
t
n
t
eda
11
at ha cootd a oit T
to no
0o en Foole coat
tm
tn,
cm
a
Y_
12
rahact to tnt c4ha
I
tht
nrc
U
I mi
t3
rcieeae
T4
a
Dtd To mot. ha or
1I oat
- . resel -J t
5a
witn
met
was
ms~t
Ten the--
To
"If
T hty
hat c--atIn C-Ntr-i.on ut
Ktto tt
Did
W. FoLer
A
t that I rehaLL
etn
tri .. s c
t at tlat
a
ce tn o ty ot
tote taso
crt
cones
to t 28th'
noure refni
ta B,
Tee
22haAsA
ha
th
Th matiha To ri;
2t
ha 01 .0
Y"
SM
VA"
ha. VoAt net
1m
I cent t""a fr
A Ye,.I tnk thny ae
A
15
semven
16 0
acne-ot
17
!a
emtn ha tt
t To non
en Fote a
t8
saeatot
to ha wtth rocet to th
o
-tt
1
It
tt t
r
A
I~
e
ate th
16L
00
eter o ha atnin oith rect
3 0 Did .oe.
21
To TeMtaoh enoat?
Ut T1
it
tet
aee ta
a
t'
tt.
UA
03
W
tnt a ontO
nt to en. Fooe athln
DAdla
0
25
Oh to ulth react tU TtMtamh eoasat?
Dt
eo
74
A7
PH3
18
6
7
3
a
1
it
U
o
0
to
5e
awe;d;.
A
,M ent
im crtat
cto
d;
dintatereiha
tootM
Unt tin
t
nta Ocw
nsct.o
t Lac
- i atTnhe
OtAa e
t tictntanin
t she aid
ha d
tc us
to th
intot te f
ett
to
8
to1
to
0n
D- Wta.
Fat conantn
I ol ttn clL
oh
at
a
wtnhe
l
en
Ac mtM
tete
te I
it
.
tot
oter
to
-ist a a-n
In
e
13
resa
141
Iarne;Ta 5
meatot t
eo
0
A
15
O10n
N22A
to
r
tat t tn
Ira
i
ofanL temt.
i tteo
reca
tira
tro
DI of
noon
e ee in
A of
or
smst
stt
t.
n
di
tt to rn en Footerin
tet
mr
ae
rLL
BLL
In
t'
22
23
04
trite
--
r1aLL.
reset
coneat
1f A i tecti ha
DId f
I -S
-.aL
o's
- 1noa
21
O5
WLt. 02 ot
U -- 0
that t!
a
i 0 ! rett
itr
T7 0 1sIt
f rentt
10
20
160 A
in
1f
61
th .
J rattyn-- thas
o
thih
I -oer
hve
is
o for
t trit. t
cm t -ALL.noo a
ren att
-etir
of tL a.
4 A 0t. Crotx000 Ia t e oject tt Its
h nistrn
t I chveed
that to o. tn
atten.
cen.
t.
man
h rota
o
=oe
ty o
t ot
co
ot a cmim
hes In a
o a Uamten tat trite
atteratne act
eu-il 20
it
mueihof tnt
to rettc NaetimaltFin
eoChit ta
old
im tnL t
e
to th
a
r
eat?
f
7iL'creo
1
wet te rathrn trtte
2
mya
et thea
thy 1l .
.t
at.
trie
t n
aT tht
,
I _
Ace ten cacttm
F t
e --
at.
fiat
etim.
Tt anLtr
ahoo
at
I Tleato
t
at
cooti
nnot?
cc that.
eta
--
tail.
at,
tram
trat
ai
nt
LYIn
to
diettn
Ac
of
the
3275
-
Pdo21
2
3
o
5
A
0
A
n
to
mits
13
15
A
0
0
5
9
25
mo
t,
uni
tO Soaotalat
~to
-PAG
0
Doctltae t-er
myt I-010
e
t
=ra
1 te I dia
-m
D
e tw.tf.mcau
.
taiso
reet
to t
D
2
A
0
1
I1
00
O- 1on.en
Il
0I
to a nir
Dott
ot
to otte loose
too,
:2
:eIt
of
It
Foters
i0e
ol
It
1001
~ ~ ~
TS
Do too rI M.l
t t
6.0st .....
Per
aItdeL
d ifa
It
r5t
R I
DILL.
-
at
hm,a
L
tto
3
22
0
A
That
cm
er
25
6
0
5 17 l 0
23
,ca
A
20 0
19
It to adalc
10 OtoA I nttm 0 c ns Tetlerto
Ie
t t
I
att tCa
In
23
25
f
f
I
11e1f
didW
171
21
trlo
%
20
5lIcto-ot
aiseo
at
WIeL. I olim
t0M
lth sely
5 0 alaa sareatr
2A
23
st
0.
Itoltoe
acme
office.
24
TM
ecer
ltetle
fxta
I
Ive
-a
hi
Lett
1a
m-diai
utt
01
Pratt
to
la~rr
11
-to
tn
t
at
on1e
my
PiG 22
25
A
s
23
20
10
10
th
nto
7
atfrol R
veo
Do
to-
sistn
00o0
n
to Coomtel
totstrate
nOtact
21
1
I
lItte
t
2
3
S
5see It on hove
Let
tO SltRl
Ohottetzatrand
coat
Tut1
1i
15
117
It
lorget
2
3
-tmtat
-to
-y -,
-- m
tttInot fo
a LmLte
12
Intt tetl
t atmtthem
s teltotISta
00 totnm
re ? tettu that to
1t 0l ler Inst
,
I
nte3
ne attenot
Tot
I1
1t122
Tt s
11
A.
VZ'
ynn
o
f*I
16
to rawno-ethat tlett
1 that t1-I -t.Yt I
0 In
17lAorectL
this letter'
Yerr ite
Yes
1B 0
-- 28 et5im?
t9
A
Is tht
t
too
ke
tats t
t1 I
tn
1t
5 ctoo isnc
hI5letter'
0 Do
cD lm
ditolO'ln
tt
0 oificat
t
ot7
he
Ftto7?
tIt
0lth
01i1m
t15
tcnrrbott
22
ohnDcmtinaor ItatCart
c
tna
_
c.
I nt
Ja
A
N1
tetlt
to tlra
emean
toI aJeot 10 Int
away o-to
oed NO
att
eY. st
l I
ale
to
t
Legatl
m. e t
mts e setle eonr
78
7a
10
12
PMl 23
m
Did
ofI
w mm
tors
VoAoCtan
IreaLLYt
1.1 a -
I
recatt.
-ItsLte E..-i
Lete.
EIto
pr- tt
0:0
Youe axmustMe
1tt Wth
-1
1.
r - 1
ADidI
erier
W. I v
-t-
th
t~t
Of
23.un
23.a
tIs
Lette
tGMaoel.mMI
uldt
Mto
Don
3276
PolE25
oo
y_
If
tere
A
O0
rta
7
o
0I
5
aft
270l10 t?0
t.
1,
I1
Did h
ever he
a ntmity
0 , aet
to
_ a
tht
If tht's It. ro
No.
tes s refaremhe Inhre.
FWe
oe, avinto that hI
A
0
12
15
07
tO
19
W
21
do
23
24
A
0
h
A
o
O 0
. Icte?
.2
FIr
A
tO 0
0no ould
t
Oe?
t~
o ter
ho
WrTt0S
tO
OtLtth et
E.m
fOE0
for he'
Ile
S-oa-n-ae-tOhWTESS
other
00
is
It usfI
ha talked
hr 1000 hat.
elo
Itth
.. :1,1=
7
Ohio mtIo d
I
oe 05. -ereOf
Cobabe
chtrl tinah that
In flt
CLLectedt
to the DCa ratic NatlmaL
28
Ien
No. Ia 000
Old hea
Me o
0
a1keamrt
Yes,
op.
2
U .
We
h1
-nret
In -That' 5ere
W o.
t
0 WeIt.
Let's talk tout the colaltes
1
Wrot, talki n t
OL c
at
7
0h ostrIouo
In_
h
PAlE
rety
the
hase
to
we
At
of
ne
Scotar
oh the orga7izato
Ohs t
chaht
els
ihvooloed'
Is tm d
A w. t trII mated
froe the PC'
tYe mtt al
tt
het
er re 000 ta10im
mru
proet
tt
25
SP
2
3
tO
And0
Ed S
5 0 '5 and OS
Wecatrluted to the CLinontlareacaon
Oh A
Yea.
e P t
0
Tt
17
e n0 tI
is hotI
O A I ths
W, 08a rloat. II
t rt
atte
I. Wht thIs
J0510ati00 27. Ic
th
oMoItI00"
f27
the
0t2
Dtto
a
md 0001I10
n uo involved?
0
2
to 2. IckeS. the
too oe
se that at00 tutat
21
A n m $15.00.
2 of tette
de ttos-referenoto In POrth
22 0 Bt th addItion to tat a15..
there ua someort
237
hEtIt
of hOC Oettih that Went a Well
23
that.
5. I heve s
24
oe this lette to 02r0
A
s
ea
he d
Yeah
chtrltu
h lo c
aste
in
I
c ... t I n -7ma uWAt
Boarae
n L
. o at east tuehseOd to tt
Im. ht
ntreain
25
1
82
00
to
ult070e
lnes
0
0
A
6
IIth7a,
7
A
9
10
A
11
0
12
f3
0
t4
A
t~2
timer
2,
ft
03
t
du
mt
0
u
16
2
3
~icatin
me
re
to
ua
23'
better. EIlll0a
k.
,
t0
o 1.
to myth0e0
testlfy
So I te It that 2.a'tot
fra
Lete
thIs
to
- Dtbrt
toot t
thtrd
5lth
t hM
hor
0 2
c
thIS
attn
o t n0
to
27
PG
50F7 7
h
0
eself?
ht
In W, san.
statealm
dates.
on dlIates
to
nsh
to
o,
Fed rat Ctdates.
Bo
0,2 id OtOyooate to
uWsemn?
in
an
A Rm
KIm.
tV0 Oldh I ate to
anr
-1 Wh 0 I5 t In the
11
L teetm
02
0
010 o re at
ta-e of
mtayelse 00ates0h
a
72
0A ineth
00 mOeoe
that
iouahet7
Old We
AnNo
11
3
contrbeti?d
13
date 1t
o
To mf tT
e ts
15 0
Stat.
Sobotheho
IheIcated to 27 Fatae that
15
0
I2
so
ho.
I 2 t Int
to
It
000d00to hIste that stahntrl
t
22
16
a
sch as
B ttt'
07
00 s It tot t tomh
that -tre not are that
17
0
h
t 0 f oreatattve BG-ett Mtuan
00
A
tat. tat
n 95
2- oa It '
1A
.
I0 e 30e a
sa.
We r refma-.t
0
0
te In State rn?
21
to?
eal
A
21
2t
0
tern,
2U AetorlhftM
22
" 0
0 - .100 haeaon os. ralllat
.t
t-tt
Xo
23
a ntey In the a
racesr
24
A
ao h
24
0
I 0I7
W- 0If-ebta
tIIraet.
25
0
,
s
Ch
ot the P.,
a. aO
state sat.
AlIce Cl-t
.
83
9
10
Ih
nli
3277
Martin Schreiber & Associates
Exhibit 14
MEMORANDUM
DATE:
TO:
May 3, 1995
FROM:
Tom Krajewski
RE:
A report from Larry Kitto on the Hudson dog track meeting witn
Democratic National Committee chairman Don Fowler
He Listened He took notes. He asked questions. He got the message: "ts
politics and the Democrats are against it and the people for it arc
Republican."
Kitto said the next step is a meeting with Harold Ickes Jr.. policy advisor to
the President. He said it would be a small meeting. I encouraged him to
work to have you there as someone who could speak to the impact this
proposal would have on all of Indian gaming.
2700 S. ShoreDrive Milwaukee. Wisconsin 33207 414 412-1214 Fax 414 49.1 N- Pinckney. S. Madison, Wiscoasi $3703 608 259-1212 Fax 601 259-1213
3278
P-T FasNule
7571
p.42.
Exhibit I
3279
Exhibit 16
KOveber 27,
YOR Die
xKKORAmDMx
523Z
ST277
TROXN
SM3.72CI:
LZGL GIDELfIVS
This
memo
fund-airing.
ill
While
set
thes
1995
7O
forth
basic
rules
can
guidelines
legal
provide
you
with
useful
guidance,
it
is
i~erat
that
you Ilk the legal staff bt'dtaking action that raises any question or concern in your Mind. in
particular;
you should clear all
direct =ail, invitations, and
other written
f"materials and scripts with the legal
depart=ent A.-yo
o
send the= out.
You can
X.
,ou
federal
*
reach
Mai
ca. raise z:
d.ffer.ant types
and non-:eteral:
Contriu::-.s
to
t.2.e
DNZ's
-4".-
of money
account,
called
fed1'
on the amounts
limits and restrictions
Since there -re leu;a
and sources of feterol cc.:ributions, as explained below, it ;5
raise federat-1money than non-federal mOney.
::
core difficult
money. Fo:
Also, the DNC needs =cre federal money than non-federal
4
the ra's
._l-r
5ho*'" be nsd*-these reasons,
0'
-n-.
B.
'i,
a-t
-:
n'
3280
In
order to give stiht
a
federal
or a non-federal
&:Yaens or Zirliall:
individuals must be U.S.
contribution,
All
card holders').
"reen
aliens (it
e2
nationelq to theDPRC are illeoel.
forionefee
S.
redaral Contributions
The
to
-ve
total
'*
'
a.ou.t
*
of
-
federal
te<,
dollars that
'ee-P'
*-
no'ticn
en*
P'
'l*
an individual can
coc--ttees. and
n--'eq
s-s
oo
been
as
to
$1,000
Contributor gives
Carl
:995,
1.n
ZXAM L--:
Cc:=ttet and S5,000 to his state
'96 Pre.ary
Clinton/Core
to
contribution
51,000
the
Democratic Party federal a:=ount. Since
give the
he can still
Clinton/Gere counts towA-rds his 1996 limit,
DIC a full
$20,000 in 1995.
:n 1996, Car. glves 51,000 to a U.S. Senate candidate in
X.inesota whose race is also in 1996 and a 55,ooo contribution to
his state Democratic P:rty federal account. Thus, since Carl has
(the 31,000 '95
already given SCOC towards- his 1996 limit
the '96 contribution to the Kinnesota
contr-bution to Cli.-/cre,
'96 Senate race and the S5,000 io the state party), Carl can only
give 318.000 in federal funds to the DNC in 1996 (and an unlimited
amount in non-federtl contributions)
-;
3281
3
.
Cast coni.butions
Generally all
contributions over 5100
houd be
personal
check, or other written
instr
re.:
(;se
cashier's check) .
The DNC may accept a cash contribution"
to $100.
ks
m onTmous Contributions
ii
The DNC must obtain the name and address for AU contribution
over
550.
However,
you
should attempt to obtain Complete
contributor
information
regardless of the amount a, the
contribution.
b.
uo-federal
Contributions
PtU-
federal.
-.
contributions
b.
Pertners..ps
can
give
unlimited
R2f=ItiE
contr;.utions.
yelaral Contributions
a.
*
contribute
up
to 5'5,00
PACe
per
(aulti-candidate Committee') 01
calendar year to the DHC'5 federt
3282
4
account.
There
is
n2
aqggegate
limit
on
contributions a federal PAC can make to
campaigns.
b.
the
total amo.,; .federal
c-- ttees
ConribUtiaos
MC:-federal
c~)o-nn
4.
Ce-C-ae-c
Azt
Unio',
7a:eral Contributions
ctributiens f:-the treasury of corporations and unions to
:e :s
federal:
.t
are
This prohibition also
Thisc11.
non-profit organizations and
ass::Lations,
to
trade
aples
avoc
ous an cte
organizations which are incorporated, as
from these groups are
Agncontributions
Sz of the-= &=G.
M::-feferal
S.*
Contributions
11111
The
DKC,
fo-'**
however,
-
- *
2=
make
CtT--T
accept contributions
-- -3*
Or
unlimited Dor
from
may
7h6 DS
=Ze-tains
a "building
fund.
which is
used to defra,
3283
5
the cost
of coanst-.::or. and maintenance a: the
headquarters building. The DNC may accept contributions
purpose from Lay source (exc12t foreign nationals and
chartered banks and associations) in unlimited amots.
a--
fo-
this
ede-ally
lo
C.
i.
KaXtz
contributions
must
be
made
Payable
"DNC/Nan*Feaderal
person,
*e*et"-r
building
to the
a-=ot
;:ve,
7he otner
=ade
cne:k
paye:e
= the
t:
remainder
"DNG/Non-Federal
Account".
qq'
Cor.bute-,
puOt
w-ite
ty
azge
date te ats
pe::o- o- bnvvhe-e
ese
particulr, the Ex: caLact accept Checks &Ade
o to Clintan/Gore, or ctects that indicate in
Ire accoanidty
asy note, letter or other:
:=*7 is for the 7:eside:t or the re-election
eaL!
7-C requatj:-s
re:e.pt by tne :S:.
Finenc-
5**-
of
on
a oarticultar
the cheek.
In
re;%uIre
-n-s
-5-
.* diatY
Jec
3284
6
You should also note
that
gfln
2.
ce
the Deoe
s"
C5-
eCt*-
7:-s
1'**4*
in
Swoial
Caves
A.
f.rst
n:: ar:et;
wit:
t.e
or estate without
a check from a trust
General counsel's
office.
iZjt.oZg
of value giveM to the DEC
c::t
tonis
AM in-tife
other thAn a m=ets:
cctrLbution.
A person, corporation, union
or otte= entity azzes
*=
in-tind contribution if
the prseso
do=&te., or charges less
LtL- the usual Lnd normal charge for 7
goods or se-ces
pevato
the DEc.
A.
-
or at a
in-kind :
For example:
reduced
:::e.
3285
-7
- An individual or corporate donor agrees to belp
UrdP
.a fundraising event by covering ce-rtain costs of the eve
provide goods or services for the event.
mec.bers
-
offices
-=t
: to
ONC s
t-eted
like *-v e .- An in-kind contribution *
Therefore, it
2e1
be accounted f'- P'd
eocOWC as a con'-utOrn. This point cannot be emphasized
enou-:
You cannot simply accept something of value from a donor Cr anyCoe
else without t-saIng '- es a contribution followed the n-ae.r
s-t out below,~
cont-ibution.
the
C-
be'o.e2-star.1~
'r
When the DNC accepts a corporate or union in-kind (or an inkind frc= an individual witZ a value above the federal limits), the
This is
DNZ must "pay fer" t!he federal portion of the expense.
acco-plished by the DXC transferring an amount of money equal to
from
the
DNC's
the
contribution,
the
value
of
share
of
the federal
federal to its nor-federal account, before the in-kind contribution
;s received.
an
The
take care of
DC legal a..: budget/operations staff will
process.
Bu;: here is what X2" need to do in order to accept
in-kind donation:
t.is
i-k~nd
contribution
forms
Must
be
approved
(and
3286
signed)
3)
The approved form MUst be forwarded to the DN=
Counsel's office bizz
each in-kind contribution is a==epte
4)
Reznaber that the DNC vill still
be liable fr a
partion of any allocable expenses that would have been pa
the DNC--that is,
it
rets
!Lsthe
use
fed*-*'
-pm.v*
et
Therez-5
Ez=estictes
types of
in-kind
donations
are
(1)
(2)
A volunteer's
(3)
An individual
own travelling expenses,
up to anaggregate of S2,000 per calendar year, incurred while
doing volunteer work;
(4)
(5)
=.st
II.BABIC
A.
BOnTCITATION
GYTDELI~z8
Stetdads
Ethical
rhere
speaking
facts
me
at
of the principals or
C7
1:
c= certably1
a
at
attendance
be comuicated.
3287
9
But special care Must be taken to avoid gir4c
-impression that he or she will enjoy an7 pciler y
frem any Adxinisaon
Officiala
age=C7, whehevith the eve
o: else2w1e.
i
c-=
Svri
Rules
f-
V1-tte: Kate-ialS
letters
it
Is
sent
out.
1.
NO *!-ztc
No solicita:e,
sno.uld give the impression that funds are
beig; raised c. behalf c Clinton/Core '96 or any other particular
=andidate, rather =.z. t.e DNC.
If you do, you may be earmarkingg"
su=h funds for ap-t
:lar candidate and you will risk having to
ret,.rn the funds to the d6..::.
You must :ake clear that the money you are raising is to
benefit all
De=ocrats.
Dir:-.g a campaign cycle in which the DHC is
able to contrit-:e
Or erpend money for a specific candidate,
you
=:y state
that
6.. :...s
being raised will benefit all
Democratic
candidates,
inclutfin
C-.ndidate X.
You may not, however, state
that money in bein
raleed for Candidate X and other Democrats.
.he e=phasis mst be c. thie DNC, not on a candidate.
Donors ca,. certaInly be informed that the DHC, among other
things, will legalv
able to expend a certain aount Of its
funds in 1996 dire::.
benefit the Clinton/Core campaign in the
general electic.
a.t
vLj
also be funding state party coordinated
painsigs tha: cn
a.will
undertake
field activities fo:
Clintcn.//Core a.-.: the 7es: of .th
Democratic ticket.
But no money
Can be specifica2=llv ei7
ked for this activity, nor can donors be
told that any speab
ool of me
or ny
account is being crteo
any candidase-spo:if::-po
e
d
2.
A~'g',
*-;'ud.
Standarn~ DiSClI~-'9'
3288
10
Under federal law, the following disclaimers must
solicitation or invitation (or an the reply card sent
the invitation or solicitation):
.evi-y
A.
Capt:Lbutions
-Your contributions is
tax pv-poses.
--
In
addition,
following
the
-Z's
efforts'
'best
Yg*era
mae1t-c
i-vual
a caleqda-
law -.
l@aQ
o-s
CQEs
and
Cc*!fttiq
oo-e'utions
af'-ess
vior,
ttS
name*
&
th@
to
0
*o
wolovr
n excess
DB29.,
e*s
of 529Q *M
var.
3.
-?'
Additionmal
Diselstie's
fo
-10
fundralsers
C.
0a'
ge':'tatve
3289
11
*
Avoid earr::KXfy,
Be sure to
particular,
if
a.
tall
as discussed above.
the donor how to make-out
the
a
contribution, emphasi=A that the check should be made paya
the fede-ral acqaunt.
PA)
is
giving
it
making
:7.
CoTrc
ors
*--
-tta7:*s
or
"nc
ets
~
A.
C'T~~
Po'!t*:a'
1.
7.D R1907RCvg
Ante5
'cversat
xcs
1Py'tiCal
bv
Qov--unt OfficilI
et!icials Cam
Actively
Participat
Activity
most qovemnoet
Under the Ha::* A:t rearts now in effect,
employees are ncv :ree ::c
the old restrictions Of the Hatch at
Under the new law, v:rt-ally ALU government employees ab all civel!
be able
i
2 below) wil
noted in
(with certain er:e:::s
li
3290
12
to participate
in political activity 0g' th.- 9 *
and
any federal
building.
This means that genealIy gave
officials
and employees can, an thei
0'.
time and not in
Federal building:
*
*
work actively in
Recruit
others
political campaigns;
briefings
*
Run as delegates to the party's National Convention
hold national and sta:e party office.
2.
and
Cannot Engage in
Certain caterr.es
of government officials and employees
n
"Hatched--thit
is,
they cannot engage in the above
actvities
or en;a;e in e.L political
activity at all other than to
vcte and contratute :ney. These categories are:
* Career Sener Zxe=tutve Service officials;
* Adzinistratvo
boards;
!aw
)udges
of Law Enfereament--ATF.
3.
All
Gc.er-s2=t
Employees
ohibtd from
I' gover-:ent c::L:is.ls and employees a
s to the DKC or any other political party
scliciti.ng cor:t:
c==1ttee or ca=;a-.n. -his ne4Dp that n2 government official or
xe2t from the Hatch Act before--car
e=ployee--even t.ose v.o were
receive a contribution for AL= political
oactually solid:
campaign or cc:::ttes.
fro=
or
3291
1,
ask for contributions to the DKC.
1-L-t2.
Mv,
However,
all
government officials
(except :rcategories noted above) rAS now anticipate as speakers
and honored guests at political
events, including
They must do so on their: own time, i.e., only
hours, unlss they are
th
s
anser
**
Presidential
appointees with Senate
confirmaticnationwide responsibility for administration of fede-al
a
*
Employees paid :=rm the appropriation o the Exe=-tive
Office of the President (i.e., some but not all White House
sta: -if someone is not sure, they should check).
Governmenteafficials
Ce
have the'= naes on an invitation to a
fundraiser as long as their On*ideI titles
ese not Uged (e.g., an
invitation can say that -. he Honorable John Smith' will be feature=
speaker at a
Urizziser but =R "Secretary of Transportation Jor:
5=ith").
covernment
efficials
*
personally Invite people to the event or have their names
used to solicit fns (except appearing an the invitation in the
way noted above);
*
have their -.- =es apear on the invitation as part off a hos
as a "s;c-sezr
cr "honorary chair* or the like, o.: the
i~ttee,
eve,.:;
*
scliit
* in a-y
associated v.=
B.
Vse of
Ceve-m-a-t
Tar
official
any way.
titles
to
be used
0:
oiew
elicited in ea ftisil-bgliS
ca: b
Ve co:-'tuth
or called for a contribution, by anyone, in
one can be scll:.:et
goverr=ent off: :s and no invitation to a fundraising event fc
ave
which the recipient v.!1 be asked for a contribution, should
S-dt-
stnt:
Cr
distributed
in
a government
office.
3292
14
C.
950e
oove-*as:4
I
No gave,'.-nt cl141-a 0- eooISvee Cal-, rse e-'&
-such as government cars, equIPment, supplies, statione--:
resources to engage in political activity. in no even- shou.t
employee AsZ
use cffical
saionery
c: antfal
title
fpolitical purpose.
Any costs of travel y any government official or enpoyee
a DNC fundaise must be paid for by the DHC, unless the c;ia
is a
arsltaown Vay.
Tere
or employee is paying their
apportioning the costs of trips on which an official or employee
Thera is a process in place
also conducts official business.
estimating and budgeting far-the costs of travel by the principal.
5
If you, have any question or concern about travel costs :or any
other government official or employee please consult the Genera;
Counsel's ofica.
Government phones, fax machines, copying machines, et=. cannot
be used for any pcliti;= al Purpose, including fundraising. (In no.
event, as noted above, could any government official or employe
solicit
a con-4,truton no matter whose phone or office is being
A limited n->er of local phone calls, for example, to
used).
schedule meetings, are okay.
concerning
questions
any
have
Vou
if
Again,
res:rIctions, please c==tact the General Counsel's office.
these
3293
Exhibit 17
.4 E Pd OR A -N D UI fM
To:
Fr
HaroldIckes
DonFood,.
Ot:
May S. 1995
R.:
LndiaoGaming Lanus
ThI~to follow up cur conasmao regarding the HudaceWisconsw CAigo pruponal.Bait.3 SAd*.a.la. of to.
Laas raisedduringmy wmg wolb .. oJ tribl landm.sad DNC sappiiMr .,oo oppo.. Lb. pmae ,,a jams
oagckgad. Pea Maroick sanpa =Mdyfo...wdatby ow winappr. Psan . 1meknow bow _, uulht pranoo
Thanks
for your Ofanumo.
-The pmopoaait cccmoua dot track In a mnois beingpraswoby Amoac Iseduntrs bo oh anpponon of
GoenrTbomsnwhoia oppoandto 8-m-, . but wosad letstand Lb. Itnow Secretay's desgnation of Lb
pmwas *od wanw'as and thus algibl o atabolaah a tamiOp u
*Tho crrent own.., of lb. dogtrac Opmulowaof Buffolo. NY andao Smn.D'Amaw us advanog thev propowa
at the Lowor DopaftmoCL
whor, lb. dacamocic granl Lholand&airussis u~ mad Lac lb.dma., of lbe SeecOur,
-The tribcs-Weomow SL Croix and io-Chsk. MinnowolaShokopto
SioCai. UPp..
So.... Prane IslandS-oo
and Mille-Lac LAkc-I mil wnlh argu that 6mor pouint opersubooil be1 ho dvaely unpacaad it lw pm)=%n u
g-oLad
'land
in uuain.
-The sbo.. tribes "WadLikeanoppotnny Lopranal Lhir impact slad, to lb. LoacnorSecmro.yor tb.
Adm=AnaOMn Offioajs wn mopoaa t0o dy akmaund by Lb. Hudson criba.
pmp.w
IIIIIIIEIIIJII.DDNC 3245524
3294
O~O,.NO~
blA
NAN
~Exhibit 18
- - I a-
.--.
W.gXuroldIckes
DeputyOtitfoiStu for Policy
and Political Affairs
aThe
Wbte House
I.
2.
The Miatesoca and gr~oosut cibcs -ft9 mnet -th lteriorv oflicsi eaplaned the ftonomic
losics they '-vuld zaffa if motner casino -are eublishod i in areavu due to the close
FOIT0AL 000
3295
Smr.Harold Ickes
MAY J. 1995
Page2
proxtcy of theit cUasa In addtttitt. Coopers k Lytr~ As -no as Peat M~arwick r~ently
tuhoutted. to Lnttoior a detaied acalrwa OtSUUt the odsoc cenemc tcpvscstons Ox would
sivuaon:
4,
5.
f she&%be%
We u
crul eay.
Pasetk 1 OtCour
EOP 064263
-- ArflD rOrAl
0009
3296
Mr.HrcidIck.
M. 1995
P.ge. 3
mind
S
2
3
coplcs
EOP 064264
3297
N1.
287
(7rspeas7se
w.
Taylor
a*C.fl"W
common
Test
DenmarytCommnnyr
-sure
Secrear/T
..
m. P-a
Cam
TIME: &
U.e
5.m
Com-Ry
TO:
PhrfT L-*
.tak
amures
EC,.rE
-ay
f71
(A/
l i'
SECRETA.RT
madam
FROM:
ned ,,~)Or
NUMBER
OE TOTAL rACES:
OpJctNAL TO FOLLOW
tra..A.wre
COMMENT:
C.
C.
C.w-.-nr~o
s-ES
cp..
715-349-2195.
Ca
Use 9-q.
san
L..
-r.
B.-5
acsm
BQA. A Csurn..st
a-y
rismsate.
c.....
a.
Ac
(fr?
G" CL
ACCOUN
oS,
flr
Cen-nn
BILL TO:
pr.blent
ples eCAl
recent
BY
AIL: YES / No
05
3298
sas
0m a
rft-ss
F. O 5)3.s47s
Tnr.'
.a
TMarch 8, 1995
Danswy
Cownaae
cur.
a-ran
s..
i..
Crsnwarw
Cr
Mayor
,,,,,..
n,
Ma'y
Gr-
ty
__""
82aA
L Pias
a-C5U.fA.-,
Siz
rely.
:s
Cial Taylor
Chara
St. Croix Tr.nal Councll
An~mw= .. nO*@
St
Croix
Trbal
Council
rn-. Ana..enam
w*qa
iarS~a~
--
V.
in Th Wall Cja.-e
Cttoo*a Came.. Cane
tanos,
Bulgo
aC..-....*9
aS
02147
GPOi
Baos
C.
3299
OC
ONNOR
.
*rrOnOr"Cs
HANNAN.L.aT .. A
-,FNTsf..
-r-su,,c am
May 8, 1995
tfinds:
The Mannesota and Wisconsin wibes who met '-th interior officials expisined the economic
loses they wold suffer ifanother casint wore established in this area.-due to the close
3300
- Mr. Harold Ickes
May 1. 1995
Page 2
as Peat Marwtck recently
ximity of their casinos. to addition. Cooper & Lybrand as wclu
thai could
saboiattio Interior a detaicd analysis outluing the advre ccononuc tepercuiion
resu] from this happening.
toward creating trust
I am concerned that those at Interior who are involved are leaning
comm issioned
lands. We requested a copy of the Arthur Andetson report which the peutioners
uhich found no adversefinancial impact. The copy submitted to us "blocked out all of the vital
we need
information relating to the size of the operation. how many machines. tabis etc.. which
casinos
to know, as well as the statistics and reasortg used in deternining that the surrounding
would not suffer.a serious economic impact. We needthis data in order to put our best ease
forward to interior. We have no objection to Interiors submining the Coopers & Lybrand or the
PeasMarwick reports to the petitioners.
I would also like to relate the poliucs involved in this situadon.
I
Senator Al DArnato supports this project because it bails out Delaware North. the
company that owns this deftnct dog rck and also operates another dog uck in
Wisconsin. Delawan North aslocated in Buffalo. New York.
The chauman of the Indian tnib in the forefront of this project is active in
Republican party politics. thu year he-as an unsuccesful Republican candidate
for the Wisconsin State Scnrt
All of the representatives of the tribes that met with Chairman Fowler are
Democrats and have bc: so for year. I can tasufy to their previous financial
support to the DNC and the 1992 Clineon/GOre Campaign Comminee
I ctanMly will appreciate it if you -ll o=--1 with me and 1-o representanss of the bes
as soon as you can -ark it into yow schedule since a decision by Interior asimminent. We are
a-ailable on a 24--hour notice.
Yours vers truly.
Pain t. I Otosnrio
PJO.shy
3301
Harild Ickes
Mr.
May 8. 1995
Page 3
blind copies:
1.
2.
3.
3302
O'CONNOR & HAr'NAN. LLP.
1919 pFnasylvania Avenus, N.W.
Washingra. DC 20006-3483
(202) 387-1400
FAX (202) 466-2198
T
.ELCOMMINFCATTON
CMVER PAGF
NAME:
TELEFAX:
715-349.5768
Torn Corcoran
FROM:
DATE:
NOTIrF OFCONFIDENTIArLLTY
7),
la
.. r
o
if
in
cent.e
onedt4
j7
ww eey
YOU150NCY
PHONE:
COMMENTS:
alTIVE
addf
upnme~wiea
40s"'kfm
se
,.rmwenn
Vra*sea.w
an
es
b.s
ea.si
*adame.V
new
ALLTHE P:CS
(202) 778-2177
ma
m.,....,.
was
ir
6e.falu
PlJILEC.
SUDIECTOTHDIAlTDtETCANT
AD"V wVAaPAODUCT 0
CD"FIDDITIAL
U.
st
LAst C.LL
v.ou-
w.hafem).akbydwmalrm0lSc
..
DlACXAs sO.
.**
AS Pt
.oa
55tSLA
Client/ManicrNo: 32594-001
3303
O'CONNIOR & RuNNAN,
vi*.
TETFlQMUNCTIN
OVE Prg
NAME:
TELEiAX.L'
456-2464
FROM:
Patrck J. O'Con=a
DATE:
ATTOb.S!Y
ItiSsmi
Mc ,,jft
~cJ*y fw
FRIrfL.E
mist
TTYOUD00
PflONE:
COMNMNTs:
(202)778-2127
Harold'John
WG 000024
3304
Exhibit 19
MayIs. 1995
[MORANDLUM FOR HAROLD ICKES
ROM
JENNIFER O'CONNOR
LlBJECT:
INDIAN GANG
IN WISCONSIN
e anached information from Panick O'Connor refers to a proposal at Interior to allow three
isconsin tribes to establish a casino at a bankrupt dog track in Hudson, Wisconsin.
ne Secretary of the Interior has the discretonary ability to create trust lands to enable the
the economic costs
ibes to establish the casinos. However, bystare, he must first ass
id benefits to the local community.
ne Department is reviewing the proposal. Staff met last night and came up with a
eliminary decision., which will likely not be final for another month. The staff believe it is
-obably a bad idea to create the trust land to allow the establishment of the casino. Their
:asos are as follows (NOTE - this information is not public and is confidential at this
The local community is almost uniformly opposed to the proposed casino. The tribes
that want i, establish it live 250 mles away. but no one in the immediate area wants
it etiablrshed, including the Mayor. City Council, other local officials and
Congressman Gunderson The Depanment feels that this local opposition is an
ndicason of adverse impact on the local commututy
The Minnesota delegation is also uniformly opposed to the proposal Minnesota tribes
located near the state border feel they would be adversely impacted by the
competton.
It is likely that a decision to approve this proposal would result in a spotlight being
shone on the Indian Gaming Regulatory Act, which rs under some legislative prewure
at the moment The Department wants to avoid this kind of negative attention to the
Act
ne other side of the argument is the support of free market economies Some
Department
aff think the bottom line here is the Minnesota and Wisconsin rbes who
are benefiting
ormously from gaming don't want the competition, and we able to
hire bigger lobbyists
an the three very poor tribes who want the casino However, the staff don't
thank this
gument negates the uniform opposition from the local community
ne currentstatus is this: the Department is revicwng the comments
received during the
)ment period which ended April 30 I has comInned to
making a final decision within a
Fno 064394
Ft63
3305
MrMOANIu
Exhibit 20
To:
Jennifer O'Connor
From:
David Meyers
Date:
June 6,
Re:
1995
EOP 064250
3306
Exhibit 21
A.
3M
W4 /5p-,p5-
TNMOU
~aaa~x
'Em
to Congr 9
ZB~OGZ!ZO~J
icl
Sion, . 81
s.
UIbpoea
"t
oc
:Wft
dW4oee
lxq
3307
to
/7/tr
Sei,,
,/
Od~trS
lt
(db/.o,
3308
7--:
. 'vpa
-Sm
Exhibit 22
hatrio
D.C.20240
MEORANDDMl
To:
Political
Jennifer O'Connor, White House Office of
Affairs
Subject:
Date:
Attachment
WG 000039
3309
61 From: George Skibine at -IOS:AE 6/28/9S 6:27PM (Bal" bytes
.ROY WOCDWARDa: -DOI/SOL HZ. KEV:N MEISNER at -DDiSZZ_HZ. H: o
-Is:A, Paula L. Hart, Tom Hartoan
Reques:eo
ot!pr
anue. a:
>wc ret~lent
text
item
1:
Text
.
-
--
--
3310
Exhibit 23
UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF WISCONSIN
SOKAOGON CHIPPEWA COMMUNITY
(MOLE LAKE BAND OF LAKE SUPERIOR
CHIPPEWA). LAC COURTE OREILLES
BAND OF LAKE SUPERIOR CHIPPEWA
INDIANS OF WISCONSIN. and RED CLIFF
BAND OF LAKE SUPERIOR CHIPPEWA
INDIANS OF WISCONSIN.
Plaintiffs,
Case No. 95C 0659
v.
BRUCE C. BABBITT. Secretary. UNITED
STATES DEPARTMENT OF INTERIOR.
MICHAEL J. ANDERSON. Deputy Assistant
Secretary. UNITED STATES
DEPARTMENT OF INTERIOR. JOHN J.
) SS.
MARICOPA COUNTY
Paul F. Eckstem. being first duly sworn on oath. deposes and states as follows:
1.
I am a member of the Phoenix. Arizona law firm of Brown & BaiL PA.
and I am making this affidavit to evidence statements made to me or that were made
3311
my presence by officers of the United States Department of Interior relating to the
plaintiff Tribes' (the 'Tribes") application to have property located in Hudson. Wisconsin
approved for off-reservation gaming pursuant to 2719(b)(1)(A) of the Indian Gaming
Regulatory Act (IGRA") and acquired in trust by the Secretary of the United States
Department of Interior under
2.
5465
3312
The letter goes on to state:
I am concerned that those at Interior who are involved are leaning toward
creating trust lands. We requested a copy of the Arthur Andersen report
which the petitioners commissioned which found no adverse financial
impact The copy submitted to us -blocked out' all the vital information
relating to the size of the operation. how many machines. tables. etc..
which we need to know. as well as the statistics and reasoning used in
determining that the surrounding casinos would not suffer a serious
economic impact. We need this data in order to put our best case forward
to Interior. We have no objection to Interior's submitting the Coopers &
Lybrand report or the Peat Marwick report to the titioners.
I would also like to relate the politics involved in this situation:
1.
2.
3.
4.
5.
3313
I certainly will appreciate it if you will meet with me and two
representatives of the tribes as soon as we can work it into your schedule.
since the decision by Interior is imminent. We are available on 24-hour
notice.
A copy of this letter is attached to this affidavit. Donald Fowler is Chairman of the
Democratic National Committee. I understand that a copy of Mr. O'Conmor's letter has
been placed in the administrative record at pages 02880-81.
3.
defendant John Duffy. I attended the meeting with Mr. Duffy on May 17. 1995. Also
in anendance were the chairpersons of the Tribes and Mr. Havenick.
During the
meeting. George Newago of the Red Cliff Tribe made an impassioned plea to Mr. Duffy
relating his personal experience growing up in a poor family as a member of a poor tribe.
Mr. Duffy listened to Mr. Newago but said very little during the meeting. In response
to a comment by Mr. Havenick, however. Mr. Duffy did say that approval of the Tribes'
application was not a 'slam dunk" but did not elaborate further.
4.
Following the May 17. 1995 meeting with Mr. Duffy, I was advised that
Department of Interior officials would meet with me but that they would not meet again
with the Tribes. I believe that the person who told me this was Barbara Atkinson. an
administrative assistant in the Office of the Secretary.
5.
Gaming Management staff, who was working on the staff report on the-Tribes
3314
applicUtnon. I asked Mr. Hartman if there were any problems with the application and
he said -nothing that isn't curable.6.
Indian Gaming Management Staff. to ask about the status of the staffs report on the
Tribes' application. Mr. Skibine said that he wanted to keep his job and therefore could
not discuss what was in the staff's report.
7.
and the Tribes' growing alarm at the political pressure being asserted against the
application and the failure of the Department to communicate with either the Tribes or
their representatives about what was happening with the application. I telephoned
Secretary Babbitt on July 11. 1995 and requested a meeting with the Secretary. At that
time, the Secretary told me that he would have John Duffy call me. Mr. Duffy called
me later that day from an airplane and said that the Department was ready to make a
decision. I requested a meeting with Mr. Duffy for later that week. Mr. Duffy wanted
to meet the next day in Washington but I could not make arrangements to travel that
quickly. After some discussion, we agreed to meet the morning of July 14. 1995.
8.
Former Congressman Jim Moody and I met with Mr. Duffy the morning
of July 14. 1995. The meeting lasted slightly less than an hour. During the first 40
minutes of the meeting. Mr. Duffy listened to our arguments in support of the application
and appeared to be receptive. Near the end of the meeting. however. Mr. Duffy said that
the application was being denied and that a decision would be issued later that day
3315
Mr. Duffy said that there were two reasons for the denial:
aming
establishment would be harmful to the St. Croix Chippewas. and (2) the City Council of
Hudson. the United States Congressman for the district, and other political officials were
now on record against the project.
9.
Later that day, on July 14. 1995. I met with Secretary Babbitt- I asked the
Secretary if he would delay the release of the decision on the Tribes' application until the
following Monday to allow time for the Tribes to anempt to respond to the political
pressure being exerted against the application. Secretary Babbitt said that the decision
could not be delayed because Presidential Deputy Chief of Staff Harold Ickes had called
the Secretary and told him that the decision had to be issued that day.
10.
I had never heard of Michael Anderson. the person who signed the July 14.
application.
Messrs. Duffy. Skibine or Hartman nor anyone else I spoke to ever mentioned his name.
My understanding was that Ms. Ada Deer. the Assistant Secretary - Indian Affairs, was
the person who would make the decision on the Tribes' application for approval under
IGRA. No one ever explained to me why Mr. Anderson rather than Ms. Deer signed the
July 14. 1995 letter.
3316
11
In my over 30 years of practice of law. I had not been involved in a matter in which mne
merits were so strongly on the side of the parties I was representing.
Paul F. Eckstein
d and Sworn to before me
Subsc
this ?k-day of January. 1996.
ROBIN
NESON BUJRRIS
-"Yham-ameans.
MARICOPACOUNTYr
Can Emmati
GALAXYPLEADING\ECK5TF.NAFF
3317
Exhibit 24
WASHINGTON
3 0 i96
AUG3
Honorable John McCain
United States Senate
Washington, :.C. 20510-0303
Dear Senator McCain:
I apologize for the delay in responding to your letters of July
19 and 25, 1996, concerning allegations made in a July 12, 1996
This article falsely insinuated
Wall Street Journal article.
that this Department has allowed campaign contributions to
dictate Indian policy.
I am enclosing two memoranda that answer most of the questions
you ask. The first describes the background of the matter in
question. and the contacts made by officials in the Executive
Office of the President on that matter. It was prepared by
Heatner Sibbison, assistant to Counselor John Duffy (who, as you
The second is
know, recently returned to private law practice)
a memorandum from the Sol ::tor discussing the court decision
addressed in your July 25 letter.
Your let:er alsc inquired acout communications directly involving
me
: nave no recollection of oeing contacted by attorney
Pa::K O'Connor cr. this mater, nor do I recall ever being
=y anyone in :ne Execut:ve Office of the President of
-n.:ie:
Further. like members of my staff.
C C..cr's involvemnt:
M
from the Director of
1996 letter
n:ctlearn of :ne Ar;1 25
:=:nelss!=n until well after the
:ne :.nnes::a :ndia. Za-n
-ar.carcpication was made, and I had no
0ecosion o-. :he ::s:
<noIwledge of any mee:ings. -emoranda, telephone calls or any
c:ner communiraziens ne:wee. Executive Office persons and trlcal
represer.:a::.es opposed := :ne acquisiozon discussed in your July
: met w::. Mr. Faul Ecas:en., an attorney for the three tribes
applying for the trust land acquisition, shortly before a
decision was made on the application. Following this
conversation. I instruote: my staff to give Mr. Eckstein the
oppor:uni:y to discuss :ne na::er with John Duffy. I must
regretfully dispute Mr. E:kstein's assertion that I told him that
Mr. !ckes instructed me to issue a decision in this matter
without delay.
I never discussed the matter with Mr. Ickes: he
never gave me any instruct:ons as to what this Department's
decision should be. nor wnen :t should be made.
3318
To the best of my recollection 1 have never been contacted by
"top-level White House staff" or. any Interior Department decisie.
directly affecting Indian tribes ncr, to the best of my
recollection, have I ever been contacted by any official from the
Democratic National Committee trying to influence the
Department's decisionmaking process on such decisions.
Like you, I believe that this Department should make decisions
like this one wholly on the merits, without any regard to
campaign contributions or other partisan political
considerations. We did Just that in this matter.
Over the years, you and I have worked together on a wide variety
of issues a~fecting Na:tve Americans, with what I believe has
been a shared determination to do our best to discharge our trust
obligations in a nonpartisan manner. I regret that, relying
solely on a newspaper article, you have chosen to so publicly
call into question the integri:y of our decisionmaking on this
matter. I am pleased to have the opportunity to set the record
straight.
Sincerely,
3319
Exhibit 25
'rE
SECRETARY
or rE
INTERIOR
wASMINGTON
Washington, D.C.
Dear Mr.
20510
Chairman:
while
nor when it
should be
made.
3320
The Indian Gaming Regulatory Act (IGRA) lays out how the
Department should make decisions on applications like this one.
which was a request to take land not contiguous to an existing
Indeed, the land
reservation into trust for gaming purposes.
applied for here is located between 85 and 188 miles from the
reservations of the three applicant tribes.
Section 20 of IGRA says that the decision shall be made after
consultation with the applicant tribe and -appropriate State and
local officials, including officials of other nearby Indian
tribes." Purther, applications may be approved only if the
Department determines that a 'gaming establishment on [the] lands
[proposed to be acquired]
to the
3321
Exhibit 26
surf COMMITTEE ON GOVERNMENT REFORM AND OVERSIGHT
MAJOR/TYMEMBERS
MEMO
$10,000.00
10,000.00
30,000.00
Democratic National Committee (9-9-96)-------Democratic CDC (non-federal) (5-31-95) --------Deborah Doxtator--DNC Serv. Corp.( 11-16-96)--
50,000.00
3,000.00
2,000.00
5105,000.00
[Tribe also paid Johnson. Dacey & Hamilton-$120.000. 00]
(Nt.
Croix Chippewa
DNC Services Corp. (6-21-96) ---------------------Democratic National Committee (11-9-95)-------Democratic SCC (11-4-96)--------------------------David Merrill---Clinton-Gore '96 (6-30-96)-------Lewis Taylor----Clinton-Gore '96 (6-30-96) ------
$15,000.00
15,000.00
20,000.00
1,000.00
0
552,000.00
01/20/98
3322
lille Lacs Band of Ojibwe
$15,000.00
10,000.00
250.00
250.00
S25,500.00
$15,000.00
300
S18,000.00
$5,000.00
1,500.00
1025000
$16,750.00
1.ower Sioux Tribal Council
Minnesota Dem. Party DFL (1-4-95) -----------Democratic SCC (7-15-96) -----------------------Roger Prescott --- DSCC (7-15-96) --------------Upper Sioux Community
Dallas Ross --- Clinton-Gore '96 (9-30-96)------TOTAL--------------------------
$500.00
5,000.00
3,000.0
58,500.00
SL000.00
$356,250.00
01120/98
3323
Exhibit 27
MA~yILLI
Bernard Schwaru
Lillian Vernon
C.W. Cone
Syd Imas
George "ec
Anelo Tsakopoulos
Haim Macklowe
Bernard (Cbppwa Indiam)
Smart Moldaw
Haim Saban
Mushall Sachs
Stephsen Roth
Harve Wesusein
mel Weis
Sanford Weil
Ted Sioms
Charlie Tie
Aridf Wkridlm
David Coffi
Steven Ghuckzer
F 10 40 5
3324
Exhibit 28
MESSAGE
Mark Thomann
2/22
8:45
Can we overnight
a Finance Board
packet to his
indians.
Gary Mauro
2/22
9:10
Piz call
512-463-5256
Dennis Hadden
2/22
Harriman Center
485-3400
NAME
DATE
PHONE
Chris VanGiesen
2/22
9:45
Plz call
496-5076
Meridith Jones
2/22
10:05
Ph call
512-371-0629
Chris Duda
2/22
10:25
Piz call
496-5085
Beth Dozorerz
2/22
10:35
Linda Moore
2/22
10:35
Lauren Supina
2/22
10:45
Plz call
215-665-5534
Sue Gin
2/22
11:00
312-243-2882
John Mantz
2/22
11:00
Plz call
544-7636
Peter O'Keefe
2/22
11:05
Plz call
496-4811
Dennis Hadden
2/22
11:05
include in ltr
federal or non fed
Jodi Trappasso
2/22
11:15
Piz call
659-3005
Mithcell Berger
2/22
11:30
954-627-9900
I ~iIJ~uI~jI811
ACTION
Athenicum
Hotel rm 710
1000 brush
ave. Greek
Town detroit
MI 48226
313
456-6500
f11hlg
DNC 3124904
3325
Exhibit 29
HROTE 500,00Mr. JohnE Connelly
Chairman andCEO
Ms. Audre Wireints
J EdwardConnelly andAssociates
1020 SawMtil Run Boulevard
Putsbureh.
PA 15220
Office.412-381-661I Home Fax 412 3819322
Mr Richard A. Havard
Chamman
Mashantucket PequotNation
P.O. Box 3060
Ledyard. CT 06339-3060
Office: 203-536-2681 Home: Fax: 203-572-0421
(Conidintial Information
Il lilfleilfli
DNC 481359
3326
varru s Vii XECE'flON - DNC/COORDINATED CAMPAIGN
October 23, 1996
6:30 - Photo Reception
Exhibit 30
Regal Hotel
Minneapolis, Minnesota
Irwin Jacobs
CEO
Minnetonka Boatworks
Jacobs Trading Company
Minneapolis, MN
Mr. Jacobs is a high-profile, nationafly-note entrepreneur and businessman- He has founded and owns
several companies in the mid-west.
Lee Lynch
CamichaelLynch Ad Agency
Minneapolis, MN
Mr. Lynch is a prominent local advertising executive. He is also the proponent of a proposed code of
political advertising known as the Minnesota Compact.
Pat O'Connorand Erie O'Connor
Partner
O'Connorand Hannon
Mr. O'Connor is a prominent local attorney. He served as the DNC Treasurer in 1968. His wife is
an active local and national fundraiser. He was Hubert Humphrey's National Finance Chairman, '8
Gore for President Finance Committee.
George Lund
CEO
Minnesota Bank Yu
Minneapolis, MN
George Dupuis
District D Representative
Fond Du Lac Tribe
Dallas Ross
Chairman
Upper Sioux Tribe
Roger Prescott
Chairman
Lower Sioux Reservation
Darelynn Lehto
Vice Chairman
PrairieIsland Siour Community
214684-1
Eop 07059
3327
Chairman
St. Croix
DNC Business Council Member
Randy Asunma
Attorney
Minnesota Indian Gaming Association
Mr. Asurna represents the Iowa Sioux Fond Du Lac tribal governments.
Lary EMao
Attorney
O'Connorand Hannon
Represents the majority of Minnesota Tribes that are involved in the gaming industry.
Glynn A. Crooks
Vice-Chairman, S.M.S.C.
Shakopee Mdewakanton Sioux Community
William John Hardacker
GeneralLegal Council
Shakopee Mdewakanton Sioux Community
Cyndy Ann Stade-Lieske
Board Member
Shakopee Mdewakanton Sioux Community
John PatrickDriscoll
Board Member
Shakopee Mdewakanton Siour Community
Robert Carl Lambert
Board Member
Shakopee Mdewakanton Siour Community
Willam Matthew Rudnicid
Board Member
Shakopee Mdewakanton Sioux Community
Mary JoEllen Rudacid
Board Member
Shakopee Mdewakanton Sioux Community
EOP 070595
21964-
3328
0CONNOR
--
.-.
ps
..-.
-P
*-ce
&
oPNrvs
HANNAN.- -
Exhibit 31
AT A
SuIiTE 500
PrNSYLVANIA AVENUE
DC 20006-M3~.
5_ 3 so B5oC0
a7.oo
'&X .2o2i 466 OlOB
NW*
TON
-o
P.O. Box 28
Henel. Wisconsin
54845
Dear Lewis
Enclosed please find OConnor & Hannan's bill for services rendered in February we
are pleased to beof service to you.
If %ou have an questions. please don i hesitate to call.
St
Thomas J Corcoran
jJ
enclosure
D.
242.1
AA 0000258
-.
-34
3329
Afl~oRNE'S AT
"AW
ENNSgy. - A AVENUE NW
WASmINGR ICZ20006 30
19'-
ErZ.rc
S2::
-00
INVOICE
St:Cr=-x 7inze
2 ==x 267
erteW,
Wsecnsisn
54445
PLEASEREr.
-n
essoEna:
are
ser:::es
of Matter:
This
* STS*YOURREMITTANCE
CP.r
Doc Trz:<
to
t.d:ar.
?ribe. new file
set
r my Tom Corcoran aettng g----- Z:::x
2828(e) (2) legislative la-rcare
:er: s coe::ves. research -- :-S- -="e=.
:_-n
.:7egar:dig forthcoming meet:
:e wth Tom Z:::1.
--- .
-=s
at Hudson, Wtsconsin doc ora:- :
-- **
rregar:t.ng creat.ng
ong distance telephone discuss::- s-:---z
nee= to ontart Tom
:
toerEsar z
s mee:t.eg on February 8 with Duffy in
reard:ng cant
7z- Z::::..
t:
TZ
n.-.sa ff~e at :nterz=r. =:scr;ssttru
=:
Ctz
r
-z
Barr:::
art P
z~ea
.r---:.:r. ,reear:%oisc~ssicn
.
zr
disz-Sso--' -!:t
wi...LYtt
=--z
Zo:rs at :n:er
:::
dra: .e: er S7.
Tayor, te:e
a':
a s-:
::. Kittr.
o-sruss:ons with
retorting to Tom.
a
-t:-:..s
re-=ar.= to . Tavlor, report to
.
TayZor
s .ss::s
-:t.. a:ne to
Babttz
a. oSe s counsel J. Duffy. dss..ss.:ns
7egaror.r Fe=rar. 5 meet:ng
-:n = Z Zcr-nc.
discussions wit K.:::. memorandum to Sec. Babbitt's cotef
of Staff 7
Collier, report to Ton :zrrora:: on Collier; get report on me-t::z
.n berstar's office from Tom Corotra.. -ee:tlg with L. Kitto and T. Ross:
-e,-eof
etord on Hudsor. oroert. reyew file and preparation :or
-e-e:
:
Taylor, em al.,
ee:L.
wlzh .. Taylor.
L. Butler and C.
:earnar-. retort from L. Zitte rezardoe; tuffy meeting; memorandum to fle,
::aegy
e-eo-ent; disruss=ns ,::.- staff of U.S. Interior's se':txtrs
reard.ng procedure issue. d-st ssizns with F. Ducheneaux, L. Kit:o woo
^:.nr
regarding procedures :ss-e and X.ISA report on Hudson and
letter
to J. Duffy ano Se:retary Babbitt; memorandum to '.ayltr, report on P. O'Connor and T. Collier. Chief of Staff to Sec. Babbl:.
os:-ssor.s
w:tn ?. Coleman, for.erl. of U.S. Interior Solicitor's
staff;
0scussit-.s w:t '. Kitto; meeting w:tn P
Coleman, formerly of U.S. Inter::r's
-licitr
s office. memorandum to f.Me; discussions with L. Kitto; ca.. to H
Snier: -ercrandum to file
regarding market impact study; discussions
ith
S 0; telephone conference with Tom Corcoran regarding need for a position
paper for Interior
and why it should not support a gaming casino at the Hudson.,
o..gresstn.a!
AA 0000259
3330
ATTO"NEYS
S5
AT
"E gOo
99
..S. ANIAAVE%.ENW
WAS-^v'"AC. 2
:CC*a3
2:
557.1SC
INVOICE
-:=
Na
ure
32-4-::**:.
of Matter: to:
Traok
tC
i-af:
Clas::ns
'4:t-
..
zale;
wsia:r~
th
:..
renarityg
aes; dis-ussi--s
t.-. 7ayer e: a-
K-zte;
discussions
analysis
-arke
ss-:.s w
impact
with
on client:
Ltn
1.
- -s
700:.::
-Tse-ents
-=7.g
:stane
stagee
:acsi-r
es
:&
20.40
16.lD
Telephone
B.14
23.-0
szarsemen:s
516.44
Due:
S7, 167.i4
AA 00DD260
S:,s-s
..
E'*5C.sa
.t
ss ,
s *ce.
-s
summ aT
ar.on
3331
O*CONNO=R
H~.AN NAN
&
A--oNrys
f~s"b7
-.
_P-
LA^
8"o~
ISD-9 E.NSTLVkAAAVC.-
_5_aTDN
DC
Z NW
sooo0e383O
:'
call.
Thc:mas J. Corcoran
enclosure
AA 0000261
3332
ATTOtNEYS AT LAW
800
SUITE AVENUENW
9 PENSYLVANIA
WAS*
Z:c20006383
'202i B-400
NGTON
INVOICE
::cr-_x 7rabe
a-
=--sin 54845
REbN
PLEASE
o r=:
fesscrcal
of Matter:
-:eare
sr-:
zes
rendered
dS
Dog
through
PennoN
Trac<
V"UR REurrANE
WITh
to
Mar:.. 3.
.995
AA 0000262
'::ss .
*esan
a.1.e-,c .
a.
.arasra
3333
ATrORtNEYS
AT
LAW
SUITE 800
gig PENNSYLVANIAAVENUE NW
0-3AS3
WASNINGTON DC
887-
(202)
E2 D,-
AX
INVOICE
-
32594-00:.
---
son ;ro:er:
Natre zf
t=
PLEASE
RETURNTWISPORTIONP
wiOUR
REMfTANCE
Taylor
reto=:
cricelli
lezIslatier
S s
57.300.00
AA 0000263
::1-
..c t'1'E.a-.*r:
u a'
JlrraOfr
3334
ATTOINEvys AT LAW
SUITE N00
-; PSYLVANIA
AVENUE
NW
AS.INGON DC 20006-34a
202)87.1400
INVOICE
995
:~
FEDDC
Pr:ezt
Nature =f
Mater
2:594-0001
to
=Srack
Zg
PLEASE
a-.S4
7e5
****
PORTION
RiTF YOURfEtMrTasc
-rSene.S:
20.4:
88.55
Photczzpes
=istance :ng
-eleohcne
Facs:-ies31.
1/95
array Kz::o
7:ps. and Ca-
Mc:el, Airfare,
fare (2/C" 95
meals, Parking,
3/15/95)
DIsz-rsemen:s:
1752.C51.992.02
AA 0000264
3335
o
COrNNOR &
a-*Da
HANNAN.L
YSA,
LP
LAw
SITE 80
99
-s-
NW
_CNSYLVAN^' AVENUE
ZGTO DC
0o0-3-S
202, es10O
1A
202' -S6-298
May 9. 1995
We an
A2J
Corcoran
Ii
enclosure
AA 00002E5
D-c 24297
3336
arront'
spy e
AT L.AW
.*
NIAAVENL
we .s-
WAS
--rx
-:!
%0t'
2O&4-Ca8
1!!!!.ace
54845
WEASEpMT
-S
-r=e=
'E: =*1:
Tribe
iso-
NW
3483
OICE
-s -aIN\
-
:20006-
p-Oe
t-ack
to
;:no :o::ersion
:fess::r.a-
ser.ces
1995
Taylor
Me--ers
ar~eax.
OC'Zonnor
AA 0000266
-.
O'CONNOR
&
HANNAN
3337
.veN429 NW
2OCCt-34a3
E:
INVOICE
-
32594-::::
--Nature of Matter: Dog Tra:-
-IS
PLEASErETuN
sT
)EMrT
aNCE
i-
e S$S7.500.0
AA 0000267
3338
AT'OMtNEYS AT LA
S,
1919
DEOS..
.2::
I-.-,
Nature of Matter:
N0C
CTE
NIAAV5CVy IA
s-''X
INVOICE
32554-C:::
Deg Track t:
PLEASERETlUP.N
-S ACaION A--
* %= aEa-
CE
L:zrsevez:s:
Pz::ocop:es
--. g Distance Telephone
P=s:age
50.60
5.48
.3 .52
90.00
W=r
Processing
Tirs im:les
:1
=sm4t:
94
.00
S283.i2
57,783.60
AA 0000268
O'CONNOR
......-9. ...- T.* 5 .. : & ! HANNAN
KU--'-"
3339
O'CONNOR
&
HANNAN. -
ATTORNEYS AT L-AW
SLTr Boo
f949 PENNSVCVANA AvCNtUt N W
7"
E -msed please find our invoice for legal services rendered for May 1995.
tf --a have any questions. please don!t hesitate to call.
*K= personal regards.
Thomas I Corecran
i1
enclos~r
AA 0000269
3340
ArTropNEYS
LAaN
SUITE6W
:
1g19PENNSYLVANIAAVENUENW
<
ase:
ns:
WASHINGTON DC 20006-34M3
2021 871400
INVOICE
Jue27, 19-
..
,
..
Zune :7'~55
Crt:x 7raze
St.
p.0.
:B7
Bx
Hertel.
Wise:-..s-t.
54845
oE'r.
PLEASE
son
PrOfect
fessional
Nature
:f
Matter:
Tw.SPORTIONW-- 'OUi
Dog
Track
rTANCE
AEM
to
1995
itszance
AA 0000270
3341
ATToRNEYS
AT LAW
SUITE SM
9-t PENNSYLVANIA AVENUE NW
DC 20006-3483
202 1 887140
a.SMINGTON
-E:NC
INVOICE
:7, 995
Project
Nature of
32594-0001
Matter. Dog Track
0.EASE =E-
to
N ThS PORTION
wiMT YOURREurTANCE
1:t:
a-mcer
Ma:::
Mercer
AA 0000271
3342
Ar-ORNEVs
AT
LAW
SUME 80m
.9-g
PPNNSYLVAIaA AVENUE NW
AAS-GTON DC 20006-343
'202) 687-A0
FED
10Nt
ceIT
INVOICE
-995
SPrc:ect
****.*
t25z4-000.
27,
Track
,LE=-W
-MISPoRio.
Sature cf Ma:er.
:o
wrN YOURREMTANCE
Deputy
to
AA 000027Z
3343
aTTOptNEY
sIT
AT LA-
soo
NW
*99
WNSYLVANIAAVENUE
wA.S--NTON DC 20ooo-m3
q-Wk
22067-1.00
INVOICE
32594-0001
21. 195
>n Prc:ect
Nature of Matter:
Dog rack
itASE
fTi
'S
......
to
PONTI
W
va
REMTTANCE
Memorandum to F. Ducheneaux.
regarding Delaware North.
Discussion with F.
Ducheneaux
Long
involving
rotal Services:
S'
AA 0000273
3344
AropqtNEYS
A'
..
surrz so
1919 PENSMYLVANA-*NUE NW
.2M
-En
3W
221k0s
WAMNCToCI
:DNO
.SU:!a.
Ac
aS
INVOICE
Z:
,995
Project
32594-00: '
YOURSEMIANCE
.Lrsements :
rW
111.20
40.08
3.12
88.50
1380.00
Photocopies
Long Distance Telephone
Postage
Facsimiles
expense for airfare. Motel.
.ARRY K:t"O
parking, meals, etc. (4/16-5/24/95
Total
$9,122.91
ard Disbursements:
Total Services
**.***Statement of Accozu*t
SI:v IUE FROM PREVIOUS STATEMENT
; 'AYMENTS)
,NIE
51.622.9:
Disbursements:
7783.60
(7783 .60)
?CRWARD
.00
9122.90
%Nzr DUE
$9.122.90
AA
1*S.E
gamc:
**...
'C
-myta..
55SuS.Dalt
AIS*aOn
000274
3345
O'CONNOR
&
S
04*
HANNAN-
c goo
'C4
El.
.[J
SDC 500065.33
4-i-
A.
Thomas J Corcoran
nci-sur
VbL!.sa
AA 0000275
3346
O'CONNOR
&
HANNAN,
ATTORNEYS
L.L.P
AT LAW
SUITE 80C
1919 PENNSYLVANIA
A.ANUE N A
WASHINGTONDC 20006.348:
FED
OD
NC
A I!2!M-
1202)8B7.i'X
INVOICE
5-0cC
:rc:x Tribe
icx 287
0,
Wisconsin
54845
Nature of Matter:
son Pr::er:
Services
fessirna:
REIrTANCE
Dog Track to
30. 1995
Ce=artment
o::nell
2.
AA 0000276
3347
O'CONNOj, &
A
HANNAN.
CoqNpBYS
AT
L L P
LAW
SUITE 8ee
AVENUENW
WAS.%GTON DC 20006 3483
,202) 88"- '-W
19195 E.1SYLAWA
INVOICE
:son Progect
3254-0001
Nature of Matter: Doc Track to
PEASE RETu
PORTION
wiT" "U REMTCE
-:S
leaders
Total Services:
AA 0D2
3348
&
O'CONNOR
LP
HANNAN
ATTOS-EYS
AT LAW
S.JITE80c
1919 PENNS- _ANIA LYENUE%
WASMIsNG- DC 20006-343
INVOICE
-y 11, 1995
dson ProjeCt
Nature of Matter:
32594-:001
Dog Track to
.sburseme=zs:
25.80
phc:z::;1es
4.
4,3:
'4
?AT':::-1
T DONNELL
out Cf
;:Ket
03
34 .15
33. 75
37.53
50.00
7.50
expenses
Total Disbursements:
Total services and
AL
_=SS
Disbursements:
********Statement of Account*
PREVIOUS STATEMENT
FAYMENT 5,
:C
9122.90
7692.76
$16,815.66
DUE
AA 0000270
:rss **OEsusEs
ETu
*C- se..rs
'-
*woe
ew
fl.u
-'
$7,692 -
9122.90
.00
ur FRl
A'.ANZZ FORWARD
YJRRENT tNVC::E
iA.ANC'
5:92
t ure
m ar
3349
O CONNOR
&
HANNAN.L
ATTOWNE'5 I-
gg*
us
.*
9V.%
ES-LVA-A
202
86
ALIvo
-s
Cn
August 9. 1995
Thomas J. Corcoran
enIlosure
AA 0000279
3350
AfTCNEVS
99
,*
AT
LAW
SUITE
800
_NSYLVANIA
AVENUENW
'- ONDC 20006-34E3
'EZ
.C
INVOICE
St. Croix -ribe
Box 287
P..
Hertel, Wisconsin 548412
REng
on 're:eCt
E-UaN
Nature of Matter:
*-s
Deg
PORTo
track
WITHYOURREMITTANCE
to
July 31,
1995
s= ssons
:th L.
itto; discussions w:th Dan Theno of cr: Mowar:
E:rpzration in. Wisecnsin; ::scussions with aides to Senate :noian
Affairs Committee and House Subcommittee on Native Americans.
with L.
Kitto; discussions with Frank Ducheneaux.
ie.Celpnent of strategy on hudson involving contact with ^eorge
r.:.v:ne. key official in the Gaming Office at the Department cf
.nter:cr
in orcer to get status report for client.
DiscussIons witn L. KIZto. work on Hudson project with CongressicnaL
aides from M=inesota and Wisconsin; discussions with BIA officials
meeting with aides to Senator McCain regarding Department of Zus.::s
inquiry. discussions with aides to House Native American
suczcr-m1ttee
w.th L..
Kitto; discussions with aides to House Nat:ve
A-er;:an Subc:-ittee; discussions with partners regarding further
involvement of White House and Secretary Babbitt; discussions ct.:
FranK Durneneaux regarding George Sk:vine, head of the relevant
agency within the Interior Department involved with
the Hudson
pr=)ect; discussions with aides to Minnesota Congressional
delegation; meeting with LArry Kitto in Minneapolis; Discussion
regarding need to go to
Hudson. WI and visit with city council
members and Coty attorney; Discussion regarding necessity
to
follow-up with Harold Ickes at the White House.
0. Fowler at DNC ar.o
Terry Mac at tne Caemictee to Re-elect, outlining
fund
raising
strategies.
21srussions
1sussions
AA 0000280
3351
PEN.svtS&MIA
WAS.IN5TCoN 0 C
2
919
Aa
'.
'E
C
m.-
INVOICE
.*****
3259;-C::
.rec
TraO.
::
tC
aEuwMACE
AA 0000281
----.
O'CO)NNORd
c -1*....
-t:
&
---
HANNAN
_--Tc--
3352
ATORNEYS AT
LAW
SUITEB0
NW
PENNSYLVANIAAVENUE
0 C -N.:03
WASHINGTON
j202)887"W3
1919
rl
INVOICE
.
32594-0001
Proleot
Track
tO
WTiS PORTION
PLEASERETURN
s
--
A 4
YOtLRaM-AFCE
:: Senate
L. Kitto; discussions with aides
i
w
wth
issues
:ndIan Affairs regarding timing and
for S. 4E7; tos-.sSions regarding
mark up of Senate bill
Hatch;
aThomas
Coverdell,
Senators
to
aides
in
with KLarry Kitto regarding arra=glng -eeting
status of work
D C. with senators; discussion regartgn
p:cy
n
-
.-w
s=
wasn ==::
legislation.
:.oan
u=n
os with Larry Kitto, review of reports =n i-ly 25 hearing
SS487 memoranda to Lewis Taylor. call :: Lewis Taylor.
- memoranda to Lewis Taylor. d:sc ssic- vin aids to Senate
:--.aa ;Affers Committee, discussions with aids n: Sen. Coverdell,
7-.-mas. Sen. Hatch and Sen. NIcKles; meetlo: with Tom Corcoran
se.
Senator McCain for appointment wit: Le'.;s Taylor, Chairman
an_ z-ro::x Tribe of Wisconsin. on 5 487, nopef.11y prior to
otry o: accommodate
s=7.e:Led m.arkup. Receive word that he will
of July 31.
.::n.
set _= appointment wion
o with T. Corcoran regarding need :
Dorgan, and :nouye. prepare cocrespondence
Se-.a::
appotmntents;
maKing
conferences
telephone
same.
regard.*.;
with Larry Kitto. diseussicns w.th Pa: ::Zonnor,
4:s:___.-s
o: with Pat O'Donnell. discussions wit= a:is to Senate
aid to Sen.
rs Committee. discussion with legisla:e
:n:iz:i Aif
discussion with legislative aids to Sen tomenic., Sen.
Sen. Thomas. Sen. Coverdell. Sen. Ham:1. Sen. Nickles,
Kasseza an: _S-.
crgan. follow up discussions to arrane -e-nong for client
O Ar._s: 3 at 3:00 p.m. Ryan Leonard aid to Se=. NL:kles, follow up
dls as:n with Rob Foreman aid to Sen. Haton f:r meeting on August
3 at : :: =.m.
Calls to C:rcoran and Kitto working on appointment "n Washington
w:tn - S.
SSenators; taxes to Senators Conrad., :orzar and :nouye:
dssE:on -Oth Larry Kitto, discussions witn Larr: Kotto and Lewis
7ayo:r regarding the development of the Congress::na meeting
soneo.-!e for Monday, July 31 and discussion wit= egislative aids to
a
se=.o
weme
C=tnrad,
AA 0000282
O'CONNOR & HANNAN
3353
A^TyoNeYS
AT LAW
SUITENo
'9'9
ENNSYLVANIAAVENUENW
AASMSNGTON
DC
'202.
OI'
20004.3e3
00
INVOICE
cet
Nat-re :f
.at:er:
og Track to
M.E5E Ar.IW
T**S
.oT'o0WITHYOUl
REuTANCE
.:-se-en
s
.
hostage. 'essengers
transporta:.: . courier enarges an
is-eaaer.s :ut-of
-FoiCet expenses
P...:Cop...
Total
Ser.o:es and
0:za:
:isbursements.
S.33.95
SBE.33. 95
iA
AA 0000283
3354
OCON
NR
&
HANCNANOP
s. -Tc oo
99
PdS%S-L"*N
**s5
5.-o oc
?022
""U".J
NW
moooe
was
086-34a3
.O
Thomas I Corcoran
enclosure
Dec 2.75o0
AA 0000284
3355
ATrOmNEVS AT L.Aw
SUITE W0
1919PENNSYLVANIaAVELS NW
WASMINIGON C :00C4-"38
'E"
'.0
CC
1887-0c
4202,
INVOICE
St.
ribe
Crota
:
Bo
Bcx
Hertel Wisconsin. 54845
P.O.
PLEASE
fETULNTMS PORTION
ClYM'REMITTANCE
WrnH
.ar.laming Rer.latory
Act
31,
1995
AA 000C85
3356
zu WE -CC
INVOCE
iamr_-g RegulatCry
Aet
RE-f;N
PLEASE
T5
0-
0-U
uEMTTnMCE
2.
AA 0000286
3357
AflOpp.AEYS
*T
SuITE MW
1919 _.'.*
WAS- %rN:
.ANIAVIL'ENLEAE:
000
:c
0C
DC
2:: 8-4:c
INVOICE
=--------
Act
PLEASEaflU-
--S
0rAnt
aEMSANCE
M:Ca:
Reading
AA 0000287
3358
ArnOPIEYs
AT LAW
SURTE800
1919 PENNSYLVANIAAVENUENW
wASrINGTON DC 20006-
202)
ho
-2
4aase:
5 7-140
INVOICE
:ember
...
32594-0002
--
.. ;
an Gamin; Re -
it::.
Act
TiS ONToIWITH
PLEASEOETLRN
Y=0
PEuITTACE
leaders;
ri-tes
dashington.
bOuse
"ato, 1 WEs --
AA 0000288
-
.An 5
3359
AroR*NEVS
AT L.AW
SUITE*D
00%
EDD.Z
INVOICE
4.
be
an Gaming RegtlatOry AC:
'...''
3:594-:002
ta.- This
acAtch
aim YOUAREMITTA.CE
Total Services:
Phooccies
sance
-l
rs
Facs
-:
14
eLez
25-
26
i11s
re.r.rse-ent
for out of
:3/95 7MCAS J. ZZR:ZRAN
pcese expenses
2 95 PA C:K E. O ZNNE.
res-bursement for out of
poosec expenses
nCuding travel.
'3/95 "ARRY KI"O
exCe-ts
lodging and meals
Total
7rta:
3.:
566
9
480..
Disbursements:
.0:
77
:6 4.:
77
*****Sta:eme=f ACoun**.....................
ANCE DUE FROM PREVICCS S.ZX4TS PAYMENTS)
-ANCE FORWARD
RENT INVOICE
-0:
8610.7-
sDUE
S8,61C -
-000289
''tot..
cC It I/li/tI
I,.selltpt
ll.ijtIY/YYPpoIe..sSn
0
7111
laths
'/14
CL,
32500
SI tel. It.
Malt.'
32590-tOOt
*t.,d.epPctatIl
PC.
I
'''psI
tsp
log
***CLIET
A IMTIO**
7,5th'.
seemitrR
It Cpel. lrite
P 0C
te 267
tNete. iUttentIs 54545
St
P
..
gaeAlllm4e.
Crose Tribe
0
207
a..
eJte.
tan
Contat
AILLIG
Psot t&7w
r
....
Lelt
049
fIee.
Chps
SWCOMTIM
BuperveIolg
Staling
96l
aet
Perat
22
Csettee Peset 3
Pee Frteuee 04 t 0ftt'lta
teat Faeueot
N
Tuise
saetanrco
85ip
ng tielspaustete 5ati
STmpet
Ti
DIN Det,
Otsteat
Laration
=O00119
tIe/n
10
f1-
fNTv WfAIL
Ste
pata ta.
673=16
02/02,95
CmS 1.1
1el
i--es
$NIT -at
PJM
PJD
OtLaING VALUE
mpt et.
e.t
A"et.
Na..t
Sap.i..taa #
.... a
...
90sSD
0Co#
~a ~a
6732-4
PJ 03/06/95
6732324 02/07/95
47=38 PJ
00/05/9
PD
5 l
PJD00
a 007
* a
23
00 touisnt
2aS t
a t0
Was sla50
o
6736
0/071/93
TJC
TJ
a 00
229
tO
ix
474123 03/02/f
IX
lie
OD 250 00
71000
3 O
wts
250 00 i60
00
400
56
sit
Ceslla.
anT
00
Tepes
eat Tell ts
Ne
sorat
Ofies
testpe
IoIa
eat
o tage ttp
eta
t
s ie
P t
osetinla
I~eister
fe
s
0Iies
t eo ewps. Ilseei att
tea
750 0 leophon
al to aetw Ct aterla 1
a
a o 6 7 S
4 00
e@e
to
tilat
eedtopcact
..
.. I
.0
. .
isHes
unsaeptel
Perespa
225
00 iLos
Ciip,5
jatate
taitesast distsilitt
witsppTso
.....S speeasepit
i tiosto
sotis
s. PsspoagI
18# soCtpaa
atpotne
* t t Ieyws
t
Cope in spat
eigsata
67l1s8 0 0si95
Po .m
at ihs t
Np.
as
C
it0t. ate at 1s C:.lat
alPl:..
Nasa
dittrats
Alhias 03/011"
.C.
wiA2lrs
.. 0"I
os2tM
t Pp topVersa WresAts
a"0thsee 0teap
diatwestesswith I
Duceees
sits
ftI
CLIET
ER
MatE
a
Protesse
Mm i4iOS
040/5 Preforwa
Statement
t
trt
lt.
32594
Hudian Protest
94-0I
Debh
nFi
as
127
01,3ates
lat
-Nturetof
to.
matter,0
og
trek
Pa
3,,500I
*ewith
1 Mitte, tol t. L 1a1ler
g8tlersi
review
**tument. free
H
all t.
TTt
P
WC
.nnergaI
.
l,
M.togShit
..
aOW
1.
hiat hlt.e P
slionastuUn
obiltela
Chairp.r..n for Mitsn
delegetlem.
discussions with L. Mitte, diicwaiieni with P.
OConner* dinouesitne uith 33 iP latE,
.dornee ha .
OCnt..r
to
latetr
*ecretrg *abbitt.
dittns uttiwith L Mitt.
Revewatserandum
iPe P. DCeiuer, awarandus
to L
Tagiers
*iscuslein
P. OMenner,
at'
6761e 03/0W/95
67376003/06/95
673746 03/07/95
5X
TJ
iJC TJC
TJC
tJ
673769
03/00/95
IX
tiC8
673705
03/09/95
OX
TX
4 00
20 00 10T0 00
4 00
3 00
250 00
2 00
250 00
500 00
2000
500
375 00
I5
1000 00
3 00
150 00
dinctstian,
with aid.
tall i* J " .Perber
IM
50
3M
750 00
500
with P O0Cent
0
.seulaswith
aid. to intrl.,
750 0
Oiscue...nt with
3 00
2ith
03/10/95
IX
TX
674209 03/13/95
Tic
tJ c
674299 03/14/95
OX
TJC
474450 031/S95
PJD
PJD
674305
TJc
TJC
50
20
00
250
00
OI5
00
625
00
250 00
750 00
50
3 00
625
03/13/f9
S00
2 S 00 7g7 50
250 00
5i00 00
3So
750 D
6 00
787
with alt
ho
inecuet.ne with P.
with Congreseinaliaides
375 0
hisuoe.enw ilth
L
Mittts
ie..tg.il
Duchenneo.,t cel to L.
Tale laditegalen with
aid. to 99treterg ashhbitt discussion with P
Onner,diit.tian
with L Mitt.
00 Diousin
with L. Mitt., i its. e
ith
iit
stal9s disiistent with tongrealenal
aid...!:
leestens
50
1500 00
witt F
i
asica with L. Tagisis discssins with L
Mitt.,
ditcet..e
with L. Tlett,
filling hi.
aeetintg with e. *tihii**.
w*1*
OPPiie,
with L Mitte, dis.aoseiin
with L. Tegle..
PNting at
teior.ath
a Ce.ceran. Il,
Mitte and Te Cliea.
iNe_.tIg at ANC with
Trusan Arneld and Chait.n e. Pneer
head
dincuswint
"
Recretarg
hthena,.lImbittdlatte
g~creteru Mabitt,
6737M3
laterit,
diss..sina with
getrg
.
a C.onner,
Yogir,,
awith
Mitte,
L.gi!.-
ti Anstetag labbitta
3700
M 750 0
25
144
to
Pieting with L.
Mitts
:9 Caspers h Lghrand
Mwasng
wa.,.-a
eenoande
o H. fi el
to L Ta.t..,
with L. Ineies
meetino with L.
Mite.discus.len
P OCannert. I Center. Chte eP *w#Pr
ha lateter.3enretegSahitt.
0-Cnne
and L
Mitteimeettage
and H. Steenia.,
with
verlels
Dem:etatinstienal
iampain erganiiattens to
DiC. DOCC
ilttisile with P 0 Onner.s
is
474655 03/16/95
674310
02/1/95
PM
TJC
SO
00
225 00
112 50
S0
250 00
750 00
3 00
c. iaonwith I
hittnl
11250 Sdit.e
een with To Ca . rg
.t
inteirior
t.d
Cit
750I00
int
*
t V Clier
e. ting,
'metrandm to Pit.
report hi L Tagi.r
memerende to
L,I.eg, additional Ciecu.isn
with L Taglle regading Conpers & Lb...d
dint
oting
0. C.
DaCA
CLitNt
mtIES
21t
/5
32594
50594-
Prprs42ka)
er
Stn..1
at
*weCLtitNTiW50ttI
St
Cres "titt
P 0 P.. 27
Ine
.tI
...
St
(to,, iIL*h
*tudaon Penget
.i
I~
Ir
Pag. t1
***'*nrl
ralr~bs
Wiaten.in54045
Hertel.
en..
1ntrus
imtest
mIiri.t
...
.t.
... . .t.
Cwttt
Perwt
3
Arrangement
PILLAPLE
Pee Frequnt
M
Cent Vreq.ea.g N
Pelaeue iling
Truat Retatner AMrent
Srust Petalwor
wount
Pitting Ipetrus
tlen.
fPenttiy
..t
P lrtg..
.t
ru,
,,
Chr.
lagior
Atter...
ih
.Atto.rn
ey
at C
or
.t
C.rroran
rYate 02/O/TA9L
Status, tP
Lotatten
t0
IMe
T3w EtiTAnRitalL
1ILLI
u0itat
tadese
Pat.
677093 04/03/95
677093
04/04/95
UIlt Cras
StAt
IJ
TJC
5JC
TJC
677102 WO31
770.**
was9
1*
540
2 30
TjC
it
Heus
230 00 625 00
2 00
P.
Amount.
*ate
Houre,
Amouents
50
625 00
tng
laterser
Ot95.
TJC
TJC
&7 0430/9 P
6771a
641St/n
0*y 04
00
P 0P S0
2 00,
with
t,.uiar
6de
",oeparte.,t
wf
Afftelves review tetter from
Set
labbitt.
t. Son Uleistwn.
IPft ia
LtA
wI ith
ti. t
a mh
250 00 500 00
2 00 500 00 Oit.ut.le
with L.
te aaerwndum tL
wit te rweartng
iettwr fat
LIOale.end 4
C-1 itt...I..Idl;
2 Mwith'..I
oo oo
2 M 2so 00
J ins terusiwns with aidwt to Prmbers wf the
.00..
500..
00
...
0 00
*iall
3I0 04/07/l
Preed
Bervates
230
225 00
250
00 300 00
112 50
00
30
2 00
50
200
500
eld.
to
*t"|i,t
te
with
wHuse wf
*.
twiott.*
Cwn,
Deg.
it,ttia,
att
Tractoti
00
itk
wha
Dutheneau,
report
nitte and L Taplri
Itruna
with
An-pril 6 ... tin .e t
dtats
with P
ivioo
Iat.
5,
.p.gtn fart
0'"nw
0Conner
tharing
t Whit tot
anOleen
in
tup
w Irt
Cepnadent
112 50
500 00
o.rilte
.egti.C
enotpat
Wen
itte
lso
inuse
wport
i
Colop
diuetens h
t .n a
teepqand P Satrerh
of
nt.
0S/"2095
ot
CLIEr
32594
MTTER00
32590
Prolrm
St
P..
tpt
1tt
r.
Coot.
Otto.
00.00,I
tdsot
t..0
r.
gt
tustoswith P
L
Invio Zd CL
Ottto regareng
i5h0
.50wh.oogton
Post tooestttton.
leelop.t t
tudton poojrto neoopeper
cltopsfor
....
h.ton
.
Post toor
r
documtl
from.
* tatte,
review of tHoChucok steenoresolution
appootog tudson prooet a.d od
s .ta o. eMt
Durbanean.
at
67710
67653
47774
04,12/95
04/1995
Otto"
Ic
tJC
PM
S50
S
tc
PA
t.ic1
250 00
t t
2 t
5M005 00
Di
po. . ita.teen-tsrg
ringH,
lt tt
as
t stdum
t
t .
tribes
nod od
iniodson projoot *ppiltation, preartic" of
mmrnu
and
dlivry
of ta-a snd lotI
projpsctto
regarding etson
op.
Otoopapt
ax
September
It.1994 Onolivong shties b
PD
0urr0y and Arthuro Anderson too . reoles
file
on
Pond5ng of No S0asntisc
im pact.,
dosruostooswthoood
to totrior Sesretasy
0ebt.dosoossiont oth L Motto. draft
ttr
orto Seoa
000'mondue toL
Meitoten.
,,ash. Otfo11ot5
PMS
50
.0
225 00
ItMSO
50
0tsuoston
oth
Lasett
677770
Ot19/95
tx
ti
200
2500
25
50
00
20
0000
50000O
625 00
50
425
to. Csooanoregarngtfe:o
Dooptong and sedanog 0.. to Ms
Aent
Dattussostregerlingt
ite.
HtouseoathP
C
onnerstfaranoum to stt
House
il.
Il
Avtoo too P 0 Connerpomeoerondu tt L
Taylor.
00
Di
mou
stl
Coonselor Jt
0
te into sepety ton
Duffy
ltter
and
H10toise and Counseler Dutty.
oith L
d isousoilens
u0th
BiA
regardingSoHeto-ser 14.
0995
oerrespoodence
otthttinneseta
toibos
ototoloh
o
it
s ot
a.
itoo
5O Dtsoseton 0ith Lorry Otte
oegardingt ttiog
Itteroc
lootmtots
to
Kittot
ditusens
47672
67407
M/22/99
04/t4/P
P.S
PM
Pm
50
800
22500
102
225 00000
50
50
00
t12
Lsog
at
at
to oeottAohtto
rear
onoatcsiton to raite
too HudtOsa
tssut ith Prestlent Clinotno to
tIdid ot hap from her
Metingto
olth
too Poeoident cn too Hudon coot tract
isosuo oith 8ruce ttLodeyandLoadeooeoftthe
White Houoe staff *nsoering ca itrtom
Lottto
Avent and hor stt regoardtng
Hudson Doo
080000
tract
Mannooapolosif
trat
67696 042R95
-411"
04000099
Tx
P.
PM
U2
50
2 00
25000
625 00
2 50
625 0 PtRepo sO
top
ryt Otat tote
beoro
t Csoe
leatlooa for "toolutttor.
ends
at Dopsrtmeot
of totersop. meorandoue to J Otod 000.0d Mrt
Epotoin. top atots ho Sonoto u0notantone.
225 00
050 00
450 00
00
Mpoton
to
duu*n
t Pootr ott
tot
etoot or.t
Matto
.0n
0
ttoodaotestrotoowtor
of
0'Cg
Cato
_t
05t02/95
CLIENt
ITttER
)I..'02
Poooa
tIo
32394
32S94-000
SI
t
ttdono
Cot,.t**
I
rotost
tN t ,..
wus
utii
..
t,tt
.t
e n 0*is.
-,.
P..o
st.n0
thoDNC
671086.1
M29/S95
T.
Ott00
I'.
Long. ditance
telephone
cootntoe.
usth
Lora
tartgan
oP Oh.
P
hotd-1
ow.lttto
to. 'loot
Cd'
ot000 no titte:oa 1tom mt
ecoon
o.ding
'oattngottthPresdttoClinotn
andstmpct ofrL
AvetI
ot rs..d
tot
sto.
arra.gemet.
r.
Hatoanytontwenttoy 0hs.0.1 for trthat tndtent
3rue lot
ot. mttang wtth
otott asses to Hou.. aot Seoat. hearing
9
tiscuseloot with
EptenOt top
osse to Seoator telitttnoo. 1ever1S dittuttten
with
Othison. oide to setroter
Babbatt
t-tu.
hat
comabtot.
67087
0/26/95
I,
3 00
0 ot
750 00
00
70
O0
o
o ot
r
oit
ds.utions with
ITtUtooot.
TOoomwjsth
thM0Duottorftotd
Otbt
h
.b.op Ho Tc,
(hoot
Ireho. tdisrton
o ith S Litol
tof
Poot
patvort. 4iscusson
y
Iahor op Coopers
with
with ond.
670084 04127/9
pJm Pm
2 00
225300
230
4300oo
000
430 00
3 I 00
730 00
Callt
toi oto
P.
Tyototouo
04/27/95
TJC
Tic
00
00
00
it
ios
Call
to
D
t
ottatalnt Dhtpotteto Senator
ttottttone.d ittuston wi.th H Sabbertonoetds
to
.e.ter
labb.tt.
oatt tto Ltatoo.
d itcuttsoot
and mwswraoom
to Coopoos t.
Lybrand.dIOtt
toot
and .morawd.
to poet
arttt. tratoggttottsioot
t Epetato
totislttiveo
atroctot
for
StoaterHo ttlltone
Mr
*utterftelt. totba
attoony
twor HewChoot
with
6740
M/2W9"
PHI
t0
223
3M 00
400
90
Nttn
cuth
Lsany
ttho
La
roal
aod
toorerot
Ootioot,
t .ooin
o'.9.. Ihtw
Pwe .,
Herter
aOd
tho
Indian toIbl
t..,
ttclding
Louit Taylor. to d iuse
tho
udon:"
Coy traot
ad toetting tupport 0rhw too Charao
to
tateroede
the
hite Hooto. Further
Susttwo
th
KOtte re
meettngwith
totld
Itio.at tbo tohito,
Hoo.
10000 Dsteottot -it
Pat OCooer sOd Loot
Kite
regartttng Hous0eeasttaoe
on ont tess,
dttocutticonwith 0 Merteroado
to D
himn eoranduofrtom
LaroyOitte
aothored
by Too Coottran for
1 Owotor. 0NCChatrmat,
meeting
op tothal leaodoorts0
fo
Mantw
aaoae
e
yChairman a02 t
h it
o
dioot
StueotaOh
473724 Ol70g9
TX
I-
IT
400
20 00 t00 IN
utthPat
NCooo
tot H Itet,
top
Protiaent linoton. regardtty lart
cop r to
ih
our
triseont
i, to
op
a
Murrti
Pay
ant
. 064
Dw
CITEM
s I
Proter
95
32594--Dt
-u
w.rei.
P.ge 1726
Proe
iii
tt
So Cr .
tIo
e.
PC
8ee 26T
,.,to.II.,,,,T.~in~
Templete56
Super-.oing
titerney themes Corceran
*nig"
Attorney thewm.se crer
23
timear4.ret
C.strard PFrmat
3
Arrangement
SILLABLESttt
........ p
t
P..
Cent Prequearg
PP
..i..w Olting
TIrut fEtRine
Acont S
trus
Mtiner
Open
02/09/195
0
Petlhly
MAIL
o0DO1
It.s
bte
aaB,
howaet
Sellinglectructifone
TI00 ENtRY
C0~O
Osw..
.1it
ct
60185 0501,95
PJO PJO
41359 050295
P.,
PJO
01LLI
-,
91.0
at
25
22500
00
225 00
e.t*
on-
VND
.or
25
25
56 25
225 00
00
22500
56
Aou-t
Report
atf
Se1rate.. PefPrmed
to
fDNC
Tliphone
oenerne
Finitht
8139605/03/95
PJD
PJD 5
00
223 00
816020SD"e93
P)
PJO
75
025 00
22500
225 00
Call
to D
appettnt
679537 05114/95
T.
0 00
w5( 00
2 50
225 00
60
75
75
2 00
166
with
ai
i..tin
Fr
altHrald
Mrrr
regarding
itieo,
Huse
ori.eig.0 T Carteran an Friday ftNtC
atMahte
appetttent
regringithe
Lenwfgdito.ce
Lerrqfitt.
75
ouse
wrteet.
fteleph~o
-Tphese ctta
to
r
a
ft
C
Ow Larr;
tte regard
iftg Choir.en P.le
me.redu.
to
i.e.
500 DO
Discusilnt
with
P .C..nn.r an
L p3ttc
aPt
tr
at.
ta hitw
Hose
regardinlevrgwIow
astrquested
by ft
Pester. DNiC Cowl,..,,
* iscuselens rwgardtrg weetiog with Matit. Houe
DeputyChtiefet
0taff itbIhe
disacslone
with F
atensweves
dioscuitns with
to
Senatndian
AIta
ut
.aw..itte
' lateior o-firile
with Otpoteet
562 50 Draft
itt.,to-iarold lt
ald t ite ouse
.etting Parti reseeosto
hsperwovetreatingtrus.t
iland. for Cooln. sh thew Musan.
*eg tewah
Ditcussioftn
LwarryMtto rhcing in twits
set torth in tlt.iesltter
Mirwhd
awed
40ihia
ft5/ft7t95 PS)P.03
36
50
2 50
with
WIi
report
N
CLIENT
903TE.
DIE
0/93
30394
Presorm.
30394-000
sttnpt
St
Ceo,.
Nueson
Pge 1727
9 Ius nIT.ena
e4 100
Go0ol'
rTse
Projed
00
/ ON
..
no ..
ON .
// on 300
3no'
/'
NOT
te
tI
00
S3eff
0.Denn33.
/0/fl
003430 03/029/
OX
3X.3
P.
Pm
I
IN 00
0300
0/3 00
00
revi
in. 30dinetee
3033
130.0'3Og~e*
3...........'
P
t
Lo Mito-z
m0louran0u
to
o D
P 0
03Dscse3n3it
0730
.e.r
0tcaon~r
eLn..,
6004963
9 ...
.n
.ettr
t.mrandu
5D
II
- t.
meIradu
to
I
M642105,0,93
600069 03/309/93
P
3.JC
tac
PA
I'm
480093 03/32/33
TJC
TX
00
00
30
030 00
30
023
00 N
00
030 00
330
-Ne,
30
30
31 30
3TS00
30
373 00
Fm
C
6403
0/12/93
640&10
DID/10/195
3 30
12 30
117
20 00 073 00
alr
Conner
telephone30t3fers3.
him
4032
03/15/95
680332@3IS/95
681646
03/16/93
PJD
VJC
so
PJOC8
3JC
PJD
PD
T.C
Ix
203 00
3 00
30
12 SO
20 00 375 00
273
00
023 00
2"
00
THM
so
330 50
30
373 00
3Ietorpor
00
203
00
i.e*oCel
artentant3 a Pepert t.
e.l ITT
.te
0lcue.tost
with P O'Coe
ree0at0g
B1et0
thito
...
03.9Cif * . St N I.bee
di.
ooA.e. with L 333te.meerd0
to two
/3/fl
2 DO
7S0
Te *teera regar
480343
to
Meter.
Iar%-e .eotslttad
.e..
.por to
antod 3e.
trn
0
sc.usl4
o ta.
.te60use07 00e. o t
3330.
333
*,0.
0tte0te stee4
Seernd eoaL.
Te3e3
00300
aNouet*.
o
atte
er...3.
rpr
t~o
.o
3p .aa Preaest
t03te.
aeo
temoetoheeto.e9r
3runde" and raretrack0
DOevee
30000
Depute
with
Peet
P.,.
-'IF.
Ctt
32500
.taogt
32594-000
"1652
05/1795
to16o4 051t1/l
"'It",'a
St
100
.00051
0S22/5
FJ
P.fl
60020
0512393
TX
OX
.aS
0S24/95
Pa
.0
a0
TJ
s0
on
20.
..
so,
00
080272 05/24/95
a , ,s
00ds00 isoet
l
P-
03/19/93
60054
Ia
crot.
0o
3 00
-ia's 02SIS/
Pa
OX
PA
50
3 00
I..
50
regerding
dels. tn
Dsceteso
with
Deved nror
ust toa-0.
ge ...ng apatet
evewal
Street
.. ad
o7S 00 nmeiong soth Fraoi.
Junlatcte
on Delssre North
testing
with
letter
to te
5se
tos Castern oe drsit.po
sent to 0,nneote delegetoon to Harooldltest
regsrdmng tudsono dog toat,.Ltog diotenceo
i th Lsrry Mittearranging
ttlephone renferents
seetong s0th Minnesota delspotionso Meodneedeg.
21y 04 on asDhington.DC
Do.
ti
-lth
ssea
D Im
e
ktre D
:h IC'leorln
clot
dele tont meetgng olith 14reld
rrtln
mate
0, DConner
250 00 6.5 00
2 50
625 00 Doc1sswithP
00
Htoose
ttatsnasoetiansthDepot Cher
14 tto
discusagooosiglh t oted
Stot
ttte I sod
e
tt
t
telet onee
OConner. diocotesienesigh p Taylor at
iottor
Duchenosu.sod
sagior Ag.sorates. *,att
Co
.re 0es Dabteeto
and senda
for
lonesetes
thesof@ ntte Houstto.
discussions
to Ht
ith P 0OConer and L
Mtt. regarding nsot
on.
meetIng o.gd
neco4-ti4e
and tr
ltoth tar 6
00
Z 0
00
2; 00
e.pl esng
our str
.nsoks
oor
oletter
Prepartien
00
00
5
23 00
House
isn
0600
to
oelegation
Cogeaea
sh Pot
dstt
aiae starsd iot, a.
wsth
Lsrtg Mtto.
0 Connor. thes otten
of oko-hutb
discussion sith 0 Krasslhi
notion. report to Larrg Riggs
rIl
t
CC
to asm.Eletro
tcA go t
6750
300
075 00
225 00
..
??SIo
d<5
1".
50so
tart
Itce
00
Mtto
223
200
23000
750
00
00
ogagenet Flsoanc
Camittee setta
his
to.,gree
appeitsomnt
0000esotn errange
to toOll Haood
Ag Osret Cteoenko
to, inaditoCMero'sth
Ptnaooooitst Osooooro ot
0t,.
::9
.
oith Peter hatght and DaSd
Otraus ... oaer
dog
indaepr
regarding ode....e
o tra
Oth
.g tt.
La
750 or
Pot 0 Coaner, dolliver9of preo**o
tt., to
toinnoetel Congrttseal
D.Uegatten to torry
oelkono.
Oitte ant agdes to CongretosMan
Congresseenl Derstg., 0en00and sbe.
tonetero
lttor
proporoation ap trkf
with
For correspondents
Desohts akd
n Oto.
at Start
whttitoNeuoDeputw Chiol
oth
ga
ditscuaton
Otteo.
to tLarr
o0f0ittals
ithO
itO50
to loo Corceran on aiscoteoso
00kotodinon.
Peter~ night. Davia Strauts t
Matuliffe
geet.n sith terry
srort ons
750 00 Discusiaon
sont Pat Conner., Olecuoaion.lth
oith
dtorusaoent olh Pat 00 Cnner
LryMotto.
sta. go Vate Protsodnt tore. dtscuetenooith
sith
issuoton
Morrow
Ait05/2S95
10
205 00
40 00
00250
750 00
50
3 00
semorenats
Reporting
teoseeon
For
Pae.
Sit..et
tPefera
St
Cipi
isPuPe P0
miT.e =594-UPt
a'
Oste
Cltent
0"
.'
e
/95
23594
...
i
,p
st..
Natur
''
rs
tes.
bi
I2
to
MIM3
Ile
05/36/93
10 ol
tOtO
It
tetthr
Oeesteiof
5itraterg
VA
gabb
~~r*Cait.
tst
er
app
Ehtsuseiens
pith T Otieer
discusaile.
*e
6t1914 05430/91
IK
I.1
I so
ease
D
Pic
iA
Pp
tic
So0
1e
00
250
00
00
SO
to
40
BiS
pith
Atle
405925 05/25191
sItle
Merth
Dets.are
fee
Carterep
S tork, - Opts Pa
of
Ne-Chul
re.
lD..ag.s
litle
0ee.In!
p Den Pe..t/Pevd
Mee.
lteaptendvp to 5ep Celiter
ltastenese
to i
ltiel/eh.
M pr.ds te L Segler
mith
Dit.cute.
with Larry Kette
t
Ca
t9
Se
D
Pap *1
0IrIe
00
1700
b
eseatSte
to
Pite Peeiient Gerp
Se ..tp,
with eiwt
F
SBute
iou
isht
O ttt
P sSt.t
e.
regareing
411676 05/3/9%
dt
cease
P i....
.tH..*.
H...teep Nativ .
pith pid. to CD. grast
I
ieu.
i . t Congresee5Pa Oaili
s e eith
pith
Osl
L s Pitt.
Do Dir.
to
iti
s0 375
00 1500
290
lis*sto .
o..
major
O*1953
/cOr*******
USite.ien
Pt
~ I/r
1.
I DetalL
adtme
COM
Datie
sOs
tO,.
Phtstep
1/07/99
ig/95
les
023
09/051/95
00100
OS/Omv
**943
09/31/9
Ph.tte
Phetesp
12
I..
am
M/31/i95
14
L-g
SO
Leag
a
lep.h.e 8
DitePte
449
449 00
V9
tePes
ease**..MeW9UNIALa.eesen
Pt 0o
99
9M
999
9 00
556 00
999
580
78
09 PC0
ptttt
"2a3
OS/33/,6
MIS1s"
14
Dilte,"
L-g
telIphe.u
Stat-nge
Telephe..
m9
A8
'
Phsttiept.
1.
00
IS
01
"
.f#t
......
).-g
Letg Pi
Asport
"Ali
Photetpp.les
Photspt
4
-t
cdl@e
4tStS
Long Di0a1
Pep.rt 3/9449
43 LePg DeItiephn
1eport S4M/9S
Telepho-
-i.t
Cede a*ta1
Cti.
Dateil
-v
t~tt ti
St
3:504
t**
or,~
t do,. t.,jnt
'.,t..,.,t
't.'tt~
t~oq
tte1
20
crol.
P00
000'I
it.lunonettn t4ga
TilI*
StIN
F et
Forat
st
Casttrt
ttge
iotgto-ht
0]a
3
SILLAitE
Arrangemn.t
SittitiA
..
c..t Frequency
ton
tu
tnt
or
no
oven
~aoa
00
eatus.
ont'ottoo
whomas
C
oo/0n/1997
Dat.
t'ti.........................att.ttt
...
h. t 0..................
)~rN
Motl
.-v
L.t
9K,
.I...N.......
0ITg
Maolo
iniese
6P2691
Dte
Mtort*S
tot? ttew
*tnt
tAq WA
Iet
...
Move
r...e
'0
0s
neetag .lth
L tii
.
regadigappontteent with Secreterg
s.m....to
n.-us d ths
nnt
sL.Ta ior
Sbitt
lotin.
Avt0.oran
.02674
"I02/93
682703 06/02/93
PoD
PnD
TIC
1J
20
50s
so
30
00
to
ITS 0n0
0 ot. )'5 00
ontCofrnrnthnn
:"::."
ttt".it!.::n
0..
so
375
Go
Discus
0.enel
S459 06/06/95
P.t
P-
OJO
TX0
50
0'0
~0'
No OS s
a
tst.
agernag
,nttistn
tnt
ith
cettor.oo
nittn
ad
nail
and
iiitte
oe'
Sentorn
4 dinscuins
with P
ofnterlerlMncCainsassnereintum
it
tsHaold
Ott
in
,*g
tntniOtipiiolt
toottrn
OTernt
c ..
ntnuloin
.. Prneang
it.at
telepho
tenference
0
3 So
060o6,e5
Catere,
"tnt:::.iitti"!:rn
lint nuth
Deaten
o
apoit
68t3O9
itomi
O.
tttD
aragn
Itte..
DInrust
ln
Dontelitegaridingiente
roe
ons
nit
tnt.,a~leSi
ni
nin
AA
**A
pop. 050 t2
1.
325
.
I0TEA
300400t
::
.:.
. ,
*,.to,0ooD,,
***tuesen
1000p0
t"
*it.
...
reg..
O/M/9O
A0S1
et
tte,
to
me.erandua
t:::o.."...
...... .ti
to . .. I..nvtt
L.
%otad
too~emigtelementa 4.to
Irs
totott
arte
474 0K0fl
Os
Ma
M 3
togt.. lIi
the nllntgin
'"e1n.1 Itt p r to
N0n
en
lith P
Dnnth
sn
wlth F
O
eeas
1:otiag
Paet
tCai.
F
hakeneus
P 0'*teon*Ile
Cln o.....
.oo.ot
pottttootto
to L MOtte 0epert,
to L Tegiert
Oeth . L
ite
CgO~
.nr
no r t2osodig
SI.
di
tosetei i th
ide ite
Hoe Clo
o
Ato
Psootto. a.to
a
.e
o
L
reit
Ater
t...11
repart
ammoo.
4000
04il2105
03
pma
/le/42m
05
.p
00
05
250
250
0250
(1(1 .23
Ftoot
50
2 30
tt00
gilte.
622
ea.C
It%
aeso
egra
...ne..tte.. el
ttotlst
Mons
et*Pi
an elE
**leVondoe
t~mn
400
194
40457
460t
0'tW
S/gp
otfat
tevoal
aldt
on the
mato
.Subuditg
oil..
to to
P.ootto
tt.
t
tkes
t 9 L loeiors
itottsleot
with L.
isuslee tl
with od.. at
g..teet
of
t.toe.otth
T2lor.
pa
p~
Hmiwnox9
50
00S 00
10
230 00
2 50
RS
ita0
400 $
aLoterCSioos
otaote tetleph~one
totaio
tt.
to
SO
So
423
SQ
6235
nte
In.to toseaith
C..IC.l Laow
itot
.e0et ing
0eettg
in
s
toettog .n oetto. 0rom Congreasseo ant.
Po**torts
t att
loot.
a
loterters
Datetoetn regaremp topport to to given to
Ctaitee to Re-eletat
S NC
U toeteeloe
ttse
elotuooeno
ota
a
Ouoteeso
alth oldo to toosto, lit.
Chatrs
of two
Bete
len Ap~etre Canattess lit.es*ttos
with 1IA effIttlaes
tdisseless
witth L islate,
disrualoot
*epteseotative
oot
He
ItoCt
.1., lc
.00,00
* .
.Hetn
.. It.
tsg..ti
dt
p..
.jt.
ootiog
olth tnitolee
t tett
Hotel
00
Copito tmil with L Kitte, enettng iooelving
ltre
toolot and L. PItte with T..
Ftete.
Iteming Coal otenert to the Nettenal
ladian
DD
aitt
ya
,4
14
ox
00
423 00
St 23 00O0
50S
123
00 Dttcuteleot
wtth
Ine rSecrtert
hitte.
tooruloo.
P.bbitt.
*emerend.e
alto
to
nst
Poge 1971
0r
oSt
41100
3259-01
60074 06/20/93
so
Hu
tx
'Jo
I 0
u*
seious
..
r.
500
me...onwl
to
00
t 06.......
d/t./Jo
o
.s tu
on
iues
ho
mn
n
o0ne0th
DIGAMS
NT
Inde.e
Dot
so.
.339 00
6057
8450
077.9
67269
0760
06/1503
06/141
06/25/95
06/M/95
14
06/3095
04/10/05
*6M0
06/30/95
1:
16
"A11 0A6,223
"
41'
06/2
/193
06/03/93
Loop
I.....
DIttan
Poetage
t6
.7459
06/Ot/95
17
446i
08ttans
25
25
25
T.Iphon.e
Deli
999
000
*
90
.....
0hno.
16
tMELL
ofPtht
epon
40 Phot-ooptt
00
00
14
I 0G0
TeiphoO . 54
.....
.or.
Proe..s.g
On
50 PolaICM E
tO
z
00 t 40 Pootocoe.
2
999
7
I
97
90
S
Phole.op....
Lonp
000
P.ot.soss
13
Dteerruptton
100
99
Photeop.tt
06/2/5
15S01
Po1 topt
1s
13
.g
boro
S.avonti 0.aont
0
At
12
13
th.
COm
S00
65723
..t i
of
CO 50
MtAIL
06/20/5
974
.5
,ng
Co gL
tt
*mattA
el,
lOTs
******************.*Tit
.31
io
po
Odon reot
99 0
320
Ph..ot.t..
2
25 A
0
2 00
000
Photorop...
13
Loot
94
Dtnc.Telephoe
I 09
4
03
t*Iephone
14
IOS 00
336
55 Postage
IS 16
00
I
o 00 34
L-ong ditnts
s.
2 25
33 75 0ord Protesiog
.ttM..........
2 05
33 75
i
99
00
WASHIN0T0M
07
EtPRCSS
WI 4/21/95
ADVICE.
IN
trn
090115
veri.s
Delov
999
00
7 93
999
00
6 87
WASHiNTON
EMPCBS
ries
SERVICE.
IN
iny
IN -
In
9015
9901,5 -
9a4e 09102/95
Pro4orm. Statement
4,
1a of 0
Pr ....
-om as
Dim
414445
3594
St
Cron.
Iase
444449 32594-5003)4
udson Prayed
44.4
ertel.
ee
4.,.
...
I....,.
Caftterd
Ceet
Fe
Sling.
F...
4590(1)
04.449
tang
4th1ma Coree
Attorney1.
..
*3C'1
0pen4Date 02/04/1995
Sttu..
1
4e 3
9ILLA9LE
Frequencey
44)4 Faq).,
Orn
IW44ATI0
Arangement
Page
(00
444
C 444.44
94L199
H.
44444
90
Instruttlenk
Menthly
Dat.
INIT C4
495361 07/#OS5S
6S59I07/90/9S
TJC
TJC
TJC
BAT
TJC
4 50
BILtim
A.
Maur,
50
250 00 375
250 00 1123 00
VA
Aount.
u...t. Hours
00
1125 DO
450
Ser------Performed
1 5o
00
0'C 375
nss,e
With L
684009 07/12/95
TJc
TJc
Tic
7JC
2 00
2 0
250
00
250 00
500
00
59000
2 00
500 00
500 40
en9
54
1.1
390
909
M 750
00
3 00
50
with L
4Kitt44..s
, novng contact
n
4'4 J
07/93t"
WithClegelative
9*Con gres,
Al
4lh D n
0.9
941
With L Kitte, di.s.c.s.i
Thes
e.FI"aad
d
th 4le
t. 0
to
t444.
Iin
A a
Comittee ad HoUse Suttemittee
on Native
us
44M,14
disres.lone
4ntheM.n
del.e.t
07/11/95
Ices
th P
A.ffare ef4I.,s
699999
Oitt.,
9h.s 4.
wta4 4..4.
. 4C- 4
9.....04Conner.i nWith
L.
es
tote.
4.
Minneape.t4.
9ter
Tribune regarding4
"Ij~4 lit94.
111-,
.4
n: 4"3914 Hud4.n
444,
alth
runl
emerge
Co.. .
.. sl
pre4ort
n4
tL4it..
4wIth Co.n.e
onal *44
meetent
es t
Seao
ith
tne
. .
usl4not
oprto
-ort
o.4. .
w frea 5taneset9
Mr
,.
in.it
....
egrI.g
4 .
. ..
76
2ame
06/02/95
CLIENT32590
Date
e
no.
Ia.
oat
Oro.erus
PFol.
Pnroaoa
it.,
Stares.n
0t
:s
*s.
..
Pags
euu
t*
*07077
07/04/95
Pa
P-
* 50
.';
0n tt
5o
ass
tO
aprtmnt otottnqaryq,
Neto. Aaerh
toallours
DOtousson
Mnsttog
r0eg.oaag
with
15.t
alth
disoossIons
n SbemIttee
5I0to
On
Larry
need
to goto
Husot.
M nnelspoth.
Mr
andv,.
tatithltitrtnIt
memerstando
Iat
0
altoorne. Dosousion0 readng necstyt
to
1o-topetth
itarod InHs an the
hlts
House.
o
st 101 sod Ionry Mac at ths Comaltttee
to
St *et.
outtlintng fund raessingstrategies
50o
L
disoussions
with
2ea.
to House Natioe Arl0an
Subtett..
loorton with partner. regardtng 'urther
t o anie noas and Setretar
.oe
Fabbtt. doastsedoneith Front Oathene...
regaraengGoorge Bkline.Oheadeoftherelevant
agenoy .ithin the Iterter Department Ira.vove
Ithto.Huoaen
projects
ITseens
ath aIdes
to Manonesota
Congretsstonal
delegatlen
000
Dteuosens
oWthP DCoo-ne. aiscuselooe olt"
L ntte eatoson
otth aides to Congressear
Longley.disoasIlons et- *ide to Cogreaase
poater
606020 07/14/95
aMT
07/17/"
6".ar
0118/"
tiC
0.
T.
1o
Tx
Tc
2 00
Z50 00
200
25
200
500 00
00
25000
W 00
500 00
nosoionsith
00
00
200
30000
Kitte,
temooandueto Los
ttoerseordu.
to L
sauissItons
IA pabitr lnferestoo
ofteetols. discassIontolth aides ts 6A
otthee.
ditouastone
s~th Less Tayer
mee00ting
ooth tooClIdden. Counsel
Ito
the Houso Natlas
Kiteo
altO
ga1.g
S407065
57/9/95
464462 07/09/95
687016
07/20/95
464697 07/20/91
611571
07,21/5
~7
07/21/95
P10
P1
Tx
Po
Po
T,
em
P0D
I0
2o
0 10
00
200
25000
50000
tOO0
225 00
22500
150
25000
375 00
I00
25000
250 00
2 0
250 00
500 00
50
3)050
tang aistanoe dlecusloos utth Chairao
detlont
of Interlor
Opartae
retardIng
aooeeine st the
applicatoessr
rejetan
nuason. lI asg trat
BondIng tacos to Chairman
Footer, Meperting te
T Caroerae and L Nitto
regardIng rtiteriavoiced kby oppeaton
2 00
50000
DiscuosloestlhP
O'Osannell.
Don Fesier. Charmon of the Doeatt
Natienat
comet
toesoeting
0000slde. to Congreessman
oact Matal
a5nd Congross-ar Joese
0 00
2250 on
oefng Larry
Ititto
onmygonerattentolth
Chalraes Fealoro e
tOheon
0 Dtsuestsn
Hoosard
regarding thank yon better. to utto
ebersstofteragress. Diotuasionoregaratng
land rateling
I 50
375 00
eorandue tot
Gleett. disnuasions lothaids
to House Native
AericanSubotmttee. lotter
to Senator MctCain regard Ing raaerable
oMasen
atonrendum
00
2 00
250 00
Osea
a tolng ty Interio
DepOtartment I
asaining
reques0tfor oetoarao
ala ansostence given
by Senator Mrc~ato. oasigr thent oou looter to
500 00
Ditits
thent
on
*ou
eals
nc000tori~tto.
Iretero
for
tribal
cra
Headers, realsea
to
1 HamaN0
Dot. 09/06/93
PrePere.
OSNT
20594
Proor.
10a6los
Dates
299'e
Staeen
00h31V95 too 00(t0,0
32594 c001
0t Co*** tr00e
Hud o0n Pre,91
0oert
*
ntO.
Do g
0th.
etEM3
0/9
630
P,
"636 01/g7/9
P.
oto
MM59-01
PJ
Psg
letter
P-
P.S
16013
50
225 00
330 50
225 00
3350
remier
6gainst Den
PM
69690 01/1229"
P.S
Pja
223 00
69652 01/11/3
P.S
P.S
223
5
337
50
S6 25
00
Col
112 50
Oe
TOTAL
oe.****.e*.ftm
so
( 1250
.
tojO
.I
t*
2
50
.87
e~phones
36
eo
stuse61-
n ai u
ts .. (n
0l
Kitt,,
Da
dog
po
..
"rI..
Kitte
and
Dausn thLar1,
P.
. (459
50
Inter6e
6~M4 00al.M
erobto
regarding
06
to
C..
Cn
en
th La-
e*p
rt g-
en
ev..
Mtte
C Cm
rte
-. 612 50
DigatW*EPENT DTAIL
I ...8
0.4.
coal
95252 0M/0/93
0tal
01106195
92206
91317
989?
MS/I
/S9
Po..p.
Pot.epl**
54
14
....e
00/37/95
3
..
939M
06/31/93
AL .......
13
84
2939 M/3/95
92023
0,
12
m/s/95
ds/0t/9S
Mount
02entity
Dist
Long
Diotnts
telep
lolophon.
eerm
er
eI
mene
of
Palatecedes
as
Leag W..
999
999
I 00
13 52
Long Distoce
3 00
24
AUST
***********
999
I
.**..*.
0
9
***s**
DO
Dietan.
mRSEM
REPORT
I 00
10
00
(0 75
75
1 50
S
0
2 G0IDO
25
P.iio
t
aeate
CALL ACCfUNINI
CALLinC CARDMILL -
1993
I
999
avTMREPORT
92 Long
Doli ve l
P.atale
eg
4 79
T.lp
"No *93/93
ao.
~~0~~~~~~,............y~~~
ge
CMCn
pe(t2
1 20
0.Dtn
Long
.elsAfLt
S J
50622
20 Photaoples
Long
**....*S*I**AL
3t
Deeotipites
56622
......
91009
(009
IW
IV
566
87224
raninan*e
aa
2CL
32594
AY94-cc02
CLIENT
CmtIE
a)
Peenas tS
t.
a.e
St crosaatatn
m audan cann
Regulat
iSWcatii***
Creis Itib
28
certeg. Uiseneasin
***CanitnT
St
P0
Sa..
5g474
nWO..C1ia
BILLINe
tent Freqentig en
te..
Sitting
Tnust
Ainent
meant
Aetainer
trs
1.pStin
Sit
snleyl
iSY
ntae
N
1.1..
2
fenthly
einsaiean.
Fe
d tesp
...-..
10~ei
of
nI
n.n
i
An...Le1.
at
Is
son
00Go
dineeen
00t25
o0
At
ndtni
il
nd ik*adeforeneran
ietitrattoice
in
sentiigAtony
nepeneten itgornng
ar
i 2 flO
t.
Dn
2
at
SILLASLE
nists
e:d
Arrangeent
ent
wtetgtttoncei.
e a te
niee en wtmerctStcgeie.'dpenccen
ro
ethspdeeegee.ne**~nde
69D2g
umcn,vs
ic ti
epent
Easerttatil
91?(
Iit
LOeede09ate,0
2c50
00
o~~~ppatle
i75
44
09/
Mc
neounte
so
i21 c0
25o.
6t
ST
JC
25
e Sn 25 A
0
ta
a: c
Sa
tDat0i9te0
d%
ot
Stko
Seteen
Perfer
"N_0Vt
ererdaednie.
o
gne sick L en
od game nKiteC...
re
eipnaen -tI
S!nnee.tee.
so dely0 en schdliaaiing
Repuninnanetoreiedsip
M iin leisletieiini linieni
teeiranin
ite
er t
s
eil
sdiuagn
DCen
T dinesienn nit, rt
eliegtn
legelthine
daesItenn
dtonceintemitteemo
awith
with
0n50e2e00
or
etirnIteei
ne
reenn0li
th ran t Dceeanen
manner
ana
tractan
rnn
.. eeneo
ia aDn
e n
us
na .
titA 5P
te5 1//
taten
tI
Alt A
i
u
m
**
StALSPS
SASSAiASo
0
ttorner
g1na0.1
aq
eqlt
name
rAs
to.tA
tsaty ato
ttAotmer TUwo. fototn
supost Attosnsr
rqa*
Ps.
Pts
CAt
illm
tit
AS
q.So
PrArt
Mi
tot
A
tu~tAuctA
ottlty
P.0
Pees
A. At
St
lrAt
ttoo
flptSA2AS2
A*/AS/95
05 1g
55
t*
See
so
J.i.
b
55
dtitS
...
AS
tABs At
distissiut.
I~tn
ni
sl~,
metAt
.e
igSt
at.ack
dithus 'i.to.ie
um *th
..
meIbT
ic
.
LA
estA
"lectetak
regardttt
stf
SASeit
t SAa-
a .
scist
ot
Ai..t
ftAtsano~il
d-scusi
.SAth.
Awith
side
tosiutet
re.
A 1m,
i S.
I- Amttee
sst
.
5ustAee,~
deemtslte
:'I'dtt
Oi
stp
At Powler.
dAscuton
wihFontr
~Sis/S5
ASASA
ilA
al
so
1 23
as aSlAt
55 AAA ta
StSt
witth
L tt,
i.t Ah.PitA
A
t
tA..n.of tiAretsesNtAl
nwt
l
A n Ap AlStt
wAsstm sitthSannttsttregatdat
spalt
AS AndSAA Sce tratk A5 threttt
tAn rowertstMarcAdilace.
to distance diocuemite.esth
regardentg
his
teptning
tslpr
Ao sue
gasttt
*t
01.
calet
1.11
P1.e"
9
tS/t
611g96
1tar
6t 6662
..
t
i
seeseent
olow
6ecor
Itdct.
6~
TON1
....
e......
aso1
11.
ete0s6e
o
6,lre0ng6te *.rm
66660t/
1aat 916
661
061/69
IJ se
1,,1. I
.
.ay
- ge
.,I.....y.. l16166600
onretsnt. 4,cs
.i
po r
I*teo
6lTems,6
Is
tle
TJ9
I
66e
66n
so
TM6
T.1
no**
as
wa
to
L19.6
low
lte0n
lea6 es
Mat6066
so
,m,6oin
of
r 4
L6t16
1,0
,ow
byea
061l16
.1Mr
im
16666
loardsqly
in.6,161o0a1d0l
idlan
06*
.o..s
h. ..
o6.T
pcknoousioul
sra et
1to
t
dat J
ottesense10er1.m
dsacuse.lame~
Ilot.
atlea4s,
6T1 6.t
ag096discuototoi
1.9I611antri1e
**1116
*98/95
it.10
w626
tlled
h
19ecset4
oot.e4
4.*
Tel
1. tt
11Pla.
at,,.
gtdlg
,
t namesote
601et.106
client
IIIff
.
.lot
th
T.
lt
with
nd
.e
t0 Ootoa a
.
0MSt odotl cIanOSi
61116T.te
ruleranc
66i66ate
th/61
I'lltoot
wIthqutoa.nch J
ease
lat
6
26e61a1dly
0oue66o6o.:2
es
-t.
olltl
n the
utolte
otewt
1..
66161166/11191
111
1114
o**.
i hI.pbu
9.1 'O
lott
maye
o
.a01.a
goo
sent
o1ran
th
6
Ilaod otier,0
iamI
was
00
Ilriol
ps1ea
tory
for1
emulu0061*d
St*rol
the
,1
P.qr
Cro.
St
.9C,
34'94
,.
CIN.
0.5.55
Centrard
(Ipen 0tI
Statu.
Format
00/10
dasu
thema.Ca
y
ary
54t
5995
4-002 74
*S~oiIro
mF.1t
"-D
tnee.s
5.s.5
59
*TIru sttinrsttesfunth sy
[NtRY
Is-Is
5*,,garatin 5.Attorne.y
Attor5
55s~gowner.q
DN0
Ar...gem
.
t
LLasE
IP
Fee Crequensg
ft5ss5NB
CsFrequency
P I
MassAumU5iIng~
Date
60,Ti03013/06/95
tal
692529 S0.02/95
(0.
4X
1T4J
550
54
T5
5690
50
50
Au-t.
..
. 00
VASla
iti
.o.e
Stat
54 I
14
693960 10/02/95
Hour Aouno
00
566
20 00
200 00
Se-Ate-
Perfored
1690 00
123
300 00
Indeen.mttesregrdsogrAcetrach
gamng atd
the Huftson dog tract
Tolephone discuss
meettnfwthtseoor
Whit. Hous
etff ana r0155.
r69
0onsen of gCsoyg0a the dog trsct a.d
oppostIton to to doirng
00
50
I25 00
ftmorandue
to partnet sot, tgs .. lth
representatives d iscussioos aith 5le Jonteyt
f..d
.
&ogarding Senoator reenu, d2suoesons
Sec.3e regar.dng Snetor Orao,* tetse.n
us th Audrag Sehoen regardIng
rilent
SIts.
dist Ttoot .lth John Duos..n.L.gisletive
Oiststoy
for Boosts Ftoance (tairao Moth,
discusont
.ltt Prays Duscheos
regayding
sh glA *threaSI
Oseatoyrt~~
Bram
disusuttso
50
306 00
hooie. materials
Frost tooet. telephone
shant, telephooonreen
cofeeceath
3
w
stafF of Snator FDrea.
t os*rhedule
lnand
Ith
694391 s0/02/95
6*3975
Tr,6e
SILLINA 11J5059
fl,'
..
..
10/03/95
0ND
55
out
5.JC
ft
D
A 00
5O
250 00
250 00
I2S
00
SW0
50
00
2
125 00
5500
noig uli
00
00
04tu.>tn
Joo,
eue
stTF9
Ldtter
Anen..Adsintstaive
For
Seyats
forectoy
nd gIslti
Assistayt
*
. thasrman
-.oth, ascusscosu uth
Leaes
Isuon
iscyustyssto
alto
Pronayus
eea
oeste veusi
bactgrono
meoandd
tveolotiug
matied
tto
Oa.
a,9r
32594
3259e
uit..*
'.507
to25t'5
Page 214
So
nureR
CLIEMf
te..
tneatat
004.
I,
*I
he
e-
to
It ...
*ut.t
t..4
*t
ith
10A.
I.
10,26.95
4.'
Ie ".
l2
fu
tGOkI
*wunt.
1.0
0
b
fl05
lo,3W93
1M
iC
TX
2!tP
s1
250
so
KM
uts
t*t
is
Lnete
sthe
andhc.Mottr
O
1ean aer. deteetene
to to
ea
t indear. AT
ar.
hat
L
Ktto.
*lStAteneW
"1 th
pt*ttons
Do
Do
1tO
trt.
.t
so
I2?
dOneseen
epeatiu
hnuet
settteseenuu
1
te
.r1da
A thaie,
',
A.. -e
1(.gressmartCutluebtand ro en.a.t. Rad
0.......senu wt l 1
stle. d.i..s.ene.ut
Auteryeehner.revtn tese
95 C 1949 C en
u..ahunpuojpth ttsutttent cat .uce to
50
bb959So.502t/95
ubstuele
Plattve
o,.
....
MatItoJtusseene .t.
.eeting ulb I Kitte.
Li
I~aetl-rs...
t.erajny
nis..
kW
it~h
Kulbe.
Atarey
Kiuet. * tIcusannb
-,t K
inesrtnue free
Frant
Ibehnaua.. Ki*uau**t.-feom I
Cute,
d,.aussuonsttith legt.istte
idesto biuuate
re-tuee
it lnean
ltl;
disuaen
iethu
Ietuse
dtulbculnsulth
tKhu,Dunutan. he
ur Stalt loubSenator Stah.Chitrman et the
liuatearuFane estue.
e.urad-W fre-I
tatto uenew 1.eg' hcseliug papesonldis
gaubng Io. utssue
Ilo
Dttootru*
fttt
101M5
**.*t*********t
29 Ot
7423
00
DI9IAMSEMINT
DETAIL
ltt.
il
born
*73.1
10/19/.5
12
-9320
10,31/95
IP
96.74
10/09/91
99432
10/21/95
blotbe
I OW
bhtAD
'9250
PhoIeraple
tLoeg
tetleponue
10/22395
12413
t03-.9.
g.
*******
Tony
SDIt
D..taece
Datts
ltelboue
99
Distence
teaphone
9.9
*****.**
Mfff0
LMRYV
I0 M
testIS
5~E
Septe.er
5lltItNIW
Espeniie
DIT
W PAtRuES
EaPett1
12
999
11 Potatpii
10/06.95
9
0(a
IM
175
594 002 77
DeatretionK
Awtnqe
Duantly
999
99
90(1
I 60
0(1.
9.9
to
It
3
(st*
I-hototeOple
ong~btatle
DI
in0
1one lttat
1.*t7 Intt e tante
In 04
1I
eti
Telephone
fall
tpln
nga
tltiru.te
Ierut.g
tnc
tuturtAllIO
slehn
CAM
SIlLL
rn
...
th.
oct00
Ototoo 0
001" 0003
tioti got-c g
tOOt
otodigoOo.toqOo.tt.t
0,
tO
0o0t00
to/og/ot tic tic
c 8100
al
0
a
tt to
Heso
so
250
ee
o
01$
has
00
ontotgth
ubeo
ea8o'1o5
ranttcoehonitc.
oo
00 tot
to
itt
800
-ith
0
r
tles
att
ttript0
. totots
in
00001
.
00/l
T1
J'
co
so
oo
Oseeusdmnoo
~t
00
tO
3as
seeso
2Soas
12 so
I.in
steh
......
thso
fo
th
.
fo
ctnti
- d. for
oetm
toe
ith
.........
t
0
Citmi t
rod
top
tos
semothio gde
aod Ooiutr
tic
so t~
So0025
000
15Do
so
so
la
ea
off
onferenc
gtogon
tttere
Otonoio ent
Conto.ind
topc
tacuommois
o
wigtoh
Tod
owth
rgardolkt
toyt
aylgott
a1.
dio
toto
Se
ao
ns
.i0anc
ithg
wi
... tor
h
ag
tor
en fsats
..
su
..
rd.
ro
.
ott
rdloto
togodor
athe
dTelep oogott
ly's
on0,0g,
r.arano
Bra
aominten
to
Olthp.la
000
.th
a00
regarfdiyg
.00080
.0 Jooslatpive
Iototcgotto~.
.
oith
dicmtto
dlo
itt
dioootoog
nten
Jetooi.
~ ~ ~ ~ ~ ~~~....
too
0/topttic
adter
otiegocss ih so
P.o~g
Og
rstodienemes
dioo goto otte
Ootee wit01...
t r gard
an
ns
legardlo
reland
Oenator
dthc.
m to
oetolmec
eo
tetaenstaOed
tO r00
resntative
.
gaid tOho.
Itoh
to s
sn
affoto
at
dotttq r toto
theg
Ott
event000.0s0htosc mileso
0p0s00
tho
peol
aen
gtdg t
000 00
stto
t. 0.03ecsetfms~
tt
tosdl atot,wth to
o w
i h ttchio
oo
aro
otk.0.p
gtOo
tlOg g oocoo
a
deoo
uotion Oho.h doeruseoton withod.
las
I.,ttog 111.
It.~
50
read.ngotoearto
Octh L ttote
0top eldtoo
Sea
ofog
o .rint
!ac ditscussitne
0.astotith
tottietr ottotd
ottl
Heso uson to
otttneatt
Ocshg
udirnnot
tcreei
to
oortoto
dancottone
to
atrtttond
to
..
e...t.
. **..
stt
n
nu
sentod
tr
l
iny.. ,
ooto
on
otreopa
ctotoandoatc ond
tea q witht
s
usetrus
t
pool oh toqs-Ta tto
aon
stor
eteremocooit
es0 4ottoy
594 002 83
00sfat
googo toce.torsggath
telol/5
tic
tica
itgloorttof
hot
oie.
olsdg
We.ceatry.
songoe
i?3(21
P.g
naViES
diti Law.,1
3259* 0002
AutOS OtI1',S
tic
hue
AtOOwOOSottiSS
tA
(Jo
*fl7?t
TA
IA
hit
I ioi
.0
resaph
*,neseo.ww
OtJhlitS
sijr.
TiOiai.,,
'0
.50
0.
00
50
C1
(0
oCon
at
ir
eie
twoussoln
th
ri
eAsitw.
ole
100050 04/tStSS
TA
t.iC
wiaettros
I ithwtiaath EC
Oint.
tawia
daocusso
withLewTaaer,
5eprn antat
Osus
ive
ntwth
ttod et.ags.
o.reo....
.b., 4
CouncI
I
FIw e tves
teith
tdeerusetoe retoin th
obe
o 00wtoa0s e.
at.
.. tto..
iw et
r
fres aLd tta.La
t
attedt.npowetiwo d
seores twlaes
st.aot
tt
ran
thw~etasuess
15(2(3
riS~'S
TA
TA
S0
20
00
tS aL
iwins
diaotaaoarw'o dog
teslwaee a HtA.
eee
t.as
eadn
acher
. 00 0050
25 2500
( a Oetatc
ll
ttus
eInw
ow
50
250050
atoo
rmeni w iotw
o~aodatet
prpoato
0
melted00m t
tetaolettetato hese
A Ite
h L
hittanwewvaiou
ondiaitibea
wigtge
in io. gaingiiow
eetltIagao
hIao tea
orw
to. clta. r g. rc.e
s9ote
tof 1ean
0hato
oitto
rtso
i popedw
C tt t Aohe
andiiwt
htg
(ha t 0 o
eta
(h
wifethiag idi ga0ng
wit
45(236 09/19255
OX
T.iC
25000
50
(25 00
i0
125
00
wdiss teo
Diiusi
troate.itawiateneioat ita
Itidos 00/20255
tX
IA
594
00 23
tseosat
mt
regioardt
cotiehTh
tesropoa.i
gaingii.
.cu 1en
and Aswort
dawaiotiO
it0
Ridtte(ahwo
tongsrgriglm
iai
s
S
WAtTS
808880880
todO.. 0o.0o.q0.4..Oo0...vtot
8*ot.t.
80*tooal,
SlOtS
OoooOotO
0...tO too
Oiginall0oq
A tea.oY
su
isin
... a.t ..
to
Twiste
at8F
mI--
tm8tl
t-.e
ali~~~ty
as
eonr
Otto- 00,oe
taCoy
rsto
scnea
Uoaqty a
e0tity
toetaer
-8~
.0
ti.goot
Ot.................t.A...
. .....
0
..
0
.......................
8 80..
..
8
to00y8
.ettt,
80800-
stat
88888)
88/80/88 8J8 OJO
a
I'o
100
iso
laes
theHuden.o
etig
o
1
88888888/88/88'JC 040
40 toach
Telettoo.dieowealot
molt 800 sta8 .ad 800s
so
004 oh. dtho
.ith
0s-..n 1
meeia
discuselmst.
80si0
88080888/00/88
tAt
Ut
ith L
o Itst
alth
gam8.
us0
ordin.
tegletave4side
to
teo
iogle~ltl
.orad.
88re L OOtto:
disloet.e wih oothe
dteneone..
wi0h sidea to Sante Omttee on Indian
enverat
I8
"o 0
00 0
00
Acheo.u
with
S
Dootuono
Oemittee,
Po
C.or
8/led
00
0s tO 48
by
otor oppooltl.
dtscussion
8004 1
disc0st0
doiscuseloneraote
-
h1-9kg1- M
Ittorle.
aeview
88888888/88/880000840
and
metor
t8
to,0
th8
It. ths
oith
80r.o,
II.nion..
uey
dto
trot
a..
toe
594 002 52
tO 0o
appalg
door.adt80ance
O0n00routra
nald
Ott.
tra
ottd
*ror0tan,.ttolse
thre.
Oto
sue
iteeg/,
Seec
P r.of
ee
ctit
lm
e t
bo e
891...
W.9/1,5
ione ltec
on
ta
useceoneccltrPC.om.
oy
*dlcuesonis eech
ant
*cegardlyetheyenulta
tem
by ecyeee
t r-e yeageiasclehecicyrotyeen d
ulti
**
See
ae seec,
as
tok
projet
dicete
with can oflricil
Pee
Plte
Telyh
32ud0ee yelepyhne cy leewth
invlv
in the
cee~SeoeeettPericki
0 oe Come aed
oe loo
annsoo
eteseen,
dteveiec
10 0o
bee to
to
eo
attie
cabat
ite
lttr,
with
Ut,
reest
"1ee T
I eyardl
See,
Piececelinitgsttet, ellts teo Theoteraey.
_it cut
o
Si led in ederel
eardlt
runinimeceec,
beet.
A90p
09c/e/9
Tec Cic
be tett
So
eegardi
let
ee
DietetewthJastr
lie gaeIc
Dis~ecseson
uc
Lbt
reveretrit
Elitoe
i*eenaies,
dicuionse eeithpdeedyee
to ae
an
on
in
so
ye
sumeso
eb
the
eece
eu
miS
celntstee. dcscueeseeeeardPiecer.
dicecettocectneake foceyto eeecpcriyeen
ttesemadee tie saysd Sect.
seeein
etitee
Irn
eec."r. eacest press1c to
.eted to
tee
ielcti
acd
to cla
h
iteindec
E
ccc eaeete
leepteec
i eleoi.
edean t.
t Itien
gete
erecnde
adeteckged ecnfocetee, be iee.
eyetee
aeyseand
ecncetietee Ppeed
eaffectien
Ican
gestg centettoeFran
itchenesonandte ti
laeare
for
inaysee
furtheepret
been tc cceeeoL to
en ticuslies
eith L
ithe, dicsceon
ith
eyaged
Tde
be
3e
ec
tic
ce
be
eel
Aeredcskeer,
itust
attorme~y
forp
tcroin
Trte.dacuseie
gealie
eithL eieeoeegeedl
e
ee te y eal
ceataieyd
It the
teiee cyeepd by e caeycee.ne
tegicleetlee
-UhD~aasaa..J
C
.0eeos
**
ase weeasiee
beese
rto
meand
ticecce
Ltr.eadiglwu
fCied en ehe dee. proeetehP
iteceeye rPr the
nee.
..
to
fl
f...
...
hca
cd el..c-.
594 007
53
oio
t m 7 ......
-fl
"Int
40
tdtoOdoq400.
I. lse too.Io.
Iso
0 00ytlonjo o s
404440
*S/00le0
T.0
1X 01
00
4h0rf000s0nta0etoo
.1por
n
00
ItI
.
so
0040
400
as o
ftiO
o
,
oo11too
.o
h.
severdat iooio
doittots
cOntit.c.titoih io
oiadioy
uo
eI.o ns..
011.
tI
1lo
cIln
ree.,
tan1,,
d..
Audor
ha
iteotttoe
iti
dso
Loo..
igseoo.
diob
.10nken~o
the.
n
of Oti"
ioopthe
dktoftdntntis
esslft
nd
n
to
e
one
to
- **uno
au
iech
oo Minuiotao
.e regarly
ci~ounCioo
oofns dfoontooooof
mtsncs
fstod..
L,0.
-otte
lort
oflep
L
inference
oogoooo omean otp
to
to:
dteoio
Septetotis
0A
Cth
Iie
te
si.
iodlo
ts
the
.. c~ofn
discusetone
400440e0/43/04
I-
...... .. ....
i
-ncto
lto
tho
tootall
0.0endtscumstonetith
t eatodtelloPtr
04
.
"sss o 14 e 0pushle
tofoenoto Cwet t eror0he
.040
*1
LOofoooa
c.al
tta
s
gatto.
ttto
tottttdfer
Olooate. dtfedtOerto
Oiuyoooten a4t
ai tooran
0t.4
dfs ooorotte
o
.ith
.
000rc oa
stodo
JS no
to
44404409/04/00
0JC
no be
at
125
to
**
dfooDis
P1seh0
Ctetiohnn
sep00
itoat
fot
oo CeCr
doeh.mOtoto , ithoolhoa
TX0
0000
1000
Of
00
aft
000he
Sentest
00400440/40/00
010
Not
diCueot
sooloo
oheum o
telt
esl
w.
oga foo.
warb
rdf
ero
wto
ttto
rtoarodlittlfncetomdtteeoSentorsof
troystadoe oo.gama
Aou
tto
ta
a.do
itht.oooo
dftor00
adoJme
s~ometts
of
tordl
ithL
eelms
disouoaoueioooL fotto
passis
to000
Joudoo
rtett
maongbooo
te ad Aorey
hre t
tooin
LoRtgo
Gra
ohmos
spior
o,,54025
.oeuesLSenor
594 002 54
ioi
tiC
46209 11/05/95
696320 1/108/95
PoD
POD
1)
2 00
TJC
IJC
Pot. ip-
ioe
250
250
50
00
00
le0
12
00
"o
00
ol
Bet
Dolt' Ad
tsttve Asteu
Dave.ilisonat
Cortersiia request to
uchedulo meeting or N ovebr S or
oath
tr'el haat .hip
to di
s lntian gaming
t~ance Coonittee and Heouse to
0insueon Sthe Sente
tiegand Hean. Committee..obta.n..eting
Novowber' 9 aod ods. Teowere.n.
.
.as
Dct
sos
th L
sootitn wth L
tilt.,te oL.i legior and Frot Dthe .
weetingwIth P ODnntot. oegarding
eoator
Det., 0scusle.wIth L
discumtien
P ODennll regarding it 00
. Nootoer
s**tiog oath legilative side to Bentor.
Dolte dicusloo. with De. Maogor.Chloefw
Start ter peoater Otngriohs ropwrt to L Ditto
otno eting ochodoled forNovmbe 9 wIth Davit
i
t wt
o
a
n
ato
ti
vei
A::ltet Davi
tililot. 0e. Cwrroe. Larrg
hittw
andrepresentatives to St Crol..
Coalionia tribe.
Di
Ikt
utth P
0Dett.
diute.ns
L
I
to cuselene oith Lowil Tager,
meeting with Leois
Tager. L DItto. P
.tilot. wid to
DeonTI and Davdn .llen.
0'enoato
Maeritt
Looser Dato, di.oo.ul.
It%
Lewig Taglor and L. hit
oooin 1i oth L
atte, *emorandeewto Colifoonia trihot
treasurer M Pot. regarding Congreoawsn tone ot
7b*
Per
00
so
12$ 00
Kitto,
Kitt,
with
9
696221
11/09/95
696333
11/09/95
POD
tic
POD
T0*
50
t0
20
00
375 00
I s0
300
250
00
250
1 00
25000
00
7toat
toi
496342 t1/10/95
Tic TiJ
250 0w
o0
so
125 00
aithL
69683 S1113/95
TJc
TJc
so
250 00
125 00
50
I25
00
Ftnonoo
U11-9
Tiog
VJ
c
50
25000123500
50
02500
o hootee
ophoeld.
dititeiionse
lt
594 002
104
Pag
Data
12/03/95
Profesa
32594
CLIENT
56T00R32594-0002
Sltant I0*
l
St 0c,
in-tan
C.-1.1 Regulat
.4.
s
It Tonnelli. anrk0nltudsonlawsuit. diaouesons
It *idei io Secre0tar
abbitt4d
et
5
.96035 11/6/95
1-
04
50
2" 00
125 00
50
DOt
teno
lait
696044 1i/i7/95
fJC
I4
697090 11/20/95
0JC
TJC
50
250 00
so
250 00
Seareter
Dabbatt
00
50
125 00
so
125
a.des
OW
with
TJC
697620 11/20/95
TJC
50
25000
125 00
50
50
250 00
1"
00
Babbitt
aides
utth
697629
1ii29/95
messeeame***
T4
.*.***TIME
70TAL9SIt
00
2750 00
II
ML.
00
DISBURSEPENT DETAIL
Indeo
100920
STAT 1KPi
CODE
Dtet.
11/30/95
i2
Ouantity
Amount
999
I 00
1 00
4 50
450
PATRICK I
12
999
22 00
22 00
4 40
4 40
Photocopls
13
sa*..**SUBTOTALe.......
100754
0it24/95
101275
1/30/95
13
P"otooples
.o****StUTOTAtL**********
25
******..a
000400
00/19/95
a.aa.aaaa.aene.ac.
D.11ir.
gUTOTA
.aa.seaa**
Si
Fatal-ti.
******. a*BUSTOTAL************.
COST TOTALS
999
999
2.
00
7 93
I0
7 92
2 00
2 T0
C).
00
2 00
D.0.itio
O'DmINELL -
ASHIMOTDNEXPRESB
ISO
10/2/95
25
SERVICE.
IN -
Inn
912160
Fana oiles
31
its03
OC
.
Dote 01/03/96
32594
CLIENT
32S94-000
NAIgE
4980
2/13/95
134:0
Prefarms0
ProPerma
St
Crti.
tIntian
TJC
DetIg
t **
of
Tribe
Segulotory
TJC
P.e
430
turet
0TOh
2l/Jgi
*o
32-94
Act
50
50 00
50
/5 00
'21 00
K-.t.
O))a,6
7oo5tt/.14/9tto
6869712/15/95
112.
.00Z
c..
too
oO~d.. ...
otTJAd,.
IJC.tO
05000 1.5 00 50 1. 00 O ,
50
TJ TJc
oP
.11/0090
12751. Enry;o"TJCn
0Oo J
Tot .hgo..
tee. .1kit.
e, de
ocoto
Mtti. Alfotro
' .1to th.
Ot
... ettokig .tto tLOto
Onbe.aotto
t
.t'b L
D.
t
.1
.
6994t
~ ~
46992/1/11
Tx
499473 1211/9
a
Tic
TX
6990 11/1-9 TJd
499465 12/19/95
Tic Tic
Tic
250 00
t2T 00
50
121 00
250 00
125 00
so
125 00
10o1.nen
icosinodonshTeOtendeconelo
tto H ousrNtevetollert rfareBeomittee
O
so
50301
so
104.0
.0
250 00GO
005
290
I2d a 00
12/2 " 0n
X Tic
COr
SATTOP
50s
125 00
so
125 00
Otetestone 110t1
Otffo. Com..
ttt
.
tontBente
IVJC
I
Itt
d
uet
dis
luol enH.onIeotto,,dle.eeoOt
!ohb It
drot
g tract
..
7oo teli
Lrr.
Ito
(1i
e stsme
tang w
L
non b127etooMa pr oontne
the
and
gotral
Gu.t
Socity
IndI
h6.1.1
Adred
tet.oI
Cunlor
o u
e*o eso
0: Com re dSot
dotegen. Pone tot
ooth.
...........e...TIM
etT
Itfl
904919
TOTALSP
tfl2 50
5 so
5 so
.362
04
Long O~tten
Totep~on
t04527ID/t/S14
.. 50,e ...0OmTOTALOo..........
1oidee
.0
SUTOTL
TOTALS
TOTAL FES IDILLED VALtE
....
00 0 0 a Long
2 00
99ep
0
0.. 0041..
00
400
5 so
*KP
IS00
2 To
12
00
2isvi
1u32
90
then
Tieph
In
aL /...
00
Longottocott9
/'
II.
t/T.jTf
DETAI
12/315
14
.etctho
-,enate
It,0 I-
nt-
AT&T CALeLINt
ATL
BILL
CALLIN
e4
3ev
1
to U
rt
tt.. metCsT
j
lte
na
n
,
eretale
SILL
NO
EC
3388
Exhibit 32
14 September 1995
Dear:
We personally would like to encourage you to attend the 1995 Presidential Reception for
President William Jefferson Cmnton and First Lady Hillary Rodham Cinton and dinner at
the home of Vice-President and Mrs. Ai Gore.
The first eight months of the Republican controlled Congress have been diffcult times for
tnbes across the country. Unquestionably, tnbal governments will need to call upon the
Ginton adrrurustration, and the President huniself, to assert leadership and assist tribes
through the difficult 19%budget process and to help fend off attacks on tribal gaming. As
witnessed in the fight to stop the Hudson Dog Track proposal, the Office of the President
can and will work on our behalf when asked to do so.
The 1995 Presidential Celebration will be held on.
Tuesday, September 26, 1995
The Omni Shoreham Hotel Ballroom
2500 Calvert Street, NW
Washington, D.C.
8:00 - 10.00 p.m.
The Vice-Presidential dinner will be held in late October, but the date has yet to be set,
PLEASE CALL 202-496-4870 TO RESERVE TICKETS
The cost of both events is $1,000 per person Tnbal checks are acceptable. All checks
should be made out to ClintonlGore '96 Please inform our office by contacting Larry Kitto
at 612-488-4855 if you are able to attend If you are unable to attend, but can contribute,
please send your contribution to Clinton/Gore '96, P.O. Box 19300, Washington, D. C.
20036-9300 Phone: 202-331-1996.
Thank you in advance for your parapabon and generosity.
Sincerely.
Larry Kitto
Pat O'Connor
K0000030
3389
Exhibit 33
HO-CHUNK NATION
*
August 3, 1995
defeat the Hudson cmo. Numerous people contbuted to the Deparuean of Imenor decision.
You were particularty mstrumental in helpimg the Depatuooem understand the sigmifcaner and
unportance of there decision
I want you to know that we apprecate.your helpand we also appreciate the opportunity to work
with you
The decision to deny the Hudson casino proposal will help protect the future of Indian gaining
We know citizens strongly support the Indian gamungon the reservations We believe that people
understand Indian gaining benefits Native American communities and the larger community We
wdi continue our work to maintain and increase that support
Thank you again for your tume,help. and understanding
incerely/
JoAnn Jo
President
w::,er
54.Vts
ox 6
667 * lack RIVER FALLS. vi 54615
15,284-9343 * Fx1l5)284.9805*1800)232.2180twloNLY)*(800)294-9343
ElhlllNll
hlIi
DNC 3245774
3390
Exhibit 34
HO-CHUNK NATION
OF
OFFICE
/5
H-E PRESIDENT
August 3. 1995
Tac Honorabe Williarn J. Clinton
Othe ofthe Prdent
The Wuse House
1600 Pcmsytnuau Ave NW
Wuhington. D C. 20500
the
That das.oon wi help protea the fu-.r of ladiar Bmyn Approvl of this ornsranon sne'
-ould havwhanded the politial and conenuc spport for induingaming. We know citizens
apcport ladian g~itag co:t~-z iands We believethat people undusand Inidian nmag
te-j.'u both the Navn A.e-acor-:m
and the !w-ay community As we wor to
-. w-unuru a u.odcoetcr it &=.ppcri
*- ycu for a de
r.on th allows us to continue our
~ongly
Suscery
Mo~nn
!5
Jone
-5
-S'
-- 'I
- *--c.
*5
3391
Exhibit 35
BRIEFINGS FOR CHAIR DON FOWLER
Friday, 23 June 1995
To:
From:
Date:
Re:
POSSIBLE-If Press hits are scheduled, you will receive a separate briefing from communications.
KATE STETSON/KEVIN GOVER
BACKGROUND
PURPOSE
IIilEIIIillliH
DNC 3024555
3392
M1191-A
115*W
OovZust STUSON
Exhibit 36
ILj~e.PC
N.W.
o--
iL
ownM1!
ewunsl.aw r. jA16OV'
A-
-lf
MIMMMorNd,
7AIS51
19.mwm1998000
..
MINu
useo bt to bila you for WheucM haIn meeting with iodine Dcratuic
setvins
bthes
al o India
policy hall not F~mngnt. fusnitly. but the reasons wetoo a mpkated to go into In this mcmo.
Suffci t to sqm thalt you cannot will by relying on the ep=mecaln of ndian county. You mus
instead comnpew wit the Republkan.
ht any special
rapr with Inlian country. although PbD Orat.. Istryins; to use John McCain to raly India
support. In ou . Jdgmen. that wl not work if you begi& lmeit for the India ,.ot o
You may, not jax. you will win India mmtv
F~bIS n
a few apeelfic .~ os
most e
flffl~l~lflfl*flDNC 3024557
3393
they believe
Tbc
cspereoce with
Navajo Presid t Hale Is a clear example. Hale bad been Id to expect to se President Oitn;
when he did
MWA
11
gMhasizdj. forwaver, compare Olnton's performance to hat of the Republican Congress. Ada
Deer did so "
You are fighdng aperception that your dlan supporters are treated no better
than your Ind
enemies. As a matter of policy and protIcol it Isproper that each tribal leader
be given eqta consideration. When It comes politics, th ph. you should embrace Your friend,
and keep youir adversaries at a distance. Your 1992 suoecra have yet to be singled out for
special atte
Indians
to have no gripon the act that some Indi.1L did not help you In 1992 and will not
in 1996.
with
ml White House should honor It some way ydur Indian supporters from 1992 at
event to wh
and other L.snocratic causes Inthe last decade. How., the DNC has spent none of this
money camp
Il**~il~fllll.**fI
DNC 3024558
3394
money
PAC to run a campaip in Indian cocut ry. You mu-g not be threatened o
lnto
th
rentful
stID contribute both to the campaign and to the DNC. dorover, Indians can campaign on
Indian reservation better than you can, and if they ha
wif0 ddlier ai
mI
majorities
'gned on a resevation. It would do
wonders to balm the President or the Vice-Preddent atnu a major Indian event. Crow Fair in
Montan" the
any White Ncus meting with the trial leaders ever will Knowing that the candidates will be
overwhelmed wth requests In 1996, why not go to a rc
We believe tltt the Navajo Nation Fair Is the best place
Montana
other than N4 jo, be gaLan that HMary ainton goes to .avsjo; the Navajos will not take kindly
to a percep"
they are.)
We need help with sate paties. New )4dfoo is the only state party that has
dealt with th tribes appropriately, and even here we save problems because of the tribes'
alienation o
CMbther
MpgS fap
with the
lIgl818gggll
DNC 3024559
3395
of thean4eil fall to zapo4.
Must
Indiana
64v
must makeqada
effots of their
ownIOlvo~
mrcn o
hmgw
Ia~
&I NMAeriansfbf fntgm ors( odlbr Its succce
and a. MalorInDAWn
MM
PAC)wilmeet
maetiap and 1"a" your Indian supporters like the superi!ioud palfh-6-n they am. Th firs
edom in )dlwaukee on August 2D-23.
opprtullb~eatiesindanOsuksgAsscladon c
The
IAt11.
am poll"
OUe. '
Director of NIGA bs a
Rapublkca ! d Isallegedly farmagan Indian Republias 1'AC) The DNC wenD/r the campaign
emudaohes between nd?4vember.
1996& 7blB
othe.71
YM
Rct
campaign
In
r I ninspotradtp
and followed vwr advice. The rmaiWt of thew simple mod oiwounltallona w~a .wirdcscad
earad vWa Indlami thought this
for the firt time ever, a Pgudadcral candidates
perceptlc
h o 1mhlnhP
win for Obacton on reservatlons throughout the country. Whenthe
resulted rn a
time
mc(ar*l
stwould be a Voo
betvw
House, too.
3396
&
You I"
have a paid Indian saffer at both tbe campaign and at the DNC
asinto the DNC and Denocreds
The tribes
campaigns in
last fouryear: and we have yet to see an Idian staffer with whom we can work.
t will look more ilke the product of
geoutne later
would give m
in all of the w
very
a.
improvemetra
14
Aro
,a
..
..
Ilvd.
and Washingtoo.
We will have
coordinators aDof these states, and they need to bw in1 c loop. If your campaign staffers are
made aware
e! the hnportance
of the Indian vote and 1.J Ian money to the Presideat, they are
1e
Nehile we know aneodotally that there are d Prct in Washington, Catlifornia, and
IS
IUUIIIgl
ll
DNC 3024561
3397
Indias ca help to unmat Republiean lnumbents, we need a more thorough
Arbons
understanding of the districts you have targeted. Partduluiy In a year when you'll be running
aPis a Rptblican Congress, the Indian vote can be cnrgired around congraSional races as
well as the +dental.
(Indeed, a central element of our trseeg b to talk loud and long about
While the turouts for Democats on the New Madco a d Montana seervations was great In
1992 and 8004 In 1994, meflstaton remains relatiav low I wo can gct them registered, they
celmingly Democrat
will vote a
tj
Above all. remember that Indians ar p rt of your hae vote They supported
Cinton In 19# and want to do so aiSa. This time they wi need a lIttle encouragement, but
believe. The relatively minor inWvstments of time and money described in this
only a little,
memo will
ome early attention wI luck up the tribes. Living the Republicans either to gi
sonot year.
campaign
ians are Inclined to vote for Democrats, afd the Prealdent has a good enough
any of the Republican candidates.
record to
eiL
18illllI1IlHl8
DNC 3024562
3398
We"Mtt Districtof li1sconsm
Exhibit 37
Otomerirf
From:
Subject:
This responds to your request that litigation counsel provide a brief analysis of
the litigation risks In Sokeogon at al. v. Babbitt et al.. No. 95-C459-C.
Substandal Potandal for Burdnsome Era-Record DlWvY.
1.
In our February 2 heaing on the discovery motions, Judge Crabb's
questioning Indicated strongly that she would deny our request to limit discovery to
the administrative record. She stated outright that 'ifthis were a non-APA case,
plaintiffs would easily have demonstrated a reasonable basis for the discovery they
seek here' and she asked 'What's a plaintiff to do when there is some evidence that
outside influences may have affected an agency's decision.* She also appeared to
believe that the White House, through Harold Ickes's office, exerted influence over the
Department, an allegation that plaintiffs pressed by observing that Secretary Babbitt
did not provide an affidavit denying his alleged statement that Ickes had ordered the
Department to deny the application on July 14, 1995.
A decision allowing extra-record discovery is therefore highly probable, and
such a decision would create a difficult precedent affecting not only the Department
but also every controversial agency decision. We can expect that the following
individuals will be deposed: John Duffy, George Skibine, Michael Anderson, Heather
Sibbison, Donald Fowler of the DNC, and perhaps Harold ickes and Secretary
Babbitt. (Note: Ickes has not been noticed by plaintiffs to date and Babbitt's initial
notice of deposition has been withdrawn by plaintiffs.) We can also expect
burdensome document requests and Interrogatories, such as requests for a list of all
persons who contacted the Department during the review of the plaintiff tribes'
application.
2.
Secon 465 Dlee WI Not Prevw Remand.
0 C
We do not believe that a defense based on 25 U.S.C. I 485 will prevent the
Court from ordering a remand to remedy alleged defects in the 1 2719 process. 4 t
e>
most, a 6465 defense precludes the Court from ordering the Department to
land into trust. But this defense will not constrain the Court from ordering a r
If
it finds that the Department did not satisfy the consultation requirements impo dy
..
6 2719, particularly given the actual circumstances of this case.
We understand the Depanment's view that it first reviews an applicatioioder
IAhst
6 465 before engaging in the 12719 analysis, but the record Inthis case sh
the sequence was reversed: the Department received the Area Office's 21
recommendaton, and began t review of same, In November 1994, while
96. 91
Ml
3399
Department did not receive the 1 485 package from the Area 0" until April 1
It's final decision
Opposing counsel have Pointed out this timing, and the Depa
Indicating that the I 27pTprocess occurred
letter of July 1995 can also be read eas
before the Department broadened its range of considerations underr 1 465.
The consequence of our factual posture isthat the COcUIZ-ould reasonably
remand this case with an order that the Department reconsider, as a threshold
matter, its 2719 analysis. Such an order would inhibit the t arttment's ability to
dispose of future applications on 1 465 grounds without real g the 12719 factors,
as future litigants could point to a precedent establishing s eefic, threshold
consultation requirements in these types of decisions.
3.
Alleged Defects in the 12719 Pro
Are Problemaic.
o
Now that we have reviewed the administrative record In greater depth, we have non
determined that the alleged problems with the 1 2719 process are significant. We are 0 E
primarily concerned about our ability to show that plaintiffs were told about and given SE
7an opportunity to remedy the problems which the Department ultimately found were
outcome-determinative. Area Directors are told to give applicants an opportunity to L
cure problems, and it will be hard to argue persuasively that applicants lose this
opportunity once the Central Office begins its review. The administrative record, as
gfar as we can tell, contains no record of Department meetings or communications
with the applicant tribes in which the Department's concerns were expressed to
c
plaintiffs. These communications may have occurred, but they simply are not
documented in the record. The second, and related, problem Is that the Department
appears to have changed In this case its past policy of requiring 'hard' evidence of
,triment to the community. The plaintiffs will therefore argue that they had no
notice, either through past policy or through direct Departmental communication, that
,he 'soft' concerns expressed by local officials would jeopardize their application.
Finally, the record shows that there was no consultation with the State, in
contravention of J 2719.
in sum, the Court could take these problems and reasonably conclude that the
Department should reconsider the application and provide the plaintiffs with
'meaningful consultation. The risk, of course. Is that the Court could also specify
what it means by *Consultation.' throwing further impediments in the Department's
future review of these types of applications. These risks would be avoided through a
voluntary reconsideration, which plaintiffs could obtain anyway with a new application.
4.
Selement Prerv
Departmta,
405
MIM 11AID
16t
3400
increase the Department's policy flexibility if this case were eliminated as an
influence.
60
0 -
FilM
'IAZI
Mi
3401
Interior_
_ _
Exhibit 38
Rcco Sno
MAR 0 2 1995
dA"-o IDPlc land in tusat for the benefit of an Indian tribe is at the discetion of the
and roquree th applicant tribe to comply wth the land araaiddtoo regulations found
in Tidle 25, CoatiPndeaJ
Regulations (CFR). Part 151. When, the aqistion is in-ade for
gaming, the reuihema
of Sectio 2D of the IGRLA, must also be conrd, in addition to the
O.rquireziens of 25 CPU 151. Additionally, the acquhliton mus be in coplianc with the
Mmvimonta Policy ACL
&Nanomul
-S=vury
As a -zIa rule, Sect! 20 prohlbits any gaming on land aouiad aic Otober 17,I.198 the
dait Of aucamm of IGRA, unlkss an exception applies or the Secrtay deemines that the
3402
of fth agog and mn mabal.
gamig hazty cc wy wird had wil be ia en mm
__ wL a e d nimeniDa th aromdig -iiunhY, and. ft Gomor of dte S=i ==An
in ftn Swe~y's detmdnabn.
Santa, lini govifamm officis and offiab of mz'by
The *=utm with WOlfl5
by t Irni M Arm Offiuf UP= -nPiedam Of dw OMIMMla, te MLA
uj~ Ls=w
-, woning aamiuty aft inormdmand
admwia-A'dvr
Arm offi= =repaan
,minimm mccved damog dw wLnam. fama flodlop and witlus ce both te neganve
- i 4 bm-Imed~ o ft Assmm
Owspopo=LThe-~
and podflw aLqaM of.~ do
savaw an egpovaL
rfirw
IniaAfi
517m
7U mvie ianducud by do IOM offii and ft Offi of d Sabcor. The pm of tb
wi d wmb t nqairu of Sod 20 of KOA hew bm adeqntey
revw isa
y1po a &vrabig
adtcumd. Nt da sm m b found IDbe hcaDy demnma w
dedindin z
= do m
bdpef-h
by do~ Smew7, pdve
dcmo
=am nd Sauys
prpqued aimg with a m t do Governor of ft Sof amMg m'
-mn M-
inabr 69 A-4-1- 0 tee led lo a far p.1mg pam is mad& edy aftr an
Asyuc
b ohm vay
MWe
-r
cdun
cbazedve and delibaadve review of a&Drejevmfnt mad
of infmamd daainimdom whr is
lengthy and tmYpay -ma10 in A haP valinreafly reviwed by the offm
If You hew fww
WOOD,
pp 219-40
ftmomrn
3403
be:Ge~r~e- Skibine
Kevin Meisner
3404
PARTY
TRIBES GIVING MONEY TO THE DEMOCRATIC
ON OFFWHO HAVE RECEIVED FAVORABLE TREATMENT
RESERVATION GAMING PROPOSALS
OPPONENTS OF THE
HUDSON DOG TRACK PROPOSAL
Oneida Tribe
Shakopee Mdewakanton
St. Croix Chippewa
Mille Lacs
Prairie Island
Leech Chippewa
Lower Sioux
Upper Sioux
$105,000
$129,500
$ 52,000
$ 25,500
$ 18,000
$ 16,750
S 8,500
$ 1,000
Total
$356,250
Exhibit 39
$384,964
$409,625
3405
Exhibit 40
V-5
THE SECRETARY
OF THE
INTERIOR
WASHINGTON
AUG 1s8 Si
3406
Based on these findings, I have determined that the gaming establishment on
newly acquired lands will be inthe best interest of the Tribe and Its members,
and will not be detrimental to the surrounding community. This determination
does not constitute a final decision to acquire lands in trust under 25 CFR Part
151.
Pursuant to Section 20 of the IGRA, I now seek your concurrence in this
determination. We would appreciate a response by September 6, 1994.
Sincerely,
Enclosures
3407
Exhibit 41
September 14,
Natural Resources
1994
Superior
Chippewa
and
the
Sokaogon
Chippewa
Community.
Also
included is
additional
information
requested by
our Agency,
regarding possible impacts to air quality and traffic flow.
Based upon
these documents,
it
has been determined that
the
proposed action will not have significant
environmental impacts and
the preparation of an environmental impact statement will not be
necessary.
Enclosed is a copy of the Final FONSI for your review.
Thank you for your comments and participation regarding this
matter.
Contact Mark Kuester, Natural Resources Specialist at
(715) 682-4527 for further information.
Sincerely,
Superintendent
Enclosure
3408
United States Department of the Interior
BUREAU OF INDIAN AFFAIRS
I
.raL
Agney
Natural Resources
FINDING
OF NO SIGNIFICANT
IMPACT
the
to
Addendum)
as
the
to
(referred
An
addendum
"Environmental Assessment for St. Croix Meadows Greyhound
Racing Park, Hudson, Wisconsin, January 1988* (referred to as
the EA), has been prepared for the proposed trust acquisition
of, and addition of class III gaming to, the St. Croix Meadows
Greyhound Racing Park by the Red Cliff and Lac Courte Oreilles
Bands of Lake Superior Chippewa Indians, and the Sokaogon
Chippewa Community.
These documents have been prepared
pursuant to requirements of the National Environmental Policy
The addendum was
in
40 CFR Parts 1500-1508.
Act (NEPA)
and the
prepared by Bischof & Vasseur from Oak Park, Illinois,
EA was prepared by Mid-States Associates. Inc.
Project Description
The Red Cliff and .Lac Cource Oreilles Bands of Lake Superior
Chippewa Indians and the Sokaogon Chippewa Community propose
to purchase,
and place into federal
trust,
55.82 acres
consisting of the St. Croix Meadows Greyhound Racing Facility
including the principal structure, track facilities, paddock
and kennel facilities
and parking lot to the north of the
principal building, for the purpose of operating a class III
gaming facility
in addition to the existing pari-mutuel dog
track operation. The main parking lot west of the grandstand
building is not intended for trust acquisition.
The existing grandstand would be remodeled to accommodate
gaming activities,
however, most support facilities
(kitchen,
washrooms, office space, etc.) would be maintained.
Need for Project
The Three Tribes anticipate the generation of revenues
from
the proposed project that are needed for community development
for each Tribe.
3409
Project
Alternatives
and Poesible
Impacts
"Alcernazive One- is
Three alternatives have been proposed.
Several possible impacts have been
the proposed project.
this
alternative.
Addendum regarding
in the
addressed
Possible negative socioeconomic impacts on the City of Hudson
have been addressed and minimized
and St. Croix County,
through the *Agreement for Government Services" developed
Possible
and the three Tribes.
County
the
between the City,
the
in
negative impacts to Tribes with gaming facilities
general area of the proposed facility are also addressed in
Ic Is not the
the EA addendum and are expected to be minimal.
intent of the NEPA process to limit competition for business
Possible social impacts are addressed in both the
profits.
is
The proposed project
addendum and the original EA.
projected to have similar attendance as the original dog track
facility was designed to manage, and the impacts to the social
environment would, similarly, not be considered significant.
already
The addition of one form of gaming to a facility,
established for the purpose of gaming, would also not be
considered significant.
"Alternative Two-,
proposes that the three Tribes would
construct a new Tribal gaming facility
at an alternate
location.
This alternative would have similar impacts as the
proposed action and would include the environmental impacts
associated with constructing an entire new facility.
'Alternative Three- is
the 'No Action* alternative.
The
environmental impacts associated with this alternative would
be minimal, however, the proposed need to gain revenues to
enhance Tribal community development would not be met.
Findings and Conclusion
Based upon the findings of the EA and the Addendum regarding
this proposed action and the alternatives considered, it has
been determined that the proposed action will not have a
significant impact on the quality of the human and/or natural
environment, and the preparation of an Environmental Impact
Statement will not be necessary.
Superintenden,
ate
3410
3411
St.
Croix Tribe
the
RESPONSE:
A market analysis was performed regarding this
proposed action and was subrmitted during the process required by
An Analysis of the
the Indian Gaming Regulatory Act (IGRA).
Market for the Addition of Casino Games to the Existing Greyhound
Racetrack Near the City of Hudson, Wisconsin, by Dr. James M.
Murray, PhD., indicates that the proposed Hudson casino/dog crack
facility could have a 20% share of the blackjack market and a
possible 24% of the slot and video market in the primary marke:
zone (predominately St. Croix County in WI, and Washingcon and
Ramsey Counties in MN) . Based upon this analysis, the
socioeconomic .impacts to surrounding tribal casinos do not appear
to be "devastating".
Although the socioeconomic impacts
regarding this proposed action are real, and are considered in
the environmental assessment process, they do not normally
require the preparation of an environmental impact statement.
These comments are more appropriately addressed in the IGRA
process.
"The artificial placement of competitor Tribes in
COMMENT:
geographic areas superior to that of the St. Croix Tribe gives
official sanction to an unfair competitive advantage, something
not envisioned by the NEPA process."
RESPONSE:
The three Tribes, as well as the St. Croix Tribe, have
the right to request land be placed in trust for the benefit of
It is not the intent of the
the tribe(s), by the US Government.
The tribes involved in this
NEPA process to limit this right.
venture have clearly expressed their intent to diversify their
respective economies and generate needed government revenues.
Tribal casinos in the general vicinity of this proposed action
are able to take various steps to make their facilities more
attractive to gaming patrons.
These comments are more
appropriately addressed in the IGRA process.
COMMENT:
"The current owners of the dog track, however, own
considerable land surrounding the dog track and have extensive
plans for the development of a destination resort."
RESPONSE: A "destination resort" is not part of the proposed
plans, nor do the Tribes have economic control over non-cribal
lands.
This comment is beyond the scope of the decision related
to this project, therefore, cannot be addressed in the scope of
environmental impacts associated with the fee to crust conversion
of the subject property.
3412
tfe
"Allowing the three tribes and the present owners
COMMENT:
.ne
c:
opportunity to conduct those games at a location outside
St. Croix
the
to
injustice
great
a
cause
would
usual territory
people.'
Inc.
3413
-That the dog crack is a failing business is n.ota
COMMENT:
legitimate reason to take action to the detriment of a
Adding the artificial
neighboring Tribe and its business.
stimulus of Class III gaming to prop up a failing non-Indian
owned industry with the resulting devastating impacts on a
neighboring industry does not qualify as a justifiable result
under NEPA."
RESPONSE: The loss of jobs related to this financially troubled
business is mentioned as a possible negative economic impact to
the surrounding community.
No effort
...
it
is
almost a certainty
Croix
...-
RESPONSE:
The principle
author of the Socioeconomic Addendum
utilizes Dr. Murray's study and other proprietary market studies
to support statements contained therein.
(Proprietary sources
include market studies for tribal and non-tribal, gaming and nongaming business ventures, as well as Wisconsin Department of
Tourism data and analysis.)
The independent studies and analysis
prepared by Dr. Murray and Arthur Anderson, Inc. utilized the
best information available to the public, including information
on the market of the St. Croix Tribe.
3414
The three Tribes in this partnership do not have economic
development control on non-tribal lands, nor have they indicated
involvement in planning for on-site or off-site expansion.
3415
Minnesota Indian Gaming Association
3416
Kenteth Tilaen
'The report fails to detail the relationship between
COMfENT 1:
the land to be placed in trust and the parking lot property,
entrance gate, etc. which is part of the facility and will not be
It fails to identify the adjacent land that will
put in trust.
remain exclusively in the control of the Florida gaming operator.
It fails to identify the long history of community opposition to
the track and it fails to identify the property as across the road
it inaccurately
from land protected by the "Wild River Act*.
indicates the track is open all year and fails to indicated that it
operates about six days a week for between 32 to 40 hours a week
NOT 24 hours a day, seven days a week.'
RESPONSE: The relationship between land taken into federal trust
status for the Tribes is stated in several places in the Addendum
and Attachments, the Notice of Availability, and the DRAFT Finding
of No Significant Impact, where they indicate that the principal
structure, track facilities, paddock and kennel facilities, and
parking lot to the north of the principal structure are intended
for trust acquisition while the main parking lot west of the
grandstand building is not intended for trust acquisition. A legal
description of the area of intended trust acquisition is provided
in Attachment A of the Agreement for Government Services.
The use
of the *1988 Report, is to provide background information and data
regarding work that had already been done regarding the dog track
facility at this location.
Whether the adjacent lands to the track facility are controlled by
a Florida gaming operator, or not, does not apply to this proposed
action. There are no known plans for future development of these
areas.
The Dec. 3, 1992, Indian Gaming Referendum, included in Attachment
II of the Addendum, indicates that the Hudson Community is neither
for, nor against, a Tribal Casino at the dog track facility. Some
opposition to actions of this nature can be expected, however,
based upon this referendum, it
does not appear that there is
overwhelming opposition to this concept.
Discussions with National Park Service personnel in St. Croix
Falls, WI, indicate that the dog track facility is outside
the
management area of the St. Croix Wild and Scenic River System.
Concerns regarding possible impacts to the St. Croix River
from
increased traffic and associated air pollution would be monitored
and addressed through the existing air pollution control
According to the Wisconsin Department of Natural Resources, permit.
Of Air management, neither a new indirect source permit,Bureau
nor
modifications to the existing permit are required,
the air
monitoring stations constructed for the dog trackhowever,
continue to be monitored and the terms of the permit facility would
would continue
in compliance.
3417
The statement that the track is open all year is accrZnumber of hours and/or days of facility operation per was can
render the statement inaccurate.
mg
n~
c
3418
cc
impacts of the proposed
the economic
used to assess
and existing tribal
Community
Hudson
the
to
facility
track/casino
Information from these documents, along with
casino markets.
to the Indian
others included in the application package pursuant
many of the
generate
to
used
was
(IGRA),
Act
Gaming Regulatory
impacts.
socioeconomic
regarding
estimates
impacts
Competition between tribal casino facilities and possible (by Dr.
to each tribal community are discussed in these studies
which show that the proposed Hudson casino/dog track
Murray),
and up to
facility could have a 20% share of the blackjack marketmarket
zone
24% share of the slot and video market in the primary
(predominately St. Croix County in WI, and Washington and Ramsey
This study indicates that the gaming market is of
Counties in MN).
sufficient size to support an additional casino operation and will
Socioeconomic and business related
not saturate the market.
matters are considered in the environmental assessment process,
however, they are more appropriately addressed in the Indian Gaming
Regulatory Act
(IGRA)
process.
It
the concept
of Indian Sovereignty
RESPONSE:
The erosion of public support for Indian gaming rights
is beyond the scope of this action.
3.
3419
RESPONSE: The solidarity of Indian Tribes in supporting ea:! c:heis more appropriately addressed in the IGRA process and is neyon
the scope of this action.
4.
It
gives
gaming.
government.
is
an issue more
3420
William H.H. Cranmer
COMMENT (1): The FONSI and Addendum refer to this as a proposal dy
three Chippewa tribes to gain trust status for the land, in order
to establish a casino. This is not an accurate statement of the
facts.
The association with
The statement is accurate.
RESPONSE:
regarding this
arrangements
business
other
and
Croixland Properties
inaccurate.
statement
the
render
not
matter does
that a casino would
COMMENT (2): The FONSI and Addendum suggest
The June 9, 1994
tribes.
the
for
revenues
significant
produce
"Impacts on Socioeconomic
Bischof & Vasseur memo concerning
however, that each tribe
Conditions: in the Addendum points out,
debt service.
will receive only 25% of the profits after
and
The revenues for the Tribes, the profit shares,
RESPONSE:
by the
after debt profits are issues more appropriately addressed
No significant
process.
Indian Gaining Regulatory Act (IGRA)
environmental impacts are expected as a result of these matters.
"The FONSI and Addendum suggest that an "Agreement
COMMENT (3)
for Government Services" (Agreement) between Croixland Properties,
the three tribes, St. Croix County and the City of Hudson would
"address and minimize""possible negative socioeconomic impacts on
the City of Hudson and St. Croix County" (language in the draft
Section 2710
25 U.S.C.
FONSI) ... this Agreement seems to violate
and Department
(d) (4) of the Indian Gaming Regulatory Act (IGRA),
a
incorporates
also
agreement
This
policy...
Interior
of
Vasseur's
Addendum
Consequently,
no
also
one
does
knows
if
not
the
prepare
Agreement
such
an
would
estimate.
adequately
3421
-address and minimize" negative socioeconomic impacts,
FONSI suggests.
as
ed
RESPONSE: Monies that would be provided to the City and the County
through the Agreement for Government services are an "allocable
amount, based upon information provided to the Tribes from the City
tor these
The signatory authorities
and County governments.
governments, and the Council and Board they represent, are in ideal
positions to assess the services necessary to address possible
negative socioeconomic impacts, and estimate the costs to provide
the services necessary to minimize these possible impacts.
COMMENT
the dog
Second,
actract
3422
to see that the Bischof L Vasseur
*t: is interesting
Addendum even gives slanted facts about the current track .
displays either ignorance or bias in its description of the track's
But the Addendum ignores
placement in Hudson area geography, ...
all the homes to the west and northwest of the track.... further,
most of the other residents of the Town of Troy are ignored in this
description of local geography, even though these residents would
have to use the same roads as casino patrons to drive to and from
The Addendum does not
Hudson commercial areas and the freeway
even mention that the Town of Troy surrounds the potential casino
site on three sides..."
COMMENT (8)
3423
cs
then a cra
If the June 9 claim is incorrect,
incorrect.
would have far less impact on the Hudson economy tha. Bsznz:
I cne:Kec
Moreover, in November, 1992.
Vasseur predicts...
Wisconsin Gaming Commission records for St. Croix Meadows contracts
I found only five Hudson contracts for all of
in the Hudson area.
1991 and 1992... These five contracts would have generated less
than 10 jobs in the Hudson area, not the hundreds of jobs Bischof
& Vasseur claims...*
3424
ativ:
overall business sales and economic
in
increases
:.oun:
increases in visitors from other states and decreases
Children. Negactve
expenditures for Aid to Families with Dependent
increases in
social consequences described in this document include
to problem
calls to gamblers anonymous and increased visits
It is expected, however, that the
gambling treatment centers.
for Government
allocable amount determined by the "Agreement for the possible
Services* will compensate the local governments
need for these services.
The Addendum comments that "no new significant
COMMENT (11) :
"are expected
effects" of noise levels or facility lighting
a dog crack
because of the operation of a Hudson casino ... Clearly
four nights per
that sends 500 to 1,000 customers home at 11 p. m. property
values
week will differ in impact on residents' lives and day casino...
from a 24-hour per day, 7,000-15,000 customers per
Increased activity at the Hudson dog track facility
RESPONSE:
out of the
would involve the movement of additional vehicles in and
This increased traffic is not expected to
proposed facility.
gates to
significantly increase noise levels in the area as toll
the parking facility would be removed reducing delays in entering
and exiting the facility. The original lighting system for the dog
track facility was required to reduce the light spillage at the
property lines to an amount equivalent to residential streets.
There are no plans to modify the existing lighting system.
"The Addendum comments that "no significant shortCOMMENT (12):
term, long-term, or cumulative impacts are expected on urban
The Addendum
casino.
a new Hudson
services" because of
specifically mentions public safety expenditures as one of these
services... however, all the surrounding casino towns have found
the need for more police expenditures because of increased crime
and traffic problems...Minnesota
RESPON3E:
Gambling
1993,
states,
'From
1989
through
to
the
increased
higher-salaried,
demand
families.
for
housing
to
accommodate
new
3425
homes
in
the
Hudson
area.
Many
other
families wou..-
facility
with
tw.
===s
3426
State of Wisconsin \ DEPARTMENT OF NATURAL RESOURCES
Macaen W..ssonse 5570:
60e 26_-2621
TELEPHONE
TaUA
6062i67.579
WlCON5IN
E
......
YAIR
AR
M
TOO
60 267.686
FAX 6-S267-0-.0
KIGMT
Sincerely,
3427
P.0
B.
77
InosD-62574s97
luly 8,
1991
P.ETURIN RECEIPT
PEqUESTED
4509
r. Burton L. Nordstrand
Croixland Properties Limited Partnership
512 Second Screet
Hudson. VI 54016
Dear Mr. Nordscrand:
Your application for an air pollution control permit for modification of the
in Hudson, Wisconsin, has been
st. Croix Meadows greyhound racing facility
processed in accordance with sec. 144.392, Vis. Stats.
The enclosed permit is issued to provide authorization for your source to
be modified and operated in accordance with the requirements and conditions
set forth within Parts I and II of the permit.
Please read it carefully. A
release for permanent operation (construction release) will be issued after
operated according to
verification that the source was modified and initially
the plans and specifications as approved by the Department.
This permit supersedes the air pollution control permit for your source issued
July 6, 1989 permitc number 89-CPB-003).
closed wich the permit there is a bill for the cost of reviewing and acting
upon your air pollution control permit.
This bill
is due and payable in
This fee should be made
30 days of rhe date of the issuance of the permit.
payable to Wisconsin Department of Natural Resources and.recurned to the
address on the bill.
The fee has been calculated under the provisions of sec. NR 410.03, Wis. Adm.
Code, as follows:
Basic fee for permit to modify an indirect major source
Basic fee reduction for applicant publishing public notice
Additional fee for holding public hearing at request of applicant
$3,000
-100
Soo
TOTAL FEE
$3.400
-5.0
$2,900
3428
Mr. Burton L. Nordstrand
Madison,
3429
BEFORE THE DEPARTMENT OF NATURAL RESOURCES
BUREAU OF AIR MANAGEMENT
FINDINGS OF FACT
CONCLUSIONS OF LAW
AND DECISION
Findings of Fact
The Department of Natural Resources
that:
finds
(DNR)
1)
2)
3)
4)
This permit
source.
is
for a major,
modified,
attainment
5)
DNR has
6)
7)
8)
9)