FEDERAL ELECTION Arnericm Federation - PDF document

1 FEDERAL ELECTION Arnericm' Federation G
FEDERAL ELECTION Arnericm' Federation General Counsel's Report dated April reviewedwarious facts forth in the complaints, available material Office advised the Commission that political activity election cycle paid for with general treasury First General Counsel's Report Commission approved specific facts found would instead investigate whether coordination between Democratic candidates the other. After considering First General Counsel's the recommendations therein, the Commission, potential recipient committees violated same date, time with respondents, leaving the those respondents; political director The investigation has developed evidence, discussed here

2 in, projects, activities, needs, at leas
in, projects, activities, needs, at least a major project "Coordinated Campaign." relatively minor exceptions, developed no evidence the general public a recipient candidate committee that meets the standard for coordination the instance came closest, which involves contacts advertisement broadcast coordination appears with representatives those elections with which report is intended the findings evaluate the most significant evidence in hand under the evaluation, this the Commission take a probable cause reporting violation. Campaign Cornmittcc Democratic committee the extent generally referred to Information developed investigation supported First General Co

3 unsel’s Report’s description d
unsel’s Report’s description divided into broadcast advertising component Between December, television and radio advertisements radio advertisements. At Democratic Members the House Representatives were were targeted more detail reproduced at Attachments First General Counsel’s Report, struggle between Congress over appropriations legislation, the ensuing Federal government. advertisements were broadcast during periods intensive action minimum wage. Counsel’s Report, advertisements about the broadcast concurrent scripts were targeted Member legislation at the viewer to call the similar language. Each advertising been created multiple version

4 s advertisement, each version comprehens
s advertisement, each version comprehensive information these advertisements advertisements’ frequency in terms ratings points purchased per district. flights between Greer, Margolis, Mitchell, Associates. However, beginning Media Strategies election, the television advertisements were arguably “flights” broadcast clearly indicate. the nine would criticize the incumbent aired in late clear connection advertisements and legislation that the subject intensive legislative the time the advertisements. these advertisements Republicans and incumbents. late September election day, so-called “electronic guides,” comparing the Republican incumbe

5 nt and Democratic challenger Democratic
nt and Democratic challenger Democratic nominees, the cases Democratic candidate’s presented more favorably advertisements appeared been carefhlIy designed avoid “express advocacy” advertisements broadcast fiom September, like the earlier advertisements, number and and ”various messages. advertisements provide it comes comes issue the ad is about], there is a difference. Call each advertising flight; the campaign candidate appeared candidates appear targeted in the First the printed voter guide broadcast advertisements, The investigation date has not been field activities has in determining the broadcast activities. Nevertheless, documents p

6 roduced by the other materials possessio
roduced by the other materials possession, indicate that printed leaflets general public and engaged in voter registration activities directed to members the general public connection with Federal elections. have provided its local affiliates staging press conferences and broadcast advertising campaigns. manual produced Services CorpJDemocratic engaged in voter registration drives, drives, phone banking, canvassing, voter identification, and voter maintenance activities with Federal elections. when the Conimission made reason believe findings in these expenditure could either a Republican Federal may trigger investigation sought potential recipient about the di

7 scovery efforts, "Coordinated Campaign"
scovery efforts, "Coordinated Campaign" described in projects and needs nominees for Federal the Democratic Senatorial Campaign Committee Democratic Congressional while this investigation the District Columbia issued Commission decided Christian Coalition court rejected the required for coordinated expenditures considered contributions. Supp.2d at district court stated that ‘express advocacy’ contribution prohibition would misread misread Valeo, 424 U.S. 1 (1976)l and collapse the distinction between contributions independent expenditures in such government’s compelling interest in preventing real large campaign contributions.” court went on

8 in which occur. First, “expressive
in which occur. First, “expressive coordinated expenditures made at authorized agent” would considered coordinated, holding that approach [taken court reasoned a spender engage certain speech indicates that candidate, giving such expenditures sufficient contribution-like qualities Act’s prohibition Second, the court absent a expressive expenditure 'coordinated;' where candidate or exercise control been substantial discussion negotiation between campaign and spender over, a communication's: intended audience radio advertisement); or court also 'insider trading' conspiracy standard" coordination. Specifically, the court addressed to extent contact

9 s expender and a campaign, such fact tha
s expender and a campaign, such fact that expender and non-public information, give rise the expressive expenditures by the court found that such contacts would not be sufficient establish coordination there was negotiation" regarding the expenditures. that coordination established if certain level decision-making authority for both the spender made expressive expenditures the campaign. other recent addressed coordination that the and the expenditures were made candidate. Memo. distinction between issue in case, which First Amendment communicative materials" spender finances materials candidate's campaign. that its standard discovery in fact-intensive inquiry a

10 ltowing inquiry into and extent communic
ltowing inquiry into and extent communications between alleged contributor the Commission determined Office determined proceed in these were in-house at that time Christian Coalition The various investigative resources have been devoted additional documents what had been did not the additional documents believed that produce evidence Should the the investigation these documents. the strands investigative resources have Democratic National Committee’s a collection statewide campaign structure[s] within state Democratic party [that was] created [partially] financed” Democratic nominees allied organizations each state; partially financed Education Associ

11 ation operated under Campaigns” eng
ation operated under Campaigns” engaged in a apparently intended centralize Democratic voter identification efforts within each thereof, thereby eliniinatirig duplication and enhancing committees’ ability Commission’s regulations non-Federal candidates. document entitled must have Campaign plan.” was also required to establish a “Steering Committee” include state- “each major ballot,” including elected officials, cases, allied organizations constituency groups such when each makes a programmatic Steering Committee within the state, state, member” was to “have a voice financial line-items and implementation the p

12 lan.” Moreover, each be formally be
lan.” Moreover, each be formally be formally which demonstrates principal players for the Steering Committee mirrored the the the plan meets the DNC’s specifications, it is shared with Coordinated Campaign funding National Campaign Committees Committees National partners including the DSCC/DCCC/DGA/DLCC and the AFL-CBO and the. NEA agree on the contents national partner will give their funding commitment the state. the individual federation personnel, considerable amount of plans, projects state parties, Instances, candidates, instance, in memorandum dated Indiana Democratic Political Director Rogers memorialized earlier telephone conversation he part

13 ies involved coordinated campaign, campa
ies involved coordinated campaign, campaign, the Weinapfel Weinapfel campaign, and the Carson campaign agree that a voter contact program in central and .. southwestern Indiana would be a vital element Democratic candidates Democratic nominee Indiana's Eighth Democratic nominee districts in which broadcast advertisements the voter the dollar the Indiana Democratic Similarly, a the DCCC regarding phone calls and direct mail plans themselves, approval, contained great deal detail about the the individual state. instance, a document that Michigan Coordinated specific plans absentee voting, canvassing, bumper stickers, activities for each Congressional district sta

14 te. Attachment specifies the number Afii
te. Attachment specifies the number Afiican American women voters telephone statewide, campaign will concentrate.” dollar available be devoted the persuasion Plan described other things, piece mailings District contrasting issues to be piece mailing criticizing . . piece mailing senior citizens “noting Republicans Craig, Medicare for seniors the wealthiest AFL-CIO either Dakota, the Coordinated Campaign following actions: Establish a a steering committee of 6-10 people. Paul Paul the South Dakota Employees] will Coordinators, with input the steering.committet, will organize labor county coordinators place by May Field Coordinators [will] identify iden

15 tify --Local Labor leaders and the Coord
tify --Local Labor leaders and the Coordinated Director will communicate financial needs input into (DNC Bates documents cited, date related the Coordinated Campaign, much less public. Where general public, parties' plans general public. the investigation evidence that veto power AFL-CIO communications a September Lindenfeld would the contrary. memorandum memorialized coordinated campaign plans were disapproved others. problems were mentioned with labor representation much phones, and “staffing.problem.” However, the that even hints at concern about conflict with the activities is the cryptic under “Wisconsin” that reads, “Overlap Feder

16 ation plan?” Attachment appear to b
ation plan?” Attachment appear to broadcast advertising activity There were requests made AFGCIO by parties, the but none for communications general public. exceptions the requests the conduct apparent point allowing the once such approval the state.” Attachment these budgets congressional district coordinated campaign.” Attachment follow-up memorandurn consultant Joe . . Where requests suggestions did involve money, involved communications by restricted class; for instance, instance, Education Association] early wherever (emphasis added). Coordinated Campaign Plan evidence tending to demonstrate through the CIO federations headquarters itself pr

17 ojects, activities, the state not merely
ojects, activities, the state not merely state Democratic the interpretation the Commission information about been more election-related communications that the "prearranged or coordinated expenditures to disguised .outside group power over million individual party committee subject to the approval that that approval "substantial negotiation coordinated expenditures, 1 1 I I 1. . . ._. I ! i I. I I :I i I -20- discovered to date do not appear to be sufficient under the Chrirtiun cocllition standard to show . coordination of the AmtCIO's communications. As noted, none of the Coordinated Campaign documents reviewed to date contain my Unmistakable rtftrence to un

18 y AFLCIO communication to the general pu
y AFLCIO communication to the general public. Accordingly, the documents do not reflect any request or suggestion by the DNC, or by any state party committee, or by MY candidate for any specific communication, or any general program of communications, by the -10. Nor is there anything in the documents that can be considered "substantial .discussion or negotiation" over the contents, .. timing, location, mode, intended audience or volume of such communic~ons. In short, the investigation of the AFLCIO's relationship to the 1996 Democratic Coordinated Campaign has developed no evidence to date of "cxprcssivc coordinated expenditures" by the AFL-CIO, as defined in C

19 hristiun Coalition. Mo~vc~~ because the
hristiun Coalition. Mo~vc~~ because the Christian Coalition analysis indicates that the AFL-CIO could obtain 8s much infokation it wished about the plans, projects, activities and needs of the DNC, the DCCC, and state Democratic partics through the Coordinated Campaign approval process and through party funding requests without engaging in "substantial discussion or negotiation" over specific :. . .. cxpmditur~ we believe it unlikely that Mer investigation of the Coordinated Campaign would devdop'such'evidcnct. ' V. CrClspqjgT s BEWEN ~.AFbcB OJpm FED ERAL CANDIDATES OR WR!R COMMITTEES 1. ' Denialsky Authorized Committees of Contacts with the AFLrCIO - Rqrsrdirr

20 g AFLCIO Communications to the General P
g AFLCIO Communications to the General Public To date, the investigation has developed no concrete evidence that any of the AFLCIO's most significant comunicatio~ to the general public were made at the rquest or suggestion of 5 any candidate or-candidate's committee, or were made after substantial discussion or negotiation 'I . .. .. .. .. . _. concernjng the committees requested broadcast advertisements the requests requests assistant to Mitchell], and Steven Rosenthal each recdl that during the federal candidates formal discostery effcctivtly denied, moderately intensive Commission, December instances, committees responded with respondents in these ejght res

21 ponded to Provide Written instances, the
ponded to Provide Written instances, the the committees’ Bell for Congress committee “respondent is without sufficient that “Respondent sufficient information the Walter . . I' .: committee to virtually every question the responding treasurer personal knowledge the matters the Commission investigating. Attachment the eight committees respond with less than complete denials Produce Documents and Orders Provide Written Williams for committee, the Congress committee, specifically selected discovery targets because their districts. communications, conferetrces, committee to documents responsive Office's initial that, although less than complete, oth

22 er candidates committees, including con
er candidates committees, including contacts with the all concerning Second, such evidence the investigation concerning transmission with the Coordinated Campaign, most often transmitted appeared that all the information it wanted about candidates’ projects, activities needs in that context specific expenditures in the examining these Office contacted counsel for eight committees in contacts between his communications to general public that counsel clients had conducted adequate searches to contentions that they Counsel took far longer Office anticipated, Nevertheless, all submitted affidavits, executed guides during which the general public. noted, docum

23 ents concerning their committees indicat
ents concerning their committees indicate the contacts other information which particularly helpful challenging the committees' denials believes fbrther discovery committees would produce evidence Walter Capps for Congress committee, somewhat disturbing that the committee even explained what efforts it contact individuals who may have would have enabled the Commission's inquiries. disturbing in light a document Commission's possession reflecting between the Capps committee Department concerning radio Capps's opponent that criticized advertising campaign. However, considering the lack contacts between any other congressional candidate's authorized committee consi

24 dering Representative Capps's death in C
dering Representative Capps's death in Congress, this Office outstanding questions Capps committee. First General 1995, the substantial resources Director Steven Rosenthal in press accounts the Oregon special election for political activity nationwide later that been political director the Service during Sweeney’s became campaign Democratic nominee the special election. has admitted in response interrogatories that Rosenthal numerous communications with with of the Wyden campaign] throughout December December the AFL-ClO’s efforts to encourage union members to special election.” Attachment included seven direct flyer that were distributed, accord

25 ing materials stated they were and. paid
ing materials stated they were and. paid Political Education, Oregon affiliate produced entirely created by pro-Wyden messages I public, under General Counsel’s “labor walks” would walk through their communities speaking people on behalf and passing Commission interrogatories that Dave Political Education, recalled “attending several AFL-CIO were also attended by Chapman and Pate [of the canvassing “canvassing program” Office conducted individual union members their spouses who participated in “labor walks.” their descriptions and CIO’s discovery responses, after communicating with volunteers, the affiliated unions

26 communicate those provide information ab
communicate those provide information about they could The union members would then literature rather than individual volunteers they were volunteers, they did time or communicated with volunteers and canvass for literature rather would have engaged in a communication public that in-kind contribution such contributions with provided compensation anyone for committee without charge the committee, the the employing organization the evidence in likely that neither these scenarios projects, activities and vojlunteers then apparently communicated restricted class; communications received general public were committee communications; were compensated, "labor walks" a

27 September Commission intenogatories, th
September Commission intenogatories, the called the investigation. The events throughout November election." a document, Attachment "Draft-Internal Document" each page, activities listed document refers were scheduled take place prior to events listed are several spouses appeared Commission's regulations exempt the prohibition labor organization premises labor organization meetings, functions under strictly conditions designed the event allow the candidate labor organization's the labor organization, their families. also permit out-the-vote communications, conduct registration .that are general public political parties, among However, if the described events t

28 heir spouses the general get-out-the-vot
heir spouses the general get-out-the-vote drives directed general public that were the committees participating candidates, they would the exemptions illegal in-kind contributions the participating candidates' However, determining conclusively these events violated the would be significant expenditure Commission resources. has already produced indicates whether actually took place, whether they were directed restricted class general public, each event Therefore, pursuing directing discovery the participating candidates' committees and contact person who was responsible for staging the events, potentially following depositions. Because investigation did about th

29 e Women Vote events differences between
e Women Vote events differences between that may have connection with the violations that have investigation to importantly, because the level outstanding questions pursuing this starting a this late date, this recommend starting developed evidence one scenario which there with persons President Clinton Gore about the content, location, details of a flight advertisements. The advertisements concerning the conflict between Congress over the Federal budget congressional districts radio spot additional six congressional districts. However, evidence indicates the advertisement may coordinated with persons acting the time, candidate for reelection extent the adverti

30 sement connection with Federal elections
sement connection with Federal elections in connection Representative, and connection with the Presidential election. The television advertisement “Families,” and reproduced at the First General Counsel’s huge tax continues, “But President Clinton said Clinton signing . . [name], this special interests. interests. ”and provided an “800” teleplrone number. In response to the complaint in MUR 4307, which placed “Families” at issue, the ML-CIO stated that a person who called the number was “greeted with a .. recorded message stressing the importance of ‘standing up .for America’s working families,’ a

31 nd based that information Congress, all
nd based that information Congress, all the'president Bates additional version, particular member News Network? Moreover, radio advertisements additional five Republican Members radio advertisements were broadcast, the Congressional leadership frequently acrimonious budget reconciliation several appropriations beginning December 16,1995. Thesc were Rick White Randy Tate Executive OfXct generic version concurrently broadcast Robert Ehrlich Jennifer O’Connor White House Chief of O’Connor testified before staff of the White labor leaders. Special Investigation, Jennifer O’Connor, October White House Political Director Political Director Karen Hancox

32 , earlier memorandum, the piece mailing
, earlier memorandum, the piece mailing coupled with “events” in congressional districts. checked targets potentially get radio a letter [AFL-CIO President Sweeney describing mail piece. piece. assistant to Sweeney] asked for our comments by the end of business today, if we want to have input into this campaign. . After a paragraph that was redacted the White leave e-mail for morning if attached. They get them input by the end because they the memo “AFL-CIO Executive Council indicating that the content mail campaign to the the television campaign reconciliation bill expected veto Sweeney’s letter said that the campaign “several objectiv

33 es,” objectives,” )the .. focu
es,” objectives,” )the .. focus, and the pressure, to drop their tax breaks rich and restore money Medicaid, student loans and worker worker the pressure on the President to hang tough;” “[elducating union public about the value government programs;” programs;” an understanding among political leaders, the media, and trade unionists of the immense amount of work unions have put into the fight against union members members )the [National Committee for districts for House.” Attachment the President, with copies House Chief fellow deputy statement that “the purpose [of television ads] The memorandum ,Has Seen.” Attachmen

34 t the investigation the White House adve
t the investigation the White House advertising campaign. However, in congtessional investigators, Ickes and meeting that 1996 in Clinton-Gore. personnel. to staff House Committee Reform and Oversight The purpose the meeting was for labor people the ads that and were planning criticized their because they failed balanced budget tax cuts, rhetoric against for the talking about. They then invited basis where, for example, they after Jeffords, winning Vermont felt that not helpful campaign, but but should be noted that the request coordination did the labor Representatives, Deposition lckes recalled meeting in which which graced us with a cameo appearance some wis

35 dom connection with the Clinton-Gore ads
dom connection with the Clinton-Gore ads Congressional districts" were suggested meetings like could well have been these ads that the running.” Attachment Governmental Affairs; Special Investigation, Deposition Ickes, Vol. Dep. Tr.”)) at Executive Office reviewed that refer unmistakably show that Denise Mitchell, assistant President Sweeney public affairs and the television advertising on the and December (Executive Office President Bates present for meeting. Attachments documents indicate that Ickes the White possessed a 160-page Associates, which was that contained targeting information, including dozens and station the “Families” adverti

36 sement; the document dated December . .
sement; the document dated December . . 4:. , President forwarded the script targets. Attachment (Executive Office President Bates 00129 through “Families” advertisement have been White House staff within the that the White House “substantial discussion “Families” advertisement, million piece developed direct evidence invitation, it meeting attended at least provided for the White House records indicate Mitchell attended meetings occurred before “Families” ads occurred afterward. budget fight” when the possibility least discussed. at the writing what their testimony Congressional investigators. the “Families”

37 advertisements congressional elections.
advertisements congressional elections. concerned specific legislation very high- profile, lepjslative activity Sweeney’s letter stated were to convince Congressional Republicans legislation that convince President However, the letter stated districts targeted which included the districts targeted (emphasis added). However, the potential coordination “Families” into contributions because no match the advertisements may have other matters under review the Commission indicates Ickes, although a member acted with apparent authority over certain activities if there occurred with representatives the United the First General also broadcasting advertis

38 ements about the struggle between Congre
ements about the struggle between Congress President over that the coordinated with advertiscments with Presidential election, latter were related elections. First, with the specific, targeted the air Federal office, President Clinton, advertisements in Senator Robert President Clinton. advertisement asked viewers “call Congress”); contrast, the ads that policies. Third, direct evidence available inferences about the strategy indicates that were targeted “Famifies” were target list retaking the House.” “Families” television that would less evidence advertisement involved, Office's recommendations to find were coordinated with,

39 therefore contributions the weight the
therefore contributions the weight the evidence indicates the "Families" dual purpose legislative outcome smaller reference to President Clinton within the advertisements at least have resulted in in-kind contributions those candidates. But there with candidates opposing targeted Members Congress. While well have been effectively coordinated neither President Clinton nor Vice were candidates elections the advertisernents about.' Therefore, other political activity the investigation conducted the presidential than "Families," that President Clinton Vice President, Secretary Rtich, political director Commission's investigation additional contacts and the General

40 Counsel's report noted common vendors D
Counsel's report noted common vendors Democratic candidate most significant Media Strategies broadcast advertisements after mid-June three Democratic candidates Nick Lampson described in the in some cases the the investigation developed Media Strategies also the the committee it conducted have concerned advertisements that already underway the advertisements activities could have been undertaken at the request "substantial discussion negotiation" between the creative consultant broadcast advertising produced a marketing of baseline poll District of about these completion of resources were focused on House candidate another district radio advertisements. the co

41 mplaints, Mitchell, the principal discus
mplaints, Mitchell, the principal discussion with Media Strategies about denied even Lampson campaigns receiving the complaints; developed information with the relevant complaint. the Etheridge campaign until the election. Media Strategies, submitted personally denying discussing anything about the Davis Etheridge conunittees, Davis and with the Media Strategies, disclaimed complete their committees’ principal .contacts Media Strategies. ‘Between Commission interrogatories, the Etheridge committee contact with Media consultants that Etheridge himself Media Strategies the Rieder conunittee, have been discovery inquiries concerning that district conside

42 rably less in the Davis, Commission’
rably less in the Davis, Commission’s regulations provides when they are “made has been, been, receiving any advisory opinion time buyer, outside organization, candidate that relationship between outside organization’s ability make independent expenditures. (in enforcement reliance on other “situations” committee did continued validity Christian Coalirion, Coalition voter guides court called coordination with one’s to coordination,” the facts presented. While . . individual had complete decisionmaking both a corporation corporation labor organization] campaign and and labor organization] expressive expenditures to’assist

43 the campaign,” it found that “
the campaign,” it found that “coordination inferred merely the fact the [individual] wore appears that under expenditure through occur in where the common agent has decisionmaking authority purported recipient; second, where common vendor acts recipient committee, either spender a request committee that by acting transaction concerning location, mode, intended audience, Media Strategies General Counsel’s might have First General (“[Wlhile Hutchens the other, say whether such information in that manner without instruction.”) does not appear the evidence decisionmaking authority over “veil-piercing” coordination advertisements,

44 Hutchens would budget” and transmit
Hutchens would budget” and transmit along with had in would describe media markets target audience, some occasions, Mitchell would conunents. Attachment Strategies would then apparently place advertisements, and Hutchens provide Mitchell with Strategies apparently behalf with television radio stations regular submission such occasions occasions know what [s.he thought]” indicate that the,AFL-CIO, television) for sufficient autonomy Media Strategies between the candidate committee that would amount coordination under Denise Mitchell exercised decisionmaking authority over the placement averred in responses campaigns until after relevant complaints (whi

45 ch, in the that district) until after th
ch, in the that district) until after the election. Mitchell did have made Media Strategies common vendor, could not have Media Strategies the candidate committees. the investigation contained communications between Media Strategies mentioned the contained communications between candidate committees mentioned' the Accordingly, under the in hand that the discrete factual General Counsel’s Report the facts described Counsel’s Report describe violations Act. One scenarios involves Democratic Republican Independent Voter Education Committee the separate expressly advocated Representative Nathan Deal in the election. That scenario, the analysis set forth C

46 ounsel’s Brief in these matters dir
ounsel’s Brief in these matters directed and the Counsel’s Report Commission found probable cause Conciliation negotiations have been fiuitfbl, recommend in approve a conciliation between the AFL-CIO the authorized Bernie Sanders involved registration handbills praising Report, a number Boston, Massachusetts, were transported Rutland, Vermont, they received proper filling Vermont voter’s then canvassed Rutland, passing out the handbills have been the complaint in the responses discovery responses Sanders campaign AFL-CIO spent spent by that the canvass resulted voters.22 This Office recommends the notification letters to commirtee contain appropr

47 iate language concerning First General C
iate language concerning First General Counsel’s Report in these matters contains following quotation book about the Federal election “issue advocacy” AFL-CIO wasn’t talking about detail with the Democratic perfectly okay political committees non-discussant for “issue advocacy” advocacy” unnamed] Democraiic Party’operative said, easy for labor relative those targets make other General Counsel’s impair the independence the general public. information exchange described in did not and "substantial negotiation" over content, timing, location, volume, appears the evidence developed Drew's description generally accurate e

48 xchanges that regurarly-occurred between
xchanges that regurarly-occurred between the Democratic party candidate committees. this Office standard governs these further investigation the investigation produce evidence significant violations with which stated .herein, Office recommends that, limited resources, Commission take fiirther action with respect to except the Education Committee close the files with respect Republican-Independent Voter Education Committee Approve the appropriate letter, including admonishment language, directed i 3. Approve the appropriate letters directed to all other respondents in thest matters with respect to whom the Commission determines to take no hrrthtr action. ~bwrcnc

49 e M. Noble I- I !- General Counsel Lawre
e M. Noble I- I !- General Counsel Lawrence L Calvert Jr. April J. Sands Tam 0. Meeker 8 AnaChmCnts: 1 . * Tlwmment. "AFL-CIIO Media Flinhts." Droductd bv Media Strategies & Research .I I I I I , 3. DNC document, "he 1996 Coordinated Campaign" . I 4. DNC document, "The Coordinatad Campaign" 1 I ' , 5. Memorandum, Steve Rogers to Jim Thompson, September 23,1996 6. Memorandum, Rab Engel to Jim Thompson, September 12,11996 7. Excepts fkom Michigan Coorciinated Campaign Plan 8. ArhnsasCo~rdinatadCampaignPlan &.- I 8 9. Idaho coordinated campaign Plan 10. South Dakota Coordinated Campaign Plan 11. Memorandum, David Billy to Jim Thompson and Tom Linaafeld, September 1

50 0,1996 12. Memorandum, Joe Velasqucz to
0,1996 12. Memorandum, Joe Velasqucz to Jim Thompson, September 19.1996 ' .. 14. Discovery mponsc, hpson for Congress 15. Discovery respxue, Bell for Con- 16. 17. 18. 19. 20. 21. 22. 23. 24. 25. 26. . 27. 828. Discoway respnse, Walter Capps for Congruss Discovwy response, Dm Wilfims fir Congress Discovery msponse, Lotl@augh for Congress Di.mvmy nt5p8w., Tier119 for Congress Discovmy resipom, Steve Owens for Congress Discovery reqmmc, Darlene Hooky for Congress letter, Marc Elim, Esq. to s;tpif, March 9,2000 Letter. Ofice of Gcnd Couns;cl to Marc Elk, Esq., March 26,2000 Midavit of David Bell, April IS, 2000 AFL-CkB 1piS;covcry Response, May 22,19913 AFL-CIO Disc

51 overy Rtsponsc, September 17, 1999 AFL-C
overy Rtsponsc, September 17, 1999 AFL-CIO document, "Working Worncn Vote Events" rn-CIO Orcgorl Fl~~oilcrlrs . .. ,. . ! :: , :. . ! ... .. . .. Margolis, Mitchell, Bums Associates document, Costs: Media Campaign Targeting Senate Committee Governmental Affairs Memorandum, Jennifer Hancox, November presidents, November the President, Governmental Affairs Electronic mail message, Jennifer to Janice the President Memorandum, Jennifer O’Connor Doug Sosnik the President Vice President, transmission, Jon Hutchens September Planning transmission, Jon Hutchens Hutchens to Denise Mitchell, June Campaign, December Budget Battle” President, December apparent re