‘STATE OF MAINE COMMISSION ON GOVERNMENTAL ETHICS ‘AND ELECTION PRACTICES 135 Stare House STATION AuousTA, MAINE, 04333-0135 October 8, 2010 By E-Mail and Regular Mail Daniel I. Billings, Esq Marden, Dubord, Bernier & Stevens P.O, Box 708 Waterville, ME 04903-0708 QUESTIONNAIRE CONCERNING CUTLER FILES WEBSITE Dear Mr. Billings: As part of the Ethics Commission staff's investigation of the Cutler Files website, the staff requests that your client respond to the questions below. The objective of this request is to receive sworn responses from your client that will assist the Ci ion in evaluating your legal argument, while maint involved. If possibie, please respond no later than Wednesday, October 13, 2010. For questions relating to payments, the request covers all payments which are known to your client, or which your client may reasonably discover, even if your client is not the party that made the payment. ‘The staff requests that the Cutler Files respond to each of the following questions in the form of a redacted affidavit, John Doe affidavit, or other sworn statement: Individuals Involved (1) How many individuals conducted the research, writing, editing, and graphics of the Cutler Files website? Include any consultants or other individuals who were paid. Please provide a breakdown between (A) individuals in a “core group,” and (B) individuals whose contributions were less significant or were peripheral 2 __ Please describe the work (¢.g,, research, graphics, writing, editing) performed by each individual counted in question (1), referring to them by whatever convention you prefer (¢.g., Person 1 ...} (3) Of the individuals counted in question (1), please identify those who were compensated for their labor. OFFICE LOCATED AT: 45 MEMORIAL CIRCLE, AUGUSTA, MAINE. 7 WEBSITE: WWW. MAINE.COV/ETHICS PHONE: (207) 287-4179 FAX: (207) 287-6775Daniel Page 2 1. Billings, Esq. October 8, 2010 (Did any candidate authorize the development of the website or an expenditure for the website? (5) Did any party committee authorize the development of the website or an expenditure for the website? (6) Did any political action committee authorize the development of the website or an expenditure for the website? Research (7). Please describe the process by which the research for the site was conducted or obiained. Include any response you wish to make to the October 6, 2010 letter from the Cutler campaign’s counsel. (8) Describe when the research was compiled or obtained. If'a major portion of the research was obtained during a specific time period, please identify that period. (9) Were payments of money made in connection with the research that is included on the site? If yes, please provide the amounts and dates of the payments with as much specificity as is possible within the time limitation of this request. (10) Was anyone compensated for the labor of gathering research displayed on the site? If'so, who was compensated and how much? (11), Provide an actual or estimated total of payments for research (including, compensation) that is included on the site. (12) Did you receive research for the site from some other source? Costs of Website (13) How much has been spent to date on the domain name for the site? Please provide the date of the purchase. (14) How much has been spent to date on the hosting of the site? (15) Please describe any other payments made in connection with the website. (16) What is the total anticipated cost of the website, including payments made for research?Daniel |. Billings, Esq. Page 3 October 8, 2010 (17) Please state which individuals referred to in question (2) made payments for the site. (18) Please state whether any payments were made in connection with the site (including for research) by any other individual or organizations, Your response will be a public document. If you cannot fully respond to any of the above questions without identifying your client, please indicate which questions have not been fully answered This questionnaire replaces my letter of October 1, 2010 requesting information concerning paid research on the site, After reading your response, the Commission staff will consider what other requests (if any) are necessary for the Commission's investigation. If you have any questions concerning this request, please call me at 287-4179. Sincerely, See oe Executive Director ce: Assistant Attorney General Phyllis Gardiner