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Union Calendar No.

471
105th Congress, 2d Session-----

--

House Report 105-829

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

November 5, 1998.-Committed to the Committee of the Whole House


on the State of the Union and ordered to be printed

U.S. GOVERNMENT PRINTING OFFICE


51-332

WASHINGTON : 1998

COMMITTEE ON GOVERNMENT REFORM AND OVERSIGHT


DAN BURTON, Indiana, Chairman
HENRY A. WAXMAN, California
BENJAMIN A. GILMAN, New York
TOM LANTOS, California
J. DENNIS HASTERT, Illinois
CONSTANCE A. MORELLA, Maryland
ROBERT E. WISE, JR., West Virginia
MAJOR R. OWENS, New York
CHRISTOPHER SHAYS, Connecticut
EDOLPHUS TOWNS, New York
CHRISTOPHER COX, California
PAUL E. KANJORSKI, Pennsylvania
ILEANA ROS-LEHTINEN, Florida
GARY A. CONDUIT, California
JOHN M. McHUGH, New York
CAROLYN B. MALONEY, New York
STEPHEN HORN, California
THOMAS M. BARRETT, Wisconsin
JOHN L. MICA, Florida
ELEANOR HOLMES NORTON, Washington,
THOMAS M. DAVIS, Virginia
DC
DAVID M. McINTOSH, Indiana
CHAKA FATTAH, Pennsylvania
MARK E. SOUDER, Indiana
ELIJAH E. CUMMINGS, Maryland
JOE SCARBOROUGH, Florida
DENNIS J. KUCINICH, Ohio
JOHN B. SHADEGG, Arizona
ROD R. BLAGOJEVICH, Illinois
STEVEN C. LATOURETTE, Ohio
DANNY K. DAVIS, Illinois
MARSHALL "MARK" SANFORD, South
JOHN F. TIERNEY, Massachusetts
Carolina
JIM TURNER, Texas
JOHN E. SUNUNU, New Hampshire
THOMAS H. ALLEN, Maine
PETE SESSIONS, Texas
HAROLD E. FORD, JR., Tennessee
MICHAEL PAPPAS, New Jersey
VINCE SNOWBARGER, Kansas
BERNARD SANDERS, Vermont
BOB BARR, Georgia
(Independent)
DAN MILLER, Florida
RON LEWIS, Kentucky
KEVIN BINGER, Staff Director
BARBARA J. COLSTOCK, Chief Counsel
DAVID A. KASS, Deputy Counsel and Parliamentarian
LISA SMITH AMAFUNE, Deputy Chief Clerk
PHIL SCHILERO, Minority Staff Director
MAJORITY STAFF

MINORITY STAFF

KEVIN BINGER, Staff Director


BARBARA JEAN COMSTOCK, Chief Counsel
JAMES C. WILSON, Chief Investigative Counsel
DAVID A. KASS, Deputy Counsel and

KRISTIN L. AMERLING, Minority Counsel


KENNETH M. BALLET, Minority Chief

Parliamentarian
MICHAEL Bopp, Senior Investigative Counsel

COURTNEY A. COOK, Minority StaffAssistant


SARAH DESPRES, Minority Counsel
JONATHAN M. FRENKEL, Minority Counsel
HAROLD W. GOSSETT, Minority Professional

J. TIMOTHY GRIFFIN, Senior Investigative

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

ANDREW H. SU, Minority Research Assistant


AMY R. WENDT, Minority Staff Assistant
BARBARA A. WENTWORTH, Minority Research

Assistant
MICHAEL T. YANG, Minority Counsel
MICHAEL J. YEAGER, Minority Counsel

LETTER OF TRANSMITTAL

HOUSE OF REPRESENTATIVES,

Washington, DC, November 5, 1998.


Hon. NEWT GINGRICH,
Speaker of the House of Representatives,
Washington, DC.
DEAR MR. SPEAKER: By direction of the Committee on Government Reform and Oversight, I submit herewith the committee's
sixth report to the 105th Congress.
DAN BURTON,
(III)

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

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2933
2933
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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

Union Calendar No. 471


105TH CONGRESS I
2d Session
HOUSE OF REPRESENTATIVES

REPr. 105-829
VOL. 3 OF 4

INVESTIGATION OF POLITICAL FUNDRAISING


IMPROPRIETIES AND POSSIBLE VIOLATIONS OF LAW

NOVEMBER 5, 1998.-Committed to the Committee of the Whole House on the State


of the Union and ordered to be printed

Mr. BURTON, from the Committee on Government Reform and


Oversight, submitted the following

SIXTH REPORT
together with
ADDITIONAL AND MINORITY VIEWS
On October 8, 1998, the Committee on Government Reform and

Oversight approved and adopted a report entitled, "Investigation of


Political Fundraising Improprieties and Possible Violations of
Law." The chairman was directed to transmit a copy to the Speaker
of the House.
(2931)

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

JORGE CASTRO'S ILLEGAL CAMPAIGN CONTRIBUTIONS,


AND WHY THEY WERE NEVER PROSECUTED
INTRODUCTION

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.

THE KEY PLAYERS

A. ORLANDO CASTRO LLANES

Born in Cuba, Castro Llanes was head of a wing of that nation's


communist party until fleeing the island in 1959 following an alleged dispute with Fidel Castro.' After landing in Haiti, Castro
Llanes went to Miami, and in 1961 or 1962, depending on the account, arrived in Caracas, Venezuela with just $150 in his pocket. 2
By the 1980s, Castro Llanes had become an influential businessman in Venezuela, earning a fortune in the insurance business. He
began aggressively expanding his financial empire, becoming active
in banking, real estate, finance companies, radio stations and
newspapers. 3 Ultimately, his Grupo Impresas Latinamericanos included among its holdings, the Banco Progreso in Venezuela, the
Banco Progreso de Internacional de Puerto Rico, and the Banco
Latinamericano in the Dominican Republic. 4
In March 1991, following allegations of money laundering, U.S.
Customs inspectors ordered the Banco Progreso accounts at New
York's Bank America International frozen, along with those of a
number of other banks.5 Castro Llanes turned to his long-time
legal advisor and business associate, Charles Intriago, for assistance. Mr. Intriago had known Castro Llanes for over a decade, and
had acted as his principal legal advisor on matters related to the
United States. In fact, they were so close that Castro Llanes provided $80,000 in start-up capital for Intriago's Money Laundering
1Ramon Maceiras, Orlando Castro: La Historia Apasionante de un Coloso de las Mnanzas
Venezolanas,
(1991) at 49-65.
2
Id. at 10.
3
See generally id.
54Id.
Peter Truell, "Too Close for Comfort?; Inquiry Touches Money Laundering Expert's Backer,"
New York Times, Apr. 4, 1996, at D1.
(2935)

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

The grandson of Castro Llanes, Castro Barredo worked in his


grandfather's banking empire as president of the Banco
Latinamericano in the Dominican Republic. In 1992, Castro
Barredo made $25,000 in illegal foreign conduit contributions to
the Democratic party. According to his sworn testimony, these contributions were made at the direction of family lawyer and DNC
Trustee, Charles Intriago. Bank documents show that the contributions were reimbursed shortly thereafter by a Venezuelan firm
owned by his grandfather." Castro Barredo was also charged in
the Banco Progreso fraud case.12
The bank fraud case was precipitated when an insurance company controlled by the Castro family overdrew its account at their
Dominican Bank, and local banking authorities required the institution to increase its deposits by $3 million. Castro Barredo improperly withdrew $3.26 million from the family's Puerto Rican
bank and deposited it in the Dominican Republic institution, using
a portion of the money to purchase a yacht.13 Castro Barredo provided testimony to representatives of the Justice Department con6

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

Maria Castro is the aunt of Castro Barredo, and the wife of


Rafael Castro, another one of Castro Llanes's sons. She made a
$20,000 illegal foreign conduit campaign contribution to the DNC,
and a $5,000 illegal conduit contribution to the Maryland State
Democratic party in 1992.17
E. CHARLES INTRIAGO

The relationship between Castro Llanes and Intriago goes back


nearly two decades. After first meeting in 1980, Castro Llanes soon
became one of Intriago's clients.18 Jorge Castro Barredo testified
about his social ties with Intriago, making reference to their attending Florida Marlins baseball games together.19 Castro Barredo
also told Committee investigators that Intriago was paid a monthly
retainer by Castro Llanes of $20,000 to $25,000 per month and
acted as his legal advisor on all matters related to the United
States. He further stated that on one occasion, during the Venezuelan banking crisis of 1994, he was instructed to pay Intriago
$100,000 by either Castro Llanes or his associate Luzmenia
Briceno. 20 In 1989, with the help of an $80,000 investment from
Castro Llanes in exchange for a 15 percent interest in the venture,
Intriago founded the Money Laundering Alert newsletter.
After getting caught up in a bitterly contested hostile takeover
fight for control of the Banco de Venezuela in 1990, Castro Llanes
turned to Intriago for help. He soon faced another potentially critical problem and again turned to Intriago. In March 1991, U.S. Customs officials, suspicious of transactions taking place in accounts
held by a number of Venezuelan banks in New York, moved to
freeze the funds held by those banks. Banco Progreso's account at
the Bank America International was among those affected. Intriago
put together what Jorge Castro Barredo described as a "Dream
to obtain release of
Team" 2 1 of attorneys and political operatives
the funds and was ultimately successful. 2 2
14
Venezuelan Money and the Presidential Election, Hearing, Committee on Government Reform
and Oversight, Apr. 30, 1998 ("Castro Hearing") at 77-78 (Testimony of Joseph J. Dawson).
15
See Letter from Lee J. Radek to Richard T. Preiss, Oct. 17, 1997 (Exhibit 1).
16
Castro
Hearinu at 9 (Testimony of Jorge Castro Barredo).
17
Id. at 10, 14 (Testimony of Jorge Castro Barredo).
s Interview of Jorge Castro Barredo, Jan. 19, 1998 ("Castro Interview I").
19 Castro Hearing at 39 (Testimony of Jorge Castro Barredo).
22 1 Castro Interview I.
Interview of Jorge Castro Barredo on Sept. 15, 1998.
2
2Id.

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

Deposition of Charles A. Intriago, Feb. 20, 1998 ("Intriago De sition").


Hearing at 36 (Statement by Robert Plotkin,
tor Charles Intriago)
e See DNC Document 076440, a review of applicants Counsel
for political appointments by the newly
elected Clinton Administration (Exhibit 2).
2 Id.
2 Id.
2Memorandum from Martha Phipps to Dana Wyckoff, Feb.
23, 1994 (Exhibit 3).
24Castro
2

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

On September 15, 1992, Charles Intriago called Jorge Castro


Barredo at his office in the Dominican Republic, and asked him to
make several contributions to the DNC.30 Castro Barredo recalls
that Intriago said either that "we are going to make some contributions to Clinton's campaign," or that "your grandfather wants to
make contributions to Clinton's campaign." 3 ' Intriago told Castro
Barredo that he and his uncle, Rafael Castro, should make the contributions, because they were U.S. citizens. 3 2 At this point, Castro
Barredo told Intriago that Rafael did not have a bank account, but
that Rafael's wife, Maria Sire Castro, had a bank account, and was
a U.S. citizen.3 3 Intriago then told Castro Barredo that he should
write one check to the DNC for $20,000, and another check to the
Ohio State Democratic party for $5,000.34 Intriago also told Castro
Barredo to have Maria Castro write a check for $20,000 to the
DNC, and a check for $5,000 to the Maryland State Democratic
party.35 After Castro Barredo's telephone conversation with
Intriago, he requested that his uncle have his aunt draft the two
checks that Intriago had requested.3 6
Castro Barredo was slightly confused, however, by Intriago's instructions, and he asked Intriago to send a fax with written instructions for how to draft the checks.3 7 Castro Barredo received
the fax the following day. On the fax, Intriago listed out each contribution that Castro Barredo and Maria Castro were supposed to
make. At the bottom of the fax, Intriago wrote in Spanish: "I want
you to send me these today by Federal Express." 3 8
At the time that he made the contributions, Castro Barredo knew
that he and his aunt would be reimbursed.3 9 Castro Barredo had
no interest in politics, had never voted, and had no interest in giving $25,000 to support any political party. 40 Most importantly, during their telephone conversation about the contributions, Intriago
assured Castro Barredo that he and his aunt would be reimbursed
by "one of his grandfather's companies." 4 1
Several days after Castro Barredo sent the requested checks to
Intriago, Intriago called him and requested that he send a new
check. Intriago told Castro Barredo that he was not going to use
"Letter from Charles Intriago to Ron Brown, Dec. 2, 1992 (Exhibit 4).
3o Castro Hearing at 13.
axCastro Interview I.
32 Id.
33 Id.

"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

After his family contributed $50,000 to the Democratic party,


Castro Llanes received red carpet treatment from the Clinton Administration over the coming year. Immeditaely after Bill Clinton's
election in 1992, Castro Llanes told Castro Barredo that they were
hopeful that Intriago would be appointed as ambassador to Venezuela.4 8 While this goal did not come to fruition, Intriago did give
the Castro family increased access to Washington, DC, after President Clinton's election.
Castro Llanes, Intriago and Castro Barredo all attended the January 1993 inauguration of President Clinton.4 9 In October 1993,
Castro Llanes, Intriago, Castro Barredo, and Castro Castro returned to the United States. The first day that the group was in
Washington, Castro Llanes and Intriago went to the White House
for a reception for DNC donors.5 0 At this event, Castro Llanes had
a picture taken with President Clinton.5 1 Castro Barredo was not
invited to this event, even though it was he, not Castro Llanes,
who had contributed $25,000 to the DNC.
The following day, the Castro group traveled to the State Department, where they met with State Department officials Perry Ball
and Monica Adler.5 2 It was Castro Barredo's understanding that
Intriago had set up the meeting at the State Department.5 3 The
purpose of the meeting was to discuss the ongoing investigations
42

Castro Interview I; see Exhibit 6.


Id.; see Check from Jorge Castro Barredo to Florida Democratic party (Exhibit 10).
Castro Hearing at 26.
45 Id.
" See Account Statement of Jorge F. Castro, International Bank of Miami, September 1992
(Exhibit
11); Wire Transfer Information, NationsBank, Sept. 24, 1992 (Exhibit 12).
47
Wire Transfer Statements (Exhibits 13-14). See also Trust
Statement for Banco Industrial
de Venezuela (listing Inversiones Latinfin as one of Orlando Castro Llanes' companies).
" Castro Interview I at 4.
4 Castro Hearing at 29.
Hearing at 29-31.
5'oCastro
1
Photograph of Orlando Castro Uanes and President Clinton, Oct. 14, 1993 (Exhibit 15). A
set of photos of Charles Intriago and Orlando Castro Lanes were sent to Intriago
by the DNC.
See52 Letter fr-om Eric Sildon to Charles Intriago, June 21, 1995 (Exhibit 16).
Castro Interview I.
5 Id.
4
4

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

Intriago himself made over $52,000 in contributions to the DNC


during the 1992 election cycle. These include contributions to the
Democratic State Central Committee of Maryland, the Democratic
Congressional Campaign Committee ("DCCC"), the DNC, the Colorado Democratic party, Senator Tom Harkin, the Illinois Democratic party, the Nebraska Democratic Future Fund Committee,
and the Ohio Democratic party.r5 After raising more than $10,000
at a Miami dinner honoring Vice President Gore in 1993, Intriago
became a member of the DNC's Business Leadership Forum. 5 6
In the course of attending various DNC fundraising events,
Intriago had the opportunity to come into close contact with other
members of the DNC's elite. One of the most important of these
was Charles "Bud" Stack, a DNC Trustee, who, along with Intriago
was a major donor to an April 29, 1993, dinner honoring Vice
President Gore. Intriago received help from Stack in arranging a
meeting between Castro Llanes and President Clinton.5 7 Intriago
became a DNC Trustee in 1992, evidenced by a letter written by
Intriago on December 2, 1992.58
III.

NEW YORK DISTRICT ATTORNEY'S INVESTIGATION


In December 1994, the Latin American banking community was
rocked by the collapse of three major financial institutions, the
Banco Progreso in Venezuela, the Banco Progreso Internacional de
Puerto Rico, and the Banco Latinamericano in the Dominican Republic. These institutions were all part of Group Impresas
Latinoamericanos, Orlando Castro Llanes' financial empire.5 9 Following the collapse of these financial institutions, the New York
District Attorney's Office initiated an investigation into possible
violations of banking law by the Castro family. 60 In the course of
the investigation, an Assistant District Attorney and several investigators were granted permission to examine the files of the Banco
Latinamericano in Santo Domingo, one of the Castro family banks.
Banco Latinamericano's president was Jorge Castro Barredo, Castro Llanes' grandson. 6 1
While conducting their search, the New York investigators discovered a number of documents in the office of Castro Barredo's
secretary, including the fax dated September 16, 1992, from
Intriago instructing Castro Barredo to make conduit contributions.
The New York investigators also discovered copies of checks showing Castro Barredo's contributions to the Democratic party. 6 2
THE

54 Id.

"See FEC website, www.tray.com/fecinfo.


" See Memorandum from Team Florida to Nancy Jacobson, Laura Hartigan, Jan Hearst, Sam
Newman,
May 7, 1993 (Exhibit 17).
57
Truell, Peter, 'Too Close For Comfort," the New York Times, Apr. 4, 1996.
5Exhibit 5.
- Kindler-Dawson Interview.
S
6 1 Kindler-Dawson Interview.
Castro Hearing at 75 (Testimony of Joseph J. Dawson); see also Kindler-Dawson Interview.
62 See Exhibits 5-7.

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

B. THE CASTRO CASE IS TAKEN BY THE PUBLIC INTEGRITY SECTION

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

Castro Hearing at 82.


at 82 (Testimony of Richard T. Preiss).
at 79 (Testimony of Richard T. Preiss).
Id.; see also Kindler-Dawson Interview.

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.

" Castro Hearing at 88-89 (Testimony of Richard T. Preiss).

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.

COUNSEL. What was the result?


Mr. PREISs. I was not put through to him.
COUNSEL. Now, it's my understanding-correct me if I'm
wrong-that you were told that Mr. Radek would not
speak to anyone unless they had a referral number for the
case, correct?
Mr. PREIss. That's correct.
COUNSEL. And do you know whether Mr. Castro's lawyer
had such a referral number?
Mr. PREiss. If he did, he didn't give it to me.
COUNSEL. Did anybody ever give you a referral number
for this case?
Mr. PREISS. No, I don't think we were ever given a referral number. I don't think anybody had a referral number.
Maybe there was a referral number inside the Department
of Justice, but, again I wouldn't be privy to that, so I don't
know.
COUNSEL. Right, but Mr. Castro's attorney was not an
employee of the Department of Justice, so he had the same
status as you.
Mr. PREISS. No he was not an employee of the Department of Justice.
COUNSEL. OK. And I don't know whether this is a question you can answer or not, but were you concerned at the
time that Mr. Castro's attorney was given more attentive
treatment at the highest levels of the Department of Justice than you?
Mr. PREISS. Well, I thought at the time, I think I said
in the conversation that I couldn't understand why the defense attorney's phone call could be taken the day before,
but mine couldn't be and I was the prosecutor and he was
the defense lawyer. I think that's what I said to the person
who answered the phone.8 5
The willingness of Mr. Radek to accept a phone call from a defense
attorney and at the same time refuse to accept a phone call from
a New York Assistant District Attorney who referred the case is curious. At the same time, however, it is not the most troubling aspect of the case. Of particular concern is the decision of Justice Department officials in Washington to ignore evidence which strongly
suggests that not only was an illegal conduit contribution made,
but that it was made in close coordination with a prominent Democratic contributor who is a lawyer and who was getting directions
from another unknown party.
85

Id. at 89 (Testimony of Richard T. Preiss).

2946
C. THE CASTRO CASE DIES

Roughly 1 week later, Preiss was called by Peter Ainsworth, a


trial attorney from the Justice Department's Campaign Finance
Task Force. Ainsworth told Preiss that he was handling the Castro
case, and had in his possession the notes and documents from the
meeting the other Federal prosecutors had had with Castro
Barredo. 8 6 Preiss offered to make Castro Barredo available for an
interview, and stated that he was willing to request a sentencing
delay if necessary. The attorney told Preiss that he did not want
with the New
to speak with Castro Barredo, but did want to speak
87
documents.
some
review
to
and
York prosecutors
On July 23, 1997, Ainsworth came to New York accompanied by
an FBI agent, spoke with the New York prosecutors, reviewed the
documents which corroborated Castro Barredo's testimony, and
took with him photocopies of some of the documents.88 At this
meeting, Preiss and Dawson told Ainsworth that they were -willing
Justice Departa
to delay Castro Barredo's sentencing pending the
ment's review of Castro Barredo's contributions. 8 9 The New York
District Attorneys recommended the delay in sentencing so that
Castro Barredo would continue to have an incentive to cooperate.
prosecuRequesting such a delay in sentencing was the standard
torial practice that they had followed in the past.9 0 In addition,
while Ainsworth was at their office, Preiss and Dawson both reminded Ainsworth that the statute of limitations on the Castro
case likely expired on September 16, 1997.91
The following month, the New York prosecutors asked for and received a stay in Castro Barredo's sentencing.9 2 On August 19,
1997, and then again on September 23, 1997, the New York District Attorney's Office requested delays in Castro Barredo's sentencing.9 3 Preiss also provided additional information to Ainsworth
after Castro Barredo's sentencing was delayed.9 4 In his letter to
Ainsworth, Preiss again asked that the Justice Department
let him
know what their plans were concerning this case.9 5
After returning from a vacation in late September 1997, Preiss
called the Task Force attorney several times to find out what the
status of the case was. 96 He was concerned that the perceived September 16 deadline would pass without any action from the Justice
Department. 97 Eventually, he received a voice mail message thanking him for his patience. Despite the lack of response from the Justice Department, the New York District Attorney again requested
that sentencing be delayed once more, and it was, this time until
October 20, 1997.98
Preiss wrote to Ainsworth again on October 10, 1997, stating:
8 Preiss-Dawson Interview.
8 Castro Hearing at 80 (Testimony of Richard T. Preiss).
8 Id.
8 Id.
I Castro Hearing at 103-104.
e 1Preiss-Dawson Interview.
93 Castro Hearing at 80.
Id.
95 Letter from Richard T. Preiss to Peter Ainsworth, Sept. 4, 1997 (Exhibit 22).
9 1d.
9 Preiss-Dawson Interview.
9 Id.
" Castro Hearing at 81 (Testimony of Richard T. Preiss).

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

Castro Barredo was sentenced on December 15, 1997, to between


3Y to 10% years in prison on bank fraud charges. No charges have
ever been filed against Charles Intriago by the Justice Department.
When he was called to testify by the Committee, Mr. Intriago invoked his Fifth Amendment rights. 10 2
The frustration of the New York District Attorney's Office with
the Justice Department was clear from the testimony of Preiss and
Dawson before the Committee. In fact, at one point during their
dealings with the Justice Department, the District Attorney's Office
considered taking the Castro case back from the Justice Department. Mr. Dawson testified to this fact before the Committee:
COUNSEL. Just one last question, and I'll address this to
you, Mr. Dawson. Did you at any time have great enough
concerns that you discussed or contemplated trying to take
the case back and have your own office do something with
the conduit contributions case?
Mr. DAWSON. Yes, we had conversations about it.
*

Mr. BURTON. Let me followup on that. When you had


conversations about it, were those conversations involving
Mr. Intriago?
Mr. DAWSON. Well, I'm reluctant to answer the question
only because it involves questions between-I mean con99 Letter from

Richard Preiss to Peter Ainsworth, Oct. 10, 1997 (Exhibit 23).


oo Id.
ioxMemorandum from Marc S. Nurik to Richard T. Preiss with attached letter from Lee J.
Radek, Oct. 17, 1997 (Exhibit 24).
102 See Intriago Deposition.

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

The Castro case represents one small episode in a large pattern


of illegal campaign contributions in the 1992 and 1996 elections.
However, the Castro case stands out from the others for the way
it was so obviously mishandled by the Justice Department. The
Justice Department was presented with clear evidence that a major
DNC fundraiser was involved in directing conduit contributions to
the DNC. Moreover, they had evidence that Mr. Intriago was receiving guidance on how to direct those contributions from some
higher authority, presumably within the Democratic party.
Inexplicably, the Justice Department failed to pursue this case, and
let the statute of limitations on the case expire, effectively preventing anyone else from pursuing it.
A key point in the testimony of the New York District Attorneys,
Dawson and Preiss, came during an exchange with Chairman Burton:
Mr. BURTON. You thought Mr. Intriago should have been
investigated?
Mr. DAWSON. That the matter should have been investigated.
Mr. PREIss. We thought the matter should have been investigated.
Mr. BURTON. Including Mr. Intriago.
Mr. DAWSON. Well, to be honest with you Mr. Chairman,
we had already looked into some of Mr. Intriago's transactions ourselves, and we had referred all of this stuff. So,
I guess it's no secret that this was among, I suppose, that
he would be among the matters we had referred.
Mr. BURTON. You thought it was worth them looking at.
Mr. PREIss. Absolutely, that's why we referred it.104
The investigation into the illegal conduit contributions of the
Castro family leaves many unanswered questions. Among the most
pressing unresolved issues are:
* The role Charles Intriago played in funneling illegal conduit contributions to the DNC and its various state affiliates.
* The possibility that the solicitation of such contributions
was coordinated with senior officials of the DNC.
* The circumstances surrounding the transfer of the Castro
family case from the Southern District of Florida to the Justice
Department's Public Integrity Section.
* Why the Justice Department chose not to prosecute
where there was clear and compelling evidence to showa case
that
several crimes had been committed.
* Why the FEC failed to act on the clear evidence
law violations presented in the Castro family case. of election
.0o
104 Castro Hearing at 107.

Id. at 88 (Testimony of Joseph J. Dawson and Richard T. Preise).

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

BY FAX AND U.S.

MAIL

Mr. Richard T. Preiss


Assistant District Attorney
Senior Investigative Counsel
Office of the District Attorney
County of New York
One Hogan Place
New York, NY 10013
Dear Mr. Preiss:
Re:

Jorce Castro Barredo

You have advised us that Jorge Castro Barredo is scheduled to


for bank fraud and related
be sentenced on October 20, 1997,
offenses, and have asked whether we would like the proceeding
continued and whether we intended to make any submission to the
sentencing court regarding Mr.
Barredo's cooperation
in
the
investigation being conducted by the Public Integrity Section's
Campaign Financing Task Force. This letter is to advise you that
we do not request such a continuance and will not make a
submission.
We very much appreciate your having brought Mr. Barredc to our
attention as a potential witness in matters being investigated by
the Justice Department. As you know, Mr. Barredo, following his
conviction in your case, agreed to be interviewed by federal agents
investigating possible violations of campaign financing laws.
Mr. Barredo answered all questions put to him and otherwise
cooperated with the agents throughout a lengthy interview.
Based
upon that interview and other information developed by the Task
Force, however, we have concluded that there is at this time no
further role for him to play in matters under investigation by the
Task Force.
Please feel free to bring Mr.
Barredo's assistance,
as
described herein, to the attention of the court
at sentencing.

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:

Mr. Mark Nyrick


Attorney for Jorge Castro Barredo

2952

APPLICANT:DAER
s athleen C. Noyt

DT!
12/18/

12/18/92

FRL Mr. Craig Smith

WILL SPONSOR: T RECONMEN:


SQURCEL JENNIFER O'CONNOR
JOB PREF. AREA OF INTEREST: ADMN
CARMAGL CC
PREFERENCE: LABOR
AGENCY/DEPARTMENT
SC
JOB LEVEL:
ASST SECRETARY OF EMPLOYMENT & TRAINING; ENDORSED STRONGLY BY GOVERNOR

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

ALSO INTERESTED IN POVERTY & CHILDRENS

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:

Also highly recommended by Eli Segal.

APPLICANT:
Mr. Charles A.

EROK

Intriago

2/69

12/16/

Mr. Eli Segal

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

SOURCE- JENNIFER 0* CONNOR

COMMENTS:

RD
12/16/92

PRE. /AREA OF
AGENCY/DEPATMEN PREFERENCE:
00

Worked really hard in

T
T
BUD

ECOMNEND: HR
STAT

NJ; capable and very competent.

EXHIBIT
2

IlfilfllilfllflllmiifilfilDHC 0764400

2953

DsmdWdhebb.Ch.

MEMORANDUM
TO:

DANA WYCKOFF

FROM:

MARTHA PHIPPS

DATE:

FEBRUARY 23, 194

RE:

SALVADORAN ELECTION DELEGATION

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

S. Mr. Prank Moore


a1i
ViePu~a GavausM
WMX Teology and Service, Inc.
U155 Coocdat Ave., NW
Suiftso
Washigngd, DC 20036
9. AtIormay Gmm Da MwA-k

P.O. Box W41


Ausdi. TX 78401
512-463-2191

IUUIEUEEIUURIU DNqC 0311809

2955
10. On=c Napltu.
12009 Eau Firemme
Norwalk. CA 90650
916-445-096

The Jeffam Group


13410 Stree, NW
suite 110
WashingM. DC
2M638-33S
Plem m~c me when you have solhcled the Individuals who will aftd doe Salvadoan
Elections. If yo have my queshins. I am be rbacbed at 86348121.

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

THE INTERNATIOC SANKOF MIAMI. NA.

.... FLOn

JORGE F. CASTRO
OR GREZIA MATOS DE CASTRO

lI 1

104A

THE INTERNATIONAL
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EXHIBrf

2960

ALEFRT INTERNATIONAL, LNC.

1401 Ddcke Avenu


Sie 570
P.O. Boz 011396
Miam, EL 33101 U.S.A.
Fax? 30S.530-9434
Phce.e: 305-530-050

FA

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AFVILUATION

coveh~tt
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DATE:F/

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FROM:
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MIBIT
8

2961

- - -- - - -

- - - - - -

ALERT INTERNATIONAL, INC.

1401 Brickell Avenue


Sulte 570 P.O. Box 011390
Miami, FL 33101 U.S.A.
Fax: 305.530-9434

Phone: 305S30-0500

FAX #;

DATE:
TO:
AFFILIATION:

5z/
9 /

3137

I =n

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(including cover sheet)

2962

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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,

if I can ever be of assistance to you, please do not hesitate to let me

Sincerely,

Enc Sildon
Director
National Membership Services

lll

know

2969
urMANDUM
TO:

Nancy Jacobson, National Finance Director


Laura Hartigan, Director, Trustee Program
Jane Hearst, Director, BLF
Sam Newman, Director, NFC

FROM:

Team Florida

DATE:

May 7, 1993

RE:

Florida donors

The following is a list


of donors whose contribution
to the April 29, 1993 dinner
in
Miami honoring Vice
President Al Gore has earned membership to either the NFC
or BLF.
Only contributions
given, not contributions
raised, were counted towards such credit.
The individuals who raised more than $50,000 should be
included as members of the Trustee program,
as should
individuals who made significant contributions as "partial
payment" towards Trustee
status,
with the understanding
they will finish their $50,000 commitment by the end of the
year.
In addition, there are several individuals who raised
substantial money but did not make a contribution towards
the event.
Their names, a brief explanation of their
situation and the amount each raised or gave is listed at
We
the end of this memo in the Honorable Mention section.
recommend each receive special consideration for membership
*
4
in one of the programs.

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

Richard D. Gregorie, Esq.


Senior Litigation Counsel
United States Attorney's Office
99 Northeast 4th Street
Miami, FL 33132
Dear Mr. Gregorie,
I enclose an Order which Judge Edward J. McLaughlin signed
today releasing certain evidence to the United States Attorney's
Office and to the United States Grand Jury for the Southern
District of Florida.
I also enclose certain documents, described in the attached
Schedule A.
The Chronologies relate to an apparent conspiracy to obstruct
justice; the checks and wire transfers relate to a series of
violations of the laws relating to campaign financing. That is, two
people sent S25,000 each to a political party, and received reimbursement for those political contributions from an off-shore
company.
I will be sending you a list of the people whom we believe are
involved in the conspiracy, either as victims, witnesses or
conspirators under separate cover--probably tomorrow. I am sending
this letter off now so that you will get when I promised it.
In reviewing the chronologies the salient facts are that
Orlando Castro Llanes was involved in a nasty fight with one Thor
Ralversson and others over control of the Banco de Venezuela which
has nothing to do with US criminal cases but provides a backdrop to
proceedings in
the chronologies. Separately the USDOJ brought civil
the Eastern District of New York against funds allegedly the
was
in 1991 and
that
proceeding
proceeds of narcotics dealings;
1992. In 1993 a Grand Jury was started in the EDNY looking at money
laundering involving Venezuela. The Customs agents working that
case were relieved of their assignment in 1994 after Charles
Intriago and Harold Tyler visited EDNY.

II

EXH4Ifl

18

2972
DISTRICr

ATTo

Ner

CoUNry

of

iw

Voam

Richard 0. Gregorie, Esq.


October 9, 1996
Page 2
true that Carlos Freeman called New York County
It
is
Assistant District Attorney Hercules tzquierdo on the dates listed
in the chronology. Neither Freeman nor Izquierdo spoke to anyone
outside the District Attorney's Office about those calls. it is
also true that Freeman spoke with Jonathan Winer on the dates
indicated; Winer confirms the accuracy of the chronology and says
he does not know how Intriago found out who was calling whom.
In sum the December chronology shows (9/23-26/91) a meeting
between agents and an AUSA in which defense counsel quotes the AUSA
correctly; it has telephone information not within the purview of
an attorney; it reports to a potential criminal defendant the names
of government informants against him. There may be a conspiracy
here to obstruct justice.
In any event I must send this out now. I will send additional
information as soon as is possible.
rul

urs

Jo
.
scow
Assistaht District Attorney

Enclosures

2973
DISTRICT ATTORNEY

COUNTY Of NEW YORK


O't

nossart~

A0N

smokGrNVsu

RACE

Oct:ber

24 1996

Richard 0. Gregorie. Esq.


Senior Litigation Counsel
United States Attorney's Cffice
99 Northeast 4th Street
Miami, FL 33132
Dear Mr. Gregorie,
I write to follow-up our meeting on
Attached are documents extracted from files

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

Assistant District Accorney


Endsa.

2974
DISTRICT
OF

ATTORNEY
T-E

COUNTY OF NEW YORK


ONE

MMAN0

FLCk

Z2I23 335000

0o0ER
P

MOnA0NTu

October 29,

1996

Richard D. Gregorie, Esq.


Senior Litigation Counsel
United States Attorney's Office
99 Northeast 4th Street
Miami, FL 33132
Dear Mr. Gregorie,
I write to follow-up our
Attached are documents extracted

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

February 24, 1997

Richard Gregory, Esq.


Assistant United States Attorney
United States Attorney's Office
99 NE 4 Street
Miami, Florida 33132
Dear Mr. Gregory:
I enclose the following documents, divided into two packets.
The first packet contains documents obtained by ADA Joseph
Dawson, Detective Investigator Ed Pozo and Investigative Analyst
Peggy Abensur from Banco Latinoamericano, in the Dominican
Republic.
It includes:
(1) A fax cover sheet which appears to be written
by Charles Intriago on September 16, 1992, in
which the author asks Jorge Castro and Maria
Sire Castro to issue four checks totaling
$50,000.00 to various Democratic Party
"Victory Funds";
(2) The front sides of four checks, issued by
both Jorge and Maria Castro and totaling
$50,000.00, to various DNC "Victory Funds";
(3) A wire transfer document showing that, on
September 13, 1994, Jorge Castro sent Charles
Intriago $100,000.00;
(4)

A Philip Manuel Resources Group document,


illustrating what appears to be legal "Work
Flow".

The second packet contains documents produced to the Grand


Jury, including:
(1) The fronts and backs of two checks issued by Jorge
Castro to two DNC election funds, totaling $25,000.00;
the backs illustrate that the checks were cashed;

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

Assistant District Attorney

2977
DISTRICT ATTORNEY
09

'.g

COUNTY OF NEW VORK


ONE MOGAN PLACE
New Vom_ N.Y. 10023
(23) 33549000

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

Dear Mr. Ainsworth:


Enclosed please find the bank documents you requested.
Specifically, we enclose copies of checks numbered 176, 129, 325
(front and back), the accompanying bank statements showing that
these checks were paid and the Chips statements. These documents
are our original copies. There is a fourth check for 5,000.00 that
we cannot find (and probably never had) that was drawn on the NCNB
(Nationsbank) account. The number of that check is probably 378.
I suggest you contact the account holder for the original cancelled
check. In any event, the account statement showing that check was
paid is enclosed.
I will be away from the Office on travel from September 10th
until September 21st.
Please call Assistant District Attorney
Joseph Dawson at (212) 335-4210 should you require anything further
during that time.
Finally, my superiors would be grateful if you would let us
know as soon as you can when a decision has been made in this
matter.
Very truly yours,
Richard T. Preiss
Assistant District Attorney
Senior Investigative Counsel
Enclosures

EXHIBIT
22

2978

OF

THE

COUNTY OF NEW YORK


ONE HOGAN PLACE
...
Y=m NY
1-13
(212)3359000

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:

Jorge Castro Barredo

Dear Mr. Ainsworth:


Jorge Castro Barredo is currently scheduled to be sentenced on
October 20,
1997.
We referred a matter to the Department of
Justice in late in 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.
Please advise us whether the Department of Justice intends to
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.
Very truly yours,

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

Richard T. Preisa, Esq.

FROM

Carolyn William

DATE:

October 17, 1997

RE

Jorge Castro Barredo

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

3es 760 4421

P.e0z

2980
U. S. Deparmme of Josee

D.C 2M

OCT 1

Mr. Richard T. Preiss


Assintsant District Attorney
Senior Investigative Counsel
Office of the District Attornay
County of mew York
One Magan Place
New York, NY 10013
Dear Mr. Preiss,
Re,

7ore

Castro Barredo

You have advised us that Jorge Castro Barredo is scheduled to


be sentenced on October 20, 1997, fr bank fraud and related
offenses, and have asked whether we i.ud
lice the proceeding
continued and whether we Intended to iake any submission to the
sentencing court regarding Mr.
Sarredo's cooperation in
the
investigation being conducted by the jhblia Integrity Section's
Campaign Financing Task Force.
This ltter
is to advise you that
we do not request such a continuarce and will not make a
submission.
We very much appreciate your having brought Mr. Barred to our
attention as a potential witness in matters be"ns investigated by
the Justice Department.
As you know, Mr. farredo, following his
conviction in your case, agreed to be interviewed by federal agents
investigating possible violations of campaign financing laws.
Mr. Barredo answered all
estions
t to him and otherwise
cooperated with the agents
ghot S lengthy interview.
Based
upon that interview and other informaion developed by the Task
Force, however, we have concluded tha there is at this time no
further role for him to play in matters under investigation by the
Task Force.
Please feel
described herein,

free to bring Mr. Barredo's assistance, as


to the attention of le
court at sentencing.

10/17/97
OCT-17-1997

10:50

305 760 4421

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:

Mr. Mark Nyrick


Attozay for Jorge Castro Barredo

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?

FEC ENFORCEMENT PRACTICES AND THE CASE AGAINST FOREIGN


NATIONAL THOMAS KRAMER: DID PROMINENT DNC FUNDRAISERS
RECEIVE SPECIAL TREATMENT?
I. INTRODUCTION

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

Federal Election Commission Enforcement Actions: Foreign Campaign Contributions And


Other FECA Violations Before the House Committee on Government Reform And Oversight,
105th
Cong., 2d sess. 114 (1998).
7
Id. at 80 (statement of FEC General Counsel) (emphasis added).
5
General Counsel's Report, In the Matter of Greenberg, Traurg, Hoffman, Lipoff, Rosen &
Quentel,
PA, et al, MUR 4638, Dec. 19, 1997, at 2.3-2.4 (Exhibit 2).
9
Federal Election Commission Enforcement Actions, supra note 6 at 80-81 (statement of FEC
General Counsel). General Counsel Noble stated that the FEC "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." Id. at 81.
1o
1 Id. at 82.
"Affidavit of Thomas Kramer, Dec. 27, 1994 (Exhibit 3); see also Letter from Roger M.
Witten to Joan McEnery and Mary L. Taksar, Dec. 27, 1994 (Exhibit 21).

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

Thomas Bernhard Kramer was born in Bad Soden, Germany on


April 27, 1957. He worked at Shearson Lehman Hutton Inc. in
Frankfurt from 1983 until 1988, leaving Germany the following
year after his plan to buy up East German pre-reunification real
estate proved unsuccessful. He settled in Miami during the early
1990s and remains in the United States as a resident on a tourist
visa.1
Mr. Kramer's lack of U.S. citizenship would certainly not surprise anyone remotely familiar with the Miami South Beach scene.
Leading a high profile life colored with self-promotion, Kramer was
often described in newspapers and national magazines by such
monikers as "the impulsive German whiz kid"' 3 or "the German
multimillionaire."14 During the early 1990s, he amassed more than
$40 million in property on South Beach and Star Island-often
paying cash for his acquisitions. The Miami Herald once ran a full
color picture of Kramer on the cover of its Tropic insert describing
Kramer as "The German Tycoon Who Wants To Rebuild South
Beach in His Own Image." '5
FEC General Counsel Lawrence Noble stated in testimony before
this Committee that, to his understanding, Kramer was definitely
known to be a German investor in the South Beach, Miami area.
Mr. Noble further pointed out that Kramer's immigration status
"was a question of whether or not it was obvious or not he was a
foreign national and whether or not he was what's called a green
card holder in this country."1 6 Mr. Noble's statement shows that
Kramers immigration status was thus something certainly in need
of scrutiny. Notwithstanding public information that might have
led potential solicitors to question Kramer's nationality, the evidence obtained by the Committee demonstrates that Marvin Rosen
2
1 Christine Evans, "Kramer vs. Kramer," Miami Herald, May 9, 1993, at 9. Notwithstanding
requests to the Department of Justice for immigration information on Thomas Kramer, this
Committee has not received as much cooperation as expected.
1aEvans,
supra note 12.
14
Christine Evans, "The Mysterious Stranger," Tropic, Jan. 3, 1993, at 11.
15
Tropic Magazine Cover, Jan. 3, 1993 (Exhibit 4).
1eFeieral Election Commission Enforcement Actions, supra note 6 at 35 (statement of FEC
General Counsel).

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

Mr. Kramer made numerous contributions to national and state


candidates of both the Democratic and Republican parties between
April 1993 and March 1994. He made the contributions in his own
name, in the name of his companies, in his wife Catherine Burda
Kramer's name, and in his secretary Terri Bradley's name. In an
affidavit filed with the FEC, Kramer said:
[N]o one who solicited or accepted my candidate contributions ever asked me about my immigration status, advised
me that I was illegal to contribute, or rejected my political
contributions because of my citizenship. 28
The Committee's investigation uncovered no evidence contradicting this claim for the majority of recipients. Two facts, however,
stand out. First, Marvin Rosen's law firm--Greenberg Traurig-did
immigration work for Kramer, thereby putting Rosen and his colleagues on clear notice that Kramer was not eligible to make political contributions. Second, there appeared to be clear and convincing evidence that Kramer was counseled on how to break the law
by Howard Glicken. Because Glicken coached Kramer on making
conduit contributions through Kramer's secretary, it is appropriate
to assume that he understood that Kramer himself would not make
the contributions.
On August 5, 1996, Kramer entered into a conciliation agreement
with the FEC stating that "[r]espondent Thomas Kramer made a
total of $322,600 in contributions either directly, through his secretary, through unknown intermediaries, or as an officer through
his various corporations which were used in connection with elections for local, State and Federal office, in violation of 2 U.S.C.
441e and 441f."29 The two conduit contributions made through
his secretary Terri Bradley, the first and third contributions made
by Kramer,3 0 are detailed in the chart below:
Contributions Made in the Name of Terri Bradley 3'
Date
3/20/93 ................
4/28/93 ................

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

On September 28, 1994, the Tampa Tribune published an article


entitled "Developer's donations questioned," bringing into question
the more than $500,000 contributed by the "flamboyant German
developer."34 Shortly thereafter, Kramer brought the matter to the
attention of the FEC. The somewhat unorthodox method by which
the case arrived at the FEC was noted by FEC Commissioner
McGarry during one of the Pre-Matter Under Review, or Pre-MUR,
hearings:
I'm convinced also in my own mind that if it weren't for
the Tampa Tribune we wouldn't be seeing this case. It is
sua sponte yes, but I always am less sympathetic when
someone is accelerated, eh, to jump in and do something
and bring it to our attention when it's publicized in a
major newspaper.3 5
On October 4, 1994, Kramer's counsel wrote to FEC General
Counsel Lawrence Noble expressing his client's desire to voluntarily disclose his violations of the Federal Election Campaign Act
("FECA").36 The case was docketed as Pre-MUR 307 (which later
became MUR 4398 as the investigation continued). A longer letter
and an affidavit from Kramer disclosing the contributions he made
to the DNC and to the Republican party of Florida followed in December.3 7 In the affidavit, Kramer cited the September 1994
Tampa Tribune article, which spotlighted his illegal contributions,
as providing the impetus for his decision to come forward. Kramer
claimed that he was "not knowledgeable about federal campaign finance laws" at the time he made his political contributions. 3 8 Both
the letter and the affidavit state that Kramer was never advised
that a foreign national could not make candidate contributions.
The fact that the FEC did not discover the identities of the solicitors of Kramer's illegal contributions until over 22 years after receiving Kramer's admissions, together with the FEC's General
Counsel citing a then-expiring statute of limitations as a reason not
to pursue a case against the solicitors, brings into question the
34

Lavelle, supra note 2.


5FEC Pre-MUR 307/MUR 4398 proceedings, June 26, 1996.
3367 Letter from Roger M. Witten to General Counsel Noble,
Oct. 4, 1994 (Exhibit 20).
Letter from Roger M. Witten and Margaret L. Ackerley to
the Offce of the Genea Counsel,
Dec.
.
3 27, 1994 (Exhibit 21); see also Afidavit, supra note
8 Affidavit, supra note 11.

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.

"FEC Pre-MUR 307/MUR


40
4 1Id.
Noble Memorandum to the
42

Commission, May 4, 1998 (Exhibit 23).


Jackson, supra note 4.
Party of Florida,supra note 3. The Committee believes that
of
Republican
Matter
the
4In
this aspect of Federal election law should be evaluated to determine whether it is appropriate.

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 .

. was to proceed against him [Kramer] and

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-

vice of counsel will be omitted. . . . The planned deletions

would omit a critically relevant fact-that Mr. Kramer


made many of his contributions at the suggestion of a law
firm that knew of his foreign national status. Because the
4FEC Pre-MUR 307/MUR 4398, supra note 35 (emphasis added).
4 Certification and Conciliation Agreement, In the Matter of Greenberg, Traurig, Hoffman,
Lipoff, Rosen & Quentel, P.A, et al. MUR 4638, Dec. 31, 1997, at 24.3 (Exhibit 24).
4 Id.

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

According to then-DNC Chairman Don Fowler, Rosen conducted


his fundraising under the control of Deputy White House Chief of
Staff Harold Ickes: the finance division reportedly "took their mission and charter from the White House and seemed to do what the
White House wanted done." 5 7 In November 1995, Rosen allegedly
estimated that 20 telephone calls by Clinton and 15 calls made by
Gore would raise $1.2 million, 8 and two lists of potential donors
were prepared for the President and Vice President.>9 Mr. Rosen
may have also been involved with setting up coffees with the President: an unidentified fundraiser stated in a newspaper article on
February 26, 1997, that Rosen said "[ulse the coffees to get the
money," thereby acting against White House guidelines. 60
2. A. Patternof Questionable Fundraising
Although he was the key DNC finance official during the 1996
campaign, Marvin Rosen has to date been largely overlooked in the
campaign finance investigation. During his tenure as DNC Finance
Chairman, Rosen was connected and involved with a number of
questionable activities:
* Rosen's law firm was retained by Mark Jimenez and his
company Future Tech International, Inc. Jimenez, Future Tech
International, and his employees donated $800,000 since 1993
to President Clinton, Democratic causes and other related
groups. Jimenez says that he was introduced to the world of
political fundraising through the Miami firm. Future Tech
began making contributions to the DNC in 1993.61 Mr. Rosen
solicited $50,000 from Jimenez as detailed on a March 24,
1994, DNC Executive Finance Summary. Jimenez visited the
White House 12 times beginning in April 1994. Twenty-two
employees of Future Tech each gave a $1,000 contribution to
Clinton-Gore '96 at a Bal Harbour fundraiser in September
1995. Many or all of these appear to be conduit contributions. 62
Jimenez was Florida's largest DNC contributor in 1996.63
On September 30, 1998, Jimenez was indicted by the Justice
Department Campaign Financing Task Force. The 17 count indictment was for, "organizing, making and concealing illegal
conduit contributions to a number of Democratic campaigns,
including the 1996 Clinton/Gore primary committee." 6 4
* Rosen was personally directed by President Clinton to hire
controversial fundraiser John Huang after the DNC had ignored the suggestion of Joe Giroir to hire Huang. Giroir was
a friend of both the President and of the Riady family. Ickes
-"Democrats' Fowler- Donors Got Access On White House Word," Inv. Bus. Daily, Sept. 10,
1997 at Al.
5Don Van Natta, Jr., "Fundraising fell short, report says," New York Times, Sept. 29, 1997,
at As.
59 David Dahl, "Lawyer Implies Clinton may have made calls," St. Pete. Times, Sept. 22, 1997,
at Al.
*0Lena H. Sun, "Grand Jury Begms Hearing Testimony in DNC Fund-Raising Probe," the
Washington Post, Feb. 27, 1997, at A7.
eJill Abramson, Jonathan Friedland, and Marcus W. Brauchli, "Latin Connection: DNC
Donor with Ties to Paraguay Presses Its Case in White House," Wall Street Journal, Feb. 20,
1997, at Al. Jimenez was born in the Philippines and is a legal resident of the United States.
He has links to the Paraguay government. Tom Squitieri, "White House link to Paraguay
probed," USA Today, Feb. 24, 1997, at 6A.
62 William March, "Feds examine campaign largess," Tampa Trib., Dec. 3, 1997, at 1.
as Id.
"Press Release, Department of Justice, Sept. 30, 1998.

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'

FederalElection Commission Enforcement Actions, supra note 6, at 60.


Id. at 40 (statement of FEC Associate General Counsel).

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

trading company indicted in a case involving laundering drug


money. 86 The charges were dropped, but in a settlement agreement
Glicken created a subsidiary that agreed to pay the government
$375,000. Mr. Glicken was never charged, but testified under a
grant of limited immunity at the trial of his former partner, Harry
Aaron Falk.8 7 Mr. Falk is currently serving a 27-year sentence.86
Committee investigators learned that another partner indicted in
the MetalBanc investigation, Duvan Arboleda, was murdered in
Colombia in early 1998.89
2. Prominent FundraiserWith Strong Ties to Vice President Gore
Mr. Glicken has known Vice President Gore since 1987, serving
as the Florida Finance Chairman during then Senator Gore's 1988
Presidential campaign. The license plates on Glicken's two Jaguars
were, at one point, "Gore 1" and "Gore 2."90 He is known to show
photos of a $6,000 pool table that he arranged to have donated to
Vice President Gore's home. 9 ' In addition, his son, Monte Glicken,
once worked for Mr. Gore during his tenure as Vice President. 92
According to a newspaper article, Glicken "frequently advises the
Vice President on ways to attract young people into the party."9 3
A request for a West Wing Tour made by Eric Sildon at the DNC
noted such strong ties to Vice President Gore: "Howard is one of
a close friend of the Vice
our strongest supporters and has 9been
President's for many, many years." 4
Over the years, Glicken has developed an expertise in Latin
American business and reportedly counsels the Vice President on
Latin American affairs.95 He testified before a July 1994 joint
House International Relations Committee hearing on trade and the
Western Hemisphere. 96 Mr. Glicken was also hosted in Argentina
dicted by the grand jury) were named in the indictment. Id. Arboleda was murdered in Colombia
in spring 1998.
"Phi Kuntz and Jill Abramson, "Glicken Raises Millions, Visits the White House Often, Arranges Introductions," Wall Street Journal, Apr. 29, 1997, at Al.
85MetalBanc bought Jillian's by paying an undisclosed sum for a 51 percent interest in the
chain of pl halls. Patrick Danner, "Banc Shot: MetalBank Prepares to Take on Billiards Industry," S. a. Bus. J., Mar. 26, 1990, at 1. MetalBanc started Metal Resources Corp. in 1987 as
a mean to capitalize on opportunities in Brazil and other markets. "Public Offering Set by Dealer of Precious Metals," S. Fla. Bus. J., July 6, 1987, at 1.
8Phil Willon, "Fundraiser for Gore Reaps Dividends," Tampa Trib., Feb. 11, 1998, at 6.
87Phil Kuntz and Jill Abramson, "Access Granted: A Fund-Rser for Gore Retools His Career
With an Aura of Clout," Wall Street Journal, Apr. 29, 1997, at Al.
a Id.
8 Phone Interview of Cynthia Arboleda, Ex-Wife of Duvan Arboleda, in Washington, DC (June
2, 1998). Mrs. Arboleda attended the funeral of her ex-husband with her two children. According
to Mrs. Arboleda, Duvan Arboleda was murdered in Envigado, Colombia on May 9, 1998. His
of death was attributed to multiple gunshot wounds. Id.
cause
9
oTamara Lytle, "Friend of Gore avoids fine for illegal donations," Orl. Sentinel, Feb. 12,
1998, at As.
91Id.
92 Id.
9sHillary Stout, "Gore Lays Strong Groundwork for the Future," Wall Street Journal Eur.,
Jan.
94 9, 1996, at 2.
West Wing Tour Memorandum, Oct. 22, 1993 (Exhibit 31).
95 Hillary Stout, "Gore Lays Strong Groundwork for the Future," Wall Street Journal Eur.,
Jan. 9, 1996, at 2. Glicken also serves/served on the board of the Make-A-Wish Foundation of
South Florida. Peter Bernard, "Legal Aid Builds Its Staff With Promotions, Hiring," Sun-Sentinel (Ft. Lauderdale Fla.), Feb. 1, 1995, at 7.
96 The Summit of the Americas Hearing Part I: Prospects for or Trade within the Hemisphere
Before the Subcommittee on Economic Policy, Trade and Environment and the Subcommittee on
Continued

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

Letter to Glicken, Feb. 27, 1995 (Exhibit 38).

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

General Counsel's Report, supra note 8 at 2.3-2.4.


Election Commission Enforcement Actions, supra note 6 at 67-68 (statement of
FEC
General Counsel).
11
8 Id. at 81.
119Letter from Marc E. Elias to Rodriguez (Exhibit 39).
17Federal

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.

THE DEPARTMENT OF JUSTICE'S INVOLVEMENT IN THE KRAMER


MATTER

On July 22, 1997, FEC Staff Attorney Jose Rodriguez wrote an


e-mail requesting that "LL check with Justice to determine if they
have any interest in pursuing the reported Kramer/Bradley activity
criminally."121 "LL" was a reference to FEC Associate General
Counsel Lois Lerner. Ms. Lerner responded to Rodriguez' e-mail 3
days later, noting that she had spoken to Craig Donsanto (her contact at the Department of Justice). She stated that Donsanto
thought that the Department was no longer pursuing the law firm
Traurig), Kramer, or anyone else involved in the
(Greenberg
case.1 22 Ms. Lerner noted that Donsanto would check with the U.S.
Attorney in Florida "to be sure." Lerner conveyed her belief that
Donsanto thought that he might be able 2 3to get the department to
"sign off on as to our potential witness." 1 The Committee believes
that Terri Bradley was this "potential witness."
FEC
An e-mail exchange during September suggests that 2the
4
was at least attempting to obtain immunity for Bradley.1 In December, however, the FEC signed off on its General Counsel Report
and decided against pursuing a case against Howard Glicken:
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 transactions at issue take
place during the 1993-1994 election cycle, this Office does
not now recommend proceeding against this identified individual or the DSCC.
Similarly, this Office 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 be time barred
until March 1999-approximately a year and 4 months
from now. However, because of Mr. Glicken's high profile
as a rominent 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. Therefore, rather than continuing this matter
for an unspecified period in pursuit of one participant and
because of the low prospect for timely resolution, the age
Affidavit, supra note 11 at 3.3.
Issue" e-mail, July 22, 1997 (Exhibit 40).
'-2 Kramer e-mail, July 25, 1997 (Exhibit 41).
123 Id
2
^"Latest from Bradley" e-mail, Sept. 15, 1997 (Exhibit 42).
120 See

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

12 General Counsel's Report, supra note 8 at 2.4.

e"GREENBERG TRAURIG (sp?)" e-mail, Feb. 12, 1998 (Exhibit 43).


United States of America v. Howard Glicken Factual Proffer and Plea Agreement, (D. D.C.
July 9, 1998), at 1 (Exhibit 44).
nId. at 44.10-44.11.
129 Id. at 44.2-44.3.
127

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 order to understand the means by which the FEC conducted


the Thomas Kramer investigation, a brief explanation of FEC practices and procedures is necessary. The statutes relevant to the Kramer matter are 2 U.S.C. 437g, dealing with the enforcement of
Federal election campaign laws generally, 2 U.S.C. 441e, prohibiting contributions by a foreign national, and 2 U.S.C. 441f, prohibiting contributions in the name of another. The FEC provided to
the Committee statistics showing case disposition by fiscal year for
cases involving conduit payments and contributions by foreign nationals.'
A. PRIORITIZATION PROCEDURE

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

If the Commission believes that a violation has been committed,


a conciliation agreement may include a requirement that the person involved in such conciliation agreement shall pay a civil penalty which does not exceed the greater of $5,000 or an amount
equal to any contribution or expenditure involved in such violation.
If the Commission believes that a knowing and willful violation has
been committed, a conciliation agreement entered into by the Commission may require that the person involved in such conciliation
agreement pay a civil penalty which does not exceed the greater of
$10,000 or an amount equal to 200 percent of any contribution or
expenditure involved in such violation.
If the FEC by an affirmative vote of four commissioners, determines that there is PCTB that a knowing and willful violation has
occurred or is about to occur, it may refer such apparent violation
to the Attorney General of the United States. The FEC cannot legally refer a case to the Department of Justice unless it reaches
this PCTB threshold. Both the standards set to reach thresholds of
either RTB or PCTB are, for the most part, known only to the FEC
staff.
In any case in which a person has entered into a conciliation
agreement with the Commission based on the PCTB threshold, the
FEC may institute a civil action for relief if it believes that the person has violated any provision of such conciliation agreement. For
the Commission to obtain relief in any civil action, the Commission
need only establish that the person has violated, in whole or in
part, any requirement of such conciliation agreement.
If the Commission is unable to correct or prevent any violation,
the Commission may, upon an affirmative vote of four commissioners, institute a civil action for relief, including a permanent or
temporary injunction, restraining order, or any other appropriate
order (including an order for a civil penalty which does not exceed
the greater of $5,000 or an amount equal to any contribution or expenditure involved in such violation) in the district court of the
United States for the district in which the person against whom
such action is brought is found, resides, or transacts business. In
certain civil actions instituted by the FEC, the court may grant a
permanent or temporary injunction, restraining order, or other
order, including a civil penalty which does not exceed the greater
of $5,000 or an amount equal to any contribution or expenditure
involved in such violation, upon a proper showing that the person
involved has committed, or is about to commit (if the relief sought
is a permanent or temporary injunction or a restraining order), a
violation of relevant provisions.
Any person who knowingly and willfully commits a violation of
relevant Federal campaign laws-which involves the making, receiving, or reporting of any contribution or expenditure aggregating
$2,000 or more during a calendar year-shall be fined, or imprisoned for not more than 1 year, or both. The amount of the fine
shall not exceed the greater of $25,000 or 300 percent of any con-

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

BEFORE THE FEDERAL ELECTION COMMISSION


In the Matter of

MUR 4398

Republican Party of Florida (federal/non-federal accounts)


and James H. Stelling, as treasurer
CONCILIATION AGREEMENT
This matter was initiated by the Federal Election Commission ("Commission"), pursuant
to information ascertained in the normal course of carrying out its supervisory responsibilities.
The Commission found reason to believe that the Republican Party of Florida (federal/nonfederal accounts) and James H. Stelling, as treasurer, ("Respondents") violated 2 U.S.C.

44 1c.

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 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),

has opted pursuant to II C.F.R.

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).

VII. The Commission, on request of anyone filing a complaint under 2 U.S.C.

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.

FOR THE COMMISSION:

wrence M.Noble
General Counsel

FOR

RESPO

L. Ginsberg
Co

Date

Date

3014
Exhibit 2

BEFORE THE FEDERAL ELECfON COMMISION

'0

In the Manerof

Greenberg. Traurg. Hoffan.


Lipoff. Rosen &Quentel. PA. er at.

MUR 4638

GENERAL COUNSELS REPORT

1.

INTRODUCTION
On October 30.1997. the Commission me

into conciliation with Greenberg. Traurig.

Hoffman. Lipoft Rosen & Quensel (Greabeg & Trsri


violations of 2US.C.

or "Respondeut) in connection with

5441e sesulting fom Respondent's involvesment in contributions made by

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

October 27. 1994

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

short of litigation. Therefore. rh

that this individual would agree to

than consinuig this maer for an

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

1. Genberg &Tmurig Proposal Md C-a


StaffMember Jose M. Rodriguez

- Am

3019

Exhibit 3

AFFIDAVIT OP TOMAS ICHER


STATE OF FLORIDA
COUNTY OF DADE

1.

is

My name

Thomas Kramer.

i.vestor living in Miami Beach. Florida.


listed

in

I am a real estate
The donor companies

Attachment A hereto are all corporations incorporated

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.

: am not :awfully admitted in the Uni:ed States

for ;eranenz residence


3.

: rad.

candidate cantributlons personally and

through my cCmpenses dur;ng a per

od

of approximately a year and

.h:ee-quarters. tegnnxr.g in early 1993.

I gave to state and

local candidates. the Republican Party of Florida. and the


.at.:.al Cemocratac and Rep.Elcan Fartes.

also personally

-ade or caused contr:Datons to tear federal candidates.


4.

Prior to and durir

:.1s period.

I was

knowledgeable about (ejer&: ca-;a&qn finance laws,


2

u.S.C.

5 441e which : now

not

including

-scerstand bars contributions by

foreign nationals to political candidates.


S.

I speaO

Engt1sh

believe most people who

know

with

a German accent, and I

w* realize I am German.

Nevertheless. no one who eolirated or accepted my candidate


contributions ever aesed

e saus: ny

uirgration status. advised

3020
-2-

me that i: was legal for me to contribute, or rejected my


political contributions because of my citizenship.
During this period, : was represented by several

6.

law firms on business matters.


Hoffman,

Greenberg,

Traurig.

Rosen & Cue.:el and Thomson MurarO Razook &

Lipoff.

The Greenberg.

Hart.

including

Traurig

firm was my principal counsel, and

handled my immigration -atters among other things.

Principals at

that firm from tire-to-ime solicited from me and suggested that


make certain political contributions.

.aw advice from Greenberg,

request electicn
Mirars.

I did not specifically


Traurig or Thomson

I generally requested Greenberg,

However.

Traurig to

taee a!: apprepr.ae action to assure that my activities of which


they

were

:he law.

aware

::rdc::ed in a fashion fully compliant with

At no :.-e d.d any attorney advise me that there was

any .ssue as to
::

were

at:.re-gn

y '.egal
rateens..

ability
-**e

to make political contributions

pro.buted from making such

contributions.
7.

On reading a Septe'ber 28. 1994

LtaA TIntuat indicating that so-e

prettlatlc.

: wee

Af:er consultaticn

: requested refund
compnes

0!

article

in

the

ry contributions may be

suyrset and :-eed:ately consulted counsel.

with co..sel

and investigation of my records.

of &:: ro:teal contributions that I or my

trade that may to candidate-related.

3021

.3-

8.

I made two contributions at the federal level

through my secretary, Ms.

7erri Bradley.

I have req-uested

refunds of these contributions.


a.
made

in

I reimbursed Ms.

Bradley for a $1,000 contribtltcn

her name to Senator George Mitchell in March 1993.

I do

not recall the circumstances surrounding this contribution or why


the contribution was made in this way.
I also reimbursed Ms.

b.

Bradley for a $20,000

contribution made in her name to the Democratic Senatorial


Carpaign Committee

recollection,

(*DSCC")

on April 28,

1993.

To the best of my

I believe that I was informed directly or

indirectly by a Democra::: party fundraiser that the


:ntribu:z:ns
-:;:
c..-, !-:=
-hat.

if

any.

explana::t:

S.

citizens.

-ay have been given.

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.

so.c~ter suggested Isr.


that. since

I proceeded as I did

y recollection.

best of

c.e

to accept political

understood that the

;resen:e of myself and my secretary)

the DSCC accepted contributions only from U.S.

citizens. a U.S. citizen should contribute on my behalf.

I have

no recollection of understanding that there was any legal issue

involved.
S.

To the beat of my knowledge,

chart of contributions

the accompanying

(Attachment B) accurately shgXAsha-

3022

. 4candidate-related and possibly candidate-related contributions

made directly or indirectly, and the status of my refund


requests.
I swear under the penalty of perjury that the foregorng
statements are true and correct.

The &s
:&s

Jj

Ader

The foregoing instrument was acknowledged before me


day of Cecember. 1994 by Thomas Kramer, who is

personally known to me or who has produced

as

identificaticn

and v*n: did take an oath.

Notary Public.

Print Name:
Cnrmission
Com-mission

State of Florida
trAv

A.

1JA4

Number:
Expires:

(SEAL)

OPPFCIAL NOTARY StAL


COMMSWON1

or01.0

NUMBEA

UaCOMMSS altp
AUC. 15lead9I

3023

Azure Coast Development. Ltd.

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.

5 Star Island, Inc.


7th & 5th Deco Corp.
35 Star Island, Inc.

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3029

3030
Exhibit 5
aN.7o

DONo

Group:

Major Donor Screeninsq

To:
From:

Nail Reiff, Kelly Fagan

Re:

Major Donor Screening


4

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:

Solicitor (If known):


Date of

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)

.....e Me.- Peco.endatio:

Deposit

Return to Donor

Com:itee CmenteS:

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For

C-e? Or Staf

LeIs:

Please contact Laqel Dept.


check Will be deposited.
1)

Disposition.

2)

Date

Chisf

by close of business

Deposit

Of Notification to Legal

Return_
Dept.

of Statt:

IUIt3IMurll UNEWilNfl DNC O62c

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

O City Labiim Lad


olymls fidagnp4.
Optiua EualamkCrpmnon

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-

The odd couple

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

0's LrsW-a.Mshi arrogant way. *Once I MWa


*1 amt a amnwiths %AMM*
al we mewvtais. and suddenly I kIsew I msi
shiusi us Oimaid. I wasor ow %V9
20 1 Vzab A Pi - Lld enl b) broker, and shoited S 25
gOWd.
Lt'wn
.e4
S 3 a" S 6 millon.
I
-to
wofti
of
gold
MOsalO
'Aaother umnI hadAdreamaNA a bus,.rg field. I bxie I should buy wheat
Thai ant I mala BsIfL.u snore. That i how iti ISWith Me..
andCums INSWMa.

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

temporarily. for wht ass su


Krmner has abandoned Miami Beanch. at
Moritz tha hot spot for new Milanese
my is a mOnteY-rfUfl jam:t ID SAWn
money. Why Saint Moritz? 'Let e put it this way.* says Swiss banker Rohrer.
'in Saint Moritz it's Mmkfishing in Lan AquariumI
When we askul Krmer about his Unwvay zqsutaton in Forida. ke droppe his
aiiary torr-ex ploding in mdulood rage: 'You journalata ameall alike.
Y'ou make -a mney, so you am IucaO or ple like me-who do. -We respoinded
am soussctdiDt deling with ple a lot mor solvemt
9WaFORBES fcpothan ha is.
GRAPICC: Pictur. Themss Kramer. Miami Beanch's attentin grabber from Germny.
H"s he te to LAi Mmi~t for go Or will bebe back to build a
Lbmon--yle billag tp Smu% &=h? Bill Wax
Fag a. Marnb 1. 1993

IUUEiln~jI~ilgI~u~DNC

062ci0

3035
F, -t .

marchi 1. 1993
FOCUS

SECrION: MONEY & DrWESTING; Pl. 59


LENG7H: 205

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.

Paine by Hen Matisse in 1946, has

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

TrrL GERMAN BUYS S3.75 NMIION ME1~


p.EM.

UAka HERALD Socn G; ?zgc 5, Column 1 JOURNAL-CODE MEH

DATE: May 3. 19M. Sunday


ABST: Gcrman Uivc~i Thomas Xrameu pays S3.75 mimlon for bayfront homeon
Indian Crack 'gland. Fla; purchwMis his scnd on island in passt two months;
pad for ham in D& County, Fla (M)
po cv
sal mpinns thud bug
DESC: HOUSING; SAL ES; PRICES
NA).M ]MRAI. THOMAS; FINEROo:. DON
GEOT: DADE COUNTY MA). INDLAN CREE ISLAND (FLA)

In~rnauu1rvI~fIDNC OGqr

3038
mairaer

Olympus Botdiap, Inc. and new 7b~a

awilpyofls betwe

amas

.ue madeany fca2'A ejc

198S-199.

IIMUMI~UShIMnffINXIM6

DNqC 06SD..

3039
Exhibit 6
Event Form for Chairrman WIlheirm
Date of the Event:

June 10. 1993

Name of the Event:

Vice Presidential Private Dinner

Sponsor.

Location:

Democratic National Comiiuee. Finance


Con=rt: Laura Hartigan
202.737.3500
BO0.SKY.PAGE 277.8476
The Four Sonas Hotel
2800 Pennsylvania Avenue. NW
Washingtoni, DC 20007
p 2M2.3-42.0444
f202.342.1673

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:

&00 pm (see end note)

Emm

ae todanor.

2-25 pel

Greeter. Laws Hartlpn. Dbectar of the Trusmee Progrm


thmeroea wk7 be clesd to the prwn.
None:
Thu is an mifmai pthmertg of inweny-some miazees and active supports of the DNC
andXmcficly of the Predentm Dinn.
Acowdigly, no program is wbhiled. Iiowr, it is possible that DW will introduce
the Viec Preaident for ckwang rcmart as he deprts. When the Chairman arrive, we will decide
if a protrzm is neactur. Tu is a way calevening and it might be more beneficial to the
the Ouatman spend a few namients a-ith endi of the guests.
I aura Hlarqanswill infom the Chairman on the status of this when she grnew him upon

til IIRI0IMffW~IIIDf4C 1102178

3040
Exhibit 7

TO:

Nancy Jacobson, National Finance Director


Laura Hartigan, Director, Trustee Program
Jane Hearst, Director, BLF
Sam Newman, Director, NFC

FROM:

Team Florida

DATE:

May 7,

RE:

Florida donors

1993

The following is a list


of donors whose contribution
to the April
29,
1993 dinner
in
Miami honoring Vice
President Al Gore has earned membership to either the NFC
or BLF.
Only contributions given, not contributions
raised, were counted towards such credit.
The individuals who raised more than $50,000 should be
included as members of the Trustee program,
as should
individuals who made significant contributions as "partial
payment" towards Trustee status,
with the understanding
they will finish their SSO,000 commitment by the end of the
year.
In addition, there are several individuals who raised
substantial money but did not make a contribution towards
the event.
Their names, a brief explanation of their
situation and the amount each raised or gave is listed at
the end of this memo in the Honorable Mention section.
We
recommend each receive special consideration for membership
in one of the programs.
* &

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

lagglgggggggg DNC 4025935

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.

We would like to list hii

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:

September 20. 1993

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

9 Arnold Fnedman (Health)


Borlan V27
II Howard Glicken jg
[S
12 Don Madden
2
"Lisa5 Barakat
1 . chael Adler 6
Q-dChiles.
'

Possible ddaoal nassm include Gi


Cofr~alv a .Dr. Salamas Mnlgen, Dr. Richard
Machado. Bud Stack. Marvin Rosen, JoepChnsun. Mote Fredkan. Paul Prospen, Jay Stem, Jim Pugh

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

REQUESTED BY: Truser Prorms


DATE SUBhCTTED: Novembn 16 1993

DEADLuE* NoveNber 19. 1993

DNC CONTACT: Jennif- Scully L* Jay Webb-PHONE- 1S72 or 0141


NAkM- Iom

las

TITLE.*
ORGANIZATION.

The Panfine Grou5

PHONE: rOS) 1122.19

(Home 1)

(90532-7519

CONTACT:
PHONL
PURPOSE OF CALL To e

Mr Krn.re to stay active and involved in the Tnmr

BACKGROUNDrRELATIONStW %%TrHDNC 199 Trus-e yave $100 000

tte Inugural

ACTVITY/FOL.OW4LP:
CaLuheet prres

by If," C wew

MIiaJillJWIS~gfDI~ilNUifilhIfllDNC

1121910

3048
Exhibit 11

May 27. 1994

Mr. and Mrs. Tom Kramer


CEO
The Portofino Group
446 Collins Avenue
Miami Beach. FL 33139
Dear Catherine and Tom.
On Wednesday. June 22. 1994. useDemocratic National Committee will host the 1994
National Presidential Dinner 'An American Celebration, honoring President Bill Clinton and
Vice President Al Gore in Washington. DC. In recognition of your friendship and support as
DNC Trustees. it gives me great pleasure to eend to you an invitation to attend this special event
as myguests.
The event will begin with a cocktail reception at 6:30 p.m. and the dinner, featuring all
star en:ertainment. will begim at 7:30 p.m. The dinner will be held at the Washington Hilton.
I have enclosed an information sheet with mormCetas.
Please RSVP to Art Swiller. our Trustee Program Director, by Wednesday. June 8th. to
reserve your complimentary seas Art can be reached a: (202) 863-8033.
Thank you for your commuted support. I look forward to joining you for this special
evening.
Srncerely.

David Wilhelm
Chairman
Enclosure

lWE18858WRMIAi DNC 1613319

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

itis my pleasure to invite you to the

1994 Business

June 2 1stat the White House with a reception hosted by the


The conference begins on Tuesda%.
President and First Lady hononag the DNC's Business Leadership Forum (BLF) members An official
invitation to the recepuon will
be extended to you from the White House and we request that you please RS.V.P to the office of the
Social Secretary. The
following day's schedule begins with breakfast and sill include morning briefings and a luncheon
featuring scruor administration
officials and congressional leadership
You are also invited to our annual Presidenuial Dinner on the evening of Wednesday, June
22nd honoring the Clinton/Gore adnumustraon The diner is a fundraiser and if you wish to attend, we
askthat ,ou make the
requested $1.500 contribuion per seat
For sour conference there is a block of rooms reseed at the Mayllower Hotel in
Washington. DC. (202) 347-10(i Rooms are reserved under the DNC block
A more deailed schedule of erenui and response form for
the conference will folio% in the nest fewdoss If %ou hac an%questions, please feel to contact Richard
Sullivan or Fran Wakem
of the Business Lzadersup Forum at (202) 861-7136
Thanks again for your generous support I look forward to sceng you in

3050
Washington on June 21st.
Sincerely.

Terry McAuliff

National Finance Chairman

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

Huritz. Charles (Mr.)


Hyjok. Steve (Mr.)
Hyn.., Tom (Mr.)

Kelly, Peter (Mr.)


Kempner, III, Harris (Mr.)
Keapner, Hotta T. (Hs.)
Kempner, Michael (Mr.)
Kertzman, Mitchell (Hr.)
Khan. Karan (Hr.)
Killeen, John Jay (Mr.)
Klabrough. Rollis (Mr.)
Kinney, Janie (He.)
Kirk. James (Hr.)
Klothen. Kan (Mr.)
Knight. Peter (Mr.)
Knoll, Albert (Mr.)
Kocat. Larry (Mr.)
Koegler, Harold (Hr.)
Kovach. Gerald J. (Hr.)
John R. (Di.)
Koz,
Kraser. Thomas (Mr.)
Krise. Ron (Mr.)
Kronmer, James (Hr.)
K.tw.ard, Jake (Mr.)
Kurtz. Anthony David (Mr.)

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

Ladar. Philip (Hon.)


Lake, Anthony (Hon.)
Lambert, David (Mr.)
Lasonica, Don (Mr.)
Landow. Nchan (Mr.)
Landeman. Dfck (Hr.)
Lardner. K 1homas (Mr.)
Larkin. Carol (Ms.)
La.. Joanna (Ms.)
Launstein, Karl (Mr.)
Lusell. Miguel (Mr.)
Lear. William (Mr.)
LABo,. Bennett (Mr.)
Lee. Thomas (Kr.)
Lafkovitz. Stephen (Mr.)
Lanteich. Maxine (Hs.)
Leggett, James Mark (Mr.)
Lounard. Thoua. A. (Mr.)

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

Dr. Steven M. Scott


Chairman and CEO
Costal Health Care Group
February
payment on Pledge:
1994
100,000,00
N-itten:

4,

1994

January 22,

1994

Mr. Alan E. Kligerman


Chairman and CEO
Akpharma Inc.
January 19,
Payment on Pledge:
1994 Written:
100,000.00

1994

. John J. Moores
resident
MI Incorporated
Payment on Pledge:
1994 Written:
100,000.00

Mr. Marvin Davis


President
The Davis Companies
December 13,
Payment on Pledge:
100,000.00
Written 1993:
Mr. Milan Panic
President
ICN Pharmaceuticals Inc.
Payment on Pledge:
December 13,
100,000.00
Written 1993:

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:

Mr. Dirk Eiff


Chairman Emeritus
iff Communications
Payment on Pledge:
December 16, 1993

100,000.00

3054
Written 1993:

100,000.00

Mr. Sidney J. Sheinberg


Mrs. Lorraine Sheinberg
.lo Price Waterhouse
Payment on Pledge: November 17, 1993
100,000.00
ritten 1993:
Mr. Steven
Spielberg
c/o Breslauer, Jacobson, Rutman, and Chapman
Payment on Pledge: November 17, 1993
100,000.00
Written 1993:
Mr.
Jeffrey Katzenberg
Chairman
Walt Disney Studios
Payment on Pledge: November 15, 1
100,000.00
Written 1993:
Mr. Steven E.
Tisch
Payment on Pledge: November 10, 1
100,000.00
Written 1993:
Mr. Dwayne 0. Andreas, Jr.
Chairman
Archer Daniels
Midland Company
October 21, 1
Payment on Pledge:
210,000.00
Written 1993:
Stern
Mr. Bruce
President and CEO
SWAT
Incorporated
Payment on Pledge: September 28,
Written 1993:
100,000.00
Mr. Walter Kaye
Payment on Pledge: September
20, 1993
1994 Written:
250.00
Mr. William Brandt, Jr.
President
Development
Specialists, tlc.
Payment on Pledge:
August 10,
1994 Written:
55,000.00
Mr.
Peter Morton
Chairman and Founder
Hard Rock America
Payment on Pledge:
July 29,
ritten 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

Mr. Walter H. Shorenstein


Chairman
The Shorenstein
Companies
July 13, 1993
Payment on Pledge:
110,000.00
Written 1993:
Mr. Finn M. W. Caspersen
CED
Beneficial Corporation
June 28, 1993
Payment on Pledge:
265,000.00
Written 1993:
Dr. Benjamin Armstrong
President
Madison Broadcasting
Company
June 25, 1993
Payment on Pledge:
Wri tten 1993:
250.00
1994 Written:
Mr. Dennis Bakke
President
The AES Corporation
May 21.
Payment on Pledge:
110,000.00
Written 1993:
Ms. Denise Rich
Zerem Inc.
Payment on Pledge:
1994 Written:

1993

May 26. 1993


2,600.OC
Witten 1f93:

Mr. Peter w. May


DWG
Corporation
Payment on Pledge:
May 3. 1993
Written 1993:
110,000.00
Mr. Roy Furman
Furman Selz, Inc.
Payment on
April 15. 1993
Pledge:
Written 1993:
100,000.0,
Mr. George E. Norcrosa, II2
Chairman and CEO
Keystone National Company.
Inc.
Payment on Pledge:
April 5I.
Written 1993:
100,000.0Z
Ms. Ann E. Sheffer
Payment on Pledge:
April 15, 1'-3
Written 1993:
100,000.0,
Alfred R. Pierce, Esq.

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

Mr. Abraham D. Gosaman


CEO
The Mediplex Group
Payment on
Pledge:
March 7, 1994
1994 Written:
50,000.00
Mr. Tom Kramer
CEO
The Portofino Group
Payment on Pledge:
March 4,
1994
1994 Written:
60,000.00
Mr. Michael Caddell
Ms. Tracy Conwell
Caddell 6 Conell
Payment on Pledge:
February e.
1994 Written:
70,000.00
Mr. Bernard Rapaport
Chairman of the Board
American Income
Life Insurance
Payment on Pledge: February 6.
1994 Written:
50.00C.00
Mr. Lee Godfrey
Sussman Godfrey
Payment on
Pledge:
February
1994 Written:
Dr.

Samuel

6, 1994
50,000.00

Klagsbrun

3057
DNC Florida Managing Trustees,

Trustees and Business Leadership Forum Members

Managing Trustee
Mitchell Berger
Berger,
Shapiro A Davis
100 N.E. 3rd Avenue

Suite 400
Ft.
W-

Lauderdale, FL. 33301


305-525-9900

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

CEO - Coastal Phamesueticals

919-383-0355

Charles R. -Bud" Stack


High. Stack, Lazenby, Palahach 6 Goldsmith
3929 Ponce de Leon Blvd.
Coral Gables, FL. 33134
W -

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

213 S. Adams St.


Tallahassee, FL 32301
W 904/222-4702
Allan Kluger
Kluger, Perett, Kaplan
201 S. Biascayne Blvd.
Suite
1970
Miami, FL 33131
Don Lamonica
Lamonica Inc.
200 South Monroe St.
Tallahassee, FL. 32301
Charles H. Lydecker
Poe 4 Brown. Inc.
220
South Ridge.ood Avenue
P.O. Box 2412
Daytona Beach, FL. 32115-2412
W904/252-9601
F 904/239-5729
H 904/672-3834
Bill Mauk
Vice President
John Alden Life
7600 Corporate Center Dr.
Miami, FL. 33126
W305/715/4381
F 305/263-4306
H 305/253-6113
Raymond McClendon Pryor.

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

ime 10. IM9 a U. Fe

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

S1O Winm ocad


inw pm

The Ve

a meam=)

humamL

Chuna and Ropfc-n-

Marna

SUBMI My b.I Line Fwau


imhf smay. Hinh Soumas Immas ama)

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

=IS LADY'S TABLE

1)Bud Stack

Attorney. DNC Trustee

2) Barbara Stack

Spouse, Bud Stack

3) Tom Kramer

Miami Red) P--a

4) Katherine Kamner

Spouse. Tom Krmecr

5) Fred Estrada

Chairm, Vista & HManic Mieni (runs unthe Sunday


isue of the Mami Herald). New DNC Trustee

6) Team Estada

Spouse. Fred Estrada

7) Mark imcrer

CEO. Portofino Ozuup

8) %Ardlie Gary

Partner. Gary. Williams, & Parusts (law firm). New DNC


Trustee Minority Advocacy Activist

9) Gloria Gary

Spoume WMii Gary

10) Rbca~ Sw

Spouse, Stephe SCOt

11) Stephen Sec

CEO Cia- Ptannarmteels

Developer, DNC Trustee

The Fluse Lady


TOTAL - 12

1I IMIIIIRIIIIIIIhIIMID. DHC 1116:334

3068
Exhibit 17

BEFORE THE FEDERAL ELECTION COMMISSION


In the Matter of

MUR 4398

Thomas Kramer, et al.


CONCILIATION AGREEMENT
This matter was initiated by a sua sponte submission by Thomas Kramer. The
Commission found reason to believe that Thomas Kramer ("Respondent") violated 2 U.S.C.

g44le and 441f

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.

Respondents enter voluntarily into this agreement with the Commission.

IV. The pertinent facts in this matter are as follows:


1. Thomas Kramer is a foreign national as defined at 2 U.S.C. f 441e(b) and
II C.F.R.

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).

9. It is unlawful for any foreign national to direct, dictate, control, or directly or


indirectly participate in the decision-making process of any person, including domestic
corporations, with regard to decisions concerning the making of contributions in connection with
elections for any local, State, or Federal office. II 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.

A. Respondent Thomas Kramer made a total of S322,600 in contributions either

directly, through his secretary, through unknown intermediaries, or as an officer


through his
various corporations which were used in connection with elections for local, State
and Federal
office, in violation of 2 U.S.C. 441e and 441 f.
B. Respondents 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;

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

amount of Three Hundred Twenty-Three Thousand Dollars ($323,000), pursuant to 2 U.S.C.

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

FOR THE RESPONDENTS:

//a8/5/96
A

ividully)Date

8/5/96
Date

3073

rDenm%
stea

Exhibit 18

C&e

C Nao

(;Ossman. National hair* (-aternr Rs Romer. srgrs

Chair

Sepner 3, 1997
Federal action Commiselon
office ofrthe Gmn..l Coused
999 E SrM. N.W.
Washinpon. D.C. 20463

ME

IM

Anemion: Jose Rodrigues


Re MilKA439
Dear Mr. Rodrigue
Enclosed armdomai that the Daimicratic Naional Comaiese("DNC") has loct
which are responsive to the Iamsraries md Requi for Doamesi sved onthe DNC i the
abowrefaned

MUR.

We have ideld

bAt inve

been o

le

to

and copy an

sruieve

additional hadfd of respove doamL We apet to be "le to prodnes those resigning


dooments to you within the m week to tm days.
Answers to the Immegratmie am d adoned. As noted t imein the amuws wr
prepared by cound for the DNC bed nthe DNC's mords ad the doamns toat we have
located. To thembe of our knoledgas none
employee of the DNCwas demly livolv in
the solicitation ofthe contttions issu aind tiatuore, weee not ale to coainany
addition infomion,
forpurpomes of awg
the intarog
ries an any curm DNC
- mployes with first-and knowledge ofthe *rummnes uroumin the solicitaion ofthe
contribution at isue.
if you have any queuious or need any additional infounation, please contact the
undersigned

Sim

l yours.

eo Bse. Sandlr
General Counsel

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3074

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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

Dear Senator Mitchell-

Sincerely,

.-

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__a

Aril 20, 1993

possible.

e
s
W6.

1.

1.

V. Wome
WI
JesseMk

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Ms

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N.-J... Md3..WI
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Dbut L assesd
Aise

Senator George Mitchell


-7c/o Frances Ceolnrte
321 DStreet, NE
Washington, D.C. 2000Z

MSRvlm

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3075
SENATOR GEORGE MITCHEU.
March 22, 1993

ALVAREZ, CESAR

3reenberg Traurig

Attorney

,221 Brickel Avenue


AiamI, Flrka 33131
35-579-0

3ASS, HILARIE
31mnberg, Trurig
Brickde Avenue
AiI, Florida 33131

Attorney

30&579450

GER, JAMES L

un.E. Third Avenue

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

x~ftMlanBeach, Florida 33160

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.

7290 NW 43rd Street


Mari, FLorida

CCOFFEY, JONI ARMSTRONG


_
SW 9Oth Terrace
MWerni,
FlNrida 33156

Houswifte

1,000.

DALY, STACY
811 Brookwood Place
Ann Arbor, Michigan 48104

Student

2,000.

DALY, THOMAS III


C/o 32 Simpson Road
Briardiff Manor, NY 10510

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.

GREER. EVELYN LANGUEB


2400 South OWe H"gwa
Suite 200
Miarnl, Flordt 313133

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

Real Estate Executive

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

PUGH, JAMES H.Jr.


Epoch Properba L-C
359 Carolina Avenue
Winter Park, Fl.
407-644-9055

Developer

1,000.

Health Care

1,000.

RELATED

GROUP OF FLORIDA

-20 Coral Way, PHI


M~mi. FLorlda 33145
Contact Mr. Jorge Psre
-305-460-990D

RUGG, JOSEPH WjL


305 Bonnie Smn Way .
--Hollyood, Flodd 3M02

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

STACK, CHARLES *Bud"


3929 Ponce De Leon Blvd.
Coral Gables. Florida 33134

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

TANNENBAUM, Dr. JEROME


Ran Corporation
682 charlotte Pike
Nashvifle. Tennessee 37209

TAPLIN, MARTIN W
-

Taplin & Associates

1177 Kane Concourse #201


Bay Harbor, Florida 33154
S305465-5760

3082
Senator George Mitchell, March 22nd, Biltmore Hotel
page 8

WILLIAMS, JOSEPH
5441 Buchanan Street
Hollywood, Florida 33021

Printer

2,000.

21FF, Dr. SANFORD L


881 Ocean Drive
Costa Del Mar Condo-26B
Key Biscayne, Florida 33149

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

DSCC Finance Division - Check Tracking Memorandum

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

WILM ER, CUTLER

Exhibit 20

Pciwa-

5IzJ'94~
ANi

U---.

October 4,

1994

-~me-.
-a.--

5.5 -5.5

e-- M

Mr. Larry Noble

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

.-

December 27, 1994

Joan McEnery, Esq.


Mary L. Taksar, Esq.
Central Enforcement Docket
office of the General Counsel
Federal Election Commission
999 E Street, N.N.

Sixth Floor
Washington, D.C.
Re:

20463

Pre-MUR 307

Dear Joan and Mary:


This letter follows my earlier communications regarding
our client, Thomas Kramer, and his wish to disclose voluntarily
to the Commission that he may have inadvertently violated
provisions of the Federal Election Campaign Act by making or
causing contributions in connection with candidate elections
despite his status as a foreign national.

We include Mr.

Kramer's affidavit and a chart of his questionable contributions


for your review.

Although we believe we have investigated quite

thoroughly, we will, of course, notify the Commission promptly of

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

unaware of Section 441e or any legal restrictions on the ability


of foreign nationals to make candidate-related contributions.
Although Mr. Kramer is quite obviously

a foreign

national in

origin, no fundraiser or candidate ever inquired into his


immigration status or refused funds from him because he was a
foreign national.

In addition,

Mr. Kramer was represented by law

firms on business matters during this period, including a firm


that handled his immigration matters and whose principals
solicited contributions from him and suggested that he make
certain other contributions.

He was never advised that a foreign

national could not make candidate contributions.


When Mr.

Kramer learned as a result of a September 28,

1994 article in the Tama Tribune (attached) that some of his


contributions might violate the FECA, he immediately contacted
legal counsel.

Counsel promptly notified the FEC of the

potential problem and of Mr.

Kramer's intention to cooperate

fully in gathering information on contributions he made or caused


to be made,

in seeking refunds of questionable contributions,

in making full disclosure to the Commission.

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.

He also made several contributions to

Democratic and Republican party committees, which are not clearly


in our effort to make full
candidate-related but which we list
disclosure.
Mr.

Kramer has requested refunds of all his personal

and corporate contributions.'

To date, he has received refunds

from the Democratic National Committee, the Democratic Senatorial


0

Campaign Committee, the Republican Senatorial Committee,


Representative Ileana Ros-Lehtinen,
Margolis and Charles Dusseau.

and local candidates Gwen

By letter of October 25, 1994,

Republican Party of Florida informed Mr.

Kramer that it

the

had

directed the bulk of his donation to its state account for "noncampaign,
$5,000.

non-Federal activities," and refunded the remaining


Mr. Kramer asked for a further refund of the additional

$200,000 he contributed, but the Republican Party of Florida


denied his request.V

Many of the local candidates who received

contributions fror Mr. Kramer, particularly those who were


unsuccessful in their bids for office, have indicated that they

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.

Of the contributions Mr. Kramer made on the

federal level,

two were made through another,

Terri Bradley.

his secretary,

Theme are listed in the accompanying chart.

We

have reason to believe Mr. Kramer also made candidate-related


contributions through others on the state and local level.

We

have included the information we have been able to gather in the


-

enclosed chart.

We did not want to further delay this submission

to the Commission,

and have noted "intermediary"

as the

contributor where we believe Kr. Kramer made a state or local


campaign contribution through another)'
In sum, Kr. Kramer was, until recently, unaware that
foreign nationals could not make candidate-related contributions.
He made some of these contributions at the suggestion and with
C
the advice of principals at his lead law firm, which also handled
his immigration matters.

Although he was solicited by numerous

campaign fundraisers and is quite .learly of foreign origin, he


was never asked about his citizenship or residency status.

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,

please let us know if we may provide any further information.


Sincerely,

Roger M. Witten
Margaret L. Ackerley

N
Enclosures

C-

C'.

-5-

3091

Exhibit 22
FEDERAL ELECTION COMMISSION

WASHINCTONDC .MY-b9

MAY- 4 1995

TO: The Commission


MEMORANDUM
FROM:

Lawrence M. Noble
General Counsel

SUBJECT:

Sunshine Act Request - MURs 4398 and 4638

The Public Records Office has received requests from the


office of Representative Stephen Norn and from the Center for
Responsive Politics that the Commission disclose tape recordings
of its Executive Session discussions of MURs 4398 and 4638.
These MURs were initiated on the basis of a mA 22=1
submission by Thomas Kramer, a foreign national, in which he
indicated that he, and several corporations he owned or
controlled, had contributed to numerous local, state and federal
campaign committees, and that some of the contributions had been
made in the name of his secretary, Terri Bradley.
.
In MUR 4398, the Commission conciliated with Mr. Kramer;
with Ms. Bradley; with several of the Kramer corporations;
and with the Republican Party of Florida (RPF) . It took no
further action with respect to a number of campaign committees.
Unable to reach conciliation with the law firm Greenberg,
Traurig, Hoffman, Lipoff, Rosen and Quentel, P.A., allegedly
the solicitor of many of the contributions, within the context
of MUR 4398, the Commission on May 19, 1997, closed the file in
that matter with respect to all other respondents and opened a
new HUR, 4638, regarding Greenberg, Traurig. The Commission
conciliated HUR 4638 with the firm on December 31, 1997.
The Commission Secretary's office has determined that the
cases were discussed in Executive Session on four occasions.
This Office has reviewed the tape recordings of those meetings.
A synopsis of each meeting, and a recommendation as to
disclosure, follow.
1. Meeting of June 25, 1996.
Commissioners Aikens and McGarry had objected to the
First General Counsel's Report, dated June 7, 1996.

1.

At this point, the case was referred to as Pre-MUR 307.

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.

Meeting of October 22,

1996.

Commissioners Aikens and Elliott had objected to the


General Counsel's Report, dated October 9, 1996.
This report
discussed the response filed by the Florida Republican Party,
recommended entering into pre-probable cause conciliation with
that respondent, and had a proposed conciliation agreement
attached.
Based on language in the GC Report, Commissioner Aikens
first raised the issue as to whether the RPF Federal account
legally could be required to refund improper contributions
received by the RPF non-Federal account.
(10 -20) . The Gene-al

2. Broadly speaking, the Government in the Sunshine Act, 5 U.S.C.


552b, requires that federal agencies disclose minutes,
transcripts or electronic recordings of closed session meetings
unless they contain exempt material. To the extent that the
records contain both exempt and non-exempt materials, the
non-exempt portions must be disclosed.
Exemption 3 to the Sunshine Act, 5 U.S.C. 5552b(c) (3) protects
materials which are specifically exempted by another statute.
2 U.S.C.5437g(A) (4)(B)(i) is such a statute.
It prohibits the
disclosure of action taken by the Commission, and information
derived, in connection with any conciliation attempted by
the Commission.

3093
Memo to the Commission

Page 3
Counsel and Staff Attorney Jose Rodriguez responded.

(21-44).

Commissioner Aikens then inquired as to certain aspects of


the proposed conciliation agreement. Her remarks, and the
responses of the General Counsel, (44-66), should be exempted
from disclosure.
expressed concern with the
Next, Commissioner Elliott
language in the GC Report which suggested that, since the RPF

Federal account had sufficient funds to do so, it should have


refunded the improper contributions received by the RPF
The General Counsel's response
non-Federal account. (67-106).
(117-125).
(107-116) was followed by other observations.
Later, Commissioner Elliott indicated her opinion as to the
contents of any conciliation agreement which might be proposed
for RPF.

(126) .

This opinion should be exempted.

Commissioner Thomas commented, in a generic sense, about


the sources of disgorgement money and of funds used to pay civil
Since his comments were not specific to
(133-146) .
penalties.
case, they should be disclosed.
any particular
and the General Counsel then engaged
Commissioner Elliott
in a discussion which went both to the facts of the case and to
Those portions going to conciliation
(147-73).
conciliation.
(147; 152-55; 163-73) should be exempted.
Commissioner Aikens, the General Counsel and Attorney
Rodriguez discussed the issue of using foreign money in
"redistricting"
accounts, first
with respect to RPF's
(174case, then in more general terms.
activities
in this
This discussion should be disclosed with the exception
211).
referred to the proposed
of those portions which specifically
conciliation of the case.
(186-87; 199-200; 208-11).

3. Meeting

of October 29,

1996.

Commissioners McGarry and Thomas had objected to the


General Counsel's Report, dated October 16, 1996.
After receipt of the letter, dated July 2, 1996, notifying
it of the Commission's Reason to Believe finding, the law firm

Greenberg, Traurig, Hoffman, Lipoff, Rosen & Quentel, P.A., did


not file a substantive response. Instead, by letter dated
July 18, 1996, it requested an extension of time within which
it might file a response, and by letter dated August 13, 1996,
indicated an interest in pursuing pre-probable cause
conciliation.

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).

Next, Commissioner Elliott and Attorney Rodriguez discussed


a document which had been attached to the GC Report.
This
Attachment specifically mentioned possible terms of
conciliation.
Thus, all discussion relating to the Attachment
snould be exempted. (140-44).
Commissioner McGarry then raised his objection, which
went to this Office's decision not to pursue a finding of
a knowing and willful violation against the firm. His
comments, those of Commissioner Elliott, and the responses
of the General Counsel and Staff Attorney Rodriguez (146217) should be disclosed, with the exception of those
portions which specifically refer to the conciliation of
tne matter. (159-60; 184-87; 201-15).
4. Meeting of June 24, 1997.
The General Counsel's Memorandum, dated June 23, 1997,
was placed on the meeting agenda as a late-submitted item.
On May 19, 1997, the Commission had voted to
its
file in MUR 4398 and to initiate a new enforcementclose
matter,
MUR 4638, with respect to Greenberg, Traurig,
Hoffman,
Lipoff, Rosen & Quentel, P.A. Following notification
of
this action, Greenberg, Traurig and Thomas Kramer
each
filed motions requesting reconsideration and remerger

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).

Staff Assigned: V. Convery

3096
Exhibit 23

BEFORE THE FEDERAL ELECTION COMMISSION

Inthe Matter of
Greenberg, Traurig. Hoffian.
Lipoff. Rosen & Quentel. P.A.

MUR 4638

GENERAL COUNSEL'S REPORT

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.'

Thesea spraate submission also contained


information normn that an unidentified individual assoclad4
withthe Democratic
Senatorial
Campaign Comminee
("DSCC) had suggested
shal Mr. Kramer amad AS20.0O0
connribution
throughhisassistant.S.y First General
Consel's Repastin MUR 4398,datedJune7. 1996( FGCR").
at 17-1.
L isOffice madeno recommendations
concerning
theDSCC atthattime. Infoning the Comntasin that
recornmendalions would followAs
tarraned
by ay newinfonatison discovered. Id at20.21. ThIntigation
intoGreenber
Traurit's involvement in Mr. Kramers cotributions hasprovided an Initial indlcatlon ofthe
5
dei
f them,ddual responsibic
forthe )CC transactionAddaisal Informaliar ispreseatlybeingpthered
arrorainrteg Ils amin) in any event. itdrs nul appear that the ndividust soliciga this contribution was

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.

See the General Coumsels

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.

PRIOR CONCII NATION HITHi GRFENRFRG & TRAt RI

UIte
Comminsn alsorecrteJ a fotalU.I11 tu

i dlprgernean

Thediscover)toGreeiberr & l&iung suht afonmatst into Reisidests onolvement


Inall of
Mr Kramer, contributions andthe producion 4i all record relaing to Ohe contributions. In conversuiions
with
this Offie. Knpundcsl hasrepreented thatit cmnmder muchof therequteed information to be privileged nider
the arnome chant reilege. thatMi Kramer%ellno -art this privalegr.and thatthereforeitwill refuse
production on thou reods should settlement
not hesuccessfulWhile thisOffecediagires wilh Respondent's
application of thepoulre o thismailer. i aprarn althenoue n uonlikel to be resolvedshon of tether
prorated

efo
aiiiuni sir

urn arlien

3098
9
IV.

RErMMFENDATTONS

1.

Enter into conciliation with Greenberg. Trauig. Hoffan. LipofE Rosen


& Quentel. P.A. prior to afinding of probable cause to believe.

2.

Approve the attached conciliation agreement and appopriate letter.

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

Greenberg, Traurig, Eoffman,


Lipoff, Rosen & Quentel, P.A.,

MUR 4638

1 Al.

CERTIFICATION

I, Mkrjorie W. Emmons,

Secretary of the Federal Election

Commission, do hereby certify that on December 31,

1997,

the

Commission decided by a vote of 4-0 to take the following


actions in MUR 4638:
1.

Accept the conciliation agreement with the


Greenberg, Traurig, Hoffan, Lipoff, Rosen &
Quentel, P.A. in settlement of NUR 4639 and
close the matter as to this Respondent, as
recommended in the General Counsel's Report
dated December 19, 1997.

2.

Close MUR 4638.

3.

as
Approve the appropriate letter,
recommended in the General Counsel's Report
dated December 19, 1997.

Commissioners
affirmatively

Elliott,

McDonald,

for the decision:

McGarry,

and Thomas voted

Commissioner Aikene did not

cast a vote.
Attest:

Date

Marjorie W. Emmons
S cretary of the Commission

Received in the Secretariat: Mon.,


Dec. 22, 1997
Circulated to the Commission: Mon.,
Dec. 22, 1997
Deadline for vote:
Tues., Dec. 30, 1997
lrd

10:52 a.m.
4:00 p.m.
4:00 p.m.

3101
BEFORE THE FEDERAL ELECTION COMMISSION

In the Matter of

MUR 4638

Greenberg. Traurig, Hoffman, Lipoff,


Rosen & Quentel, P.A.
CONCILIATION AGREEMENT
This matter was initiated by the Federal Election Commission ("Commission"), pursuant
to information ascertained in the normal course of carrying out its supervisory responsibilities.
The Commission found reason to believe that Greenberg, Traurig. Hoffman, Lipoff, Rosen &
Quentel. P.A. ("the Respondent") violated 2 U.S.C.

441e.

NOW. THEREFORE, the Commission and the Respondent, 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 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.

Respondent has had a reasonable opportunity to demonstrate that no action should

be taken in this matter.


III.

Respondent enters voluntarily into this agreement with the Commission.

IV.

The pertinent facts in this matter are as follows:


1.

Greenberg. Traurig. Hoffman, Lipoff. Rosen & Quentel, P.A. is a


professional association engaging in the practice of law.

2.

Thomas Kramer is a foreign national as defined at 2 U.S.C.


11 C.F.R.

110.4(a)(4).

441e(b)

and

3102

3.

Respondent was retained by Thomas Kramer to represent him

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.

During the 1993-1994 election cycle, from approximately March 1993


through September, 1994, to the best of its knowledge Respondent,
through its personnel, participated in conversations with Thomas Kramer
and/or his agents which resulted in Mr. Kramer making contributions,
directly and through entities related to him, totaling approximately
591,000 to various local and state candidates and a national political
committee. The local and state recipient candidates were both Democrats
and Republicans.

5.

Several of these solicited contributions were made by Thomas Kramer and


his spouse directly.

The majority of these contributions were made by

various United States corporations owned and controlled by Mr. Kramer.


6.

It is unlawful for any person to solicit a contribution from a foreign


national in connection with an election to any local, state or Federal
political office. See 2 U.S.C. 441e(a); 11 C.F.R. 110.4(a).
Commission's regulations prohibit U.S. corporations

The

from making

contributions in connection with any election if the corporation's


contribution is controlled or directed by a foreign national.
110.4(a)(3).

11 C.F.R.

For purposes of 2 U.S.C. 441e(a) and 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.

Respondent Greenberg, Traurig, Hoffman, Lipoff, Rosen & Quentel, P.A.

solicited approximately 591.000 in contributions from a foreign national.

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

not intentionally violate 2 U.S.C. 441e.


VII.

Respondent will pay a civil penalty to the Federal Election Commission in the

amount of Seventy-Seven Thousand Dollars (577,000), pursuant to 2 U.S.C. 437g(a)(5)(A),


in full and complete settlement of all matters, transactions or occurrences related in any way to
the allegations contained in MUR 4638 which are or could be directed to or against the
Respondent or any of its shareholders, members or employees by the Federal Election
Commission.
VIII.

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.
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

FOR THE RESPONDENT:

By:

Leslie J. Kerman
Counsel for the Respondent

Date

3105
Exhibit 25
WILMER. CUTLER & PI
OS

Snag.
,

&

a.

HQ37-

June 20. 1997

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

you consider this letter in that regard.

prevents us from setting out our arguments and possible solutions

in greater detail here, we would be happy to supplement this


letter with further information at your request.
We have been told that in severing this matter into two
separate MUR., 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

3106
accompanying affidavit to his having made contributions at the
suggestion and with the advice of counsel will be omitted.
AttachmentA.

our letter and Mr.

(aft,

Kramer's affidavit as they

were

submitted, and Attachment B. the relevant sections as the staff


The planned deletions would omit .
proposes to edit them.)
critically relevant fact --

that Mr. Kramer made many of his

contributions at the suggestion of a law firm that knew of his


foreign national status.

Because the omissions will obscure the

fact,that Mr. Kramer had every reason to believe he was acting


within the law when he made candidate campaign contributions, the
public's understanding of the facts will be skewed in a manner
grossly unfair to Mr. Framer.
Contrary to the staff's position that any injustice to
Mr. Kramer will be cured when the second MU

is made public, we

submit that the bifurcation unfairly, unnecessarily, and uniquely


exposes Mr. Kramer to a double dose of bad publicity in a highly
charged political atmosphere relating to foreign national

contributions (even though his contributions were unrelated to

CO

the

years earlier) .

'96 campaign and were disclosed to the FEC voluntarily two


Further,

there is no guarantee the record will

ever be completed since the Commission may act in the Greenberg,


Traurig matter.

Even if it

will have been done.

does so, the damage to Mr. Kramer

We maintain that the confidentiality

provision of the Federal Election Campaign Act does not


necessitate the planned redactions.

(5=, Attachment C,

the

relevant sections of our letter and Mr. Kramer's affidavit with


our proposed alteration..)

However, to the extent the Commission

3107
believes otherwise,

fairness and public policy concerns compel a

reconsideration of the decision to create a separate MOR.


Creating a new MURin this matter is unjustified.
First, the conduct at issue with regard to Mr. Kramer and the
Greenberg,

Traurig firm are inextricably bound; this is

not an

instance of respondents involved in separate and separable acts.


Further, given the Commission's very broad interpretation of the
confidentiality provision. creation of a new MUR will have the
perhaps unforeseen effect of harming the party who voluntarily
made full disclosure and promptly settled while rewarding the
-7

respondent that has refused to conciliate.

Surely this is

contrary to the incentives the Commission should wish to


establish for future respondents. While we appreciate that there
are instances in which creation of separate MURs is
reasonable,

it

is

justified and

difficult to escape the conclusion that in this

instance two cases are artificially being created from one to


bring public closure of a foreign national case with a large
penalty.

We submit that the desire for such closure should not

overwhelm consideration of the rights of all of the parties


involved as well as the probable effects on future matters of
actions the Commission takes here.
For the reasons stated above, we ask that the
Commission recombine M'JR 4390 and MUR 4638.

Alternatively,

as we

are continuing to discuss wtth your General Counsel's office,

the

Commission could redact the record in a manner that observes the


confidentiality provision with respect to Greenberg, Traurig
without sacrificing fairness with regard to Mr. Kramer.

3108
pinally. we ask that the Commission notify us of how it

intends

to proceed when auch decision has been made so that we can


casider further action, if necemmary.

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

TIME 12:25 p.m.

STAFF MEMBER J. Rodriguez

CHECK ONE: >[X ] TELEPHONE CALL >[ ] VISIT

NAME OF PERSON: Lou Vendittelli, Esq.


NUMBER CALLED: (305) 379-3515
CHECK ONE: >[ ] RESPONDENT >[ X ] WITNESS >[ ] OTHER
SUBSTANCE: Counsel called to inform me of his client's knowledge concerning the various
contributions
20K DSCC (in her name)
Ms Bradley overheard a conersaton between Mr. Kramer and another individual dunng
wtuch the individual asked Mr Kramer if there was -anyone else who could make the
contbution in your place - This indeidual also explained that the requested contribution would
make Mr Kramer a member of the inner circic with various accompanying perks. In fact.
Mr Kramer later wrote an internal memo complaining about how none of the stated perks
matenalszed after the contribution Mr Bradley can identify this individual and his business
affiiation She was not a party to this converanior. but instead overheard it while at her desk
next to Mr Kramer's office I asked counsel if ths individual was DSCC; counsel noted that his
client could I.D the individual but did not kjo- his afftiation w..ji the committee.
Other Contribs
Ms Bradley has information concernng vanous solicitations by a named partner at G&T.
This individual was not the lawyer who usually handled Kramer's business matters. This
indisidual's only interaction with Kramer -as the solicitation of contributions. According to Ms.
Bradley. during the period of Prop 6 (Gamsng).(Bradley believes 1995. but contribs at issue 9394). this individual began soliciting Mr Kramer for fund-raisers There were approximately 5-6
solicits, they were either by fax or by phone She was not pnvy to any of Mr. Kramer's
conversations She orly knows that the individual called and faxed solicitations. She believes
Mr. Kramer bought a full table for a Gore fund-raiser She can also identify this individual.

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

THE HUDSON CASINO REJECTION


INTRODUCTION

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

In late 1993, three impoverished 4 Wisconsin Indian tribes-the


Mole Lake Sakaogon Chippewa, the Lac Courte Oreille Band of
Lake Superior Chippewa, and the Red Cliff Band of Lake Superior
Chippewa-applied to have the U.S. Government, through the Department of the Interior, take land into trust in Hudson, Wisconsin, for the purpose of gaming.s An existing Class III gaming facilvery little modification
ity already on the parcel of land required
to add additional gaming devices. 6 The structure was originally
built as a greyhound racing park and included a 10,000 car parking
lot to accommodate a capacity crowd. A four lane roadway had already been built by the developer of the existing track to relieve
potential congestion problems that could be created by a crowd attending a specific event at the race track. Furthermore, the expected usage of the casino was not greater than that originally anticipated for the greyhound facility.
The applicant tribes moved the application forward according to
the prescribed guidelines of the Indian Gaming Regulatory Act
(IGRA). After an exhaustive review by both the regional office and
the area office of the BIA, including consultation with area officials
and the surrounding tribes, the Area Director sent a 32 page recommendation for approval to the central office in Washington, DC.
Once the application arrived in Washington, a number of native
American tribes who felt that new competition might jeopardize
their casino profits hired lobbyists to bring political pressure on
those who might be in a position to reverse the earlier decisions.
The tribes hired Patrick O'Connor, a well known lobbyist, former
fundraiser for Bruce Babbitt's Presidential bid in 1988, and former
DNC treasurer. O'Connor, a name partner at the law firm of O'Connor and Hannan based in Minneapolis, wasted no time in applying
significant pressure on the Democratic National Committee (DNC),
'According to Arlyn Ackley, Sr., the chairman of the Mole Lake Sokaogon Chippewas, the unemployment rate for his tribe was over 40 percent, and the average household income was approximately $8,000 per year. George Newago, the chairman of the Red Cliff Chippewa, indicated
that his tribe faced over 50 percent unemployment and a household income of $5,300 per year.
Committee interviews with Chairman Arlyn Ackley, Sr., and Chairman George Newago, Dec.
16, 1997.
"This is the normal process used by Native American tribes under Section 20 of the Indian
Gaming Regulatory Act (IGRA) for the acquisition of "off reservation" land. See 25 U.S.C. 2719
(1988).
"In an interview with Committee investigators, Mr. Fred Havenick, the owner of the existing
dog track in Hudson, WI, confirmed that no external construction was necessary or planned if
the application had been approved.

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

The April 24 entry in O'Connor's calendar reads, "Meeting w/the


President on the Hudson Race track issue with Bruce Lindsey and
Linda Moore of the White-House staff."15 This meeting with the
President was the breakthrough the tribes and lobbyists had6 been
looking for. O'Connor explained in his state court deposition 1 that
President Clinton was receptive to O'Connor's problem:
When he [the President] got to me, I said "Mr. President,
the Indian tribes I represent are concerned about a possible casino going in near Hudson, Wisconsin which is
across the river." And that's what I said. At that juncture,
he said "Bruce." And Bruce [Lindsey] came over . . . [The

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-

ing to get our side of this matter, this issue, across to


the-to the people in Interior because" and I explained
. . . "I don't believe we're getting through, although we've
been trying." . . . And he [Bruce Lindsey] said, "Well," he

said, "II1 get someone to call you on this." I said, "I


haven't"-that Loretta Avent call came afterwards. I said,
"I haven't been able to get anywhere with Loretta." And he
didn't say anything. He said, "I will have someone call
you." And that was it.21
This brief meeting with the President was the catalyst for White
House activity regarding the Hudson casino application. It is likely
14See

i16 Id.

Patrick O'Connor's Datebook, Apr. 24, 1995 (Exhibit 5).

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

have received concerning these kinds of issues, I have not


and would not speak with him or any lobbyist or lawyer.
Irrespective of [who] lobbyists and lawyers say they know
in this Administration, my first responsibility is to the
presidentt. Because I am aware of the politics and press
surrounding this particular situation, it is in our best interest to keep it totally away from the [W]hite [H]ouse in
general, and the pres[ident] in particular. This is such a
hot potato (like Cabazon) 23-too hot to touch. The legal
and political implications of our involvement would be disastrous. . . . This is a Department of Interior and Justice

Department [matter] and that's where it should stay. . . .


I explained this to Bruce and he understands the way I operate and I assured him that I would make the call directly to advise the party that called. I will do this as soon
as my meeting is over. I'll call later and give you an upId. at 79.
The Cabazon Band of Mission Indians were involved in litigation with the Federal Government for the operation of slot machines. They also reportedly funneled over $750,000 into the
State of California's Attorney General's race. When asked in her deposition before the Committee about her reference to the Cabazons, Avent replied: "just that it was in court, it was a big
court case, and I don't have specifics on it, because I wasn't particularly interested in it other
than I just knew it was dealing with gaming and I am not an expert on gaming and I have
no expertise in the legal arena at all." (Avent Deposition, Dec. 5, 1997, p. 18). Mark Nichols,
the Chief Executive Officer of the Cabazon Band, was indicted in June 1998, and accused "of
laundering thousands of dollars in illegal contributions to six Democratic candidates, including
President Clinton . . ." (Rosenzweig, David, California and the West 2 Casino Executives Accused of LaunderingPolitics, Los Angeles Times, June 19, 1998).
2

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

issue. As you know, last year WH counsel advised Loretta


that she should not meet with lobbyists or lawyers on Indian issues. . . . The White House should not be involved

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

the status of the Indian gaming issue at Interior.3 7


From this it is clear that the DNC had very clear fundraising goals
related to O'Connor, and there was a clear understanding that the
lobbyist was interested in a policy issue far from the legitimate
purview of the DNC.
DNC contacts the White House and Departmentof the Interior
True to his word, Fowler focused his efforts on the White House
and the Department of the Interior. In his testimony before the
Senate he stated: "I called Mr. Ickes, explained to him the situation, and I called someone at the Department of the Interior ...
I simply asked that the situation and the facts in that situation be
reviewed." 38 However, a memo from DNC counsel Joe Sandler and
Neil Reiff to the DNC finance staff updating the "basic legal guidelines for fundraising," specifically states that:
[I]n no event should any DNC staff ever promise a meeting
with or access to any government official or agency in connection with a donation, or ever imply that such contact or
access can be arranged, or ever contact an3 9Administration
official on behalf of a donor for any reason.
Although this memorandum was updated after Fowler's action,
Fowler admits that he was also instructed by White House counsel
Jack Quinn and House Political Director Doug Sosnik that such
contact on behalf of a donor was inappropriate as was White House
involvement in the decision of an in ependent agency. 40
Ignoring the warnings he received about the impropriety and illegality of such conduct, Fowler continued to contact the White
House. On May 5, 1995, he sent a memorandum to Harold Ickes
following up on a previous conversation they had about the Hudson
casino proposal." Fowler acknowledged in this memo the politics
involved and the stance of the DNC supporters:
3 Memorandum from Carl Artman to Scott Dacey, May 1, 1995 (Exhibit 15).
3 Memorandum from David Mercer to Chairman Fowler, May 19,
1995 (Exhibit
3Testimony of Don Fowler before Senate Committee on Governmental Affairs,

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.

. .

. The proposal to convert a dog

track to a casino is being pushed by American Indian


tribes who are supporters of Governor Thompson[.] 4 2
Continued pressure on the White House
Fowler's calls and memorandum only added to the pressure
placed upon the White House to intervene on the issue. Ickes had
tried to contact O'Connor on a number of occasions but appears to
have been unsuccessful.4 3 O'Connor's May 8, 1995, letter to Ickes,
where he expressed his concern that the steps being taken by the
officials at the Interior Department were not in his client's best interests, only solidifies the belief that the lobbyists, the DNC and
perhaps the White House were working to pressure a decision from
Interior:
I have been advised that Chairman Fowler has talked to
you about this matter and sent you a memo outlining the
basis for the opposition to creating another gaming casino
in this area.... I am concerned that those at Interior who
are involved are leaning toward creating trust lands."
O'Connor then put the issue into terms Ickes, President Clinton's
chief fundraiser at the White House, could not easily miss: "I would
also like to relate the politics involved in this situation: . . . All of

the representatives of the tribes that met with Chairman Fowler


are Democrats and have been so for years. I can testify to their
previous financial support to the DNC and the 1992 Clinton/Gore
memo
Campaign Committee." 45 O'Connor's purpose in writing the
admittedly was "to alert Ickes as to the politics involved." 4 6 When
asked whether he thought the Department of the Interior was required to review the political factors mentioned, Patrick O'Connor
testified, "I don't imagine they were." 4 7 If these were not areas
that the Department of the Interior would be considering for the
application, it seems reasonable to conclude that O'Connor was
looking to exert political influence upon the Department of the Interior's Hudson decision.
On May 14, 1995, Tom Schneider, another O'Connor & Hannan
partner, met with President Clinton and Harold Ickes and elicited
up" on O'Connor's requests
Ickes' assurances that he would "follow
relating to the Hudson application.4 8 Notwithstanding49Schneider's
denials that he met with the President on this matter, he did bill
his clients for a "meeting with senior White House staff and
42 Id.
-See Letter to Harold Ickes from Patrick O'Connor, May 8, 1995 (Exhibit 18).
"Id.
a Id.
"State Court Deposition of Patrick O'Connor, Apr. 18, 1997, pp. 128-129 (Exhibit 8).
Id.
4s Deposition
4Deposition
47

of Thomas J. Schneider, Dec. 10, 1997, p. 17.


of Thomas Schneider, Dec. 10, 1997, p. 15.

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

of their "discretion" in this matter."5 5 Sibbison also mentioned the


fact that there was local opposition to the application, but noted
that "much of the opposition, however, was a5 6by-product of wealthiThe recognition that
er tribes lobbying against the application[.]"
local opposition was a by-product of lobbying efforts by "wealthier
tribes" is particularly troubling. The regional office and the area office had both concluded that local opposition was not sufficient to
deny the application. Only after wealthy opponents became involved-and the Department of the Interior had accorded their
tribes preferential treatment in the form of an extended comment
period-did local opposition become a dispositive issue. Even then,
as will be discussed in later sections of this chapter, the "opposition" failed to articulate substantive reasons for denial of the application. The Department's obvious favoritism tends to undermine
the Secretary's assertion that the denial of the application was appropriate.
Further communication between the White House and the Department of the Interior
Harold Ickes' office appears to have been the primary contact at
the White House for the Department of the Interior. Ickes, in an
55 O'Connor and Hannan Billing Records (Exhibit 31).
52xJennifer O'Connor is no relation to Patrick O'Connor.
Memorandum from Jennifer O'Connor to Harold Ickes, May 18, 1995 (Exhibit 19).
5s
Id.
54
Memorandum from David Meyers to Jennifer O'Connor, June 6, 1995 (Exhibit 20).
55 Id. The quotation marks around the word "discretion" are found in the original. One of the
central concerns in the rejection of the Hudson application is whether the Department made
its decision according to articulated standards and past practices. It is curious that someone on
Harold Ickes' staff would use quotation marks to describe something the Secretary of the Interior was about to do. Contextually, it seems as though Meyers recognizes that it would not be
appr oriate in this case to ignore the law, ignore the facts, and decide based on discretion.
6

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

Affidavit of Paul Eckstein Jan 8, 1996 (Exhibit 23).


Id. This is Eckstein's recoiection of the exchange.
8Letter from Secretary Bruce Babbitt to Senator John McCain, Aug. 30, 1996 (Exhibit 24).
7
Sokaogon, 961 F. Supp, at 1284.
76

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

Large contributorsgot what they wanted


During the 1996 election cycle, tribes opposed to the Hudson application donated at least $356,250 to the DNC and other Democratic party causes during the 1995-1996 election cycle.8 6 This figure does not include money donated by the lobbyists paid by the
opponents or other "intangibles," such as the fundraiser held in the
home of lobbyist Tom Schneider which raised $420,000 for Clinton
Gore '96 the night before the decision to deny the application was
made.87
Prior to the fundraiser at his home, Schneider had elicited Ickes'
promise to "follow up" on Patrick O'Connor's requests regarding the
dog track in Hudson, Wisconsin.8 8 According to Schneider: "my experience, due to sort of a personal relationship with the White
House, is when people say they are going to follow up, they usually
will follow up."8 9
These large donations from Native Americans were not merely
coincidental. On the contrary, the Democratic National Committee
and Clinton/Gore '96 campaign staff were actively soliciting such
contributions from Native American tribes.
It is also interesting to note the pattern of wealthy Native American contributors getting what they wanted where off-reservation
gaming was concerned. The Sault Ste. Marie Chippewa gave at
least $384,964 to the Democrats in 1995-199690 and received approval from the Department of the Interior to9 1open a gaming facilThe Mashantucket
ity over 300 miles from their reservation.
Pequots gave over $409,625 in 1995 and 1996 to the Democrats and
the Department of the Interior not only approved their application,
but hired mediators to try to alleviate some of the extraordinary
local opposition to the expansion of gambling. Indeed, the Committee received one document from the DNC on August 28, 1998-7
months after the Committee held hearings on this subject-which
shows that Richard Hayward, the Chairman of the Mashantucket
Pequots, is listed as: "Wrote $500,000 +" to the DNC. 92
The opposing tribes in the Hudson matter contributed (through
Patrick O'Connor) at the same time that opposition tribe lobbyists
were meeting with White House and DNC staff (through O'Connor)
86 See Committee on Government Reform and Oversight Chart (Exhibit 26).
' See Vern Shen and Karl Vick, "Schaefer and Bentley's Latest Pitch," the Washington Post,
July 20, 1995.
9 Deposition of Thomas Schneider, Dec. 10, 1997, pp. 16-17.
* Id.
90 A "movie list" of attendees at White House movies was produced to the Committee which
lists "Bernard (Chippewa Indians)" along with Ted Sioeng, Charlie Trie, Arief Wiriadinata and
16 others. See movie list (Exhibit 27). At one point, the DNC appeared to be feeling great urgency regarding matters pertaining to this tribe. In a call sheet dated Feb. 22, 1996, Mark
Thomn ced Richard Sullivan and the following message was recorded: "[c]an we overnight
a Finance
Board packet to his Indians." (Exhibit 28).
e1 The tribe's casino application was vetoed by the Governor of Michigan and therefore the
casino was not built.
92This is a sum far greater than that known prior to the recent production of documents (Exhibit 29).

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

list, Oct. 23, 1996 (Exhibit 30).


Testimony of Don Fowler before the Committee on Governmental Affairs, Sept. 9, 1997.
* Id.
1oo See O'Connor & Hannan billing records (Exhibit 31).
1o Patrick O'Connor Datebook, July 14, 1995 (Exhibit 5).
102 O'Connor & Hannan billing records, July 14, 1995 (Exhibit 31).

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

Deposition of Hilda Manuel, Jan. 6, 1998, pp. 81-82.


E-mail from George Skibine to Heather Sibbison, Paula Hart, Tom Hartman, Troy Woodward
117 and Kevin Meisner, June 30, 1995 (Exhibit 46).
As will be discussed later in this chapter, the Department of the Interior significantly misrepresented the amount of support for the application in the record submitted for the purposes
of the Federal litigation in Wisconsin. The Department of the Interior also failed to inform the
court that their own Solicitor's office found opposition by elected officials to be irrelevant. See
e-mail from Kevin Meisner to Heather Sibbison, Mar. 23, 1995 (Exhibit 56). In this e-mail,
Meisner states that he is also sending the e-mail to another Department of the Interior lawyer
named Tim Elliot "who should be able to shed some further light on this question." No documents were produced to this Committee regarding Mr. Elliot's position on this matter. Notwithstanding Mr. Elliot's potential role as a witness m this matter, however, Elliot represented all
Department of the Interior employees in depositions taken by this Committee.

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.

. .

. We told them we would con-

fer with policy makers within the Department and let

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

126 20 U.S.C. 2719(b)(1XA).


227 E-Mail from George Skibine

to Hilda Manuel, Mar. 17, 1997 (Exhibit 57).


Secretary of the Interior Bruce Babbitt, Letter to the Editor, the New York Times, Jan. 4,
1998.
128

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

Act (IGRA), 25 U.S.C. 2719.129

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

Commissioner of Indian Affairs, to Hon. Steve


bit 38).

ao Deposition of George Skibine, Jan. 13, 1998, p. 44.

1a1Id. at p. 133.
2 Testimony of

Secretary of the Interior Bruce Babbitt, Jan. 29, 1998, p. 769.

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

According to Dacey, Mike Anderson relayed that the Department


merits" and would "try to
was "trying to keep this issue on the
5
thread the needle on this request."'1 The memo concluded:
Things might change when the politicians like Babbitt and
Duffy become involved, but without5 6the law on their side
it will be difficult to "kill the deal."1
On July 14, 1995, the Department of the Interior did in fact "kill
the deal.' The Department relied upon a finding of detriment in
the face of the career professionals who had stated that there was
no articulated detriment. Interestingly enough, Dacey noted in his
memo that if Babbitt were to come out against the Hudson application he would "find his excuse in Section 151." 157 It is significant
that a lobbyist for the opponents was being briefed on the legal
analysis at the Department, while the applicants were being told
nothing. Indeed, given what was discovered during the Committee's
investigation, it is reasonable to speculate that Interior officials did,
not inform the applicant tribes about perceived problems because
either the problems were not supported by past practice and current fact, or the concern that by identifying "problems," the applicants would have an opportunity to cure. Given the obvious preferential treatment given the opponents of the application, there appeared to be little interest in allowing the applicants an opportunity to address the Department's concerns. Although George
Skibine now states that he would have done things differently, it
is hard to believe that Interior officials would not have worked with
the applicant tribes-unless the ulterior motive was to help the opponents achieve their objective.
It is significant that the Department was prepared to take the
unprecedented step of rejecting the application for off-reservation
gaming using a 151 analysis. Kevin Meisner confirmed this when
he wrote on July 11, 1995, "I thought after the Friday meeting that
everyone (except Duffy who we had not yet consulted) agreed that
there was not enough evidence supporting a finding of "detriment"
to the surrounding community under section 20 and therefore we
would decline to acquire the land under 151." 1s Notwithstanding
the fact that "everyone" agreed the decision could not be made
under Section 20, Secretary Babbitt has repeatedly said that the
Department based its decision solely on the criteria set forth in
Section 20.159
1

4Deposition

of Thomas Hartman, Dec 8 1997, p. 37.

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

had the handwritten signatures converted to type script,


eliminated duplicate signatures so that these 716 or however many there were taken out were actually in there
twice.191
This testimony is particularly interesting when compared with the
memo authored by George Skibine, the head of the IGMS, which
states: "Several thousand cards, letters, and petition signatures
have been received in support of an Indian casino at the Hudson
dog track." 19 2 Mr. Leshy's statement, given every benefit of the
doubt, does not explain how "several thousand cards, letters, and
petition signatures were represented by 797 names compiled by
the Department to provide the Federal Court in Wisconsin a sense
'"Petition
of General Support (Exhibit 62).
m9Letter to Secretary Babbitt from petition sinatories, Jan. 26, 1994 (Exhibit 63).
mLetter from Wisconsin resident to George Skibine (with attached cards), June 5, 1995 (Exhibit
64).
19 1
See Jan. 29, 1998 hearing testimony before the Committee on Government Reform and
Oversight, pp. 932-933.
192emorandum from George Skibine to Assistant Secretary-Indian Affairs, undated (Exhibit 45).

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

Skibine, the head of the Indian Gaming Management Staff, who


made the following statement in a deposition before this Committee:
Q. If I asked you the question, the decision to reject the
Hudson Dog Track application was based solely on section
20 of the Indian Gaming Regulatory Act, would you say
that that was correct or false?
A. It would be false.196
The confusion over how the application would be rejected is seen
in an exchange of e-mails in the days before the decision was made.
In an e-mail to Skibine and Heather Sibbison, Kevin Meisner
states:
Why are we changing our analysis to deny gaming under
Section 20? I thought after the Friday meeting that everyone (except Duffy who we had not yet consulted) agreed
that there was not enough evidence supporting a finding
of "detriment" to the surrounding communities under Section 20 and therefore we would decline to acquire the land
under 151.197
In an indication that John Duffy was the driving force behind the
ultimate decision on how the rejection would be made, Meisner
sent the following message to Troy Woodward:
Troy: Apparently Bob Anderson did review the letter late
Monday. I checked with him Tuesday and he thought that
since Duffy wanted the Section 20 finding so badly that we
would let the letter go through. I still think that there was
not enough evidence for a section 20 finding of detriment.198
Once again, this exchange of e-mails shows that there were significant concerns about whether there was evidence to support a finding under Section 20 of IGRA. Given the strong feelings that there
was not enough evidence to make such a showing, it is all the more
curious that Secretary Babbitt continues to maintain that the decision was based "solely on the criteria set forth in Section 20 of the
Indian Gaming Regulatory Act." 9 9
'"Deposition of George Skibine, Jan. 13, 1998, p. 17. In a document that runs counter to
many of the other important documents related to the Hudson matter, George Skibine makes
the following request of lawyers in the Solicitors office: "As you know, I am drafting a document
relating to the acquisition of the Hudson dog track by three Indian tribes in Wisconsin. The
letter will decline to take the land into trust pursuant to the IRA and Part 151 relying on the
discretionary authority of the Secretary not to take such land into trust. The acquisition is for
gaming purposes, but we want to avoid making a determination under Section 20 of IGRA." Email from George Skibine to Dave Etheridge, Kevin Meisner and Troy Woodward, June 6, 1995
(Exhibit 73). This communication is particularly strange because others on Skibine's staff were
not aware of the decision in early June, and all indications are that the record had not provided
support for a finding that the application was a detriment to the community. Furthermore, it
is curious that Skibine would come right out and say that there was a desire to avoid making
the decision under Section 20 of IGRA. One can speculate that he wanted to avoid setting a
precedent by making the decision under Section 20 without employing the traditional Section
20 criteria.
inExchange of e-mails between Kevin Meisner and Heather Sibbison, George Skibine and
Troy Woodward, July 11, 1995 (Exhibit 74).
Te
I.
199Testimony of Secretary of the Interior Bruce Babbitt, Jan. 29, 1998, p. 776.

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

On August 20, 1997, the Department of the Interior was asked


to provide documents pertaining to the Hudson matter. The compliance date for this request was September 8, 1997. Unfortunately,
however, Interior failed to respond adequately to this Committee's
legitimate request.
On October 23, 1997, Interior provided one file of records. On November 3, 1997, another file of records was produced. At this point,
the Committee was under the impression that production of
records-with the exception of a record prepared for litigation in
Wisconsin, which the Committee initially elected not to receivewas complete.
On December 11, 1997, during a deposition before this Committee, Robin Jaeger, the Superintendent of the Regional Office in
Wisconsin had the following exchange with Committee counsel:
Q: When did you receive communication that you are requested to produce documents about the Hudson dog track
matter?
0

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

The White House appeared to be particularly concerned about


turning over to the Committee a number of documents that indicated the President had some level of familiarity with the Hudson
application. Many months were consumed while the White House
argued that some documents responsive to legitimate requests
made by the Committee were "subject to executive privilege."
The Committee did ultimately receive relevant documents from
following
the White House. The original of one document with the
message has still not been provided to the Committee: 204
Leon
What's the deal on the Wisconsin tribe Indian dispute?

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

Evidence obtained by this Committee indicates that the decision


to reject the Hudson application did not comport with factual evidence and past practice. The fact that the Department of the Interior has continued to misrepresent how and why the decision was
soaDeotion of Robin Jaeger, Dec. 11, 1997, p. 11-12.
2m Exhibit 78.
sesMemorandum from American Law Division, Congressional Research Service, to Honorable
Dan Burton, Dec. 3, 1997 (Exhibit 79).

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

United States Department of the Interior


BUREAUOF INOLANAFFAIRS
UWWAPOU5ALLAornam

IwND

11 sotT
AVENLIE
MML'.AOLI MINNESOTA
IWI012141

Exhibit I

Tribal operations

MEMORANDUM
TO:

Assistant Secretasy - Indian Affairs

FROM:

Office of the Area Director

SUBJECT:

Request for Off-Reservation Gaming for Land in Hudson, Wisconsin

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

RECOMMENDED FINDINGS AND CONCLUSIONS

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

MINNEAPOLIS A REA OFFICE'S

RECOMMENDED FINDINGS OF
FACT
AND
CONCLUSIONS

November 15,

1994

EOP 064505

3161
INDEX

Paoe
Introduction

Part I.

A.

B.

..

Best Interest of the Tribes

...

Gross and Net Income to the Tribes ..................

Table

...................................

.......

Projections of Management and Tribal Expenses ........

1.

Assumed Liabilities and Nonrecourse Liability ...

2.

Joint Venture Agreement of Meadows Parking Lot


Joint Venture .................................

3.

Agreement for Government Services ...............

4.

Ground Lease ....................................

5.

Activities Loan .................................

9.

C.

Basis for Projections and Comparisons ................

D.

Projected Tribal Employment ...........................

10

E.

Basis for Projecting the Increase in Tribal


Employment .. ......................................... 11

F.

Projected Benefits from Tourism ......................

11

G.

Projected Training Benefits ..........................

12

H.

Projected Benefits to the Tribal Communities from


the Increase in Tribal Income ......................

12

I.

Projected Benefits to the Relationship Between the


Tribes and Surrounding Community ...................

13

Possible Adverse Impacts on the Tribes and Plans for


Dealing with those Impacts .........................

13

J.

Part II.

A.

Not Detrimental to the Surrounding Community ....

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

..

............................

County of St. Croix

..........................

4.

Town of Troy

S.

General Public Response

6.

B.

a.

15
.16

................................

a.

Public Opposition

b.

Public Support

.........................
...............

16

17

......... 17

..........................

18

Consultation with Neighboring Tribes ............

19

a.

St.

b.

Wisconsin Winnebego Nation

c.

Leech Lake Band of Chippewa Indians ..........

20

d.

Shakopee Mdewakanton Sioux Community .........

20

e.

Prairie

21

f.

Lower Sioux Community

g.

Minnesota Chippewa Tribe ......

h.

Mille Lacs Band of Chippewa Indians .......... 22

i.

Minnesota Indian Gaming Association

j.

Lac du Flambeau Band of Lake Superior


Chippewa Indians .........................

22

k.

Oneida Tribe of Indians of Wisconsin .......

23

Croix Band of Chippewa

Economic

2.

Political

................

Island Dakota Cotnunity ..............

Impact on Nearby Tribes


1.

Indians ........... 19

......................
...........

........

20

21
21

22

..............................

23

........................................

23

...................................

24

Evidence of Environmental Impacts and Plans for


Reducing Any Adverse Impacts ........
..............

24

1.

Environmental Considerations

24

2.

Natural and Cultural Resources

.................
.................

25

EOP 064507

3163
a.

Land Resources

b.

Water Resources

C.

Air Quality

d.

Threatened and Endangered Species ............

26

e.

Cultural Resources .........................

27

........

25

........

.......

26

..............................

26

D.

Impacts on the Social Structure in the Community .....

27

E.

Impact on the

27

Infrastructure

.......................

1.

Utilities ............................

2.

Zoning .................................

3.

Water ...............................

4.

Sewer and Storm Drainage ........................

28

5.

Lighting ........................................

28

6.

Roads ...........................................

29.

a.

Access .......................... ...........

29

b.

Traffic Impact Analysis ....................

29

Impact on the Land Use Patterns in the Surrounding


Community .........................................

30

G.

Impact on Income and Employment in the Community .....

30

H.

Additional and Existing Services Required or Impacts,


Costs of Additional Services to be Supplied by the
Community and Source of Revenue for doing so .....

31

Proposed Programs, if any, for Compulsive Gamblers


and Source of Funding ..............................

31

I.

Part II.

Recomendationm

..........

27

........ 28
...........

.............................

28

32

EOP 064508

3164

RECOMMENDED FINDINGS
OF FACT AND CONCLUSIONS
INTRODUCTION:

The Sokaogon Chippewa Community of Wisconsin, the Red Cliff Band


of Lake Superior Chippewa Indians of Wisconsin and the Lac Courte
Oreilles Band of Lake Superior Chippewa Indians of Wisconsin
(Collectively referred to as the "Tribes*) have entered into an
agreement with the current owners (Croixland Properties Limited
Partnership or 'Croixland') of the St. Croix Meadow Greyhound
Park located in the City of Hudson, Wisconsin, to purchase the
The Tribes have requested
assets of the pari-mutual dog track.
that the land currently comprising St. Croix Meadows, as well as
land immediately surrounding the dog track (totaling
approximately 55 acres), be placed into trust. The stated
purpose of the acquisition is to begin Class III gaming at the
2,000 slot machines and
facility with the introduction of 1,500
40 blackjack tables.
30
Section 2719 of the Indian Gaming Regulatory Act, 25 U.S.C. SS
2701-2721 (1988) states, in part, that lands can be acquired for.
gaming only if "the Secretary, after consultation with the Indian
Tribe and appropriate State and local officials, including
officials of other nearby 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..." 25 U.S.C. 5 2719
(b)(1) (A).
The following is the Minneapolis Area Office's
analysis and recommendations of the Tribes application under this
section.
I.
A.

BEST INTEREST OF THE TRIBES

GROSS AND NET INCOME TO THE TRIBES:

Two separate market studies were prepared regarding this


proposal.
One by Arthur Andersen & Co. (AA) (Tab 3)' which used
the "comparative market analysis approach" to estimate the Hudson
market potential, and one by James M. Murray, PhD. (Tab 4) which
used the gravity model and Reilly's Law of Retail Gravitation to
establish the sphere of influence of the Hudson facility both
currently and as projected. Although the specific findings of
the two reports do differ significantly in some respects, we will
incorporate both reports into our analysis.
The AA Study estimates the total market gaming revenues in the
primary market of Minneapolis/St. Paul to be between $550
$630
Unless otherwise stated, the tabs are located in Volume I.
EOP 064509

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

in amount of gross income


of expenses expected to be
in the first
year (See Table 1 of.combined the two reports to
and a worst case scenario.

Dr. Murphy does not give a breakdown of the expected expenses


since his report focuses more on the overall impact to the Tribes
and surrounding community from the spending of the net proceeds.
Nevertheless, we feel it is important to include this information
since it substantiates the Tribes position.
If you combine Dr. Murphy's total expenses ($73 million) with
AA's estimated Total Revenues ($88,367,000), the Tribes would net
approximately $3.84 million each (15,367,00 multiplied by 25).
This number represents the worst case scenario under a
combination of the two studies.
The best case scenario under a combination of the two studies is
a Net Revenue of approximately $46.6 million ($104.10 million in
Gross Revenue under Dr. Murphy's study minus $57.45 million in
total expenses in AA's study) to be divided equally among the
three Tribes and current owner. Under this scenario each Tribe
would receive $11.65 million in the first year of operation.
We find that due to the sheer size of the market of the urban
area, the Tribes would en)oy a financial benefit well beyond any
financial benefits generated from reservation located casinos.
Also, an urban location would be more likely to produce a
relatively stable annual cash flow for the Tribes. It would also

EOP 064510

3166
Table 1

COMPARISON OF THE MARKET STUDIES


Revenues:
Casino
Dog Track
Food & Beverage
Total Gross Revenues:

FOR TEE FIRST YTEAROF OPERATION

Arthur Andersen:

Dr. James Murray:

$70,000,000
11,367,000
7,000,000
88r367,000

104,100,000

Expenses:
Casino

20,300,000

Dog Track

7,131,000

Food & Beverage

5,600,000

G&A, Marketing, Sec, Property

17,673,000

Operating Expenses

60,000,000

Depreciation

3,111,000

Interest

3,641,000

Debt Service per Year


Total Expense.L

PROJECTED NET INCOME:

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

can use to fur-her

Self-Determination and economic independence.


B.

PROJECTIONS OF MANAGEMENT AND TRIBAL EXPENSES:

For the first


five to seven years the Hudson Venture will be
operated by the three Tribal Economic Development Commissions

and

Galaxy Gaming pursuant to the terms of the Joint Operating


Agreement (Tab 7D, page 11, S 3.1)
We informed the Tribes that
we view this agreement as a management agreement subject to
approval by the National Indian Gaming Commission.
The National
Indian Gaming Commission concurred verbally in our determination.
The Tribes have submitted the Joint Operating Agreement and the
collateral agreements to NIGC for approval.
Under the Joint Operating Agreement, the "Business Board" will
have general oversight and authority over the operation.
It will
be composed of eight persons:
two Galaxy Gaming representatives
and two representatives from each of the three Tribes (Tab 7D,
page 4, 5 2.7). The primary management officials include any
person with the authority to hire and fire employees and any
person with the authority to set working policy (Tab 7D, page 10,
5 2.31)
The Business Board will unanimously select four of the
primary management officials. They include the Chief Executive
Officer, General Manager, Chief Financial Officer and the Human *
Resource Director Id
The Chief Executive Officer will be a member of the Business
Board.
This position will be unanimously selected by the
Business Board and will be granted the power and authority to
oversee the daily business affairs and operations of the
Enterprise (Tab 7D, page 5, S 2.9). The CEO is required to
report to the Business Board and under the Joint Operating
Agreement, will not be able to undermine the Boards authority.
Thus, even though the CEO must be a Galaxy Gaming Representative
as long as the Financing Debt remains outstanding, the three
Tribes will have substantial control of the operation (Tab 7D,
page 16, 5 5.1).
The
Each Tribe will also select their own Tribal Inspector.
three Tribal Inspectors will have full access to all aspects of
the Enterprise (Tab 7D, page 20, S 5.6.3).
Under the Joint Operating Agreement, each Tribe is guaranteed a
minimum monthly payment of 566,667.67 from the net revenues.
Galaxy Gaming will then receive the next $66,667.67 for that
month. Anything over $266,667.67 for any particular month will
be distributed equally between the three Tribes and Galaxy Gaming
(Tab 7D, 5 2.26 and 5 7.1). Galaxy will be entitled to a 25%
share in the net revenues for the first seven years of operation
with the Tribes maintaining the authority to "buy-out" all of
Galaxy's rights in the agreement after the completion of the
4

EOP 064512

3168
fifth full year of the operation (Tab 7D,

page 41, 5 24)

The Joint Operating Agreement requires Galaxy to loan' the


Enterprise the amount necessary to fully pay the Tribe for any
yearly shortfall of the guaranteed payments (Tab 7D, page 8. 5
However, the market studies indicate that loans will not
2.26)
be necessary to fulfill this minimum monthly obligation.
1.

Assumed Liabilities and Nonrecourse Liability:

The Economic Development Commissions (EDCs) of the Tribes have


agreed to purchase the St. Croix Meadows real property for
The assets necessary to run the operation (the building
$10.00.
and improvements constructed on the land) will also be
transferred to the EDCs subject to certain obligations of the
seller. Under the Asset Purchase Agreement, the obligations will
be paid as operating expenses and are referred to as the
They include the
"Nonrecourse Liability, (Tab 7, pages 6 & 7).
debt owed to First Union National Bank of Florida (principal of
$37,900,000 plus certain accrued interest arrearage which has
been or will be capitalized) and the debt owed to the First
National Bank of Hudson (Principal in the amount of $1,230,000).
Although the agreement provides no limitation on the amount of
interest that the Tribes will eventually pay, it does state that
"in no event shall the aggregate principal amount of the
Nonrecourse Liability exceed $39,200,000* (Tab 7, page 7).
The EDCs have also agreed to take the assets subject to certain
"Assumed Liabilities" (Tab 7, pages 7 & 8) . They include the
following:
(a)
(b)
(c)
(d)

Real property lease obligations;


Personal property lease obligations;
Obligations under contracts and licenses;
Deposits held by seller under the real property
and personal property leases.

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.

of the Parking Lot Land

(Tab 7E,

page

7,

Article

Joint Venture Agreamant of Meadows Parking Lot Joint


Venture:

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.

Agremnt for Governmant Services

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

pay the City and County


The Tribes have agreed to initially
The payments will be paid on a
$1,150,000 for the services 1d.
The first
semi-annual basis beginning on January 31, 1995.

payment will be pro-rated from the date the land is actually


accepted into trust.
Beginning in

1999,

the Tribes will begin paying the City and

County an amount equal to the allocable amount for the preceding


year ($1,150,000 in 1998 with no adjustments) multiplied by 1.05
(Tab 9, page 3) . The following table provides a comparison of
the amount the Tribes will initially pay the city and county and
the future value of $1,150,000:
ALLOCABLE AMOUNT PROJECTIONS

ana

Actual Amount Owed:

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

As the above chart indicates, the yearly 1.05 increase in the


payment by the Tribes to the City and County for services is
reasonable.
The Office of the Field Solicitor, Twin Cities, has
also indicated the Government Services Agreement is an agreement
in which the Tribes may participate (Volume II, Tab 2, page 3).
Thus, we find this agreement acceptable.
The Agreement for Government Services states that "any real
estate taxes and assessments and personal property taxes paid
with respect to the Non-Trust Property with respect to any
calendar year shall be treated as a credit against the payment by
the Tribes of the Allocable Amount (as adjusted) for such
I

Formula Used to determine the future value:

For Column A:
For Column B:

Annual Interest Rate is


Annual Interest Rate is

7.9% for 1 period a year.


7.9% for 2 periods a year.

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:

This lease agreement is between Croixland Properties Limited


Partnership and the Tribe's EDCs.
The Asset Purchase Agreement
provides that the land will be leased to the Tribe'c EDCs at the
same time the conveyance of the Assets' takes place and
immediately prior to the conveyance of the land (Tab 7, page 3 5
1.01(a)).
The Asset Purchase Agreement then calls for the land
and the Croixland's interest in the Ground Lease to be conveyed
to the Tribes j4
Thus, the Tribes will become the landlord and
the EDC's the tenants under the terms of the Ground Lease.
Initially, we had concern over the language in Article I, Section
1.03(d) of the Ground Lease and Article II, Section 2.01 of Asset
Purchase Agreement since it appeared as if these agreements
required the United States to become the landlord and a party to
the Ground Lease.
We informed the Tribes that this type of
arrangement is not acceptable.
As a result, the Tribes and
Croixland amended the requisite sections to make clear that the
United States, as trustee for the Tribes, will not be assigned or
conveyed the landlord's interest in the Ground Lease or have any
obligations or responsibilities under its terms (Tab 7,
Amendments) . We are satisfied that the Ground Lease is now only
between the Tribes (as the assignee of the Seller), as landlord,
and the EDCs, as tenant.
The Ground Lease is for 25 years and may be extended by the EDCs
for an additional 25 year term (Tab 7C, page 1) . All rent is
payable directly to the Tribes.
The EDCs will be required to pay
4 We note that the land is
of the agreements.

not defined as an *Asset'

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:

The Joint Operating Agreement is between the Tribe's EDCs and


This agreement
Galaxy Gaming and Racing Limited Partnership.
also provides that Galaxy Gaming will assist the Business Board
in securing financing to the EDCs for the funds necessary to
renovate and remodel the existing dog track facility and to begin
operation. Galaxy guarantees the obtainment of this financing
(Tab 7D, page 2, 5 1.6).
To fund renovation of the third floor of the existing building,
an "Activities Loan" (Tab 7D, page 3, 5 2.1) will be made by a
third-party lender to the EDCs and Galaxy Gaming and Racing
Limited Partnership in an amount of up to $10,000,000 (any amount
over $5,000,000 must be approved unanimously by the Business
Board).
This money will be usdd for costs, expenses and
expenditures set forth in the Renovation Budget, for initial
working capital as needed and for payments of expenditures
necessary to 'protect and keep perfected the Activities Loan."
C.

BASIS FOR PROJECTIONS AND COMPARISONSt

The Proposed facility will be located at 2200 Carmichael Road in


Hudson, Wisconsin. The site is approximately one mile south of
the Carmichael Road/Interstate 94 interchange in a rural area in
the southeast corner of Hudson.
The existing grandstand building
of the greyhound track has three floors with over 160,000 square
feet of space.
The property includes parking for approximately
4,000 vehicles.
9
EOP 064517

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.

PROJECTED TRIBAL EMPLOYMENT:

The Tribes have stated they plan to "actively recruit Native


For employees
American candidates for positions at all levels.,
at the Hudson Venture, a hiring preference will be given in the
first, to members of the three Tribes and
following manner:
their spouses and children, second, to other Tribal members and
third, to local residents from communities surrounding Hudson
(Tab 7D,

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.

BASIS FOR PROJECTING THE INCREASE IN TRIBAL EMPLOYMENT:

When we assume the figures provided by Dr. Murphy are accurate,


the impact of a total of 450 new jobs on the reservations will
The
have a substantial beneficial impact on tribal unemployment.
following figures provided by the three Tribes bolster this
contention

(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.

PROJECTED BENEFITS FROM TOURISMr

As with any project of this nature, the success of the Tribe's


proposed facility will depend on the volume of people/visitors
who come to gamble at the Tribe's proposed facility. Based on
the Market Analysis prepared by Dr. Murray, the Tribes estimates
that 3,184,330 people will visit

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

PROJECTED BENEFITS TO TEE TRIBAL COMMUNITIES FROM THE


INCREASE IN TRIBAL INCOME:

The Tribes contend that substantial benefits would accrue to


their Tribal members and surrounding communities.
Specifically,
(Tab 1, page 7):
they show the following benefits will result
*

The creation of. approximately 150 new jobs on each


reservation.

The employment will generate an annual average of about $3


million per Tribe in added earnings for these employees.

A total of over $11 million in additional earnings and 600


additional jobs will be created as a recirculation of the
gaming revenue.

The proceeds will be applied to health,

education,

scholarship funds, housing, elderly care, early child care,


land purchases and other community support services and as
The Tribes expect that a substantial
per-capita payments.
increase in the quality of life will be directly experienced
by all members.

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.

-This is true in part because they are


urban markets than other tribes in
The Hudson proposal will help remedy
these Tribes with access to a urban

As we have already indicated, the Tribes have relatively small


populations and land holdings.
Thus, the proposal is expected to
have a significant positive impact.
However, the positive impact
is not expected to be employment in the proposed facility, but
from the spending of the income by the Tribes on their respective
reservations.
I.

PROJECTED BENEFITS TO THE RELATIONSHIP BETWEEN TEE TRIBES


AND SURROUNDING COMMUNITY:

The Tribes anticipate that between 80 and 90 percent of the 1600


employees will be from the non-Indian surrounding community (Tab
5, Page S-2).
The Tribes are also committed to providing funding
for the increased infrastructure costs to the City of Hudson (Tab
1, page 12) . This indicates the Tribes willingness to cooperate
with the surrounding community as well as the local governments.
Once the Casino goes into operation and begins generating income
for the community, we anticipate an improvement in the
relationship between those persons now opposed to the Hudson
Venture, casino management, and the three Tribes.
J.

POSSIBLE ADVERSE IMPACTS ON THE TRIBES AND PLANS FOR DEALING

WITH TEOSE IMPACTS:

The Tribes have stated that they do not anticipate any adverse
impacts as a result of this proposal.

The Minneapolis Area Office recognizes possible conflict between


some members of the local community and the proposed management
of the Hudson Venture.
In fact, a member of the local Hudson
community has formed her own activist group to oppose the Casino.
The group has submitted a petition in opposition to the Venture
and claims to have collected over 3,000 signatures.
Please note,
the petition was submitted after the City of Hudson, County of
St. Croix and the School District of Hudson, held public
hearings, made findings and submitted their own comments on the
proposal.
Thus, we have only provided cursory review of the
petition. We have not determined whether all the people who
signed the petition are registered voters in the State of
Wisconsin or Minnesota.
Since the group has not provided any
additional specific substantive reasons as to why the Hudson
Venture should not be approved, other than those already

addressed, we have informed the local activist group that the


petitions should be directed to the Governor of Wisconsin.
Nevertheless, we do not regard the possibility of friction
13
EOP 064521

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.

NOT DETRIMENTAL TO THE

SURROUNDING

COMMUNITY

CONSULTATION:

To satisfy the consultation required by Section 20 of the Indian


Gaming Regulatory Act, 25 U.S.C. 5 2719 (1988), the Bureau of
Indian Affairs, Minneapolis Area Office, consulted with State and
local government officials and nearby tribes on the impacts of
the gaming operation to the surrounding community (Volume III).
The Bureau's consultation process consisted of letters to local
government officials, including the applicant Tribe, seeking
responses to several suggested areas of discussion for an
analysis of the "best interest of the tribe and its members" and
"not detrimental to the surrounding community" determination 10
1.

Consultation with the Governor of the State of Wisconsins

There has been no consultation with the Governor of Wisconsin by


the Minneapolis Area Office or the Great Lakes Agency since it is
not required by the Indian Gaming Regulatory Act until the
Secretary makes favorable findings.
2.

Consultation with the City of Hudson:

(a) Mayor: The Mayor of the City of Hudson, Thomas H. Redner,


responded to our request for input by providing detailed material
addressing possible impacts on the environmental, social
structure, infrastructure, land use patterns, income and
employment, the possible need for additional services and
compulsive gamblers programs. The Mayor stated in his cover
letter, 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, (Volume III, Tab 1).
(b) Common Council: The Common Council of the City of Hudson
adopted a resolution with a stated purpose of protecting the
"city's interest in the event the transfer takes place."
The
Council only sought to protect the City's financial interest and
did not take a position on the proposal (Volume III, Tab 1, page
12).
(c) School Districts The School District of Hudson provided
considerable correspondence on the proposal (Volume III, Tab 4).
Their primary concern was insuring that the tax revenue that
would be lost after the land was placed into trust be replaced.
To accomplish this, the School District passed a resolution to
protect their financial interests (Volume III, Tab 4).
However,
the resolution did not approve or disapprove the purpose of the
proposal. An agreement between the City, County and Tribes was
15
EOP 064523

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.

Consultation with the County of St. Croix:

The County Board Office of St. Croix County, Wisconsin also


Tab 2).
On
provided correspondence on the proposal (Volume III,
March 13, 1994, prior to the signing of the "Agreement for
Government Services', they wrote to the Governor to advise him
that significant back real estate taxes are owed on St. Croix
Tab 2, page 8) . The Board requested that
Meadows (Volume III,
the Governor not approve any agreement in relation to the
has received payment of all real estate
until
the
county
proposal
taxes, penalties, and interest due and unpaid on the St. Croix
Meadows dog track property. They also noted strong public
opposition to the proposal. However, after the signing of the
agreement, the Board showed their support of the proposal by
criticizing the Hudson School District in their call for in-depth
No
investigations by the Governor (Volume III, Tab 2, page 10).
mention was made of the public opposition. This indicates that
the Board fully supports the proposal.
The St. Croix County Board Office also prepared an "Impact
Assessment" of the proposed gaming establishment (Volume III, Tab
It focused on the impact of the proposal to the
2, page 1)
County as a whole, including the City specifically. The
assessment was prepared by the County Planning Department Staff
and reviewed by the Chairman, Richard Peterson. Although each of
the seven subject matters were addressed, Mr. Peterson stated in
the cover letter that the County could not conclusively make any
findings on whether or not the proposed gaming establishment will
be detrimental to the surrounding community. We note that this
assessment was completed prior to the signing of the Agreement
for Government Services.
4.

Consultation with the Town of Troy:

The Town of Troy provided their response to our consultation


The town had
Tab 3).
letter on March 14, 1994 (Volume III,
several areas of concern dealing with, increased traffic, lowered
standard of living, limited housing, and the possible additional
cost services.
16
EOP 064524

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.

General Public Response:

(a) Public opopition; Approximately 76 letters', written by


people in the Hudson community, were sent to the Department of
the Interior expressing opposition to the proposal.
Their
arguments against approval of this proposal are based primarily
on social concerns, i.e. concern over increased crime; concern
over the impact of gaming on the children in the area; concern
over the projected increased traffic; concern over a possible
increased cost to the city; possible increased cost to the social
programs that problem gamblers would cause; concern over
organized crime; and general concern over the diminishment of the
aesthetical values to the city. The people against this proposal
also cited the referendum of April 1993, to show that a majority
of people were against the expansion of gambling in Wisconsin.
Many stated that the market is already saturated and that the dog
track was a failure so the Casino will be too. As a result, it
is only serving as a "bailout, for the current owners of the St.
Croix Meadows. Many people stated that Hudson is fine
economically without the casino and does not need the low paying
jobs that would be created.
A few people were morally opposed to
the idea of gambling.
Approximately 3,100 people signed a petition expressing
opposition to the proposal.
We have not verified the legitimacy
of the signatures. Nor have we determined how may people who
signed the petition are registered voters in Hudson.
It is our
determination that these petitions should be directed to the
Governor of the State of Wisconsin.
A thorough report was sent in by one member of the Hudson
community to provide evidence to form a basis to reject the
application. However, each of the issues raised in the report
These letters are attached.
17
EOP 064525

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.

(b) Public Support: One letter, written by Wisconsin State


Legislature, Doni Burns, was sent expressing support for the
proposal. He stated that the majority of people in Hudson were
in support of this proposal.
To support his position he referred
to a referendum passed in 1992 in regard to the possibility of a
casino at St. Croix Meadows.
The referendum voted on in 1992 asked the following question:'
Do you support the Transfer of St. Croix Meadows to an
Indian Tribe and the conduct of casino gaming at St. Croix
Meadows if the Tribe is required to meet all financial
commitments of Croixland Properties Limited Partnership
to the City of Hudson?
Results:

1,351 people voted "yes".


1,288 voted "no" (48.8%)

(51.2t),

The survey results were provided by the City of Hudson and


referred to in a number of the responses by people in favor as
well as people opposed to the casino.
This referendum differs from the April
in that it
is site specific.
The 1993

1993 statewide referendum


statewide referendum

(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:

6,328 voted "yes"


3,352 voted "no'

(65.4%)
(34.6%)

While the Hudson Proposal may be an expansion of a type of gaming


in Hudson, it will not be an expansion of a gaming facility.
Additionally, since the Tribes have agreed to a limited number of
Class III facilities with the State of Wisconsin, it will also
not be an expansion of gaming in Wisconsin.
It may also be
argued (indeed, the Tribes have done so) that this is not an
expansion of gaming even in Hudson since the building is already
' The question and results where obtained from the City of
Hudson (Volume III,
Tab 1, page 11)
18

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.

Consultation with Neighboring Tribes:

18 Tribes in the State of Minnesota and Wisconsin were informed


We requested that
of the proposal (Volume III, Tabs 5 - 16).
these Tribes provide input on the impact the proposal would have
on their respective reservations by letter, all dated December
Nine of the eleven responses that we received were
30, 1993.
emphatically against the proposed Hudson project. However, none
of the Tribes that responded provided reliable or scientific data
to support their views. The following are the Tribes and Tribal
Organizations that responded as a result of our inquires and a
summation of their comments and our response:
(a) St. Croix Band of Chinewa Indians of Wisconsin:
St. Croix
is strongly opposed to the project (Volume III, Tab 12).
They
stated, *the proposed Hudson fee to trust acquisition will have
an extreme detrimental and crippling impact on the St. Croix
Casino located in Turtle Lake, Wisconsin.'
They supported this
position by providing a detailed response to the seven questions
and an Impact Statement. This material focused heavily on the
probable loss of revenue at the Tribe's Turtle Lake Casino.
The
St. Croix Tribe stated that the Hudson proposal would cut into
the revenue generated at their Turtle Lake Casino because the
Hudson proposal is larger, in a better location and has a better
highway system. St. Croix also stated that the gaming market is
already saturated and as a result, they would have to increase
marketing expenditures just to survive and would lose current
qualified employees to the Hudson project. The Tribe did not
provide any data to support their position.
St. Croix provided a casino density illustration to show that
"the market is becoming saturated-.
However, they did not
provide any financial studies to back up this or any other claim
dealing with a loss of income.
We question St. Croix's opposition to this project since
initially, they were the first Tribe to consider purchasing the
St. Croix Meadows Dog Track for gaming purposes. We also find
that their economic position is overstated since they have two
19
EOP 064527

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.

2) This proposal could damage the national efforts to


protect gaming and could have severe political ramifications
in Minnesota. They did not elaborate or provide any
scientific information to support this claim.
The proposal could cause the State of Minnesota to open
3)
up gaming around the State thereby diminishing the
The Tribe has
beneficial economic impact of Indian Gaming.
not provided any legal justification to show why gaming
should not be expanded by Wisconsin Tribes in Wisconsin.
The market is at or very near the saturation point and
4)
cannot absorb another casino in the Twin Cities area without
having a negative impact on jobs. A market study has not
been provided by the Shakopee Mdewakanton.
5) The proposal could damage the current cooperative
government to government relationship between the State of
The Tribe has yet to explain how
Minnesota and the Tribes.
this will happen.
The Prairie Island Dakota.
(a) Prairie Island Dakota Communitv
Community passed a resolution voicing their opposition to the
proposal (Volume III, Tab 10) . They stated that the Hudson
Casino would "saturate the already extremely competitive
In addition, the Tribe
Minneapolis-St. Paul market area."
contends that they would not be able to compete due to the
Specifically, the Tribe
advantages the Hudson site offers.
stated that they would suffer a severe loss of revenue (they
estimate a 30%-50% reduction in customers) due to the following
reasons: the proximity of Hudson to the metro area, the proximity
of the proposed casino to an interstate highway and because the
dog track is already an existing "first-class facility".
(f) Lower Sincx Comunityj The Lower Sioux Community did not
However, the Chairman
pass a resolution opposing the proposal.
did write a letter indicating his opposition (Volume III, Tab 7).
He stated that the Lower Sioux Community would be severely and
He also indicated that the
unfairly damaged economically.
Community would be damaged politically since all of the Minnesota
Tribes have not sought to locate a gaming establishment away from
the reservations and to do so would cause a region-wide and
No
probably a nation-wide race by other Tribes to do the same.
data was provided to validate his arguments.
(a) Minnesota Chippewa Tribe,
The Minnesota Chippewa Tribe
passed a resolution opposing the Hudson Project (Volume III, Tab
14).
They stated this proposal could set a dangerous precedent
by creating an open market for expansion by other Tribes.
21
EOP 064529

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.

(W) Minnesota Indian Gammpq Association: The Minnesota Indian


Gaming Association passed a resolution and wrote a number of
letters expressing their opposition to the Hudson Proposal
(Volume III, Tab IS). They stated that since Minnesota Tribes
oppose off-reservation gaming activity and have promised not to
expand tribal gaming off-reservation, the Hudson proposal is an
infringement upon their own inherent sovereign rights.
In
addition, the following reasons were given for their opposition:
1) Other gaming Tribes would suffer economically due to the
Hudson proposal's close proximity to the metro area.
In
particular, the more remote casinos would be hurt.
2) The St. Croix area has historically been considered to
be Dakota land.
Findings: This issue will be addressed in
the actual transferring of the land into trust pursuant to
25 C.F.R. Part 151.
The objections identified in the
Preliminary Title Opinion, if any, will have to be satisfied
before the land may be transferred.
3) An off-reservation expansion of this magnitude would
The
create huge political problems for Minnesota Tribes.
Minnesota Indian Gaming Association stated that State
Legislators have been under political pressure from private
businesses who want to expand gaming by placing video games
in bars among other things. They also stated that they have
fought hard to keep this from happening and the this
proposal would jeopardize what they have fought to maintain.
MIGA also argues that the National Governors Association and
other adversaries have been stating that tribes would expand
gaming off-reservation into major cities in direct
MIGA does not want
competition with non-Indian businesses.
them to be proven right.
(1) Lac du ?lambeau
Lac du Flambeau Band
project (Volume III,
experience in gaming

Band of Lake Superior Chippewa Indians; The


stated that they do not oppose the Hudson
Tab 1) . They also stated that their
indicates that there would be a beneficial
22
EOP 064530

3186
impact.

(k) Oneida Tribe of Indians of wisconsit: The Oneida Tribe


stated that since they are located 250 miles away from Hudson,
Wisconsin, they are not in a position to offer detailed comments
or analysis on the impacts of the proposal (Volume III, Tab 9).
They did state that they do not perceive that there would be any
serious detrimental impacts on their reservation or gaming
operations.
B.

IMPACT ON NEARBY TRIBES:

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

Estimated per capita gaming revenue.... $145 - $165

We also note that the Hole in the Wall Casino in Danbury,


Wisconsin, was not included in figuring the total estimated market
revenue.
23
EOP 064531

3187
Mystic Lake,

Turtle Lake and Treasure Island Casinos.

The

Tribes

did not respond in writing.


Their representative, Bill Cadotte,
did state that there is no legal basis to reject the proposal
based on what the potential political ramifications *might" be.
We concur.
Specifically, we find that additional market studies
cannot be completed by the three Tribes without financial data
supplied by the three casinos in question.
2.

Political:

A number of Tribes and commentators have indicated that expansion


of off-reservation gaming erodes their political power and will
eventually undermine their ability to limit States from expanding
gaming.
However, it can be argued that each new gaming
operation, whether or not on land placed into trust prior to
October 17, 1988, erodes Tribal political power to protect the
gaming industry.
We find that the Tribal Sovereignty of the Lac
Court Oreilles, Red Cliff, and Sokaogon Tribes is far more
important than limiting the expansion of Tribal Gaming.
In fact,
each Tribe currently operating gaming facilities went into the
industry knowing that expansion into major metropolitan areas was
a possibility and maybe even likely. We find that it is up to
each individual Tribe to operate within the limits of the Indian
Gaming Regulatory Act, their Class III Gaming Compacts and theirexisting governing documents.
The Minneapolis Area Office willnot restrict Lac Courte Oreilles's, Red Cliff's, Sokaogon's or
any other Tribe from operating within these limits and find that
any negative political ramifications from this proposal would be
minimal.
C.

EVIDENCE OF ENVIRONMENTAL
ADVERSE IMPACTS:

IMPACTS

AND PLANS

FOR REDUCING ANY

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

An "Environmental Assessment for St. Croix Meadows Greyhound


Racing Park, Hudson, Wisconsin, January 1988" was prepared by
24
EOP 064532

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.

Natural and Cultural Resources:

The addendum to the Environmental Assessment states that the


proposed facility will have no new significant short-term, longterm, or cumulative impacts on the regional geology, including
bedrock and soils, ground water/water quality, or climate (Volume
IV, Tab 3).
The Addendum also states that the facility is not expected to
impact any natural areas such as native trees or wildlife
habitat. Additionally, there are no anticipated impacts from the
planned action on wetlands or other surface waters in the area.
According to the National Wetlands Inventory Map for the site,
there are no designated wetland areas located on the site. No
rare plant or animal species or other significant natural feature
will be adversely impacted.
(a)
Land Resources,
The topography of St. Croix County ranges
from gently rolling to hilly and rough (Volume IV, Tab 4, pages 3
& 4).
All of the county has been covered by continental
glaciation. The St. Croix River has also had a major impact on
the topography of the area.
The St. Croix River is bounded by
100' - 200' bluffs along its eastern shore.
The Hudson Casino
Venture would be located on the plateau above these river bluffs.
The site where the proposed facility would be located and the
25
EOP 064533

3189
immediate area surrounding the site is
elevation of 840 feet'

with an average

*mostly gently rolling


LL

The site surrounding the facility is a combination of many soils.


Pillot silt
loam is the most common 14
The slope of this soil
is 0 to 3 percent so runoff is slow and there is slight hazard of
erosion.
Most of the remaining soil at the site is BurkhardtSattre complex of differing slopes.
Since most areas of the
Burkhardt-Sattre complex are cultivated, there is no identified
erosion or soil blowing problem.
Since the planned action will utilize the existing racetrack
facilities, there will be no significant impact on prime or
unique farmlands in the Farmland Protection Policy Act (Volume
IV, Tab 3, page 3).
(b) water Resources:
The Hudson area has an abundance of
groundwater.
All potable water used in St. Croix County is
groundwater.
The supply of water is presently determined by the
ability to pump it out of the ground.
The source of the
groundwater is precipitation (Volume IV, Tab 4, page 3).
The Hudson area surface waters occupy two major drainage systems.
The St. Croix River drains the western two-thirds of St. Croix
County.
The balance of the county is mostly drained by the
Chippewa River which flows into the Mississippi River I.
The St. Croix River is located approximately 4800 feet to the
west of the proposed facility.
There are no other existing
surface water bodies in the EA study area Id.
(c) Air Quality: Both the City of Hudson and St. Croix County
have stated that the projected traffic increase will not cause
the air quality to exceed applicable standards (Volume III, Tab
1, page 1 and Volume III, Tab 2, page 2).
Air monitoring
stations are currently in place at the track exit and the
southeast corner of the Carmichael Interchange to detect any
change in the air quality which could be harmful to the area 14.
(d)
Threatened azd Radangered Species. St. Croix County is
listed as a habitat for the following three endangered or
threatened species (Volume IV, Tab 4, page 4):
(1) Peregrine Falcon - Potential breeding habitat; Endangered.
(2) Bald Eagle - Breeding and wintering habitat; Threatened.
(3) Higgins' Eye Pearly Mussel - River habitat; Endangered.
According to the EA, site visits in 1988 to the area around the
proposed facility did not detect any of these species
The
development site may serve as a habitat for the Peregrine Falcon
and Bald Eagle.
However, none have yet been located.
Additionally, there is no habitat for the Higgins' Eye Pearly

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.

IMPACTS ON TER SOCIAL STRUCTURE IN TEU COMMUNITY:

Concern over an increase in crime has been expressed by most of


However,
those people who wrote to oppose the Hudson Venture.
none of the letters contained any scientific or statistical
evidence to back up this claim. The City of Hudson has stated
that similar predictions were made in regard to the St. Croix
The
Meadows dog track before it went into operation in 1990.
City stated, to date, "none of the earlier negative predictions
concerning increased crime, etc., have come true..." (Volume III,
To prevent any crime escalation in the City of
Tab 1, page 2).
Hudson, and to help offset any fear among the community, the City
has stated that they will hire an additional Investigator Crime
Prevention office in the year the Casino is opened (Volume III,
Tab 1, page 4).
The City also expects the Police Department to
expand the police force by five officers and one clerical
employee within the next five years 1.
Additionally, the Tribes
have stated that they are committed to paying for the reasonable
costs of these services (Volume I, Tab 1, page 12).
The City stated that the residents of the community have come to
accept the dog track's existence and that there is no
overwhelming majority of citizens either in favor of or opposed
to the casino (Volume III, Tab 1, page 2) . Nevertheless, the
city is prepared to handle any negative reaction by the community
over the casino.
a.

IMPACT ON TEE IFRASTRUCTURZs

1.

Utilities$

The current facility is supplied by existing public water,


sanitary sewer, electric, and telephone utilities. No additional
infrastructure is scheduled to be constructed as part of the
proposed action.
27
EOP 064535

3191
2.

ZoningI

According to the City of Hudson, most of the proposed trust site


is zoned general commercial district (B-2) for the principal
structure and ancillary track, kennel and parking facilities
Six acres of the proposed trust
(Volume III, Tab 1, page 4).
The east,
site are currently zoned single family residence 1.d
south and westerly perimeters are classified as on-family
residential districts (R-1) and serve as a buffer area between
the track operation and other surrounding land uses 1d,
3.

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.

Sewer and Storm Drainage:

According to the Impact Assessment of the Proposed Casino on St.


Croix County which was prepared by the County, St. Croix County
anticipates an increase in waste generation from the proposed
casino (Volume III, Tab 2, page 1) . Currently, the St. Croix
This equals
Meadows generates .5 pounds per person IA
Based on the
approximately 104 tons of waste per year.
anticipated average daily attendance of 7,000 people, the
proposed casino would result in a production of 639 tons of waste
per year, an increase of 535 tons. The County has stated that
the waste-to-energy facility that services St. Croix County has
adequate capacity to handle the increase Id, To verify the
figures, the County compared their estimates to the St. Croix
That
Bingo and Casino gaming facility in Turtle Lake, Wisconsin.
facility averages .53 pounds per person or 677 tons per years.
An existing storm water collection system collects storm water
runoff and directs it towards a retention pond located near the
southwest corner of the parking area. From there, collected
storm water is allowed to evaporate, percolate into site ails, or
slowly flow along a regional storm water control system towards
According
the St. Croix River (Volume IV, Tab 4, pages 7 & 8).
to Hudson officials, the existing storm water control system is
adequate to handle storm water runoff from the site (Volume III,
Tab 1, page 3).
S.

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.

IMPACT ON THE LAND USE PATTERNs

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

ON INCOME AND EMPLOYMENT IN TEE COMKUNITY:

Total employment at the proposed facility is expected to be


between 1,500 and 1,600 positions. Current employment figures at
St. Croix meadows is approximately 175 full-time positions and
All
225 part-time positions (Volume III, Tab 2, page 4).
existing employees would be offered re-employment at their
current wage rates. Thus, between 1,100 and 1,200 new positions
are expected to be generated L.
Even though the three Tribes will give hiring preference to their
own tribal members, 80-90% of the new positions are expected to
be filled by non-Tribal members already living in the Hudson area
Id. Wage rates for these jobs are estimated at between $5 and
510 per hour, not including salaried positions 1d.
According to statistics provided by the St. Croix County, the
service industry accounts for 20 percent of the County's 1993
total labor force of 28,300 people. Since the casino is expected
to pull some employment from existing service jobs within the
county, County officials estimate that approximately 175 service
positions will be filled by currently unemployed County residents
either through direct employment at the casino or by other
service jobs LL
The remaining 900-102S positions are expected to be filled by
people from the nearby Wisconsin counties.
According the Economic Impact Report by Dr. James Murray, over 90
percent of the spending at the proposed Hudson Gaming Facility is
expected to originate from outside the state (Volume I, Tab 5,
page S-2). Dr. Murray estimates the total impact of the gaming
facility would be to support 2,691 jobs and generate over $56
million in annual earnings for residents of Wisconsin (Volume I,
Tab 5, page 12).
EOP 064538

3194
S.

ADDITIOKAL AND EXISTING SERVICES REQUIRED OR EMPACTS, COSTS


OF ADDITIONAL SERVICES TO BE SUPPLIED BY TEE COMWWITY AND
SOURCE OF RZVEDZ FOR DOING SOs

Additional services will be needed in the City of Hudson, County


of St. Croix and at the site of the Hudson Project. To assure
that all necessary services are provided, the three Tribes,
County of St. Croix and the City of Hudson have entered into an
Agreement for Government Services (Volume I, Tab 9).

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.

PROPOSED PROGRAMS, IF ANY,


SOURCE OF FUDNDIG:

FOR COMPULSIVE

GAMBLERS

AND

Currently, there is not a compulsive gamblers program within St..


Croix County. The County has indicated that if the Hudson
Project goes into operation, their Human Services Department
would initiate staff training and would develop treatment
programs, including initial on-site screening of potential
problem gamblers, treatment and aftercare services (Volume III,
Tab 2, page 5).
There are six State-Punded Compulsive Gambling Treatment Centers
in Minnesota (Volume II, Tab 7, page 38) . Two are in
Minneapolis. The other four are located in St. Cloud, Bemidji,
Granite Falls and Duluth. According to the Minnesota Council on
Compulsive Gambling, since 1984, limited funds have been
appropriated by the Minnesota Legislature for training, research,
gamblers' hot-line services, rehabilitation and public awareness
programs (Volume II, Tab 6, page 2).
Unfortunately, Minnesota
Planning has also found that current levels of treatment in
Minnesota are inadequate and that some treatment facilities
already have waiting lists while others are near capacity (Volume
II, Tab 7, page 37).
Since there are no Wisconsin state-funded treatment facilities
near Hudson, the three Tribes will address the compulsive and
problem gambling concerns by providing information at the casino
about the Wisconsin toll-free hot line for compulsive gamblers.
Additionally, the Tribes have stated they will contribute
money
to local self help programs for compulsive gamblers (Volume I,
Tab 1, page 12).
31

EOP 064539

3195
III.

RECOHMDDATIONS

Based upon the discussion and conclusions provided above, we


recommend that the Secretary of the Interior find that the
proposed action will be in the best interest of the Lac Courte
Oreilles, Red Cliff and Sokaogon Tribes and that it will not have
a detrimental effect on the surrounding community.
We also
recommend that the decision be made to take this particular
parcel into trust for the three Tribes for gaming purpose.
I attest that I have reviewed this transaction and the case file
is documented in compliance with all of the above stated
regulations and facts.
I further state that I will not accept
the property in trust until I have received satisfactory title
evidence in accordance with 25 C.F.R. Part 151.12.
ATTEST:

Area Director

Date

32

rOP 064-540

3196
TAKI

United States Deparunenl of the Interior

OFFICE OF TIF. SECRETARY


ae

C 2U240

JUL1 4 199

Exhibit 2

Honorable Rose M. Gurnoe


Tribal Chairperson
Red Cliff Band of Lake Superior Chippewas
P.O. Box 529
Dayfield, Wisconsin 54814
Honorable Alfred Trepania
Tribal Chairperson
Lac Courte Oreilles Band of Lake Superior
Chippewa Indians
Route 2. Box 2700
Hayward. Wisconsin 54843
Honorable Arlyn Ackley, Sr.
Tribal Chairman
Sokaogon Chippewa Community
Rout- I. Box 625
Crandon, Wisconsin 54520
Dear Ms. Gurnoe and Messrs. Trepania and Ackley:
On November IS, 1994, the Minneapolis Area Office of the Bureau of Indian Affairs (BIA)
transmitted the application of the Sokaogon Chippewa Community of Wisconsin, the Lac Courte
Oreilles Band of Lake Superior Chippewa Indians of Wisconsin, and the Red Cliff Band of Lake
Superior Chippewa Indians of Wisconsin (collectively referred to as the 'Tribes*) to place a 55acre parcel of land located in Hudson. Wisconsin, in trust for gaming purposes. The
Minneapolis Area Director recommended that the decision be made to take this particular parcel
into trust for the Tribes for gaming purposes. Following receipt of this recommendation and at

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

Tribes. This decision is final for the Department.


Sincerely,

Michael J. Anderson
Deputy Assistant Secretary - Indian Affairs
CC

Minneapolis Area Director


National Indian Gaming Commission

3199

6.5 o 2-

SOKAOGON CHIPPEWA COMMUNITY


MbiOLE LAKE BAND
RT. 1. BOX 62 5
CRANDON. WISCONSLN 54520-9635
(715) 478-26N4

Exhibit 3

Secretaryv Babbitt

Department of the Interior


Washington, D.C.

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

Document provided pursuant


to Congressional subpoena

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

Document provided pursuant


to Congressional subpoena

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
/ '-&

Dear Chairman Ackley.

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

Indians for Taming purposes.

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:

galashkibos, Lac Courte Orelles Band of Chippewa


Rose Gurnoc, Red Cliff Band of Lake Superior Chippewas

FrIIDAY 20, 1995


JANUARY

20.2 2AUAY2.19

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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:

Call from Lobbiest Pat O'Connor

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

Fat O'connor is a lobbyist that represents a number of gaming


He is also, I believe, a DNC
tribes in Wisconsin and Minnesota.
Ye is working on some off-reservation
trustee of so-e sort.
called "the Hudson Project,"
t.-:r
;=ar.; project (do; r ::, ;
which under the Indian Gat.t; ?e-latorv Act will need Secretary
Babb:t:'s approval to c: fcr--ari. s-nze it is off reservation
Pat called Loretta last week on this issue. As you know, last
year WR counsel advised Loretta that she should not meet -with
lobbyists or lawyers on Indian issues. Also, on April 29, the
President signed a memorandum stating his strong support for the
government-to-government relationship with the Tribes and direct
consultation (which they nold us to in every letter they send!
We get hit hard by Tribal leaders when we meet with Lobbyists,
since many times the tribal leaders are not even aware that the
lobbyists are calling us on their behalf. Loretta was out of town
when Pat called, but asked Jay and Katy Button on her staff to
return the calls from Pat. informng him that he needed to have
tne Tribal leader(s) that h represent send in whatever request
tha; they had, and that she would work with the leaders directly.
This is her standard response in these situations.
After several calls trying to get around Jay and Katy, on
Wednesday of last week Pat sent in a memo from him (not from the
Tribal leaders as requested) to Loretta asking to talk to her
about intervening with Secretary Babbitt to allow this Hudson
project to be able to do off-reservation gaming.
This fax also

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

stop telling others that he has access to the fH on 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.
Loretta consistently will not allow anyone take advantage of the
President's best intentions and put him into potentially negative
press situation (especially with 100 tribal leaders coming to town
on Friday) .

Loretta asks that you do whatever you think we need to do to take


care of the President's best interests on this -- these Indian
Gaming issues are always explosive (as the Cabazon situation made
clear) .
If you lave any questions on any of this, call Katy Button to get
ahold of 'Loretta in AZ, or call me at 6-5567 and I will try to

0
a

3254
give you

'hatever info you need.

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

To ensure we oon': cet caughL


This puts us in a Ca:ch-22
:ns
web, I treat al 550 elected tribal leaders :ne same (I
deal directly with them. on Dehalf of the President)
Narold, my goal is to clean up as much as I can clean up
(seven reservations in less than ten days) prior to the April
28th meeting. We are 981 there.
I do not want this situation to
be part of or anywhere near tne meeting on the 28th. This is a
EOP 069070

3256
Departmen: of Interior anc justice DepartmenL anC tna:

snerthat he would even sJOges:


would discuss anything remotelv connected to IncIar ga.-nC Le-.should stay.

Finally, the fact

is

not truly connected to :ndian country (al: 550 'ecea_


tribes know I con't do gaming anc say ::
Domestic Policy and Intergovernmental Affairs deal IC:s
issue in this manner.
me he

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 Bruce and he understands the way


him I would make the call directly to
called. I will do this as soon as my
call later and give you an update
:
for this kind of story. We don't nee:

to them.

One last concern leading into Friday, but I am working on


that now. Because of the diversity and complexities within
Indian Country and the constant changes in elected leadership,
there is no lobbyist or lawyer that I will put before my
responsibility to the President and his commitment to Indian
Country (April 29, 1994).
cc:

Maggie Williams
Cheryl mills

EOP 069071

3257

FADE1
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Exhibit 8

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57071OF01610061

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57 nEEt 15
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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,

t9E ITNS : Yemi


-- you everanswered
hePENTELOrTCH:
that a ti.
TEWITNESt:fast.
WLL.If he's in MiteLiS
W.V1ARA:
23

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

teat. Turn t ear 5 osthere.


T1EITOESS: em. all right
i
This15 1r. Kitto's Daytiaer from cur oeousition
testergary
les.
550120
to ReeLect.
DorIL
26. "NC.Comeltoes

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

Thereason I ask that is that Larry Kitto


for
Arit 26 have a reference to the DLC
-- the
A
$50.
.M-ti- to the
wM
raisino 1.0
5
ftor the 25 DedLe hecessr- for the Clintoi/are
a
I uas
JAst
wondering. we
6
7
might have written it doen n the wrong date.
B
11 tPE ELLIVITCH:
You knowI i" 'oId to
9
ODiectto the foa of that saestion Dease
I
1
thirt
tio
is hot a coMleteLy
celaotioMof Wat me'Kitto testified. Sag
11
12
cma fladMA& gami
13
5 eLL. h had
Most the 50.00 WA to the Ot
IA
A
he ad
15 0 Yeh. onthe M8th. AM I A uoneriho
if he eight
16
nose been on the
date
17 A
I wCwtot know
18 0 Youdon t hose my notes referriho to 50.in rand
19
for the DNCas Your htes for the 27th or the 25th.
3

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

Date May 23, 1995


Re:

Hudson fee to trust proposal

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

2 East Mlffl,, Street _-Suite 701

,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

TOTAL NUMBER OF PAGES


DATE:

April 23,

TO:

7
1997

IF YOU DO NOT RECEIVE ALL PAGES,


(612) 341-3800
POSSIBLE TO:
Client/Matter No.. -

PLEASE

CALL BACK AS

SOON AS

Transmission Ended:

David Mercer returned your call regarding you and


comMEHXs: Pat:
He wanted to know if 3:00 would be O.K. to meet
Larry.
which he thought
with Chairman Fowler at the D.N.C.,
would be after your meeting with Collier.
Please call him at:
202-544-0471 - Home
or 202-863-7105 - Office
NOTICE OF CONFIDENTIALITY
The information contained in and transmitted with this facsimile
is:
SUBJECT TO TE ATTORNEY-CLIENT PRIVILEGE;
1.
ATTORNEY WORK PRODUCT; or
2.
CONFIDENTIAL
3.
It is intended only for the individual or entity designated above.
You are hereby notified that any dissemination,
distribution,
copying, or use of or reliance upon the information contained in
and transmitted with this facsimile by or to anyone other than the
unauthorized and
recipient designated above by the sender is
If you receive this facsimile in error,
strictly prohibited.
please notify O'CONNOR 6 HANNAN by telephone at (612) 341-3800
immediately.. Any facsimile erroneously transmitted to you should
be immediately returned to the sender by U.S.
mail, or if
authorization is granted by the sender, destroyed.

OC 000050

3267
Exhibit I I

TO:

ACl Tnb-J -=i

FRONL

)oao WkC(aky

RE.

Met

wit Dmodc SadoWi Csnvr Se!C; WldmhiouseSudl,


da scs

EArrys Offi.Sc

Scm

WW'O~e elsutrwmus Ofe

ApW 21L99S

DATS.

P 9 -cmL Crmw Bay* oThcrayArla


0h
l been satrF AyAp~
216 at320piu. %,MML DamFo-lertbe beadadfthc~zm~cu~r ?o a-mim &rtop1-.L
WhImHoam Saf c
w, u p 1o-ml umif 6= Scsw Bob Xacrys' offi~c. So.= To.

sutu lor pocieoc am th Wxm= Dog


w -rm be ming
ithtrzocjI d~ow in WLI1AC=ILTM PW

The pcrpose of this nmcig is


Propo

ceate

i b vy awana

m pcde Ciam en co ;mcth job doaYow

We eve hopug thm c~ = C u mmayTtiAM Lm4o w

Thm

Trj Fcc toTw


WM am y
au these Folks-

o u pdb.

roo

DM~k Nuica' Cmmzc Of ko


43O Saj* Cipicu Sma SM!
WuhiumflDCr
3-Mpm Ape2 lUth
[fycm.b aqtaapma,;h
C211J130 C311 LAC MOt3(612) 123-4*23.

auky~lI 3S71

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77

Y.

oAIM
MO
Me YOUa AUl bA-o PUdaY.

RtL J. "mC-

Lk4JfNS 366

cmD rOIAl 0003

g.~lhl~flUI~l DC 3245324

3268

Minnesota

1995

III.

Legislative Update 117

Exhibit 12

April 24
page 2

HUDSON DOG TRACK UPDATE

On Friday April 18, a delegation of tribes from Minnesota


and Wisconsin met with DON FOWLER, CHAIRMAN OF THE
The purpose of the
DEMOCRATIC NATIONAL COMMITTEE (DNC).
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 fee-to-trust land transfer for the
Hudson Dog Track.
The message was quite simple:
all
of the
,people against this 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

)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

if necessary, would arrange a meeting with Tribal officials


and the White House, and that he would do this in a very
timely manner. They spent almost two hours educating the
DNC on the issue and felt

the meeting was both timely and

productive. Please Note: It was reported that.at.a-.


fundraiser in Madison, Wisconsin, last Thursday night, a
representative of Governor Thompson announced that the
Governor was looking for ways to make gaming more equitable
for ALL tribes in Wisconsin, not just a few.

K9000110

3270
TAYLCI.

15VI

balldt d a d ness.
ba-hfirst a-ty 5dr
ose.
ca
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Let

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Exhibit 13

17. 19

CM

ST COIx COJatT
-

COT
STATEP ISCONSIN CIRCUIT
.------------------

A,.

ha

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CV-til

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-------

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OPOMITIM
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15 Attacrena
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icatdty to awtor astsioh
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isetim K. MCrItta

58

-PAGE4
PAC 2

1 ca io 5 TIWsot tio 85e. s. Stats


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13

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i tteo
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e
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3275
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lorget
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-to
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a LmLte
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s teltotISta
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re ? tettu that to
1t 0l ler Inst
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ynn
o
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16
to rawno-ethat tlett
1 that t1-I -t.Yt I
0 In
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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
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cD lm
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he
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away o-to
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att
eY. st
l I
ale
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t
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m. e t
mts e setle eonr
78
7a
10

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m
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pr- tt
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1tt Wth
-1
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r - 1
ADidI

erier

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-t-

th

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23.un
23.a

tIs

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uldt

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Don

3276
PolE25

oo

y_

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tere

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o

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aft

270l10 t?0
t.
1,
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ever he
a ntmity
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tes s refaremhe Inhre.
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oe, avinto that hI

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0

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do
23
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t

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o ter
ho
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Ile
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ha talked

hr 1000 hat.

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7
Ohio mtIo d
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oe 05. -ereOf
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In flt
CLLectedt
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28

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0
a1keamrt
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op.
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1
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at

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there ua someort
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s
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21
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ot the P.,
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AlIce Cl-t
.
83
9

10

Ih

nli

3277
Martin Schreiber & Associates

Exhibit 14

MEMORANDUM
DATE:
TO:

May 3, 1995

FROM:

Tom Krajewski

RE:

Hudson dog track

JoAnn Jones, President. Ho-Chunk Nation

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

To: Scott DaceY


From: Carl Araman
Date: May 1. 1995
Re: Friday meeting at Democrat National Comminese regarding the
Hudson Bay Track.
A meeting was held with he chairman of the Democrat National
Committee, Don Fowler, on April 28, 1995. MIGA and four tribes
were represented at the meeting: Oneida, St. Croix. Ho Chunk, and
Mile Lacs. Other individual in attendance were Larry Kitto, Frank
Ducheocaux, and Jerry Sikarski- The purpose of the meeting was to
discuss the Hudson Dog track fee to trust proposal put forth by three
Wisconsin tribes.
It was noted that the three tribes purchasing the track have
not released sufficient information to conduct an accurate impact
study on the surrounding communities and operations. However, a
Pcat Marwick study suggests that if this were to occur, it could
reduce the income of nearby tribal gaming operations between 30
percent and 60 percent.
It is believed that the approval of the compact rests with
Secretary Babbit's chief of staff. Tom Collier. He has indicated dhat he
will approve the compact. Therefore, tribal members at the meeting
appealed to Mr. Fowler for help In convincing Secretary Babbit of the
deleterious ramificaions. The problem was framed as a situation in
which tribes with pronounced Republican leanings are about to
receive approval of their proposal, which will hurt tribes which have
traditionally supported Democrats.
Mr. Fowler stated that he would speak with the Presidents
assistant, Harold Ickes He would urge Mr. Ickes to urge Secretary
Babbit to make a closer e
ominan
of impact of the proposed
operation.

P-T FasNule

7571

p.42.

Exhibit I

3279
Exhibit 16

KOveber 27,

YOR Die

xKKORAmDMx

523Z

ST277

TROXN

-0O 81XDsZ2 & NZIL RXZ77

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

Coe Sandler at 863-7110,

and Nell Reiff at 479-

Mai

ca. raise z:
d.ffer.ant types
and non-:eteral:
Contriu::-.s

to

t.2.e

DNZ's

-4".-

of money

for the DHC:

account,

called

fed1'

=cnev, is money that can be used In


cr,
s=:et.:es,
iz.O
. Presidential, Senate, and
C:.._net::cn v4= :edera: ele=tions (c
H"=se campaIgns). Also
:os:
of the DNC's operating
expenses 2=
be paid for with federal :cney.
Contributions to the DHC's non-'edeal account, called n2r
"soft' money, can be used in state an-d
e nnqv Or, seat.zes,
It can be used for
1:cal elections ad is regulated by state lay.
a portion of DNC c;era:1.; expenses and can also be transferred to
allowed by state
law.
:
-pcses
state parties
*

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

Generally speakin;, an individual can give up to 520,000 in


An individual and his/he:
federal funds per year to the DNC..
spouse together can give S40,000, even if one spouse does not have
independent income.
The federal definiticn of a "contribution" is very broad.
be
v''v received by the DNC vill
considered a cnr:ihut:or. (i.e., free or discounted office space,
You should
er free goods from a ve.der for a fundraising event).
anynote, however, trot voltnteered time by an individual,
course of business are noq
-:. tre ordinary
disco=u.nts given
Consequently,

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

...-oses c: deterz:-.ng whether the $25,000 annual limit


=a F= = counts federal contributions to
exceede
tic:al parties a-d political comittees in the calendar year
po
co .. ts centributions to candidates in the
were g-ven, t:
-tey
year of t.e elet;:.-., z= t-e year of the contribution.

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)

-;

Staff should make donors aware of this limitation to avoid


them indaverte.tly get themselves.in trouble.

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

in addition to giving federal contributions, individuals can


1
cive an t-'
-te
e.out: in need
contributions.
2.

PtU-

federal.

-.

contributions

Generally speakin;, partnerships may give up to S20,000 per


ctlendar year.
Ncte, however, that
a partnership contribution
co*.n-s tdre:
c:e a;az.nst the partnership itself
and once against
Z..e indvidual
pa:rt-s
who are making the contribution.
The
rtnership cay all:aets t. .contribution against each partner in
an actual
ed that the allocation reflects
any way _t vishes,: pr
For
detit
to each partner's a::oent within the partnership.
exm==le, the c:ntr.b...tion may be attributed to each partner
equally. or a-::r-ing to each partner's agreed upon partnership
attribute
to enable you to
forms
provide
we
will
snare.
partnership shares ::r partnership contributions.
inco--2orated or which is A
itself
A pa-nership whict is
make a federal contribution (but car
cczve------ --------Pleas& consult the legal staff
:.xe a non-federal contritution).
you have any q-estice regarding the status of .- partnership-f
N::-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

*Federal PACs which have given'the maximu- 515,000 to the D":'s


federal account may =axe unlimited non-federal contribuics
state and local
Also, PACs which are not federally-registared (,e,
trade associations and state and local candidate comittees) mas
not contribute federal runds but may contribute an unimi te
- of no-'-dfunds to the DNC.
Note that generally, PACs-.that are controlled by 12ZIeD
one
or
by
foreign
nationals
yEV not
make
eny
c---'
b- * c-s. However, PACs of American subsidiaries of foreign
national corporations
=
be able to make a contribution.
The
abilitv
of the DNc -c accept such contributions must be deter=ind4
1
by the DNC Genera- ce.nsel's office on a case-by-case basis.

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

Ccrporatio-s and unions generally


t:s
to the ONC.
contri!:

11111

The

DKC,
fo-'**

however,
-

- *

2=

make

CtT--T

accept contributions

-- -3*

Or

unlimited Dor
from

In s:ce cases. K.cerican subsidiaries of foreign corporations


be able to :axe a c:ntributio to the non-federal account; ALL
iih the
be ds:yuspd on s case-bv-C
SUO1 Situations o'7

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.

t-t the Checks

KaXtz

checkss for federal


"DHC/Federal Acoun:..

contributions

must

be

made

Payable

Checks for nan-ederal contributions


should be made Payable to
Account..

"DNC/Nan*Feaderal

Checks for the


"DNC Suilding -fitnd.
Zf
maz-;=.=

person,
*e*et"-r

building

fund should be made Payable

to the

an indivjdual c=ntributor who has not already


given
t
te CKC Federal account (520,000 per year the
perp
S40,000 per year per married couple),
yoU
should dg
oo
ny
e~ metq*oftge
the doneto
wite
two sqopyate

a-=ot

* One chek ::te "DHC/Federal Account" for the maximum


that
ctrib:ucr can s:.11 give to the federal account, and
*
t-

;:ve,

7he otner

=ade

cne:k

paye:e

= the

t:

the doner dCeS

remainder

of what the donor vants

"DNG/Non-Federal

Account".

only one check, the DOC may request


mat te con:r desrn-te, in wr-iting, a portion of his or her
-ce.tr;tion f:
.*
DN
federal account. Susan Ochs has form
letters for t!..s p-rpcse and will ad-inister this process.
Lr-te

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

out to the President


the mzao section, or
indication that the
campaign.

re;%uIre
-n-s
-5-

checks be deposited within ten days


Means that:
ryheCks

.* diatY

Jec

* Non-DNC stat: receiving checks on behalf of the DOC (e.q*.


event co-chazrs,
tr-stees,
other lay solicitors) must forward
checks to theCappr";t..e DNC staffer
within ten (10) calendar days
after receiving te:.

3284
6
You should also note

that

federal law prehihbits hcth DN

and non-staff solicitors fram depositin g8l


contributons
. their personal bank aoom: for Any amou.t of tia.

gfln

2.

ce

the Deoe

s"

C5-

All contributiOs sust be attributed to the person or amtit


who actually provides the ftads.
Reporting a cootLibution f-on
s5aeans in the Mame Of soneane else is a Very serious afense-often resulting; in crixiOal liability.
This applies to a=7 attamts
by a corporation so
e-sihLta ze
an employee for a
n.
Contribution.
The DNC
All checks should be forwarded with a donor caxd.
must have the name and address of any contributor, as wall as the
date the ONC received the contribution.
if
the contribution is
above 5200, the DX: Xy11 also have the occupation and plays
of
the contributor fo: yE: disclosure reports. Contributors should be
made aware that this infer-ation is required by federal law.
New
rules make it absolutely L=pfrative that the ONC have thisfcr every donor.
information
J.

eCt*-

7:-s

1'**4*

in

Swoial

Caves

Spouses may e:n


c=.tribute
they m=ake a
in: c:.h-tution

$20,000 to the federal account.


:f
of $40,000 to the federal account
on one S40,000 check,
spouses 3211 11E the check and coo2ete
-e
--- cv-"s.
Alternatively, each spouse can make out a
separoze c.er. : t.%e fettral, account.
by a
be accompanied
Oust
partnership cc=tribution
>-statement t.rt
e
how the partnership contribution is
allocated
::.n; Its part.-ers.
We Will provide a form.
You shcld
consultin;

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

can take any for=.

in-kind :

For example:

A vend:r suplles ceartain goods for an event free of charge,

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.

A corporation flies the guest speaker and/or


on its private )et to a fundraising event.

mec.bers
-

offices

-=t

: to

ONC s

A vendor supplies free services or goods for use i the ON:(e.


free computers, free phone usage, free Cff:ce spC~e).

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

Under FEC rulings, by following the procedure set out below,r


the
DNC
can
accept ?cco-ainn
I1hebunion
; n-k*onjt-;bu'inn for DNC admInistrative or fundraising activties.
An
individual can also cake an in-kind contribution with a value
exceeding the 520,000 federal limit.
kind

The DHC, however, Canno


under any circumstances accept incontributions
fre:
fc-*,,r
co-er-ations,
or
fede-a I I
.

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

Before an I.-kind contribution may be accepted, the


1)
entirety, and must be
its
attached forr .. s: be complete, in
accompanied by sc=e docunantation indicating the value of the
An in-kInd contribution is valued at the usual and
contribution.
what you would have
normal charge for suc' goods Cr services (i.e.,
you
to pay if you bou;n. c- rented the goods on the open market-.if
have any questions abou: thIs, ask).
'

i-k~nd

contribution

forms

Must

be

approved

(and

3286

signed)

by the Finance Director or his designee.

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

as a policy matter, you must ask yourself whether it wouI be we .


to pay for the goods cr services if they Were not be4ng do-te
it
in kind.
D).

Ez=estictes

The following specific


considered contributions:

types of

in-kind

donations

are

(1)

An individual's volunteer service to the DHC;

(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)

Expendit res for invitations, food and beverages by an


individual, up to an aggregate of S2,000, for meetings,
.alles
and -- ties
held in the individual's own has or
a ccr==.-.ty -oc=; and

(5)

Discour.:s by a vendor o: food and beverages which do not


exceed S:,000 in a calendar year, provided that the price
char;e-d is no less than the actual cost for those goods.

own food and lodging expenses;

It is important to note that any volunteer activity undertaken


and that the
own time,
individual's
t!e
done cn
be
individual's exiplrver any not compensate him/her for any time spent
incurred by
costs
Pathermore, any unreimbursed
as a volunteer.
t.ne employer in cc.nection with the volunteers activity would be
c=nsidered an .- Ki7.d contribution from the employer to the DNC.

=.st

II.BABIC

A.

BOnTCITATION

GYTDELI~z8

Stetdads

Ethical

&M source thAtoud


Donations shaulf not be ac'*pted fra
to the White nouse or DEC or create any
cause aarrsaszm:t
appearrace of iArc;riety.
be

rhere
speaking

facts

me
at

of the principals or
C7

1:

c= certably1

a
at
attendance
be comuicated.

A-mimistration officials vil


DEC fundraising event, tho

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

ZnAR event should any 9NC staff


pieaise a acting with
ar aqces
:adZy governmant_&fficial or agency in connect
with
a donati5n,-ar,
ever impLy-" at such .contact or acces ion
it
arranged
or ever contact am Adafnistration Official on behalf o
a danor'ter any reason.
3.

Rules

f-

V1-tte: Kate-ialS

The following are general rules which apply to invitations


soliciting
c:.tributions includingne letters
inviting
prospective
donors
to
join
DHC
fundraising
councils
and
organizations) a.nd ether
copy for DNC fundraising.

letters

Please ree~ber that all


invitations, direct
other copy must be clezzed ty the General Counsel's mail, and all
office bec,

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

Solicitations for All

A.

Capt:Lbutions

Your contributing to the DKC/Federal Account is for use


fede-al elections and is subject to t
action
with
of the FederLl Election Campaign Ac
prohibitions and liniatiar"s
easy.:] Any contribution to the
Clf also soliciting ma-federal
be used in connection with state And
will
A:ct
ONC/Non-Federal
local elections.
--

-Your contributions is
tax pv-poses.

not tax deductible for federal incoee

--

Paid for by the Den-Ocratic National Comittea.

In

addition,

following

the

-Z's

regulations require !he

efforts'

'best

disclainer to appear on all solicitations:

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.

T!%e 77 -les also reu-ire t-hat this latter statement appear


.=ar~ner" on any donor card or other
se---a "clear and :
.n a solicitation. The FEC states that
-luded
response =amerials
is in small
: -=!ear and conspicuous" if it
fte disclaimer .s
type in co=paris:. to th.e solicitation and response materials, or
to read or if the placement is easily
is d ::t
if t e printin;
overlooked.

3.

-?'

Additionmal

Diselstie's

fo

-10

funds for joint


Under federal law, all copy used to solicit
must cz:.matn, in addition to the standard disclaimers,
Please consult with the General
several special dis:::.:ers.
(The DHC must
f .nd-raiser.
a joint
p-n;.ng
Counsel's office bef:e
enter into a co=;er a;ree=ent wish the otner participant(s) before
having a joint : .t:Lser)

fundralsers

C.

0a'

ge':'tatve

Oral scl::1tations need not include formal disclaimer


should be followed up vith A
solicitation
But an, s.
langu-a;e.
donor card tha: will a::ompany the check, has all the above
disclai~ers and captures the required information. In addition, in
in phone conversations
you 112u 1,
solic ting co..--:..s crally,

3289
11
*

Avoid earr::KXfy,

Be sure to

particular,

if

a.

tall

as discussed above.
the donor how to make-out

individual (or federal

the

a
contribution, emphasi=A that the check should be made paya
the fede-ral acqaunt.
PA)

is

giving

* Make sure an individual donor knows about the S2Ok


federal contributicns-

it

The General Cu.sel's


Office is
available to answe- a,,
questions fra
donors cr their
lawyers as appropriate; do nehesitate to refer people to us if
they have any legal cc.-=rn
about,
a donation, concerns that we may be able to alleviate
with an opinion letter
a: 4 discussion.

making

:7.

CoTrc

All contracts =ust be submitted for approval by the Finance


Director; reviewed ty the General Counsel's office; and signed b,
Fo on- 4n the field doing en event has
the Chief of staf:.
B.

ors

*--

-tta7:*s

or

"nc

ets

any ite-, wnetner a work of art, a souvenir or a t-shirt,


If
tsl beneflt the DXC, the full payment for such items
::
:.s be.n;
's Considered a c:ntribution to the DNC, and should be treated likC
contributor
all
(i.e.
DNC
the
c..t---------to
other
any
=csz be chtained, depending upon the contribution
.. fcraton
If a cecnert or other event is used, the full ticket:
a=ount) .
Whenever you plar
;-ice is considered a contribution to the DNC.
1n; program, please consult our office in the
to use such a funtrs
early pla.-ning stages.

~
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;

outside the gove-r.nent to work on catpaig-

Be featured speakers, panelists, honorees and guests at


party events (dinners, retreats
ca=paig-. and political
political
=ut sea below an funtraising restrictions;
briefings, etc.)
*

Be ca=ped to political fundraisers;

a Participate in national and state party meetings,


and other events of every kind; and

briefings

*
Run as delegates to the party's National Convention
hold national and sta:e party office.
2.

Certain C:ficials/Exployees still

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

and members of contract appeals

* Officials and e=ployees of the FEC, FBI, Secret Service,


CIA. National Ser.Lrty Agency, Merit Systems Protection Board,
Cffice of Special Ccumsel, Dept. of Justice--Criminal Division,
-RS--OC:; 0:fice Cf investigativee Prograes--U.S. Customs Service,
Office

of Law Enfereament--ATF.

3.

All

Gc.er-s2=t

Employees

Le Barred Irom soliciting

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=

In the ;3t, certain senior officials who were exempt


with prospective donors an(
visit
the Match Act could call.or
Thus,

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

and employees SALD21--

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,.:;
*

er e.-c::ra;e contributions once at the event; or

scliit

way per--it their


the furraser in

* in a-y
associated v.=
B.

Vse of

Ceve-m-a-t

Tar

official
any way.

titles

to

be used

0:

oiew

DNC events, whetha: they are fund-raisers, donor maintenance 0:


including
anc government D2iLdi~j,
re 1914j in
ca--ct
elsa,
The only exception is that donor maintenance
t.e White House.
events (not ""- -risers) :ay be held in the Executive Residence'
The DMC is charged for all the
portion of tne W.Ite House.
The Residence has special authority t
expenses of surt events.
rc: a pr vate entity for the costs of Surexcept reirbcrse-cevents.
anrthing

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

1600 Pamil'niaA'wsue. N-W.


Washington. D.C. 20500
Fu: propoa pending at Interior to crt= vust
laods at the Hudson Dog Track i Hudsn.
for an Indian Gaming Casio
Wisconsin
Dear Mr. Ickes:
I appreciate your eusfing me oaming the abow vsOL at Tuesday. Ad 25. and
agi nWedmeday. Apra 26. 1 mame dm W -mm-u I~e 1 y 11 y MY&CSInoS with the
an Apral 24 wben they -we In ).mepsrs. I scuteod yaw cls
President and lanuce Lindsey
andtalked to yoir "dink ?&. Suman, who ad Lseclthat you -M = imthe oMee whom I
called. Since: L had in appoeran with Dan FoAtmr on Fddzy, Apd 21. to dinis tis miner, I
dercided amrto try to contc you 'int after the Fowler meeting with die chairman of five of the
and Vaseuin tribe thatz oppose the arulon of the ams land%for gSsihlig
tmamy K~ommo
Purpose: and the hallous of Whcunt dog rack ownwm
arid sent
I ha-e ha=o dised thWCad=an Fo..dr his talked toyou shout sis manor
awt=n snota s -- 'n ;a th:s iam
to uds
ytss a memo cmnling the basis .%6he nfo
Since the Fe-icr mento -a on to ymu the City Council otHudwos Wiaonsin. poised a
resolutiont opposin& the constion moad oponnon of&a camno a te do 1 oesk.
The Socretary of Inteior has the discrvn

I.
2.

to caeoe such wasslands if he fmds:

it crut an eooma; boncit for thteapplicants, and


it does not create onnmric histushp for otbess

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

result fromttis hafpawg.


I amconcerned
Chas
those at Intis?~r -- o am usolved Are[wing toward crang tust~
!ustdLWe requested a copy o*(the Ardsur Anderson repees which the peutiaes commissioned
bic found no ad~erse finaaulal impact The copy submitted tow u-blocked osc' all of the snua
iformston relating tothe re of theopwtiakfl haw many masclse. tibIa. etC. -bich weneed

woknow. Aswellas thestatistics andrecain wsedin duarrunM that Uesurrounding casinos


-ould rot suff'er a serious .eooase impact. Wgeed this data in order to put our bat case
forward to Lnacroe. We have naoabjetion to lteers subitting the Coapers A:Lybrsnd or the
Feet M&-wick repwctto die petitioners.

I -wild alsolika to relte


I.
2.

the politics inol~svedin tl

sivuaon:

Ca~crstor Thorapson of Wisconsin -tipports aapsjer


Senator Al DAinno supporus this project hdemse it bssb o Delaiwmr Noth the
company'that awas thsis defoac dot track ad also operates another dog track in

Vrucoravjn. Delma Noah is loated in Buffao He- York.


3.

The cksaism of te Ind;an Oibe in the foret-vat oflds project is aonrein


pipublilompatypolicies thisyea hewasso oxseeasF Rqohlican adidate
SCOMaa
farthe VroscnA Ut

4,

All of the rcrc=t:im%


of th inbc tha et .th Cain=n IMir ea
Democa andharmbe= sofor years.I canteadf sotheir preious finooSCalI
support to the DNC Andthe 1992 Cflstoors/:w Campaign Co-neittoe

5.

The =tire Waceoc (Dernoast andRe-rubucans) Constg isonal delegaton


oppoe this projer The Wiseonnn Dcroc==c COMPenioal de~F'in
in -bose district the dog neck is locased)
ruiscJ~sgConptam Oruaderson
oppose the psjm

I erainly -all appro~x it if youwill meet -nth mteandtwo rersozu


adennon bylntaiOr ssisinssa.
canwork it into yox schedule. eusCe
assoon Asyoua
notia
szJlbie assa24-11o1Z
Yoi e*

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

ChairmnDonFo-le -David Merer


Lany Kia
aranding Friday .r.esng with Fewiar
Pcnous

EOP 064264

HUD FOIAL 00010

3297

St. Croix Tribal Council


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05

3298

St. Croix Tribal Council


P0.

sas

0m a

rft-ss

F. O 5)3.s47s

Tnr.'

.a

TMarch 8, 1995
Danswy

Cownaae

cur.

a-ran

s..

i..

Mr- Jack Breault,


City of Nudson
SOS 3rd Street
Hudson, wi
54016

Crsnwarw

Cr

Mayor

,,,,,..
n,

Dear Mayor Breault:


EXECuLIvE SECREFAs
U."

Ma'y
Gr-

ty

This letter is a foll1vup to air Conversation today


regarding the conversion of the Hudson Dog Track to a
Tribal Casino.
The St.
Cix Chippva Indians of
Wisconsin through
its
Tribal
Council appa.es
that
proposal.
Impacts on the St. Croi Tribe's Tltie
Lake
Casino would be devastating. We have cmmunicated this
position to both Federal And State officials involved in
this very imponrant decision.

__""

82aA
L Pias

If there is anything we can provide or do to assist you in


ypposing or respona
g to tais proposal, please do not
hesitate to Contact myself or my staff.

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~

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Cttoo*a Came.. Cane

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Baos
C.

3299
OC

ONNOR

.
*rrOnOr"Cs

HANNAN.L.aT .. A

-,FNTsf..
-r-su,,c am

May 8, 1995

Mr. Harold Ickes


Deputy Chief ofSTaff for Policy
and Political Affairs
The Wtte House
1600 Pennrylvania Avenue, N.W.
Washington. D.C. 20500
Re:

Proposal pending at Interor to crease trust


lands at the Hudson Dog Track in Hudson.
Wisconsin for an Lndan Gaming Caisano

Dear Mr. Ickes:


I appreciate your calling me concerning the above subject on Tuesday. Apni 25. and
ags on Wednesday. April 26- 1 assume these calls were prompted by my discussions with the
President and Bruce Lindsey on Apnil 24 when they were in Minnapolis. I returned your calls
and talked to your assistant. Mr. Sucan, who ades that you were not in the office when I
c.sid Sart I bad an appoirsnear with Dan Fowier on Friday, April 21, to discuss this matter, I
decided riot to ty to contact you ndl aftic the Fowler meretg with the chairman of five of the
mazy Minnesota and Wisconsin tribes that oppose the crastron of the trust lands for garibling
ouroeos end the bailout of the currrt dog track owners
I haec beenadvased that Chairman Fowler bs talked to you about this matter and sent
you a memo outlirnag the basis for the opposition to creaung another gaming casino in this area.
Since t1: Fowler mamo was sent to you. the Cty Counin of Hudson. Wisconsin. passed a
resolution opposing the conswenoon and operation of& casino a the dog tack.
The Secretary of lnterior has the dascreton to creac
1
2

such trust lands ilhe

tfinds:

it creates an onorome bencrit for the applicants, and


it does not create economic hardship for others.

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

Governor Thompson of Wisconsio supports his projeeL

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

Tne er.nre Minnesota (Denocras and Republicans) Congremsronal delegation


oppose this project The Wsrenlit DeMoersic Congressional delegation
(including Congressnn Gwrlrrson - whose district the dog rack is located)
oppose tmeproject.

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.

Chairman Don Fowler - David Mercer


LaiTy Kino
Persons amending Friday meeting with Fowler

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

PLEASE DELIVER THE FOLLOWING PAGE(S) TO:

NAME:

Lewis Taylor/Mary Harmann

TELEFAX:

715-349.5768

Torn Corcoran

FROM:

TOTAL NUMBER OF PAGES INCLUDINGG COVER PAGE):

DATE:

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3303
O'CONNIOR & RuNNAN,

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1919 Pennsyvania Avenue. N.W., Suite 300


Wushlngto, DC 20006-343
(202) 837.1400
FA]X (202) 466-2193

TETFlQMUNCTIN

OVE Prg

PLEASE DELIVER THE FOLLOWING PAGE(S) TO:


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NAME:
TELEiAX.L'

456-2464

FROM:

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TOTAL. NUMBER OF PAGES (INCLUDING COVER PAGE): 15


Mlay
16.12995

DATE:

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CALL. NAoCASSOONAS POSS)L.E

Clienv/Matter No: 32594-001

(202)778-2127

Harold'John

ThouE~h you'd be interested in the Peat Marwick report on the Hudson


pro~tctl that Concerns U.S.

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:

Wisconsin Dog Track

1995

Jennifer, I spoke with Heather Sibbison regarding the status


of the Wisconsin -Dog Track announcement.
Interior will make an
announcement in the next two weeks. At that time, they are 951
certain that the application will bt turned down.
She explained
that there is significant local opposition.
Much of the
opposition, however, is a by-product of wealthier tribes lobbying
against the application. Therefore, they still
want to receive
public comment in making a fair determination regarding the
application.
Nonetheless, she 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.
Finally,
because it is

she asked that this information be kept quiet


not public information yet.

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
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oc

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lxq

3307

to

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(db/.o,

3308

7--:

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-Sm

Mnt Off t:,

Exhibit 22

hatrio

OFFICE OF THE SECRETARY

D.C.20240

MEORANDDMl
To:

Political
Jennifer O'Connor, White House Office of
Affairs

From: _00eather Sibbison,

Departenlt of the Interior

Subject:

Draft responses to letter from Hinnesota Delegation


Regarding the St. Croix Meadows Greyhound Racing Park

Date:

June 27, 1995

Please find attached a draft response letter to members of the


I am sending it in double space format on
Minnesota delegation.
the theory that it will be easier for you to edit and for the
typist to read.
Please note that I anticipate that the Department's decision to
decline to take the St. Croix doqtrack into trust may be made
Accordingly, another way to approach the
public later this week.
longer and then just announce
response would be to wait a little
I also drafted a letter
along
that the issue has been resolved.
those lines, and am including it in case you would prefer to take
that route.
If there is anything else we can do to be of assistance, please
do not hesitate to call (202/208-7351).
In any event, I will let
you know as soon as the final decision has been announced.

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:

c:: Hudson decision letter


V. Heather SizbIscn at -IOS
--------------------- Message Contents

>wc ret~lent

text

item

1:

Text

Please find attached a draft of the Hudson decision


letter refusing to take land into trust pursuant to the
doscret::nary authority of the Secretary and 25 CFR
Par: !51.
IGMS is also drafting a proposed memorandum
to the Commissioner c6ncluding tnat the acquisition is
not detrimental to the surrounding community under
Tnat draft wil: be ready before the end of
Section 20.
the week.
These two drafts represent the alternatives
available to the Secretaty, as discussed at previous
As you recall, we advised the three tribes
meetinas.
trat ::mS review under section 20 would be completed by
--en- C- ::-e month.
Please remember that I will be
on. =a .e nex: weeK, and on travel for 638 the week
0le
--e know wnat
vou
h:nk, and whether we
nee- -= -ee:
: zLnalize our pos.::or. on this issue by
weea: S eno
Tnank you. .
.
. .Gi

.
-

--

--

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.

DUFFY. Counselor to the Secretary.

UNITED STATES DEPARTMENT OF


INTERIOR. and GEORGE SKIBINE.

Director. Indian Gaming Management Staff.


UNITED STATES DEPARTMENT OF
INTERIOR.
Defendants.
AFFIDAVIT OF PAUL F. ECKSTEIN
STATE OF ARIZONA

) 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

of the Indian Reorganization Act (-IRA-)

On or about May 1. 1995. 1 was retained by Galaxy Gaming and Racing

Limited Partnership ("Galaxy)

to assist Galaxy and the Tribes in their efforts to obtain

Department of Interior approval for off-reservation gaming at Galaxy's greyhound racing


facility in Hudson and for the trust acquisition described above. On May 8. 1995. Mark
Goff. a consultant to Galaxy. faxed me a copy of a letter dated May B. 1995 from Patrick
O'Connor to Harold Ickes. Harold Ickes is the Deputy Chief of Staff to the President of
the United States. The letter states. in part:
I appreciate your calling me concerning the above subject [The Tribes'
Hudson proposal] on Tuesday. April 25. and again on Wednesday.
April 26. 1 assume these calls were prompted by my discussions with the
President and Bruce Lindsey on April 24 when they were in Minneapolis.
I returned your calls and talked to your assistant. Mr. Sultan. who advised
that you were not in the office when I called. Since I had an appointment
with Don Fowler on Friday. April 23. to discuss this mauer. I decided not
to try to contact you until after the Fowler meeting with the chairman of
five of the many Minnesota and Wisconsin tribes that would oppose the
creation of the ast lands for gambling purposes and the bail out of the
current dog track owners.
I have been advised that Chairman Fowler has talked to you about this
mater and-sea you a memo outlining the basis for the opposition to
creating another gaming casino in this area. Since the Fowler memo was
sent to you, the City Council of Hudson. Wisconsin. passed a resolution
opposing the construction and operation of a casino at the dog track.

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.

Governor Thompson of Wisconsin supports this project.

2.

Senator Al D'Amato supports this project because it


bails out Delaware North. the company that owns this
defunct dog track and also operates another dog track
in Wisconsin. Delaware North is located in Buffalo,
New York.

3.

The Chairman of the Indian tribe in the forefront of


this project is active in Republican Party politics: this
year he was an unsuccessful Republican candidate for
the Wisconsin State Senate.

4.

All the representatives


Chairman Fowler are
years. I can testify to
to the DNC in the
Committee.

5.

The entire Minnesota (Democrats and Republicans)


Congressional delegation oppose this project. The
Wisconsin Democratic Congressional delegation
(including Congressman Gunderson in whose district
the dog track is located) oppose the project.

of the tribes that have met with


Democrats and have been for
their previous financial support
1992 Clinton/Gore Campaign

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.

On May 16, 1995. I travelled to Washington to anend a meeting with

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.

On June 16. 1995. 1 telephoned Tom Hartman. a member of the Indian

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.

On June 26. 1995. I telephoned defendant George Skibine. Director of the

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.

At a result of Mr. Skibine's comments to me on June 26. 1995 and Galaxy s

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:

(1) the proposec

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.

1995 letter denying the Tribes'

application.

Neither Secretary Babbitt, nor

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

I was deeply disappointed by the decision denying the plaintiffs appiucauo.

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.

Notary Public. State of Arizona


My Commission:

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

October 10, 1997

Honorable Fred Thompson


Chairman

Committee on Governmental Affairs


United States Senate

Washington, D.C.
Dear Mr.

20510

Chairman:

I understand your staff has requested written notification of my


deczsioir not to be privately interviewed on issues relating to
the Department' s denial of an application by three tribes in
Wisconsin to place a parcel of land located in Hudson, Wisconsin
in trust for a casino development.
Let me explain the reason for my decision against a private
Given that numerous allegations are now being aired
interview.
in public before the Committee, I would respectfully request that
I of
the Committee make any inquiries of me in public as well.
course remain fully willing to respond in public at any
convenient time.
I am troubled by the fact that at least one deposition taken by
your staff on this matter, that of Mr. Paul Sckstein. has found
its way into the news media. while it and others taken by your
The result has been the
staff remain unavailable to the public.
circulation of a good deal of incorrect information as to what
application nere.
actually occurred with respect to the tribal
For example,

while

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
Mr. Ickes never gave me instructions as to
in the White House.
what this Department' s-decision should be,

nor when it

should be

made.

I do believe that Mr. Bckstein' s recollection that I said


something to the effect that Mr. Ickes wanted a decision is
correct.
Mr. Bckstein was extremely persistent in our meeting,
and I used this phrase simply as a means of terminating the
It was not the first
discussion and getting him out the door.
time that I have dealt with lobbyists by stating that the
judgment
to resolve
expects
me
to
use
my
good
Administration
controversial matters in a timely fashion, nor do I expect it tobe the last.

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]

would be in the best interest of the

Indian tribe and its members,


surrounding comnity."

and would not be detrimental

to the

In conducting the consultations required by this section, the


Department learned that a Wisconsin Indian tribe situated within
50 miles of the land was adamantly opposed to the application
because of the detrimental effect on its own gaming operation.
(The three applicant tribes, incidentally, were already operating
casino gaming on their own reservations, under compacts approved
by the Department of the Interior.)
Further, these consultations revealed that local communities
surrounding the land were, contrary to recent press reports.
strongly opposed to the concept of developing a casino on the
property.
The Hudson City Council adopted a resolution
expressing opposition, as did the nearby Town of Troy.
The
Department also received several letters signed by state and
local elected officials, including the Wisconsin State
Representative in whose district
the land is located, expressing
strong opposition to casino gaming on the site.
Given the strong opposition of the neighboring tribe and the
local communities, and the distance of the site from the three
applicant tribes - all undisputed facts in the record before the
Department
the Department declined to take the land into trust.
Your staff has already spent many hours deposing officials of
this Department who were directly involved in this decision, and
who have provided full explanations of the Department's
decisionmaking.
Yet these basic facts were not presented during
the Committee' a discussion of this issue this week nor in any
other documents that have found their way to the media.
I reiterate my willingness to address this matter publicly before
the ComSeittee.
Sincerely,

3321
Exhibit 26
surf COMMITTEE ON GOVERNMENT REFORM AND OVERSIGHT
MAJOR/TYMEMBERS

MEMO

OPPONENTS OF THE HUDSON DOG TRACK PROPOSAL


Oneida Tribe
Democratic National Committee (9-15-95)----Democratic National Committee (11-13-95)-------

$10,000.00
10,000.00

Democratic National Committee (3-28-96) ----

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

[Tribe also paid O'Connor& Hannon--S100,000.00]

Shakopee Mdewakanton Sioux


DNC Services Corp.(6-6-96) -------S 5,000.00
DNC Services Corp.(6-7-96)------------------20,000.00
Dem. Nat'l. Comm.(8-2-96)--25,000.00
Dem. Nat'l Comrnm.(I0-7-96)
-----------25,000.00
Dem. Nat'l Comm.(10-9-96) ---------25,000.00
5,0000
Minnesota Dem. Party DFL (9-3-96) ------------Minnesota Dem. Party DFL (10-7-96)-------------2,000.00
Minnesota Dem. Party DFL (10-31-96) -----------22,500.00
$129,500.00
(AN
[Tribe alsopaid Dorsey& Whitney---S60,000.00

and Swindler & Berlin--520,20000


00]

01/20/98

3322
lille Lacs Band of Ojibwe

Democratic National Committee (9-13-95)------Marge Anderson --- DSCC (11-4-96) ---------

Melanie Benjamin--Clinton-Gore (9-29-96)---Doug Twait----Clinton-Gore (9-29-96)-----------Prairie Island Tribal Council


Minnesota Dem. Party DFL (11-3-96) -----------Darelynn Lehto--- DNC Serv, Corp. (9-30-96)-Leech Band of Chippewa
Democratic SCC---(10-31-96)---------------------Alfred Pemberton---- DSCC (11-4-96)------------Moh Mah Wi No Min li (PAC)-------------------

$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

RICHARD SULLIVAN CALL SHEET

February 22, 1996


TIME

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

Bob Belfer wants


to add to her list

Linda Moore

2/22

10:35

Plz call back

Lauren Supina

2/22

10:45

Plz call

215-665-5534

Sue Gin

2/22

11:00

Needs zip code


for Potus

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

Piz call Bonnie


McNair needs
date on philly
w/vp setup time
to talk tomorrow
asap & may 16

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

Leech Lake Reservation


Lewis Taylor
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

March 21. 1995

Hon. Lewis Taylor


Chairman. St Croix Tribe

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

-.

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3329

Afl~oRNE'S AT

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PLEASEREr.

-n

essoEna:

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ser:::es

of Matter:

This

* STS*YOURREMITTANCE
CP.r

Doc Trz:<

to

rendered through ?e.*..ary 28, 1995

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::::..
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dra: .e: er S7.
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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!

O'CONNOR & HANNAN

BEST AVAILABLE COPY

AA 0000259

3330

ATTO"NEYS
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32-4-::**:.

of Matter: to:

Traok

tC

LSE RErvom.-. wTION wiTH 'UR KEurTANCE


-sr.dcg track; discussions w;:h :.. K::::;
call to L. Taylor; -enoranoaylcr; memorandum to L. Ki-t:; memorantiu
to H. EIchlez; memorandur
M=:ar:-.y review "acqisit:on :ecklmst. -emorandum
to j. Jones regard-n:
meeting:
discussions w:h
key aide to Cong. Gunderson, J- ?rank;
- . Taylor; memoranouo '.
Kitto; memorandum regarding Cong.
i.cers:.n to .. Taylor and copy :c .. Kitto: discussions with staff aides tc
Sme.rerrgold ant Sen. Kcnl; cal. :c ickter; discussions with L. Taylor.
=itsz:ssicns w:
Kitto regaro.-c Wisconsin congressional delegation;
:n.w
Taylor; rev~e.
me-crandum from L. Kitzo; discussions
deveoo
correso-der.:e for .. .avlor to Minnesota conaressio-a;
scussio.ns w:i:
3:A
:!fi=.als;
ciscussion with aide to tong. Ce'.
-:::

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:

K-tto; memorandum to '7-=:-':r regar:in 10n..es:a


delegs:::
mem.ra- -file:
memeranduto L.
is:s
:t R ass::.s
:tn
Kitto; djscussjons
:oaessinaL
aides; dsr
Kstns *:.n . L:::: review BIA materials;
sK erfor-e
y ..
L:: for Fecrary: discussions with :.. K: :
=a:! m
K. Meisrer. Office of Solicitor, U.S. interiorr Department;
--.
: c
- I Taylor.
-e
an: . Kitto; discussions with BIA
-

Ltn

1.

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:&

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Due:

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O'CONNOR & HANNAN

E'*5C.sa

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3331
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April 17. 1995

Hen. Les'is Taylor


Cnairrn=n St. Croix Tribe
P0 Box 8Hi-el. Wisconsin 54845
Dear LewisEnclosed please find O'Connor & Hannan's bill :or services rendered in March. We are
10~sz
t
of service io you,
lfou haNe any questions, please donit hesitate

:'

call.

Thc:mas J. Corcoran

enclosure

AA 0000261

3332

ATTOtNEYS AT LAW
800

SUITE AVENUENW
9 PENSYLVANIA
WAS*
Z:c20006383
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REbN
PLEASE

o r=:

fesscrcal

of Matter:

-:eare

sr-:

zes

rendered

dS

Dog

through

PennoN

Trac<

V"UR REurrANE
WITh

to

Mar:.. 3.

.995

meeting with Duff,


Telev.=t.e :nference with Tom Corcoran regarding forthcccg
Interior regarding creating trust lands at Hudson, Wsconsin dog track for a
n;a-. nee: to contact Tom Collin: long distance telephone discussion wt:-.
meeting on Feor:uary S with Duffy in Oberstar's
regarding client's
:::-an
=all to Tor Collin's cff:e a: nter:cr: telephone call to
.e:Ee.:e
and fax to Collins; rrpnrting to Tom
olln~s a: :nterior; draft letter
to Tom Corcoran on Collier, ge: report :- meeting in
-:-:zza:.
re:z:oference with Tom Corcoran
from Tom Corcoran, teepcle
C.zerstar s ::::e
and
t. it should not suppr:
paper for In:ericr
:ee= -or a position
:egarzcnz
at the Hudson, Wisconstn dog track; re'.ew memorandum from :a za7.ng ::as..
c a:: v::A discussions with BIA an: Department of :tericr officials; ca::
K
on Wisconsin delega :c. pr:ert, discussions with K. Meisner
.rrk
z= 7%.-::
of Solcitor s office; discussions with F. Ducheneaux; is=ussions with L.
Taylor and H. BL:er. review documents from H. Bichler; call
o :o:
a.:
to P. O'Connor regarding Secretary Babbitt. *e.orandum == L. Taylor; draft
le::er for :11snt and Winnebago Chairperson for Wiscns-- delegation;
s:-ss:c:sct:
L. Kitto; discussio.s wit* P- O'Cor.or: discussions with B.A
-:frtals.-em.randum to L. Taylor; memorandum for P. OCocnnor to Interior
Secreta-y Baobitt; discussions w:th L Ktt:. review me-crandum from P.
tor.
rcrandurm to L. Taylor, disc.ssiens with P. :z'onnor; discussions
t2.:. aide to Secretary Babbitt;
call : B.:. Parker; dis-ussions with aides to
:r:cr Secretary Babbitt; discuss:ons with L. Kicto; t-zscussions with P.
tonn.:. :s:wssions with L. Kitto; discussions with a:de to Interior
Secretary Banb:t; discussions with F Ducheneaux; disc-ssions with L. Kitto:
discussions with aide to Secretary Babbitt; discuss.:ns with P. O'Connor;
d.scuss::ns w.:t. Congressional azdes. discussion wit L.. Kitto; discussions
with r. Ducneneaux; call to L. Taylor; discussions with aide to Secretary
rlitbitt: discussion with P. O'Connor; discussion with L. Kitto: discussions
:h L. K:t:o:; discussions with NIGC staff; discussions with Congressional
aides; dlscuss!on with L. Taylor; discussions with L. Kitto: discussion with L.

AA 0000262
'::ss .

*esan

O'CONNOR & HANNAN


' *a
aoct as amar

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

a:ter: Dog Track

t=

PLEASE
RETURNTWISPORTIONP
wiOUR

REMfTANCE

following his meeting with G. Skibine, head of 5A Saming _- f--ee


disvuss:=n
:lth
..
KI::z. discussion with L. Taylor; meeting at Interrcr with
Tom corcoran. .arry Ktto
and Tom Collier.
Meeting at =C with Truman Arnoid
and Chairman Don Fowler; meeting with L. Kitto; memorant-.* to M. Gable or
oopers & Zybrar.d. me=randum to L. Taylor. discussion wit -.
Taylor. meeting
vith L. Kitto, P. O'Ccnor, T. Collier, Chief of Staff to Interior Secretary
saboit.
and H- Sssn:s; P. O'Connor and L. Kitto meetings with various
Democratic national campaign organizations (eg. DNC, DSC"); discussion with P.
Oer.er.
zise*ssion
i:h L. Kit.o: discussion with Tom torcoran regarding
-eeings
at Interior and DNC; review notes frc= T. Collier meeting; me-=randu-r
file
to I. Taylor; memorandum to L. Taylor; additional dascssion
. a%.cr regardL.= Coopers & Lyorand Impart analysts for io tZuc
Troe;
z0report
.
ayor regarding meeting with DNC Cha:rman C Fowler;
ls=ssl=n
.
:
:s:ss::
wit- ;
C t--er
me*oDranur t: . Kltto recardln= 7.
C=ker
-ee:-nc.
tst-.SsIon wi:th . Kitto regarding cocrlination i-.pac: study
a r
St Creix 7r:be M:d Locs -rite and ho Znunk Tribe Involvi:r. Coc=ers &
Ly=ran. analsts,
tisZrss:ons
it* EtA offerials,
discuss:lns woth heuse Nat:ve
A--eria:a- staff
aides. discussions with L. Ltto regarding
De-ocratic Gove-nor with dog track problems contacting terroror Secretary
Sarm:.
dcscuss:n=s with aide to tzng
Solomon, Chair-E- of House Rules
:r.ree; repcr
to .. Kitto, discussions with aides to NIGC; discussions with
. Ducneneax: discussIons with H. Gu:cn:.
discussions &;d meetings with key
Z.gressional staff assistants regarding :mpl1ca::cas c Ccng. Solomon Cong.
.egsla:Icr
on Hudson and off-reser-ation pr::ects generally.
-itussIons w.::::nD
staff, call to L. Taylor for a reo:r:. discussicns with
- avL::
discrssions with L. Ki::o; discussions with C:ngressional staff
:egarIng Solo-cniTorr:cell
legislaton. mee:ng with aide to Cong. Solomon;
dIscussions w:n
L. Kitto meeting with aide to Interior Secretary Babbitt;
tisussions witn I Taylor; discussions with G. Pitthlyt: discussions with L.
*-to::
discuss:ns w:th aides to Cong. Solomon. discuss::ns with BIA
Zcngressicnal lIaIson aides, memorandum regarding Solomnc/Torricelli
to L. Taylor and '. Kitto; review Solomon/T::ricelli legislation
u!tn partners; discussions with Congressional staff, re:Iew L. Kitto's
m

Taylor

reto=:

cricelli

lezIslatier
S s

57.300.00

AA 0000263

::1-

..c t'1'E.a-.*r:

O'CONNOR & HANNAN


K" *' **.co.P - * s ewoe -"
sew
l-

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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

O'CONNOR & HANNAN

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

Hon Lewis Taylor


Chairman. St. Croix Tribe
P-0 Box 287
Hertel, Wisconsin 54845
Dear Lewis.
Enclosed please find OCror & Hannar. s bill for services rendered in April
pleased to beof service to you.

We an

If you have an\ quesuso.. easee don't hesitate to call

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

Nature of Matter: ZCo

-r=e=

'E: =*1:

Tribe

p.:. Sox 287


er:el. Wisconsin

iso-

NW

3483

OICE

-s -aIN\
-

:20006-

p-Oe

t-ack

wan" "OL SEMfTTANCE

to

;:no :o::ersion
:fess::r.a-

ser.ces

rendered through Ar:1 30.

1995

of Interior Insular Affairs; review


. Glidden of Depa-mez:
wItMee- -from J. Diffy, aide to Sec. Babbitt. tD Sen. Wellstone; discussions
letter
discussions with 1. L-zto; discussions with L. Kitto: memor:--"
of::nals:
a=: J. Jones; discussions w::h ites
for ..
letter
.:zKl::regarding
of the Wisconsin Conrg-ess:onal delegation; discussions with L
::1l2:::
o:scussions with aides to %embers of Congress from Wisconsin;
d:srussion with Tom Corcoran regarding need to call White House an Hudson c=
Trark
:s:ZssI:: wItn Larry Ki:::. iscssi::.s with L. Kitto; discussi:ns .:-.
.report on April - meet:ng of L-. Kitto and L. Taylor; discussL-vt:-. 7.
regarding Sen. D'Amato's in-.*lvement in Hudson Dog Track
:..oany and need to communicate this fact to White House and Sec. Babbitt z
: teorer Department; call to Loretta Avent at- White House.
Report to Tom
: :oran, meeting with M. Colopy;
istussic-s by teleconference with m.
aBaroock of Washington Post. - scussi=s with P. Ducheneaux, L. Tayr:
an.: L Kitto regarding the Washangt
Post i:vestigation, development of
s.-z:tersnewspaper clips for Washn:c--on Pzs: reporter; review documents fr=
-r
re,:ew of Ho Chuck Nati= res:lut.:o. approving Hudson project and
oass statement of oppositic=: re-*:ew pulic
statements regarding Milwaaae
.- e=alj stadium statements by tribes invo--d in Hudson project applicatic-:
= =earat::. of memorandum and de:ive-v of sane and local newspaper clips
-- zaro:.
Hudson project to Waso:in.=-n Pos: call to White House to Loretta
A.e=t's office; discussions wit= L, t tto. review MIGA file
for September
F -:zr-volv:.9g
studies by Dr. Wrra-. and A---ur Anderson, Inc.; review file oo
*Finding of No Significant Impact ; discussions with aide to Interior Secro-r.Babitt:
discussions with L. Kitto; draft letter
for Sen. Wellstone; memorazdu::
L- Kitto; discussion with Tom Cor--oran regarding fax to Loretta Avent.
:--afti=g and sending fax to Ms. Ave:-; discussions regarding White House wvz*
.
Connor; memorandum to white ame aide L. Avert for P. O'Connor;
:rora-dum to L. Taylor; memorandum to L. Kitto in Green Bay, Wisconsin;
.scussions with H. Sibbison, deputy to Interior Counselor J. Duffy7 letter
a=t

Taylor

Me--ers

ar~eax.
OC'Zonnor

AA 0000266
-.

O'CONNOR

&

HANNAN

3337

,99 OENNS VLJ.


wasMcos. ::

.veN429 NW
2OCCt-34a3

E:

INVOICE
-

32594-::::
--Nature of Matter: Dog Tra:-

-IS
PLEASErETuN

sT

)EMrT

aNCE

documents to H. Sibbison and Counselor Duffy: discussions with L. Kitto,


drscss:ozs with BIA regarding September 214, 1994 correspondence with Minnesca
up appointments witn
tribes; discussion with Larry Kitto regarding setti:.N-C and White House; long distance calls to Loretta Avent office regarding
*r, decision to raise the Hudson Race Track issue with President Clinton in
Mi-eapclis if : did not hear from her- Meeting with the President on the
9Ldson Race Track issue with Bruce Lindsey and Linda Moore of the White House
regarding Hudson Dog
staff answering call from Loretta Ave-t and her staff
Tracx. Repor::ng to Larry Kitto; plan strategy for final week before T. Collier
memorandum fo S
flnine for 'consultation, ends at Department of Irterior,
. -5 . Epstein, top aides to Ser-at:r Wellst:ne, discussions with Larry
on Fr:day
meeting
and
dis=.issing
K:::c
St. Paul with .arry
.n
Long distance telephase conversation witn Lora
.- : ::
?cwer of the D.N.C.
:scussion with Pat
Rartlsan of the Presidential Comittee to Re-elect
and impact of L. Aver: f
.eeting
with :resient C1i:.t
- r regarding his
r- .:e-s: s 5aff. arrangements for Wasnng::n meer:g this week for Tribal
with staff aides to House and
Incans
:rom Wisconsin and Minnesca, see::g;s
Senate nearing committees, disciss-rs .. :h .. Epstein top aide to Senator
-:re several discussions with H. Sibbison, aids to Secretar Babbitt.
S
asc-ssions with 0. Skibine: disouss.:-s i;:. .ar-y Kitro, discussions wit r,
-ri
tr-e.d:scwssion with S Liable of Peat
5
B:erfield
of Ho
rwv:
olscussion with M. Gaber of :c-=zers & Lycriand, call to L. Taylor.
dzscu4ssimns w::h aides to Interior Secur::y Bobbitt. discussions with aides to
Fenarer We-s:nne: calls to the White Boise and the D.N.C. regarding tribe-s
Call to
-eeting with Chairman Powler. Call to 7o, Ccreoran regarding same.
arry K:::
..
n Washington, D.C; disc ss:r.s with M. Epstein top aide to Senator
-e1stone oisoussions with H. S:boers:.r a.de to Secretary Babbitt, call to L.
.isr=ssions and memorand:- t: Zocpers & Lybrand, discussions and
rrards to Peat Marwick, strategy dis:.ssions witb M. Epstein legislative
:::
f=r Senator Wellstone and 1. Bu:terfield. tribal attorney for Ho
. Natior.. discussions with Larry
::tto; meeting with Larry Kitto and David
ercer at D.N.C. discussing contributions program for the Indians; Meeting with
chairmann Fowler, David.

i-

e S$S7.500.0

AA 0000267

O'CONNOR & HANNAN

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

VWSWUTOU DC. ZOOOG634A


,202 &07-.00
,- z2cZ .6-21108

7"

June 27. 1995

Hun. Lms Tarle


Cham. 2L Croix Tribe
HimL1 'R~sionsin 54845

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

serv~ies retiered through May 31,

1995

Report to -z- Corcoran regarding Friday meeting at D.N.C.


Telephcne conference with D. Mercer regarding appointment at White
House with Rarold Ickes; Finish briefing of T. Corcoran on Fr.day
reetMt.==
t N.Z.
calls to: N : regarding White House appointment; Long
with Larry Kitto.
::rference
te-e=ho-e
TeLethene rails to D. Mercer at D.N.C.: Report to Larry txtto
rezarctng Thair-an Fowler's memorandum to Harold Ickes: discussions
O ton=or and L. Kitto regarding delivery of materials to
wt:n F
Whzte House as requested by D. Fowler, DNC Chairman; discussions
regard =g see:Lng with White House Deputy Chief of Staff H. Ickes;
cs=uss:ons wctz F. Ducheneaux; discussions witn aide to Senate
:a.ian .Aff1:rs ::mm:tee: discussions with Department of Interior

itszance

to Harold Ickes at White House setting for.t reasons t=


Draft letter
trust lands for Casino at the Hudson, w: dog track;
approve crea:.=c
:s=ss~on vt::. Larry Kitto check-ng on facts set forth :n Ickes
etter

Ds-ussLor-s wit- p. O'Donnell: review memorandum for Whi:e House


Deputy Chief of Staff H. :cKes; discussions with P. O'Co~nor; letter
KItto; merrandum to ..
and meonradm to H. Ickes: memorandum to '.
avor
-e=:a-.zum to DNC Chairman Fowler and D. Mercer; discussic=s
with F. Du-heneaux; memorandum to P. O'Connor; discussion with Tom
Corcoran a- editing letter
to Harold Ickes; Arranging distributicz
of letter.
Discussiorns witb F. Ducheneaux; discussions with L. Kitto:
discussions 'Ith BIA officials;
discussion with Tom Corcoran; Long
distance telephone conference to Tom Snyder briefing him an problem
Fax to Snyder; Call to D.N.C.

AA 0000270

O'CONNOR & HANNAN

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

Long distance discussion with David Mercer regarding follow-.p with


Harold Ickes: Diseusuican with Tom Corcoran regarding follow- -p v:it
congressional delegatims; discussions with P. O'Connor reaardi-g
White House involvemei
in our case at Interior Department;
disv ssitr.s with L. Kit-to; review materials from L. Kitto a=! PO znr.zr. memoranira to L. Kitto.
Meetg with triba: representatives; discussions with F. Duc=eneaux.
tt::
discussions with partners regarding White House actions to
discussions
discussions with BIA officials;
nizstt pr:e:
ant
tto
regarding hearing advising the :rzes
-=a'to .a -y
Mi:teszta and Wjsronsin delegations regarding my letter
to
to get update.
:ces: Call to David
e-ephcne conference to D. Mercer of D.N.C. regarding status report
o. nee:;t. with Harold Ickes; Call to Tom Corcoran regarding se-dng
accou.:ar.ts repc-: to Harold Ickes. discussions with P, O' C:tz=r
rezart:ng Deputy White House Chief of Staff H. Ickes; disc-s;te-.s
w:tn Z. Ktto; me-crac na to key Wh:te House aides regard:t; c1iet:
issues.
Revew of Peat Ma-wick report. .etter and memorandum and Peat
Marwicx report to H. Ickes, Deputy white House Chief of Staff;

1:t:

a-mcer

Ma:::

discussions with White House aides: memorandum to L. Taylor;


memorandum to L. Etetc for MIGA: report to L. Eicto regarding
President Clinton's comments about "our friends' and racetrack
issue; get report from Tom Snyder that he talked to Presiden:
Clinton regarding status of matter. Report to D. Mercer, To
Corcoran; call to John Sutton at Harold Ickes' office; Report to
Larr, Kzto.

Mercer

Discussion with David


regarding delay in getting appzin-ment
with Harold Ickes.
Meeting with Frank D. and review wall Street Journal article
on
Delaware North; Meeting with Tom Corcoran and draft proposed letter
to be sent to Minnesota delegation to Harold Ickes regarding: Hudson
dog track; Long distance telephone conference with Larry KLtto
arranging meeting wn
Minnesota delegation on Wednesday, May 24 in

O-CONNOR & HANNAN

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

emeeting with David Mercer of the D.N..;


Washimgton, D.C.; D
Report on cause of delay in meeting with Harold Ickes; discuss::s
w::h P. O'Connor regarding White House strategy and action wiDeputy Chief of Staff a. Ickes; discussions with L. Kitto; te..-a--z
conference with L. Ei-to and P. O'Connor; discussions with P. "ayl_=
for Minnescta
of Dueneneaux and Taylor Associates; draft letter
Ccngress~onal Delegacim and send to H. Ickes of White House staff
regarding
next meet:-,
dlsctsstcis with P. OConnor and L. Kitto
lans and actions.
for Minnesta Congressional Delegation t: sez
Precarat:cn of letter
White House aide Harild Ickes, discussion with Pat O'Connor.
discussion with T. Krazewiski of
discuss.cn with Larry Eit:e.
Nation. report to 'ar-y Kitto: meet with Larry Kitt: and
.Terry MacAuliffe explaining our story.
Trip to the Commnittee to Re-Elect: (Terry MacAuliffe) : Conference
with Chairman of Natinal Finance Camnittee asking him to agree to
call Harold Ickes and arrange appointment for Indians; Dinner wiz
Al Gore; Conference with Peter Knight and David Strauss regarding
Indian problem regarding Hudson dog track; discussion with La-r
Kitto.

discussion with Pat OConnor. delivery of proposed letts-

Minnesota Congressional Delegation to Larry Kitto and aides to


Congressman Wellstcne. :ngressmen Oberstar, Vento and Sabo,
preparation of draft letter for Senators Daschle and Kerrey for
correspondence with White House
Chief of Staff H. Ickes.
memorandum to Lar-y Kitto. discussion with BIA officials.
Discussion with Pa: C'Conor
discussion with Larry Kitto,

Deputy

discussions with Pat O'Connor with aide to Vice President Gore.


discussion with aide to Clinton/Gore Re-election Comittee, f:zalioe
letters for Senators Dasctle and Kerrey to send to Interior

to

Secretary Babbitt, draft of letters


for tribal leaders to se-o
Secretary Babbitt; reporting to Tom Corcoran on discussions with
Peter Knight. David Strauss at Al Gore dinner; Report on meeti-g
with Terry MacAulife.

O'CONNOP & HANNAN

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

Discussion with E. Ducherneaux, discussions with aides to House


Natural Resource Caunittee, discussions with T. Glidder, major-:v
counsel to House Subcomnittee on Native Americans, discussion w::z
aide to COngressman D. Young, discussion with aide to Congressmam
Gallegly.
Discussion with Larry Kitto.
Discussion with Pat O'Connor.
Discussion with David Strauss, aide to Vice President Gore.

Memorandum to F. Ducheneaux.
regarding Delaware North.

Discussion with F.

Ducheneaux

Long

distance discussion with 7om Corcoran regarding Milbur Wiz


;ourmal article regarding dog track; Read fax; memorandum from 7
Krazewski of Ho-Chunk Na::.
Memorandum to Don Fowler/David Mercer
Memorandum to Tom Collier. Memorandum to H. Ickes/Johin Sutlon.
Discuss::.
Merncrandun to L. Taylor. Discussion witn Larry Kitto.
-itPat O'Connor. Meetings. discussions and correspondence
L. Kitto. clie=t. agency representation and Minnesota
Members of Congress and their staff assistants
on this matter.

involving

rotal Services:

S'

AA 0000273

O'CONNOR & HANNAN

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: '

Nature of Matter: Dog Tracx t:

RE-JAN "5s POP "N WPLEASE

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

O'CONNOR & HANNAN

1*S.E

gamc:

**...

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-myta..

55SuS.Dalt

AIS*aOn

000274

3345
O'CONNOR

&

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04*

HANNAN-

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'C4

El.
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SDC 500065.33
4-i-

-2-R 007_-06 -05-202

A.

July 11. 1995

Hon. :' wis Taylor


Chai:-an. St. Croix Tribe
P.O. Box 287
Her... Wisconsin 54845
Dea Lewis:
Enclosed please find our invoice for legal services rendered for June 1995.
If you have any questions, please don't hesitate to call
Warm personal regards.

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

THI5 PCAION wTH You0


RETURN
PLEASE

Nature of Matter:

son Pr::er:

Services

fessirna:

REIrTANCE

Dog Track to

rendered through .une

30. 1995

Yem::ng with L_ Kitto; memorandum to L. Taylor regarding appointment


with Secretary Babbitt; memorandum to White House aides Ickes,
Sutton, Avert; memorandum to DNC; meeting with L. Kitto and S. Dacey
regarding Wisconsin tribes and Wisconsin Congressional delegation.
zO-Uerence with Tom Corcoran and call to Senator McCain to set up a
7=eing concerning a contested application for certification at the
of Interior; discussions with L. Kitto; discussions witr
regarding Senator McCain; re-orandum to P. O'Donnell;
F. :
wth P. O'Ccnnor; discussions with D. Mercer of DNC,
.s:ssr.s
:
memorandumm to Vice President Gore; memorandum to T. MacAulliff of
C11nton/Gore Re-Elect Committee.
- - .
distance telephone conference to T. Corcoran regarding Terry
'arAuliffe arranging appointment with Harold Ickes: Discussion
regarding getting City Council at Hudson to take legal action
opposing casino; discussions with P. O'Dennell regarding Senator
McCain: discussions with Democratic National Committee officials;
o*s:ussions with P. O'Connor. discussions with BIA officials;
d-sussions with L. Kitto; memorandum to L. Kitto; report to L.
.a,-0r regarding meeting with Senator McCain on June 8; discussions
F. Ducheneaux; discussions with MIbA regarding Senator McCain
F- e:ing; discussions with Ho Chunk representatives regarding meeting
-ri. Senator McCain; discussions with partners regarding City of
=son involvement and representation.
with Senator McCain, Frank Ducheneaux and Tom Corcoran
==ncenng possible infringement of unseemly elements into the
:=dian gaming situation in Minnesota: review file;
discussions with
O'Donnell; discussions with F. Ducheneaux; meeting with Senator
McCain. F. Ducheneaux and P. O'Donnell; report to L. Kitto: report
to L. Taylor; discussions with L. Kitto regarding Congressman Sabo;
discussions with White House Chief of Staff Leon Panetta: review
ren-orandum from L. Kitto

Ce=artment
o::nell

2.

AA 0000276

O'CONNOR & HANNAN

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

setting update from T. Corcoran regarding meeting with Senator


M:Cain and with Hanew developments.
: sussions with aides to senator McCain; discussions with several
aides on the White House staff, including aides to Leon Panetta and
Harold lekes; discussions with L. Kitto; memorandum to L. Taylor;
dosoussions with L. Taylor. discussions with aides at Department of
Interior.

Cscssions with F. Ducheneaux; discussions with aide to Senator


vocarn, Cnairman of the Senate Indian Affairs Committee; dieusseons
L Kitto; discussions with
=:A officials;
discussions wt.
--.
representatives of Ho Chu'x Nation regarding Hudson prect; long
:stanoe telephone conference win Larry Kitto regarding *eeting
from Congressmen and Senators
Checkin.e on letter
Sdson. Wisconsin;
:o Wnte House and Interior. Discussion regarding support to be
given to Committee to Re-elect and D.N.C.; Discussion with Tom
to roor an.
Meeting with tribal
leaders at Hyatt Hotel on Capitol Hil:
with L.
K.ttc. eeting involving troal
and L. Kitto with Tom Foley.
ncorring Commissioner to the National Indian Gaming Commission;
discussions with aides to Senator McCain; discussions with BIA
ifficals.
:tecussions with L. Kitto: discussions with tribal representatives
of the Minnesota tribes; work on the tribal leaders' meeting with
Interior Secretary Babbitt; memorandum to L. Kitto.
wem.erandum to L. Kitto; discussions w:: L. Kitto; discussions with
azdes to members of the Minnesota delegation in Congress.
Discussions with partners regarding status of client issue;
discussions with BIA officials;
discussions with aides to Interior
Secretary Babbitt; discussions with L. Kitto; discussions with aides
to Senator McCain. Meetings, discussions and correspondence
involving Larry Kitto, client, agency representation and Members of
Congress and their staff assistants on this matter.

leaders

Total Services:

O'CONNOR & HANNAN

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

TwIS OfTo wiT. yo0UREMIACE


RETURN
PLEASE

.sburseme=zs:
25.80

phc:z::;1es

4.

:-=a tszance Telephone


?zst ace
;c:r:ocess:ng

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

O'CONNOR & HANNAN


e*t
S

ETu

*C- se..rs

'-

*woe

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fl.u

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$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-

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us

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9V.%

ES-LVA-A

202

86

ALIvo

-s

Cn

August 9. 1995

Hon Lewis Taylor


Chairman. St. Croix Tribe

P.O. Box 287


Hertel. Wisconsin 54845
Dear Lewis
Enclosed please find our invoice for legal services rendered for July 1995.
If1ou hase any questions. please don't hesitate to call.
Varm personal regards.

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

essional services rendered roughh

PORTo

track

WITHYOURREMITTANCE

to

July 31,

1995

Discussions with L. KZtto; discussions with P. O'Connor; disvussizts


with aides to House of Representatives Native American Subcommittee
Discussions with L. F-tto: review story in Minneapolis Star
rioune
regarding Hudson prc:ect; discussions
with Bureau of India. Afars
off:::als;
discussions with legislative aides to members of :e
wis:onsin Congressional delegation and the Minnesota Congress::.a
aeie=auctc.

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

O CONNOR & HANNAN

3351

PEN.svtS&MIA
WAS.IN5TCoN 0 C
2

919

Aa

'.

'E
C

m.-

INVOICE
.*****

3259;-C::

.rec

Nature of Matter: Dog

TraO.

::

PLEASEPtETiaN",$ .Pcro wr'-

tC

aEuwMACE

DOscussons with P. O'Connor; dscu-ss:r=s with L. Kitto; discussions


witn aides to Congressman Longley;
-:-ssions
with aide to
Congressman Metcalf; memorandum to .. K:oto.
Memorandum to Lewis Taylor; memerart
** to L. Kitto: discussions with
BIA public information officials; discussions with aides to BIA
ga-ing office, discussions w:th .evs taylor; meeting with Tim
Glidden. Counsel to the House Nativem .rerican Subcommittee.
Discussions with P. O'Donnell; wemoranduz to Don Fowler, Chairman of
the Democrat1c National Cornittee; mec:rg with aides to Congressman
Jac< Metcalf and Congressman Jc=es; :== distance discussions with
Cha:r=an Fowler regarding :epar:-en: : interiorr decision to reject
an app.ication for a casino at
.ne
.:..
WI dog track; Sending
faxes to Chairman Fowler; Reporting t: 7 Corcoran and L. Kotto
regarding criteria voiced b y oppos:t.:r.
Sr.e!ng Larry Kitto on my conversa=::s with Chairman Fowler of :ne
DNC: Discussion regarding thank you letters
to White House and
re-rers of the congress; Discussion regarding fund raising;
ne-:randum to L. Kitto; discussL:ns .- aide to House Native
American Subcommittee; letter
t= Se-a.:: McCain regarding favorable
Huzsc. dec-sion for client.
Discussions with L. Kitto; review traft onank-you letters
for tribal
.eazers. review memorandum from L. .t::. discussions with general
o=.cnset of Senate Indian Affairs CerL:tee; review ruling by
inter-=
Department declining req-uest !=r certification via
assistance given by Senator McCain.
::s-nr. thank-you letter
:
Sens:: McCain for his assistance tze:eot.
Discussions with Pat O'Connor regartooq follow up on Hudson project;
dIscussoons with L. Kitto; meeting
i-. Lewis Taylor, L. Kitto and
trLca
representative.
Meeting with tribal leaders regard.== 5. 487 and scheduled hearing
by Senator McCain of the Senate Cos:::ee
on Indian Affairs today,
Zy; discussions with L. Taylor: tosrussions with L. Kitto to
get debriefing on today's hearing cn o=e Senate hearing; discussions
wit: L. Kitto regarding plan of aroLt" for 5. 487 and during mark up
by c'rittee and during August. mascrL't-:* to Lewis Taylor.

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

-reof Matter: Dog

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

Sen. M:.iuskS-en. :omenici. Ser. Thomas, Sen. Cc.erteli


dis:ussicn v!:.n Larry Kitto regarding this week s ee::.:;
::. Sen
:
:ee. :ax
Sinon. dis-.vsss with aids to Senate Indian Affa:rs
to Lewis Ta-:r memorandum from Lewis Taylor, work an=
represen-am:= :f tribe oy Larry Kitto during month cf
involving e:;s and discussions with client represe=z:-.es.
discuss:cs
research and meetings with aids and me-ers of
Minnesca :=rssional
delegation. discussions and reprrse.:a::c.
before agen.:.es of :.S. Government on bena-f of client:.
.:tal Servi:es.

.:-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

O'CONNOR & HANNAN

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

September 15. 1995

Hon. Lewis Taylor


Chairman. St. Croix Tribe
P.0 Box 287
Hertel. Wisconsin 54845
Dear Lewis
Enclosed please find or urvoice for legal services rendered for August 1995.
If you have an% quesnoas. please don'i hesitate to call.
Warm personal regards
incerely.

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

:essocna- ser-.::es rendered through August

31,

1995

15sc2ss-ons with P. O'Donnell regarding meeting scheduled with


Senator 'clain, Chairman of the Senate Committee on Indian Affairs
set for Friday, August 4; discussions with Lewis Taylor and his
re-resen.atives regarding the addition to the Congressional meeting;
itz
srnedule for this week; discussions with L. Kitto; discussions
homas and Coverdell;
Kassebaum,
aides me Senators Murkowsk".
preparation of schedule IGRA meetings
disc-ss:=ns with L. Kito
preparing for meeting with Senatr=
wasniz::n. :his week for :e.:.
Cz~raZ c. Wednesday and Thursday, Cal: to Senator Conrad's
and discussion regarding
ap1-.:-e*nt secretary: Reviewing bill
"=ssiz!e amendments; -rip to Wasningtcr. Discussion with Larry
Ki:::. indian matter regarding racetrack gaming and the Hudson dog
:razc
Telephone discussion and meeting with senior White House
staff and POTUS re expansion of gaming and the dog track and
cppos ::r. to so doing.
Meeting with Tom Corcoran to prepare for gathering of Minnesota and
with Senator McCain to discuss support for the
Wisconsin tribes
National Indian Gaming Regulatory legislation; discussions with P.
O'Connor; discussions with L. Kitto discussions with aides to
Senators Kassebaum, Thomas, Domen-c.
Murkowski, Coverdell, Dorgan
and Conrad; review memorandum from L. Kitto; meeting with Lewis
taylor for dinner and discussing purposes; call to Senator Zorgan's
office: Discussion with T. Corooran regarding Slate Gordon
Amendment; Discussion with Larry Kitto regarding who will speac at
the Senator Conrad meeting; Read L. Kitto memorandum on the Indian
Gaming legislation trip to the Hill m meeting with Senator Conrad;
Strategy discussion at dinner with clients.
Meeting with Larry Kitto reviewing gaming bill
and amendments;
Discussion regarding amendments clients oppose; Discussion regardSkip Humphrey amendments; Calls from Senator Dorgan's office a=d
.Senator Inouye's office changing time of appointments; Mee ting wit
Senator Dorgan and clients; Meeting with Senator Inouye and clients;

O'CONNOR & HANNAN

AA 000C85

3356

zu WE -CC

INVOCE
iamr_-g RegulatCry

Aet

RE-f;N
PLEASE

T5

0-

0-U
uEMTTnMCE

discussions with L. Kitto; disc.:ss.tZs with P. O'Connor; meeting


with trbal leaders; meeting w:z :r-zal leaders and Rob Foreman.
regarding
-e*orandum to file
leg slative aide to Senator 4atzstrategy disnssions with
. 49
position of Senator Hatcn on
leaders and Ryan Leonard,
tribal leaders; meeting with trregarding
leg s:at ve aide to Senator N::L.s: memorandum to file
post:on of Senator N4ickes cn S. 42-: discussions with tribal
Senator Inouye
leaders regarding the meetings wC-- Senator Dorga-.
and Senator McCain.
P. O'Donnell regarding
-.
wath
st-sr=s
Duszs2Ins with L. Kitto:
with Senator McCarn; z s-3-S.izns with James Symington and L
-ee::_n
regarding eeating witn Sers::r Zan Akaka. arrange and
-::=
accrnpany delegation of three :z-Ln tribal chiefs to Senator
McCain's office and discussios ==:erning development of the new
oill amending the Indian Gamseg 5.ef:--n Act and report back to Tom
Corcoran on the positive react.c= :! Senator McCain on same;
discussion with Tom Corcoran reza_;*g Senator Inouye meeting;
Work-UP
Kitto getting briefing on
Long distance discussions watt "..
to Senators Inouye,
Senator :nouye meeting and detalE =f letters
Dorgan.
and
Conrad
on Senator Inouye meeting
Long distance to Tom Corcoran rep=tng
to
1995; Arranging for letters
with clients on Thursday, August
go to Senators Inouye, Conrad az :,crgan; memorandum to file
to tile regarding Senators
regarding Senator Akaka: memora-r
Akasca. :nouye and McCain: dis-as::ns with R. Leonard, legislative
aide to Senator Kassebaum; disc-sza=ns with L. Kitto; discussions
with Frank Ducheneaux; discussing.
with aide to Senator Coverdell;
discussions with P. O'Connor; rev--s
memorandum from L. Kitto;
discussions with Executive Dire===r of Senate GOP Conference Thad
Cocnran: discussions with legisaave
aide to Senator Cochran and
report to L. Kitto regarding meet.ng scheduled for 2:30 on August a.

2.

AA 0000286

O'CONNOR & HANNAN

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

t:iscss=ns with L. Kitto; discussions wi-v legislative aide to


S-.atzr McCain and Senator Coverdell. ettng with Haley Fisackerly,
ae
to Senator Thad Cochran, Cha:t-naz :f the Senate Republican
Committee; discussions with aide to Upper Sioux Tribe in
Czerence
reference to L. Kitto's meeting with too aides to Senator Wellstone,
in the day with L. Ytto; discussions with
dzsussicns earlier
t:lislat:ve aides to Senators Cam-bell. Thomas, Hatch, Nickles.
draft letter for tribal
^orton, Murkowsk: and
- sseba:--.
eaters regarding S. 487; semorant-z7 to tribal leaders.
;::endanze ov L. Kitto at tne Senate CZ*-:t:tee on Indian Affairs
-r
n.S.
487; discuss:ons witn
7.tto; discussions with aides
:o
Sena-e Z=1::tee on Itna.
Affairs
ro-zx Tribe; review various
3=
A ss.ons with E. Songe:ar-y of S:
:e;:r:s regarding action taser. by the Se-ate Committee on Indian
-:ars
on S. 487; disouss:or.s .mt
L.: 1:ddon, Counsel to the
-..se Na::ve American Suncomrt:ee. meradum to clients;
:.st sslons with Audrey Kennen. discussons with P. O'Connor and
t st*ussi:ns with L- Kitto, preparing -- a-k you letters
to Senators
C:=uye, Conrad and Dorgan. Z:soussion
::h Tom Corcoran and getting
trading
on Marklys; Revising letters.
is:=,ssions with aides to Senate Coa::tee
on Indian Affairs; review
4E7 as passed by Senate Ce=.ttee = :ndian Affairs; memorandum
:: Senator Inouye; memorandum to Senator Conrad; memorandum to
Senator Dorgan; discussions with Patritk O'Connor.
CIsz ssions with P. O'Connor: dis-usso--s with L. Kitto; discussions
*Lt" 7
Ducheneaux; discussions with aides to Senate Committee on
Iri:an
Affairs; discussions with aides to National Indian Gaming
on. discussions with aides to t!e Bureau of Indian Affairs.
:etter
from the Canazans -- ribe; preparing response.

M:Ca:

Reading

AA 0000287

O'CONNOR & HANNAN

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

discussions with aides :: Senate


s :h L. Kitto;
4
ership aides
r n :ndian Affairs; discussions with :-- :e
regaz---.' ;cst-Labor Day Senate floor schedule; :a-: fr-m David
regarding possible lawsuit by wisr.sin Tribes
erer =6 =e DiNC
that !a. ei to get the race track trust land free ::teror against
and Tom
Don 7:wer a.-. our clients; Discussion with Larry ?zt:
Corcerat regarding same.
:..% K ::
attendance in Milwaukee at tribal neet:i= regarding
.ative
:5RA d er-ssions with aides to House Subcomm:ttee ::
discusstions with P. O'Connor; :isr ssrons with GOP
A,.rer az- sass.
call to Larry Kitto; Call to DNC recarz--c possible
eaders.n:.
t eporting to T. Corcoran.
ss:
:-volving
L. Kitto in Milwaukee with var:v s national
=d =.= associaiton representatives and
discussions
r-:::
discussions with P. O'C:nncr; dsss.s
with NICA
-epresenrta:::-es; call to David Mercer of D)NC regarin-g possible
:aws-:: Recrting to T. Corcoran.
7ele=y.Tere ::s:ussions
with Larry Kotto regarding 7o Zaschle
-- aiser i= Minneapolis; Discussion regarding ::r
ttee to
Re-E-ect d--rer in Washington, D.C; discussions wi-t L. Kitto;
isz ss:A.s with aides to Senate Committee on Indian Affairs;
tlscass =-s with outside lawyers and consultants t= "arious Indian

leaders;

ri-tes

dashington.

R-ev-w .. Litto's memorandum to tribes regarding stat-s


of
Zon-ess:ral
analysis concerning IGRA; discussior-s vib aides to
S-=:o-ettee on Native American Affairs.
Dis= ss:.s
with L. Kitto; review O'Connor & Harnar's analysis of
all
.5. Senators' likely positions on S. 487 as repor-ed by the
Senate :neittee
on Indian Affairs; review memorandal from L. Kitto
regard:
Senator Wellstone and the Coeurd'Alene tribe of Idaho and
:nat trzoe s national lottery proposal.
Zis ss rs
-. wi=h L. Kitto; discussions with aides Boose Native
Ame:: "at C=cossmmittee; discussions with staff of
tre NGC regarding

bOuse

O'CONNOR & HANNAN


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4.
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3:594-:002

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Total Services:

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14
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'3/95 "ARRY KI"O
exCe-ts
lodging and meals

Total
7rta:

3.:

566
9

480..

Disbursements:

Services and Disbursements:

.0:

77

:6 4.:

77

*****Sta:eme=f ACoun**.....................
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