request for expedition (exhibits): crew: department of justice (doj): regarding tom delay...

8/7/2019 Request for Expedition (Exhibits): CREW: Department of Justice (DOJ): Regarding Tom DeLay Investigation: 10/19/1…

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EXHIBIT 1



Department drops investigation ofDelay ties to Abramoff

tIle ttlt\sllitl:gfolt st_.

Justice Department drops

investigation ofDeLay ties to

AbramoffBy R. Jeffrey Smith

Washington Post StaffWriter

Tuesday, August 17,2010; AOI

Former House majority leader Tom DeLay (R-Tex.)

was both defiant and ebullient on Monday after

hearing that the Justice Department had dropped its

six-year investigation of his interactions with lobbvist

Jack Abramoffand a host of other political

contributors for whom he allegedly did political favors.

http://www.washingtonpost.comlwp-dyn/content/article/2010

"I always knew this day would come," DeLay said on the telephone from his home in Sugar Land, Tex.

He said he has no regrets about his conduct in Washington, insisted that his actions were always legal,

and assailed what he called the "criminalization of politics" by a federal ethics enforcement process he

considers deeply flawed.

His celebratory remarks came a week before he is slated to return to a Texas courtroom for a pretrial

hearing on allegations of felony conspiracy and money laundering, which still could put the 63-year-old

politician behind bars. His 2005 indictment in that Texas case is what short-circuited his three-year

tenure in one of Washington's most powerful jobs.

The Justice Department declined to comment about DeLay's claim of exoneration, following its policy ofnot discussing the status or termination of its criminal investigations. A source familiar with the

long-running inquiry, in which many witnesses were brought before one or more grand juries, confirmed

that it had ended.

Speaking on the condition of anonymity, he said the main reason for dropping the effort was that

prosecutors were unable to compel incriminating testimony by a former DeLay aide, Edwin A.Buckham, and find other witnesses or evidence that could have led to a conviction.

Buckham has similarly been cleared by the Justice Department, a source close to DeLay said. Buckham's

attorney, David Geneson, declined to comment.

In recent years, DeLay has worked on rehabilitating his public image as well as his career, appearing in a

television dancing competition, working as a paid consultant to corporations and advising -- by his own

description -- the factions that make up the "tea party" movement.

Asked whether he plans to attempt a return to Congress, DeLay acknowledged that his political

effectiveness has been hampered by years of scrutiny. People don't necessarily "want to associate with

you" after being under such a heavy legal cloud for so long, he said, explaining why he has declined to

endorse candidates.

The Justice Department investigation focused in part on payments made by Buckham, a former adviser

10115/201



Department drops investigation of DeLay ties to Abramoff http://www.washingtonpost.comiwp-dyn/contentiarticle/20 10

who was a registered lobbyist in 2000, to cover some of DeLay's expenses on an overseas golf trip.

Doing so violated House rules, but DeLay said he was unaware of the payments. Buckham's

now-shuttered firm employed DeLay's wife, Christine, from 1998 to 2002 and set up a retirement

account for her. A political action committee that Buckham controlled employed both DeLay's wife and

his daughter.

The payments amounted to nearly half a million dollars, drawn partly from revenue from corporations

and their officers that had interests in legislation pending before the House.

DeLay and Buckhamwere at one point two of the principal targets in the department's multifaceted

probe ofAbramoffs lobbying practice that led to the convictions of 19 people, including two DeLay

aides. DeLay has maintained he was unaware of their wrongdoing. He said Monday that the department

"couldn't find anything" otherwise in the documents, e-mails and computer hard drives that his office

had turned over to investigators without protest.

The source familiar with the investigation said that some of those working on the probe had disagreed

about the importance of holding out for Buckham's testimony when Abramoffhimselfwas potentially

available as a cooperating witness. Abramoff recently worked in a kosher pizza parlor in Baltimore while

wrapping up a four-year sentence for conspiracy, mail fraud and tax evasion.

DeLay referred to Abramoff, who admitted to corrupting public officials and defrauding his clients, as "a

friend of mine." He said Abramoffs lavish pay from Native American tribes for lobbying had resulted

from inattention by the leaders of those tribes.

Known for a hard-edged, take-no-prisoners political style reflected in his nickname, "The Hammer,"

DeLay decried what he called "new politics" in which opponents try to "drown you," ruin your finances

and then "dance on your grave."

When asked whether he thought the recent House ethics charges against Democratic Reps. Maxine

Waters (Calif.) and Charles B. Rangel (N.Y.) also resulted an effort to punish successful fundraising andstrong political views, DeLay said their cases are different from his.

DeLay's principal attorney, Richard Cullen ofRichmond, said the Justice Department's decision also

covered Christine DeLay. "We had conversations off and on during '05, '06, '07 that were across the

board," Cullen said of his contacts with the Justice Department. "Prosecutors follow leads and a lot of

those leads were in the paper."

DeLay and Cullen said that he was never interviewed during the probe.

Staffwriter James V Grimaldi contributed to this report.

View all comments that have been posted about this article.

Post a Comment


10115/201



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As lobbying scandal drags on, Delay takes a shotat FBIEx-congressman blasts Justice as 'running amok' in the Abramoff

case

ByMICHAEL HEDGES Copyright2007 HoustonChronicle Washington BureauMay 9, 2007, 10:10PM

WASHINGTON - Tom Delay is lashing out at federal prosecutorsprobing his ties with disgraced lobbyist Jack Abramoff, challenging

Digg them to charge himw ith a crime or drop their lengthy investigation .

Yahoo! Buzz "I t is a Justice Department that is running amok," theformer Sugarland lawmaker said to The Hill, a publication covering Congress,

'E:1 StumbleUpon "Fish or cut bait. Do something."

Delay, the former House majority leader who resigned his seat inBe thefirstof yourfriends to Congress last year after being charged inTexas inan unrelatedrecommend this. case, has not been accused of wrongdoing in the Abramoff

investigation.

But one former GOP member of Congress, Bob Ney of Ohio, andtwo former top aides of Delay's have pleaded guilty to corruption

in the Wide-ranging grand jury investigation into efforts by Abramoffto gain illegal advantages for his clients in exchange for bribes.

Abramoff has pleaded guilty to corruption charges and is cooperating with investigators.

The inquiry into Delay's actions has focused on payments to his wife, Christine, by two organizations controlledby former Delay chief of staff Edwin Buckham.

After leaving Delay's staff, Buckham ran a lobbying firm called Alexander Strategy Group that paid her about$115,000 between 1998 and 2002.

Christine Delay and Delay's daughter, Dani Ferro, were also paid consulting fees and expenses totalling about$350,000 by Delay's political action committee, ARMPAC, which was also managed by Buckham.

Delay's lawyer, Richard Cullen, said the payments were for legitimate work.

"Clearly the Justice Department is conducting a very thorough investigation into all aspects of Mrs. Delay's

employment," Cullen said. "We have given them documents that demonstrate clearly that she was an integral partof Tom Delay's pol it ical operat ion, and that she earned every penny - probably more - than she was paid."

The FBI and the Justice Department declined to discuss the ongoing Abramoff investigation Wednesday.

FBI director Robert Mueller, meeting with Washington journalists Wednesday, sidestepped a question on theDelay probe.

But he said, "Public corruption has been our NO.1 priority on the criminal side.... We've almost doubled thenumber of convictions in the last year that we had in 2000-2001. We have additional resources addressing publiccorruption (and) I'm comfortable we've taken the steps that are appropriate."

Delay had not voiced frustration or anger at federal investigators before.

But he has been open with his contempt for Travis County District Attorney Ronnie Earle, who obtained acampaign money laundering indictment of Delay. The former congressman has called the charges a thinly veiledpolitical attack by a Democratic prosecutor.

Cullensaid Delay's remarks Tuesday are a spillover from his aggravation at the Texas case.

"I think the frustration is consistent with somebody who believes passionately that he has done nothing wrong,"

Cullensaid. "Tom Delay wants the investigation to be over. That is a very human response."

[email protected]

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10119/2010



Aide Pleads Guilty In Lobby Case - The New York Times http://query.nytimes.com/gst/fullpage.html?res=9903E4D7 I230

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This copy is for your personal, noncommercial use only. You can order presentation-ready copies for distribution to

your colleagues, clients or customers, please click here or use the "Reprints" tool that appears next to any article.

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April 1, 2006

Ex-DeLayAide Pleads Guilty In Lobby Case

By PHILIP SHENON

A former top aide to Representative Tom DeLay pleaded guilty on Friday to charges that he

accepted thousands of dollars in illegal gifts, including money funneled through a consulting

firm he set up with his wife and travel by private je t to California, in return for influencing

legislation on behalf of the lobbyist J ack Abramoff.

The plea agreement by the aide, Tony Rudy, a lobbyist who was Mr. DeLay's deputy chief of

staff from 1998 to 2000 and one of his closest advisers, makes Mr. Rudy the second former

DeLay aide to admit wrongdoing in the corruption investigation centered on Mr. Abramoff.

Mr. Abramoffpleaded guilty in the investigation in January, acknowledging that he had

conspired with Mr. Rudy and others to corrupt public officials, including members of Congress.

Another of Mr. Abramoffs former lobbying partners, Michael Scanlon, who had been Mr.

DeLay's press secretary in the House, pleaded guilty last year to similar criminal charges in a

scandal that has pu t pressure on Congressional leaders to tighten federal ethics rules.

Mr. Rudy, Mr. Scanlon and Mr. Abramoff are all cooperating with the Justice Department,

which is investigating whether Mr. DeLay and other members of Congress, including

Representative Bob Ney, Republican of Ohio, accepted travel, gifts or money from Mr. Abramoff

and his associates in return for legislative favors.

Mr. Rudy's plea agreement, which covers actions he took on Mr. Abramoffs behalfboth while

on Mr. DeLay's staff and after leaving the House to work as a lobbyist, d id not allege any

wrongdoing by Mr. DeLay, the former Republican majority leader, or say that Mr. DeLay knew

of any criminal activities by Mr. Rudy. Mr. DeLay is under indictment in Texas on unrelated

charges involving violations of state election laws.

But the plea agreement suggested more trouble for Mr. Ney. It said that Mr. Rudy, who joined

Mr. Abramoffs lobbying firm after leaving Mr. DeLay's staff in late 2000 , said he, too, was

involved in "providing things of value to and soliciting and obtaining the agreement" of a

lawmaker -- identified only as "Representative NO.1" -- to assist Mr. Abramoffand his clients.

Federal law-enforcement officials, speaking on condition of anonymity because federal grand

jury rules bar them from commenting publicly, said "Representative No.!" was Mr. Ney.

10119/2010



Aide Pleads Guilty In Lobby Case - The New York Times http://query.nytimes.com/gst/fullpage.html?res=9903E4D7123O

Mr. Rudy's plea agreement suggested that tens ofthousands of dollars in illegal gifts were

funneled to Mr. Rudy through a consulting firm that he and his wife, Lisa Rudy, established in

August 1999, when Mr. Rudy was working on Mr. DeLay's House staff. According to the Justice

Department's calculations, the firm, Liberty Consulting, took in about $86 ,000 , much of it

from a nonprofit group underwritten by Mr. Abramoffs lobbying clients.

Under the plea bargain, the Justice Department agreed not to prosecute Ms. Rudy in exchange

for her cooperation. Prosecutors said at the hearing that they would ask that Mr. Rudy, who

remains free, not be incarcerated until his cooperation was no longer needed in the

investigation.

He faces a maximum penalty of five years in prison, a $250 ,000 fine and restitution of up to

$100,000 . But under federal sentencing guidelines, Judge Ellen Huvelle ofthe Federal District

Court in Washington said he was more likely to receive a prison sentence between two and

two-and-a-halfyears.

In return for the gifts, court documents show, Mr. Rudy helped block a bill in the summer of

2000 to restrict Internet gambling -- Mr. Abramoff represented an Internet-gambling company

-- and had Mr. DeLay sign a letter in April 2000 opposing a postal-rate increase. Mr.

Abramoffs clients in the magazine-publishing industry opposed the increase.

In the plea agreement, Mr. Rudy acknowledged that he had received a long list of gifts from

Mr. Abramoffwhile serving on Mr. DeLay's staff, including a trip by private je t to the u.s. Open

golf tournament in Pebble Beach, Calif., in 2000; use of a box sui te for a bachelor party at an

August 2000 Washington Redskins game; tickets to the Daytona 500 in Florida; a trip with his

wife to Hilton Head, S.C.; meals at "expensive restaurants" in Washington; and golf clubs"costing several hundred dollars."

Mr. DeLay has acknowledged that he took a series oflavish overseas trips that were arranged

by Mr. Abramoff; Mr. DeLay's wife received more than $100 ,000 in consulting fees between

1998 and 2002 from Alexander Strategy Group, the lobbying firm where Mr. Rudy worked

most recently.

But the plea agreement signed by Mr. Rudy and made public on Friday does not allege that Mr.

DeLay had any knowledge of his former aide's corruption or that he himself had ever accepted

any gifts in exchange for specific acts in Congress.

"I have no indication that prosecutors are circling in on Mr. DeLay," said Richard Cullen, Mr.

DeLay's criminal defense lawyer. Mr. Cullen said he was advised several months ago by the

Justice Department that Mr. DeLay was not considered a target ofthe investigation. The

lawyer said he had no reason to believe Mr. DeLay's status had changed.

"Mr. DeLay was unaware of any of the acts to which Mr. Rudy has pleaded guilty," Mr. Cullen

said. "To say that he's bitterly disappointed is an understatement."

10/19/20 I0



Aide Pleads Guilty In Lobby Case - The New York Times http://query.nytimes.com/gst/fullpage.html?res=9903E4D7123

In the summer of 2000, Mr. Rudy said in his plea agreement, he assisted Mr.Abramoff in

devising a strategy that killed an otherwise popular bill backed by most House Republicans to

restrict gambling on the Internet; at the time, Mr. Abramoff represented an Internet-gambling

company, eLottery, that faced collapse if the bill passed.

Despite his longstanding opposition to gambling, Mr. DeLay was instrumental, with Mr.

Rudy's prompting, in blocking action on the bill. In May 2000, eLottery made a $25,000

contribution to a private educational group that underwrote a trip that month by Mr. DeLay

and his wife to Britain; Mr. DeLay has said he had no knowledge of the company's

contribution. Mr. Abramoff has told prosecutors that he steered $50,000 in consulting fees to

Ms. Rudy as a resul t of her husband's help.

Mr. Rudy also acknowledged that, at Mr. Abramoffs behest, he obtained Mr. DeLay's signature

on a letter in early 2000 criticizing plans by the Postal Service to raise its rates; the increase

was strongly opposed by the Magazine Publishers Association, one of Mr. Abramoffs lobbying

clients. Mr. DeLay was among many lawmakers, including Democrats, who opposed the rate

increase, and while the rates were increased the next year, theywent up less than originally

planned.

Mr. Rudy's deal with the prosecutors appeared to buttress information provided earlier to

prosecutors about Mr. Ney by Mr. Abramoff and Mr. Scanlon. In their earlier plea agreements,

Mr. Abramoffand Mr. Scanlon had singled out Mr. Ney as the recipient of many of their gifts,

including a 2002 golf excursion to the fabled St. Andrews course in Scotland.

Mr. Rudy said in his agreement that Mr. Ney, identified as Representative NO.1, agreed in

March 2001 tosupport

legislationthat

would have allowed Mr.Abramoffs

clients inthe

Northern Mariana Islands, a small American territory in the western Pacific, to continue to

make clothing that could be labeled "Made in the U.S.A." even though the islands' migrant

Asian garment workers were not protected by federal labor laws and the minimum wage.

Human rights groups and labor unions have long described the garment factories as sweat

shops.

Mr. Rudy's plea agreement refers to the 2002 Scottish golfing trip, with Mr. Rudy

acknowledging that he solicited $25,000 from one of Mr. Abramoffs Indian tribe clients to

help pay for the trip, claiming to thetribe that the money would be used by a charity group.

Court documents show that Mr. Rudy invited Mr. Ney on the trip, promising golf and "drinkingand smoking Cubans."

Mr. Ney's office did not dispute that he was Representative No.!. His spokesman, Brian J.

Walsh, said in a statement that Mr. Rudy's plea agreement made "clear yet again that Jack

Abramoff and his subordinates engaged in a collaborative and deliberate strategy to defraud,

manipulate and lie in order to advance their own personal greed." Mr. Walsh said Mr. Ney,

who is facing a difficult race for re-election in November, remained confident "that he did

absolutely nothing wrong."

10/19/2010



Aide Pleads Guilty In Lobby Case - The New York Times http://query.nytimes.com/gst/fullpage.html?res=9903E4D7123

Mr. Rudy, 39, entered his guilty plea in Federal District Court in Washington, saying nothing

beyond "yes" and "no" in response to a series of questions posed by Judge Huvelle about the

terms of his agreement with the Justice Department. Asked later how he pleaded to the single

conspiracy count in the plea agreement, Mr. Rudy replied, "Guilty, your honor."

Photo: Tony Rudy, a lobbyist and former Congressional aide, pleaded guilty to corruption

charges yesterday at Federal District Court in Washington. Mr. Rudy's case is tied with that of

the lobbyist Jack Abramoff. (Photo by Lawrence Jackson/Associated Press)(pg. A12)

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10/19/20 I 0



makers Under Scrutiny in Probe of Lobbyist

tJ)e WntiJ)ingfun J10tit

Lawmakers Under Scrutiny in

Probeof

LobbyistNey and DeLay Among the Members ofCongress Said

to Be a Focus ofAbramoffInvestigation

By Susan Schmidt and James V. GrimaldiWashington Post StaffWriters

Saturday, November 26, 2005

The Justice Department's wide-ranging investigation of

former lobbyist Jack Abramoffhas entered a highly

active phase as prosecutors are beginning to move on

evidence pointing to possible corruption in Congress

and executive branch agencies, lawyers involved in thecase said.

http://www.washingtonpost.com/wp-dyn/content/artie le/2005

Prosecutors have already told one lawmaker, Rep. Robert W. Ney (R-Ohio), and his former chief of

staffthat they are preparing a possible bribery case against them, according to two sources

knowledgeable about the matter who spoke on the condition of anonymity.

The 35 to 40 investigators and prosecutors on the Abramoff case are focused on at least half a dozen

members of Congress, lawyers and others close to the probe said. The investigators are looking at

payments made by Abramoff and his colleagues to the wives of some lawmakers and at actions taken by

senior Capitol Hill aides, some ofwhom went to work for Abramoff at the law firm Greenberg Traurig

LLP, lawyers and others familiar with the probe said.

Former House majority leader Tom DeLay (R), now facing separate campaign finance charges in his

home state of Texas, is one of the members under scrutiny, the sources said. Sen. Conrad Burns

(R-Mont.), Rep. John T. Doolittle (R-Calif.) and other members ofCongress involved with Indian affairs,

one ofAbramoffs key areas of interest, are also said to be among them.

Prosecutions and plea deals have become more likely, the lawyers said, now that Abramoffs former

partner -- public relations executive Michael Scanlon -- has agreed to plead guilty to conspiracy and to

testify about gifts that he and his K Street colleagues showered on lawmakers, allegedly in exchange for

official favors.

An attorney for DeLay, whose wife worked for a lobbying firm that received client referrals from

Abramoff, said there was no connection between her work and congressional business. A spokesman for

Doolittle, whose wife received payments from Abramoffs lobbying firm, also said there was no

connection with her husband's position. Burns's office has said his actions were consistent with his

support for improving conditions for Indian tribes.

Ney is the congressman whose name has surfaced most prominently in the Abramoff investigation. His

spokesman and attorney have said for weeks that Ney has not been told he is a target of the inquiry,

even while acknowledging that his office has received a grand jury subpoena and that his activities were

mentioned in Scanlon's plea agreement.

10115/201



wmakers Under Scrutiny in Probe of Lobbyist http://www.washingtonpost.comiwp-dyn/content/articie/2005/

But the sources said that during the third week ofOctober prosecutors told Ney and his former chief ofstaff, Neil Vo1z, that they were preparing a bribery case based in part on activities that occurred in

October 2000. Abramoff and another business partner, Adam Kidan, were also told that they are targets

in that case, the sources said.

The five-year statute of limitations for filing charges based on those events expired last month; the

prosecutors sought and received a waiver of the deadline from all four men while they continue their

investigation, the sources said. Prosecutors are often able to obtain such waivers by givingthe targets achoice of being indicted right away or granting more time to see if information might surface that

exonerates them.

Ney's attorney, Mark H. Tuohey, did not return calls seeking comment on the waiver. Ney spokesman

Brian Walsh said the office had no comment, as did a lawyer for Volz.

The attorneys ofAbramoffand Kidan did not return calls seeking comment.

The events in 2000 that interest investigators are connected to the purchase by Abramoff and Kidan of

SunCruz Casinos, owner of a fleet of Florida gambling boats. Ney twice placed comments in the

Congressional Record about SunCruz, first criticizing its former owner when Abramoff and Kidan werein difficult purchase negotiations and then, in October, praising Kidan's new management. Abramoff andKidan are facing trial in January on charges of defrauding lenders in their purchase of the casino boats.

The statute of limitations may also soon run out on a 2001 Super Bowl trip sponsored by SunCruz thatsources said investigators have reviewed. The Washington Post reported earlier this year that aides toBurns and DeLay were ferried to Tampa on a SunCruz corporate jet arranged by Abramoff. Ney and his

sons were invited to the 2001 Super Bowl outing, former Abramoff associates said, but did not go.

The Hill aides were treated to the game and a night of gambling on a Sun Cruz ship. They were offered

$500 in gambling chips, sources knowledgeable about the trip said.

The Post has reported that Burns, who received $137,000 in contributions from Abramofflobbyists andtheir tribal clients, obtained a controversial $3 million school construction grant for one ofAbramoffs

wealthy tribal clients after pressuring the Bureau of Indian Affairs.

Investigators are also gathering information about Abramoffs hiring of several congressional wives,

sources said, as well as his referral of clients to Alexander Strategy Group, a lobbying and consultingfirm run by former senior aides to DeLay. Financial disclosure forms show that the firm employed

DeLay's wife, Christine, from 1998 to 2002.

Former Abramoff lobbying associates have said that Abramoffshared some of his high-paying clients

with the group, including Malaysian interests, the Mississippi Choctaw Indian tribe and online gambling

firms. Federal investigators have questioned some former Abramoff associates about whether thosereferrals were related to Christine DeLay's employment there, sources said.

Alexander Strategy Group is run by former DeLay senior staffers Edwin A. Buckham and Tony C.Rudy. Rudy served as DeLay's deputy chiefofstaffunti12001, when he took ajob with Abramoff, and

later moved on to join Buckham.

Investigators are looking into whether Rudy aided Abramoffs lobbying clients while he was working on

the Hill, the sources said, and are reviewing payments from Abramoff clients and associates to Liberty

Consulting, a political firm founded by Rudy's wife, Lisa. The Washington Post reported last month that

10115/20



makers Under Scrutiny in Probe of Lobbyist http://www.washingtonpost.com/wp-dyn!content/article/2005

Rudy, while on DeLay's staff, helped scuttle a bill opposed by eLottery Inc. , an Abramoff client, and

that Abramoff had eLottery pay a foundation to hire Liberty Consulting.

Richard Cullen, an attorney for the DeLays, said Christine DeLay was hired by Buckham, an old family

friend, to determine the favorite charity of every member of Congress. She was paid $3,200 to $3,400 a

month for three years, or about $115,000 total, he said.

"It wasn't like she did this 9 to 5, but it was an ongoing project," Cullen said. He said Christine DeLay'swork was commensurate with the project and had nothing to do with her husband or any official

congressional business. "This was something that she found to be very interesting, very challenging and

very worthwhile," Cullen said.

Rudy and Buckham and their attorneys did not return calls seeking comment.

Abramoff's connections to Doolittle are also of interest to investigators, sources said. Doolittle's former

chief of staff, Kevin A. Ring, went to work with Abramoff. Doolittle's wife, Julie, owned a consulting

fIrm that was hired by Abramoff and his firm, Greenberg Traurig, to do fundraising for a charity he

founded. Two sources close to the investigation said that Ring, while working for Abramoff, was an

intermediary in the hiring of Julie Doolittle's firm, Sierra Dominion Financial Solutions Inc., which lastyear received a subpoena from the grand jury investigating Abramoff.

Julie Doolittle's attorney, William L. Stauffer Jr., said Sierra Dominion Financial was hired by GreenbergTraurig to provide "event planning, marketing and related services, as requested by Mr. Abramoff" forAbramoff's Capital Athletic Foundation and his Signatures restaurant. Sierra Dominion received a

monthly retainer from Greenberg Traurig from January 2003 until February 2004, at a rate similar to that

paid by other Sierra Dominion clients, Stauffer said.

Abramoff frequently used the athletic foundation as a pass-through organization to run lobbying efforts

and to pay for expenses, records show. Julie Doolitt le was hired to put on a fundraiser for the foundation

at the International Spy Museum, but the event was canceled because it had been scheduled to takeplace just at the Iraq war was commencing, Stauffer said.

"Sierra Dominion primarily performed public relations and other event planning services for the Spy

Museum event," Stauffer said in an e-mail reply to questions. "This included responding to all individuals

calling the Capital Athletic Foundation concerning the Spy Museum event, identifying (and contacting)

possible attendees for the event , and assisting in fund raising strategy and letters."

Doolittle's office denied any connection between the firm's work and official acts.

"In no way did Sierra Dominion's business services work for Greenberg Traurig have any relationship to

Congressman Doolittle's official duties as a member of the House of Representatives," said Doolittle

spokeswoman Laura Blackmann.

"Congressman Doolittle has never received a subpoena regarding this matter, nor has he ever been

contacted by the Justice Department to provide information or be questioned," she said.

The Justice Department investigation is also looking into Abramoff's influence among executive branch

officials. Sources said prosecutors are continuing to seek information about Abramoffs dealings with

then-Deputy Interior Secretary 1. Steven Griles, including a job offer from the lobbyist at a time when he

was seeking department actions on behalf of his tribal clients.

10115/201



wmakers Agree on New Ethics Rules http://www.washingtonpost.com/wp-dyn/content/article/200710

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Lawmakers Agree on New Ethics RulesHouse Set to Vote on Reconciled Bill; Roadblocks May Delay a Senate Vote

By Elizabeth WilliamsonWashington Post StaffWriter

Saturday, July 28, 2007

House and Senate negotiators completed days of contentious talks and

reached fmal agreement last night on an ethics bill, despite the objections of

members unhappy with tougher rules on lobbyist-delivered campaign

contributions.

In a concession to those lawmakers, negotiators weakened a key provision

requiring disclosure of contributions "bundled" by lobbyists. Under

yesterday's agreement, lawmakers must report every six months any

lobbyist-bundled contributions totaling more than $15,000. The originalHouse bill required quarterly reports for bundled contributions above $5,000.

The reconciled bill is slated for a vote Tuesday in the House under fast-track

procedures. It will then be sent to the Senate, where procedural roadblocks

could delay its passage until the end of next week. Senate Majority Leader

Harry M. Reid (D-Nev.) has vowed to prevent senators from beginning theirmonth-long recess, scheduled to start next weekend, until the bill passes.

"Republicans will stand in the way of this at their own peril," said Rep. Chris

Van Hollen (D-Md.), chairman of the Democratic Congressional Campaign

Committee and sponsor ofthe stricter bundling rules. "Voters sent a verystrong message in November that they want a change in the way that

Washington does business, and we're following through."

The bill is a centerpiece of a Democratic-led overhaul of congressional ethics

and lobbying rules, and party leaders hailed it as the most significant

congressional ethics reform legislation since the post-Watergate era.

"Lobbying laws and rules have been collecting particles and dirt for 30 years,

and this is the most comprehensive scrub they've gotten," said Rep. Rahm Emanuel (Ill.), chairman of

the Democratic Caucus.

After winning control of Congress in November, Democrats moved quickly to push tougher ethics rules,motivated by voters who expressed disgust with scandals including the ties of former congressman

Robert W. Ney (R-Ohio) to jailed lobbyist Jack Abramoff, and bribery allegations against formercongressmen Randy "Duke" Cunningham (R-Calif.) and Rep. William 3. Jefferson (D-La.).

In their first week in the majority, House Democrats tightened the rules on accepting gifts, travel and

meals from lobbyists. The rules also require sponsors of pet spending projects to identify themselves and

certify that they have no financial interest in the earmarks.

A bill passed by the Senate in January included similar bans, as well as reporting requirements for

10119/20104



wmakers Agree on New Ethics Rules http://www.washingtonpost.com/wp-dyn/content/article/200710

earmarks and bundled campaign contributions from lobbyists. But the measure stalled as members wary

of greater scrutiny over campaign fundraising haggled for changes, and Senate Republicans repeatedly

blocked moves to begin final negotiations.

The House passed its ethics bill in May after intense talks over the bundling language, the provision

targeted once more in yesterday's agreement.

The agreed-upon version requires lawmakers to file bundling disclosures to the Federal ElectionCommission, rather than requiring lobbyists to file to House and Senate record-keepers, as in the earlier

bill.

It also retains limits on Washington's "revolving door" by requiring congressional members and top

staffers to wait after leaving their jobs before lobbying their former colleagues. The "cooling-off' period

is one year for the House, two years for the Senate. In addition, House members must disclose any job

negotiations that could conflict with their legislative work, and recuse themselves from that work.


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10119/20104



bpoena list inDelay case reads like a who's who of political, busine... http://www.statesman.comlnews/texas-politics/subpoena-Iist-in

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Subpoena list in DeLay case reads like a who's who of

political,business

interests.Witnesses include associates ofAbramoff,former state House SpeakerCraddick.

By Laylan Copelin

AMERICAN-STATESrvlAN STAFF

Updated: 10:18 p.m. Saturday, Oct. 16,2010

Published: 10:00 p.m. Saturday, Oct. 16,2010

lawyers in the Tom Delay conspiracy trial have subpoenaed a who's who of witnesses, from associates ofdisgraced Washington, D.C., lobbyist Jack Abramoff to former Texas Speaker Tom Craddick, for the biggestpolitical trial in Austin in years.

The witness list for Travis County prosecutors includes chief executives of companies indicted for donating

corporate money, several state lawmakers, enough Beltway lobbyists to pack a Capitol hearing andassociates that Delay shared with Abramoff, a former D.C. powerbroker nicknamed "Casino Jack" whopleaded guilty to conspiring to bribe public officials.

Delay's lawyers have countered with their own heavyweights: former Ambassador Tony Garza, Austinlobbyist Buddy Jones and Craddick, the politician who benefited the most from Delay's campaign efforts,which led to the charges that he conspired to launder corporate money - which is illegal in Texascampaigns - during the 2002 elections.

Jury selection begins Oct. 26, and testimony is expected to begin the following week.

Jurors may have to be reintroduced to Delay, known as "the Hammer" and who as U.S. House majorityleader reshaped Texas politics before the conspiracy indictment forced him to retire from Congress. Afterall, it's been five years - a lifetime in politics - since he resigned to become a guest on cable TV talkshows and a contestant, albeit with two broken feet, on "Dancing With the Stars."

Several of the witnesses, particularly those tainted by ties to Abramoff, aren't likely to be called unlessDelay is convicted on the conspiracy charge, allowing prosecutors to bring up allegations that the U.S.Justice Department couldn't prove as an argument for a stiff penalty.

The witness list includes Abramoff associates Edwin Buckham and Michael Scanlon, two former Delay

staffers who, according to the subpoenas, may be asked about "the inner workings of Tom Delay's politicalorganization" as well as the defendant's lobby-paid trips to Russia, Scotland and the Northern Mariana

Islands.

In the paperwork, prosecutors cite allegations that Russian energy executives donated $1 million to theU.S. Family Network, a Buckham client, to influence Delay's vote to help the Russian economy. Buckhamis Delay's former chief of staff who created an influential lobbying firm that paid Delay's wife, Christine,

$3,200 a month to identify federal lawmakers' favorite charities.

None of these allegations are new.

In August, the Justice Department suspended its long-running investigation of Delay's and Buckham's tiesto Abramoff, the central figure in a federal investigation that shook Congress five years ago and promptedScanlon and Tony Rudy, another Delay staffer, to plead guilty to corruption charges.

10118/201



poena list inDelay case reads like a who's who of political, busine... http://www.statesman.com/news/texas-politics/subpoena-Iist-i

So why bring upallegations so far afield of the conspiracy charges rooted in one transaction during the2002 elections?

Travis County prosecutors declined to discuss their strategy because of orders by Judge Pat Priest, asenior judge from San Antonio who's presiding over the case.

Dick DeGuerin, Delay's lawyer, is upset by the wide-ranging and inflammatory subpoenas, but he declinedto comment on the prosecution's tactics.

He also wasn't tipping his hand on how he chose his own witnesses.

Garza served with Delay on an advisory board of Texans for a Republican Majority, the fundraising

committee at the center of the controversy, before President George W. Bush appointed him ambassadorto Mexico. It's unclear why Jones, an Austin lobbyist with a peripheral role to the controversy, will be adefense witness.

As for Craddick, the former Texas speaker could help the defense, but there is a risk that prosecutors mightelicit information unfavorable to Delay under cross-examination.

Travis County prosecutors investigated Craddick at the same time they were pursuingDelay. But theynever sought charges, even though Craddick personally picked up a $100,000 corporate donation for

Delay's committee. Texans for a Republican Majority also routed its donations through Craddick's office toindividual candidates to bolster Craddick's campaign to become speaker of the Texas House.

Those donations allowed Craddick's office to deliver money to grateful candidates who would be voting for anew House leader after the election.

Putting Craddick on the stand would allow prosecutors to paint a fuller picture of the committee's activities.But the defense also would be able to contrast Craddick's hands-on involvement with what the defensecontends was Delay's limited role with the committee.

The crux of the conspiracy charge is $190,000 of corporate money that Delay's political committee,Texans for a Republican Majority, sent to the Republican National Committee. An arm of the RNC, in turn,

donated the same amount from its noncorporate account to seven Texas candidates.

Texas law prohibits corporate or union money from being donated to candidates.

Jurors must decide whether Delay conspired to launder that corporate money into campaign donations, asthe indictment claims, or whether the exchange was a legal transaction, as Delay says, and that hislieutenants did it without telling him beforehand.

Almost everyone who touched that money - donor or recipient- has been subpoenaed.

Much of the money was raised in Washington D.C., by Delay fundraiser Warren Robold from corporationswith interests in front of Congress. That's why so many Beltway lobbyists or company CEOs weresubpoenaed. Some of the companies that were indicted got their charges dropped in exchange for

cooperating with prosecutors. One was Questerra Corp., a Charlottesville, Va.-based software company.It's former CEO, Tim Milovich, was subpoenaed to testify.

The seven former and current Texas House members who got donations from Texans for a RepublicanMajority also are on the list, including Austin-area residents Todd Baxter, Jack Stick and Rick Green.

Also subpoenaed are Texas officials who served with Delay on the advisory board of Texans for aRepublican Majority: Sen. Florence Shapiro, R-Plano ; former Rep. Dianne White Delisi, R-Temple; andRep. Beverly Woolley, R-Houston .

Prosecutors also are seeking testimony to paint a broader picture beyond Texans for a Republican Majority.

10118/201



list in Delay case reads like a who's who of political, busine... http://www.statesman.com/news/texas-politics/subpoena-Iist-i

For example, Peter Cloeren, a business executive from Orange, is expected to testify about pleadingguiltyto illegally funneling money to a congressional candidate in 1996 at the urging of Delay, an allegation thatDelay denied. Federal authorities never charged Delay in that case, but Cloeren was fined $400,000 andgot two year's probation. Cloeren pleaded guilty to funneling money through his company's employees andout-of-state groups.

Prosecutors also will try to use Delay's own words against him.

They have subpoenaed tapes of several cable news shows on which Delay declared he knew nothingabout the $190,000 transaction until after it happened and professed his general lack of involvement with

Texans for a Republican Majority outside of headlining five fundraisers.

Prosecutors are expected to contrast Delay's public remarks with the evidence they have gathered duringthe eight-year investigation.

[email protected]; 445-3617

The crux of the case

In 2001, Tom Delay and several Texas officials created Texans for a Republican Majority, a political actioncommittee that raised money to elect Republicans to the Texas legislature.

The purpose: A GOP majority in the Texas legislature would redraw the state's congressional districts tofavor Republicans and help Delay maintain his leadership role in Congress.

The hurdle: Texans for a Republican Majority had trouble raising money from Texas business interestsbecause they didn't want to offend Democratic state House Speaker Pete laney, so the GOP committeeturned to corporations with interests before the U.S. Congress.

Key players: Delay's chief political aide, Jim Ellis, oversaw the operation inWashington, D.C., whileassociate John Colyandro ran its Austin-based efforts.

The law State law forbids corporate money being donated to Texas candidates.

What happened: Colyandro sent a blank check to Ellis, who filled in the amount and gave it to theRepublican National Committee after meeting with RNC staffers. An arm of the RNC, in turn, sent the sameamount ($190,000) to seven Texas candidates two weeks later.

The legal question: Did Delay conspire with Ellis and Colyandro to launder corporate money intocampaign donations, or was Delay just a fundraiser who was briefed about a legal and routine transactionafter it occurred?

Find this article at:

http://www.statesman.com/news/texas-politics/subpoena-list-in-delay-case-reads-like-a-976216.html

Print ttiis page Close

10118/201



EXHIBIT 2



CREWIcitizens.for. r e s p o n ~ i b i l i t yand ethics in washington

October 19,2010

By facsimile: 202-514-6117

Rena Y. Kim

Chief, FOIA/PA Section

Criminal Division

U.S. Department of Justice

Suite 1127, Keeney Building

950 Pennsylvania Avenue, N.W.

Washington, D.C. 20530-0001

Re: Freedom of Information Act Request

Dear Ms. Kim:

Citizens for Responsibility and Ethics in Washington ("CREW") makes this request for

records, regardless of format, medium, or physical characteristics, and including electronic

records and information, audiotapes, videotapes and photographs, pursuant to the Freedom of

Information Act ("FOIA"), 5 U.S.C. §§ 552, et seq., and U.S. Department of Justice ("DOJ")

regulations, 28 C.F.R. Part 16.

Specifically, CREW requests any witness statements, investigation reports, prosecution

memoranda, and FBI 302 reports related to DOl's investigation of former House Majority Leader

Tom DeLay. This includes, but is not limited to, DOl's investigation of relationships betweenMr. DeLay and Christine DeLay, Dani DeLay, Jack Abramoff, Edwin Buckham, Tony Rudy,

Michael Scanlon, Susan Hirshmann, the Alexander Strategy Group, the National Center for

Public Policy Research, eLottery, Inc., the U.S. Family Network, Americans for a Republican

Majority PAC ("ARMPAC"), Texans for a Republican Majority PAC ("TRMPAC"), and/or the

Commonwealth of the Northern Marianas Islands.

Mr. DeLay was one of the subjects ofDOl's extensive investigation into illegal lobbying

activities by Mr. Abramoff and others. See R. Jeffrey Smith, Justice Department Drops

Investigation ofDeLay Ties to Abramoff, Wash. Post, August 17,2010 (attached as Exhibit A).

Among other things, DOJ investigated allegations Mr. Abramoff, Mr. Buckham, and Mr. Rudy

laundered money from entities with interests before Congress through non-profit organizations topay for Mr. and Mrs. DeLay's overseas travel. For example, Mr. Abramofffunneled payments

provided by eLottery, Inc. and other gambling interests through the National Center for Public

Policy Research to pay for Mr. and Mrs. DeLay's trip to Scotland, and used the same

organization to launder money from a Russian oil company to pay for Mr. and Mrs. DeLay's trip

to Russia. See, e.g., Phil Shenon, Ex-DeLay Aide Pleads Guilty In Lobby Case, N.Y Times,

April 1,2006 (attached as Exhibit B); R. Jeffrey Smith, The DeLay-AbramoffMoney Trail,

1400 Eye Street, NW., Suite 450, Washington, D.C. 20005 I 202.408.5565 phone I 202.588.5020 fax I www.citizensforethics



Rena Y. Kim

October 19,2010

Page 2

Wash. Post, December 31, 2005 (attached as Exhibit C); R. Jeffrey Smith, DeLay Airfare Was

Charged To Lobbyist's Credit Card, Wash. Post, April 24, 2005 (attached as Exhibit D); JamesV. Grimaldi & R. Jeffrey Smith, Gambling Interests Funded DeLay Trip, Wash. Post, March 12,

2005 (attached as Exhibit E).

DOJ also investigated allegations: (1) the Alexander Strategy Group, a lobbying firm run

by Mr. Buckham and Mr. Rudy, employed Mrs. DeLay in an effort to influence Mr. DeLay, see

Susan Schmidt & James V. Grimaldi, Lawmakers Under Scrutiny in Probe ofLobbyist, Wash.

Post, November 26,2005 (attached as Exhibit F); Philip Shenon, Lobbying Cases Highlight

Prime Targets' Family Ties, NY Times, April 9, 2006 (attached as Exhibit G); (2) Mrs. DeLay

and the DeLays' daughter Dani improperly were paid $350,000 in consulting fees and expenses

paid byARMPAC, Mr. DeLay's political action committee, see Michael Hedges, As Lobbying

Scandal Drags On, DeLay Takes a Shot at FBI, Houston Chronicle, May 9, 2007 (attached asExhibit H); (3) Mr. Abramoff and Mr. Buckham funneled $1 million from the Russian oil

company through the U.S. Family Network in an effort to influence Mr. DeLay and others, see

Smith, Wash. Post, December 31, 2005; Laylan Copelin, Subpoena List in DeLay Case Reads

Like Who's Who of Political, Business Interests, Austin American-Statesman, October 16, 2010

(attached as Exhibit I); and (4) Mr. DeLay and two associates conspired to illegally lauder

corporate campaign contributions through TRMPAC, id.; and (5) Mr. Abramoffarranged for a

trip to the Commonwealth of the Northern Mariana Islands to influence Mr. DeLay, see Michael

Hedges, Lobbyist Pleads Guilty to Conspiracy, Houston Chronicle, November 22,2005 (attached

as Exhibit J).

DOJ apparently concluded its investigation ofMr. DeLay recently without bringing

charges against him. See Smith, Wash. Post, August 17,2010.

Please search for responsive records regardless of format, medium, or physicalcharacteristics. Where possible, please produce records electronically, in PDF or TIF format on a

CD-ROM. We seek records of any kind, including electronic records, audiotapes, videotapes,

and photographs. Our request includes any letters, emails, facsimiles, telephone messages, voice

mail messages, and transcripts, notes, or minutes of any meetings, telephone conversations, or

discussions. Our request also includes any attachments to these records.

If it is your position that any portion of the requested records is exempt from disclosure,CREW requests that you provide it with an index of those documents as required under Vaughn

v. Rosen, 484 F.2d 820 (D.C. Cir. 1973), cert. denied, 415 U.S. 977 (1972). As you are aware, a

Vaughn index must describe each document claimed as exempt with sufficient specificity "to

permit a reasoned judgment as to whether the material is actually exempt under FOIA."Founding Church ofScientology v. Bell, 603 F.2d 945, 949 (D.C. Cir. 1979). Moreover, the

Vaughn index must "describe each document or portion thereofwithheld, and for eachwithholding it must discuss the consequences of supplying the sought-after information." King v.



Rena Y. KimOctober 19,2010

Page 3

us. Dep 't ofJustice, 830 Fold 210,223-24 (D.C. Cir. 1987) (emphasis added). Further, "the

withholding agency must supply'a relatively detailed justification, specifically identifying thereasons why a particular exemption is relevant and correlating those claims with the particular

part of a withheld document to which they apply. '" ld. at 224 (citing Mead Data Central v. U. S.

Dep 't of the Air Force, 566 F.2d 242,251 (D.C. Cir. 1977)).

In the event that some portions of the requested records are properly exempt from

disclosure, please disclose any reasonably segregable non-exempt portions of the requested

records. See 5 U.S.C. § 552(b). If it is your position that a document contains non-exempt

segments, but that those non-exempt segments are so dispersed throughout the document as to

make segregation impossible, please state what portion of the document is non-exempt, and how

the material is dispersed throughout the document. Mead Data Central, 566 F.2d at 261. Claims

of nonsegregability must be made with the same degree of detail as required for claims ofexemptions in a Vaughn index. If a request is denied in whole, please state specifically that it is

not reasonable to segregate portions of the record for release.

Finally, CREW welcomes the opportunity to discuss with you whether and to what extent

this request can be narrowed or modified to better enable DO] to process it within the FOIA's

deadlines.

Fee Waiver Request

In accordance with 5 U.S.C. § 552(a)(4)(A)(iii) and 28 C.F.R. § 16.11(k), CREW

requests a waiver of fees associated with processing this request for records. The subject of thisrequest concerns the operations of the federal government and expenditures, and the disclosures

will likely contribute to a better understanding of relevant government procedures by CREW and

the general public in a significant way. Moreover, the request is primarily and fundamentally for

non-commercial purposes. 5 U.S.C. § 552(a)(4)(A)(iii). See, e.g., McClellan Ecological v.

Carlucci, 835 Fold 1282, 1285 (9th Cir. 1987).

These records are likely to contribute to greater public awareness of alleged malfeasance

and possible criminal behavior by the former majority leader of the House ofRepresentatives,

and ofDO]' s recently concluded investigation into Mr. DeLay's activities. Related DO]

investigations resulted in criminal convictions ofMr. Abramoff, Mr. Rudy, Mr. Scanlon, former

Rep. Bob Ney, and others. While DO] eventually decided not to prosecute Mr. DeLay, his

activities still may have been illegal or violations of the rules of the House of Representatives,

and the requested records would shed light on them. In addition, other criminal allegations

against Mr. DeLay remain very active - a trial on state charges related to money laundering

through TRMPAC is scheduled to begin on October 26, 2010. See Copelin, Austin American-

Statesman, October 16, 2010. The public unquestionably has a powerful interest in learning the

extent to which a leading member ofCongress engaged in illegal or improper behavior. Us.

Dep 't ofJustice v. Reporters Comm. for Freedom of the Press, 489 U.S. 749, 774 (1989)



Rena Y. Kim

October 19,2010

Page 4

(suggesting a public interest in documents that would reveal a congressman's allegedly corrupt

behavior).

These documents also would shed light on DOl's conduct in conducting the investigation

ofMr. DeLay, and its apparent decision to close the investigation without bringing charges

against Mr. DeLay.

CREW is a non-profit corporation, organized under section 501(c)(3) of the Internal

Revenue Code. CREW is committed to protecting the public's right to be aware of the activities

of government officials and to ensuring the integrity of those officials. CREW uses a

combination of research, litigation, and advocacy to advance its mission. The release of

information garnered through this request is not in CREW's financial interest. CREW will

analyze the information responsive to this request, and will share its analysis with the public,either through memoranda, reports, or press releases. In addition, CREW will disseminate any

documents it acquires from this request to the public through its website,

www.citizensforethics.org, which also includes links to thousands of pages of documents CREW

acquired through its multiple FOIA requests as well as documents related to CREW's litigation

and agency complaints, and through www.scribd.com.

News Media Fee Waiver Request

CREW also asks that it not be charged search or review fees for this request because

CREW qualifies as a "representative of the news media" pursuant to the FOIA and SEC

regulation 17 C.F.R. § 200.80(e)(l0). In Nat'l Sec. Archive v. Us. Dep'tofDefense, 880 F.2d1381,1386 (D.C. Cir. 1989), the Court ofAppeals for the District ofColumbia Circuit found the

National Security Archive was a representative of the news media under the FOIA, relying on the

FOIA's legislative history, which indicates the phrase "representative of the news media" is to be

interpreted broadly; "i t is critical that the phrase 'representative of the news media' be broadly

interpreted if the act is to work as expected. . . . In fact, any person or organization which

regularly publishes or disseminates information to the public . . . should qualify for waivers as a

'representative of the news media. '" 132 Congo Rec. S14298 (daily ed. Sept. 30, 1986) (emphasis

added), cited in id.

CREW routinely and systematically disseminates information to the public in several

ways. First, CREW maintains a frequently visited website, wwvv.citizensforethics.org, that

received 108,643 visits in September 2010. In addition, CREW posts all of the documents it

receives under the FOIA on www.scribd.com. and that site has received 419,786visits to

CREW's documents since April 14,2010.

Second, since May 2007 CREW has published an online newsletter, CREWCuts, that

currently has 17,322 subscribers. CREWCuts provides subscribers with regular updates

regarding CREW's activities and information the organization has received from government



Rena Y. Kim

October 19,2010

Page 5

entities. A complete archive of past CREWCuts is available at

http://www.citizensforethics.org/newsletter.

Third, CREW publishes a blog, Citizens bloggingfor responsibility and ethics in

Washington, that reports on and analyzes newsworthy developments regarding government ethics

and corruption. The blog, located at http://www.citiznesforethics.org/blog, also provides links

that direct readers to other news articles and commentary on these issues. CREW's blog had

1,772 hits in September.

Finally, CREW has published numerous reports to educate the public about government

ethics and corruption, including agencies' failure to comply with their record keeping

responsibilities. See Record Chaos, which examines agency compliance with electronic record

keeping responsibilities; The Revolving Door, a comprehensive look into the post-governmentactivities of24 former members of President Bush's cabinet; and Those Who Dared: 30 Officials

Who Stood Up For Our Country. These and all other CREW's reports are available at

http://www.citizensforethics.org/repOlis.

Based on these extensive publication activities, CREW qualifies for a fee waiver as a

"representative of the news media" under the FOIA and agency regulations.

Request for Expedition

Pursuant to 5 U.S.C. § 552(a)(6)(E)(I) and 28 C.F.R. § 16.5(d)(l)(iv), CREW requests

that your office expedite the processing of this request. As required by DOJ regulations, 28C.F.R. § 16.5(d)(2), CREW is submitting its request for expedition to the director of Public

Affairs. A copy ofCREW's request is enclosed.

CREW also requests that DOJ expedite its request pursuant to 28 C.F.R. § 16.5(d)(l)(ii).

As explained above, CREW is engaged primarily in the dissemination of information that it

gathers from a variety of sources, including the FOIA, and seeks the information requested in the

FOIA request for the express purpose of disseminating it to the public. In addition to the

websites on which CREW posts all documents it acquires through the FOIA, CREW's website

contains numerous examples of its efforts, including reports it has published based on

information it receives through the FOIA. For example, CREW's report, Record Chaos: The

Deplorable State ofElectronic Record Keeping in the Federal Government, was based on

significant part on documents CREW requested under the FOIA from a variety of agencies,

including DOJ.

There is a particular urgency to inform the public about these investigations because, as

noted above, Mr. DeLay's criminal trial on state conspiracy charges is scheduled to begin in one

week. See Copelin, Austin American-Statesman, October 16,2010. Witnesses subpoenaed by

the prosecution for the trial include Mr. Buckham and Mr. Scanlon, who may be questioned



Rena Y. Kim

October 19,2010

Page 6

about '''the inner workings of Tom DeLay's political organization' as well as the defendant's

lobby-paid trips to Russia, Scotland and the Northern Marianas Islands" that were the subjectof

DOl's investigation. Jd. In light of the importance of this information for Mr. DeLay's criminal

trial, immediate action is required.

Pursuant to 28 C.F.R. § 16.5(d)(3), I hereby certify that the basis for CREW's request for

expedition, as outlined above, is true and correct to the best ofmy knowledge and belief.

Conclusion

If you have any questions about this request or foresee any problems in releasing fully the

requested records please contact me at (202) 408-5565. Also, if CREW's request for a fee

waiver is not granted in full, please contact our office immediately upon making such adetermination. Please send the requested records to Adam J.Rappaport, Citizens for

Responsibility and Ethics in Washington, 1400 Eye Street, N.W., Suite 450, Washington, D.C.

20005.

Sincerely,

Enclosures



EXHIBIT A



Department drops investigation of Delay ties to Abramoff

Q;be WtWbingrou Jlo!itJustice Department drops

investigation ofDeLay ties to

AbramoffBy R. Jeffrey Smith


Tuesday, August 17,2010; AO1

Former House majority leader Tom DeLay (R-Tex.)

was both defiant and ebullient on Monday after

hearing that the Justice Department had dropped its

six-year investigation of his interactions with lobbyist

Jack Abramoff and a host of other political

contributors for whom he allegedly did political favors.

http://www.washingtonpost.com/wp-dyn/content/article/20 10

"I always knew this day would come," DeLay said on the telephone from his home in Sugar Land, Tex.

He said he has no regrets about his conduct in Washington, insisted that his actions were always legal,

and assailed what he called the "criminalization of politics" by a federal ethics enforcement process he

considers deeply flawed.

His celebratory remarks came a week before he is slated to return to a Texas courtroom for a pretrial

hearing on allegations of felony conspiracy and money laundering, which still could put the 63-year-old

politician behind bars. His 2005 indictment in that Texas case is what short-circuited his three-year

tenure in one ofWashington's most powerful jobs.

The Justice Department declined to comment about DeLay's claim of exoneration, following its policy ofnot discussing the status or termination of its criminal investigations. A source familiar with the

long-running inquiry, in which many witnesses were brought before one or more grand juries, confirmed

that it had ended.

Speaking on the condition of anonymity, he said the main reason for dropping the effort was that

prosecutors were unable to compel incriminating testimony by a former DeLay aide, Edwin A.Buckham, and find other witnesses or evidence that could have led to a conviction.

Buckham has similarly been cleared by the Justice Department, a source close to DeLay said. Buckham's

attorney, David Geneson, declined to comment.

In recent years, DeLay has worked on rehabilitating his public image as well as his career, appearing in atelevision dancing competition, working as a paid consultant to corporations and advising -- by his own

description -- the factions that make up the "tea party" movement.

Asked whether he plans to attempt a return to Congress, DeLay acknowledged that his political

effectiveness has been hampered by years of scrutiny. People don't necessarily "want to associate with

you" after being under such a heavy legal cloud for so long, he said, explaining why he has declined to

endorse candidates.

The Justice Department investigation focused in part on payments made by Buckham, a former adviser

10/15/2010



Department drops investigation ofDeLay ties to Abramoff http://www.washingtonpost.com!wp-dyn/contentlarticle/2010

who was a registered lobbyist in 2000, to cover some of DeLay's expenses on an overseas golf trip.

Doing so violated House rules, but DeLay said he was unaware of the payments. Buckham's

now-shuttered firm employed DeLay's wife, Christine, from 1998 to 2002 and set up a retirement

account for her. A political action committee that Buckham controlled employed both DeLay's wife and

his daughter.

The payments amounted to nearly half a million dollars, drawn partly from revenue from corporations

and their officers that had interests in legislation pending before the House.

DeLay and Buckham were at one point two of the principal targets in the department's multifaceted

probe ofAbramoff's lobbying practice that led to the convictions of 19 people, including two DeLay

aides. DeLay has maintained he was unaware of their wrongdoing. He said Monday that the department

"couldn't find anything" otherwise in the documents, e-mails and computer hard drives that his office

had turned over to investigators without protest.

The source familiar with the investigation said that some of those working on the probe had disagreed

about the importance of holding out for Buckham's testimony when Abramoffhimselfwas potentially

available as a cooperating witness. Abramoff recently worked in a kosher pizza parlor in Baltimore while

wrapping up a four-year sentence for conspiracy, mail fraud and tax evasion.

DeLay referred to Abramoff, who admitted to corrupting public officials and defrauding his clients, as "a

friend ofmine." He said Abramoff's lavish pay from Native American tribes for lobbying had resulted

from inattention by the leaders of those tribes.

Known for a hard-edged, take-no-prisoners political style reflected in his nickname, "The Hammer,"

DeLay decried what he called "new politics" in which opponents try to "drown you," ruin your finances

and then "dance on your grave."

When asked whether he thought the recent House ethics charges against Democratic Reps. Maxine

Waters (Calif.) and Charles B. Rangel (N.Y.) also resulted an effort to punish successful fundraising andstrong political views, DeLay said their cases are different from his.

DeLay's principal attorney, Richard Cullen ofRichmond, said the Justice Department's decision also

covered Christine DeLay. "We had conversations off and on during '05, '06, '07 that were across the

board," Cullen said of his contacts with the Justice Department. "Prosecutors follow leads and a lot of

those leads were in the paper."

DeLay and Cullen said that he was never interviewed during the probe.

Staffwriter James V Grimaldi contributed to this report.


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10/15/2010



EXHIBITB



-DeLay Aide Pleads Guilty InLobby Case - The New York Times http://query.nytimes.com/gst/fullpage.html?res=9903E4D7I230

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April 1,2006

Ex-DeLayAide Pleads Guilty In Lobby Case

By PHILIP SHENON

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A former top aide to Representative Tom DeLay pleaded guilty on Friday to charges that he

accepted thousands of dollars in illegal gifts, including money funneled through a consulting

firm he set up with his wife and travel by private je t to California, in return for influencing

legislation on behalf of the lobbyist Jack Abramoff.

The plea agreement by the aide, Tony Rudy, a lobbyist who was Mr. DeLay's deputy chiefof

staff from 1998 to 2000 and one of his closest advisers, makes Mr. Rudy the second former

DeLay aide to admit wrongdoing in the corruption investigation centered on Mr. Abramoff.

Mr. Abramoffpleaded guilty in the investigation in January, acknowledging that he had

conspired with Mr. Rudy and others to corrupt public officials, including members of Congress.

Another of Mr. Abramoffs former lobbying partners, Michael Scanlon, who had been Mr.

DeLay's press secretary in the House, pleaded guilty last year to similar criminal charges in a

scandal that has put pressure on Congressional leaders to tighten federal ethics rules.

Mr. Rudy, Mr. Scanlon and Mr. Abramoffare all cooperating with the Justice Department,

which is investigating whether Mr. DeLay and other members of Congress, including

Representative Bob Ney, Republican ofOhio, accepted travel, gifts or money from Mr. Abramoff

and his associates in return for legislative favors.

Mr. Rudy's plea agreement, which covers actions he took on Mr. Abramoffs behalfboth while

on Mr. DeLay's staff and after leaving the House to work as a lobbyist, did not allege any

wrongdoing by Mr. DeLay, the former Republican majority leader, or say that Mr. DeLay knew

of any criminal activities by Mr. Rudy. Mr. DeLay is under indictment in Texas on unrelated

charges involving violations of state election laws.

But the plea agreement suggested more trouble for Mr. Ney. I t said that Mr. Rudy, who joined

Mr. Abramoffs lobbying firm after leaving Mr. DeLay's staff in late 2000 , said he, too, was

involved in "providing things of value to and soliciting and obtaining the agreement" of a

lawmaker -- identified only as "Representative NO.1" -- to assist Mr. Abramoff and his clients.

Federal law-enforcement officials, speaking on condition of anonymity because federal grand

jury rules ba r them from commenting publicly, said "Representative NO.1" was Mr. Ney.

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eLay Aide Pleads Guilty In Lobby Case - The New York Times http://query.nytimes.com/gstffullpage.html?res=9903E4D7123

Mr. Rudy's plea agreement suggested that tens of thousands of dollars in illegal gifts were

funneled to Mr. Rudy through a consulting firm that he and his wife, Lisa Rudy, established in

August 1999, when Mr. Rudy was working on Mr. DeLay's House staff. According to the Justice

Department's calculations, the firm, Liberty Consulting, took in about $86 ,000 , much of it

from a nonprofit group underwritten by Mr. Abramoffs lobbying clients.

Under the plea bargain, the Justice Department agreed not to prosecute Ms. Rudy in exchange

for her cooperation. Prosecutors said at the hearing that they would ask that Mr. Rudy, who

remains free, not be incarcerated until his cooperation was no longer needed in the

investigation.

He faces a maximum penalty of five years in prison, a $250 ,000 fine and restitution of up to

$100 ,000 . But under federal sentencing guidelines, Judge Ellen Huvelle of the Federal District

Court in Washington said he was more likely to receive a prison sentence between two and

two-and-a-halfyears.

In return for the gifts, court documents show, Mr. Rudy helped block a bill in the summer of

2000 to restrict Internet gambling -- Mr. Abramoff represented an Internet-gambling company

-- and had Mr. DeLay sign a letter in April 2000 opposing a postal-rate increase. Mr.

Abramoffs clients in the magazine-publishing industry opposed the increase.

In the plea agreement, Mr. Rudy acknowledged that he had received a long list of gifts from

Mr. Abramoffwhile serving on Mr. DeLay's staff, including a trip by private je t to the U.S. Open

golf tournament in Pebble Beach, Calif., in 2000 ; use of a box sui te for a bachelor par ty at an

August 2000 Washington Redskins game; tickets to the Daytona 500 in Florida; a trip with his

wife to Hilton Head, S.C.; meals at "expensive restaurants" in Washington; and golf clubs"costing several hundred dollars."

Mr. DeLay has acknowledged that he took a series oflavish overseas trips that were arranged

by Mr. Abramoff; Mr. DeLay's wife received more than $100 ,000 in consulting fees between

1998 and 2002 from Alexander Strategy Group, the lobbying firm where Mr. Rudy worked

most recently.

But the plea agreement signed by Mr. Rudy and made public on Friday does not allege that Mr.

DeLay had any knowledge of his former aide's corruption or that he himselfhad ever accepted

any gifts in exchange for specific acts in Congress.

"I have no indication that prosecutors are circling in on Mr. DeLay," said Richard Cullen, Mr.

DeLay's criminal defense lawyer. Mr. Cullen said he was advised several months ago by the

Justice Department that Mr. DeLay was not considered a target of the investigation. The

lawyer said he had no reason to believe Mr. DeLay's status had changed.

"Mr. DeLay was unaware of any of the acts to which Mr. Rudy has pleaded guilty," Mr. Cullen

said. "To say that he's bitterly disappointed is an understatement."

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f4

In th e summer of 2000, Mr. Rudy said in his plea agreement, he assisted Mr. Abramoff in

devising a strategy that killed an otherwise popular bill backed by most House Republicans to

restrict gambling on th e Internet; at th e time, Mr. Abramoff represented an Internet-gambling

company, eLottery, that faced collapse if th e bill passed.

Despite his longstanding opposition to gambling, Mr. DeLay was instrumental, with Mr.

Rudy's prompting, in blocking action on the bill. In May 2000, eLottery made a $25,000

contribution to a private educational group that underwrote a trip that month by Mr. DeLay

an d his wife to Britain; Mr. DeLay ha s said he had no knowledge of th e company's

contribution. Mr. Abramoffha s told prosecutors that he steered $50,000 in consulting fees to

Ms. Rudy as a result of her husband's help.

Mr. Rudy also acknowledged that, at Mr. Abramoff's behest, he obtained Mr. DeLay's signature

on a letter in early 2000 criticizing plans by th e Postal Service to raise its rates; the increase

was strongly opposed by th e Magazine Publishers Association, one ofMr. Abramoffs lobbying

clients. Mr. DeLay was among many lawmakers, including Democrats, who opposed th e rateincrease, an d while th e rates were increased th e next year, they went up less than originally

planned.

Mr. Rudy's deal with th e prosecutors appeared to buttress information provided earlier to

prosecutors about Mr. Ney by Mr. Abramoffan d Mr. Scanlon. In their earlier plea agreements,

Mr. Abramoff an d Mr. Scanlon ha d singled out Mr. Ney as th e recipient of many of their gifts,

including a 2002 golf excursion to th e fabled St. Andrews course in Scotland.

Mr. Rudy said in his agreement that Mr. Ney, identified as Representative NO.1, agreed in

March 2001 to support legislation that would have allowed Mr. Abrarnoff's clients in th eNorthern Mariana Islands, a small American territory in th e western Pacific, to continue to

make clothing that could be labeled "Made in th e U.S.A." even though th e islands' migrant

Asian garment workers were no t protected by federal labor laws an d the minimum wage.

Human rights groups and labor unions have long described th e garment factories as sweat

shops.

Mr. Rudy's plea agreement refers to th e 2002 Scottish golfing trip, with Mr. Rudy

acknowledging that he solicited $25,000 from one of Mr. Abramoff's Indian tribe clients to

help pay for the trip, claiming to thetribe that th e money would be used by a charity group.

Court documents show that Mr. Rudy invited Mr. Ney on th e trip, promising golf an d "drinkingan d smoking Cubans."

Mr. Ney's office di d no t dispute that he was Representative No. 1. His spokesman, Brian J.Walsh, said in a statement that Mr. Rudy's plea agreement made "clear yet again that Jack

Abramoff an d his subordinates engaged in a collaborative an d deliberate strategy to defraud,

manipulate and lie in order to advance their own personal greed." Mr. Walsh said Mr. Ney,

who is facing a difficult race for re-election in November, remained confident "that he did

absolutely nothing wrong."

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Aide Pleads Guilty In Lobby Case - The New York Times http://query.nytimes.comigst/fullpage.html?res=9903E4D71230

Mr. Rudy, 39, entered his guilty plea in Federal District Court in Washington, saying nothing

beyond "yes" and "no" in response to a series of questions posed by Judge Huvelle about the

terms of his agreement with the Justice Department. Asked later how he pleaded to the single

conspiracy count in the plea agreement, Mr. Rudy replied, "Guilty, your honor."

Photo: Tony Rudy, a lobbyist and former Congressional aide, pleaded guilty to corruption

charges yesterday at Federal District Court in Washington. Mr. Rudy's case is tied with that of

the lobbyist Jack Abramoff. (Photo by Lawrence Jackson/Associated Press)(pg. A12)

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10/19/2010



EXHIBIT C



e DeLay-AbramoffMoney Trail

Q.t1)e Wtt6f)ingfun JlO1JtThe DeLay-AbramoffMoney TrailNonprofit Group Linked to Lawmaker Was Funded

Mostly by Clients of Lobbyist

By R. Jeffrey Smith


Saturday, December 31, 2005

The U.S. Family Network, a public advocacy group

that operated in the 1990s with close ties to Rep. Tom

DeLay and claimed to be a nationwide grass-rootsorganization, was funded almost entirely by

corporations linked to embattled lobbyist Jack

Abramoff, according to tax records and formerassociates of the group.

http://www.washingtonpost.com/wp-dynlcontent/article/2005

During its five-year existence, the u.s. Family Network raised $2.5 million but kept its donor list secret.

The list, obtained by The Washington Post, shows that $1 million of its revenue came in a single 1998check from a now-defunct London law firm whose former partners would not identify the money's

ongms.

Two former associates of Edwin A. Buckham, the congressman's former chiefof staff and the organizerof the U.S. Family Network, said Buckham told them the funds came from Russian oil and gas

executives. Abramoff had been working closely with two such Russian energy executives on theirWashington agenda, and the lobbyist and Buckham had helped organize a 1997 Moscow visit by DeLay

(R-Tex.).

The former president of the u.s. Family Network said Buckham told him that Russians contributed $1

million to the group in 1998 specifically to influence DeLay's vote on legislation the InternationalMonetary Fund needed to finance a bailout of the collapsing Russian economy.

A spokesman for DeLay, who is fighting in a Texas state court unrelated charges of illegal fundraising,

denied that the contributions influenced the former House majority leader's political activities. TheRussian energy executives who worked with Abramoff denied yesterday knowing anything about the

million-dollar London transaction described in tax documents.

Whatever the real motive for the contribution of $1 million -- a sum not prohibited by law butextraordinary for a small, nonprofit group -- the steady stream of corporate payments detailed on the

donor list makes it clear that Abramoff's long-standing alliance with DeLay was sealed by a much more

extensive web of financial ties than previously known.

Records and interviews also illuminate the mixture of influence and illusion that surrounded the u.s.

Family Network. Despite the group's avowed purpose, records show it did little to promote conservative

ideas through grass-roots advocacy. The money it raised came from businesses with no demonstratedinterest in the conservative "moral fitness" agenda that was the group's professed aim.

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In addition to the million-dollar payment involving the London law firm, for example, half a milliondollars was donated to the US. Family Network by the owners of textile companies in the MarianaIslands in the Pacific, according to the tax records. The textile owners -- with Abramoff's help -- solicited

and received DeLay's public commitment to block legislation that would boost their labor costs,according to Abramoff associates, one of the owners and a DeLay speech in 1997.

A quarter of a million dollars was donated over two years by the Mississippi Band of Choctaw Indians,

Abramoff's largest lobbying client, which counted DeLay as an ally in fighting legislation allowingthe

taxation of its gambling revenue.

The records, other documents and interviews call into question the very purpose of the US. Family

Network, which functioned mostly by collecting funds from domestic and foreign businesses whose

interests coincided with DeLay's activities while he was serving as House majority whip from 1995 to

2002, and as majority leader from 2002 until the end of September.

After the group was formed in 1996, its director told the Internal Revenue Service that its goal was to

advocate policies favorable for "economic growth and prosperity, social improvement, moral fitness, and

the general well-being of the United States." DeLay, in a 1999 fundraising letter, called the group "a

powerful nationwide organization dedicated to restoring our government to citizen control" by mobilizinggrass-roots citizen support.

But the records show that the tiny US. Family Network, which never had more than one full-time staff

member, spent comparatively little money on public advocacy or education projects. Although

established as a nonprofit organization, it paid hundreds of thousands of dollars in fees to Buckham and

his lobbying firm, Alexander Strategy Group.

There is no evidence DeLay received a direct fmancial benefit, but Buckham's firm employed DeLay's

wife, Christine, and paid her a salary of at least $3,200 each month for three of the years the group

existed. Richard Cullen, DeLay's attorney, has said that the pay was compensation for lists Christine

DeLay supplied to Buckham of lawmakers' favorite charities, and that it was appropriate under Houserules and election law.

Some of the US. Family Network's revenue was used to pay for radio ads attacking vulnerableDemocratic lawmakers in 1999; other funds were used to fmance the cash purchase of a townhouse

three blocks from DeLay's congressional office. DeLay's associates at the time called it "the SafeHouse."

DeLay made his own fundraising telephone pitches from the townhouse's second-floor master suiteevery few weeks, according to two former associates. Other rooms in the townhouse were used byAlexander Strategy Group, Buckham's newly formed lobbying firm, and Americans for a Republican

Majority (ARMPAC), DeLay's leadership committee.

They paid modest rent to the US. Family Network, which occupied a single small room in the back.

'Red Flags' on Tax Returns

Nine months before the June 25,1998, payment of$l million by the London law firm James & Sarch

Co., as recorded in the tax forms, Buckham and DeLay were the dinner guests in Moscow ofMarinaNevskaya and Alexander Koulakovsky of the oil firmNaftasib, which in promotional literature counted

as its principal clients the Ministry ofDefense and the Ministry of Interior.

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n

Buckham, a graduate of the University ofTennessee, had worked for DeLay since 1995, after serving in

other congressional offices and then as executive director of the Republican Study Committee, a group

of fiscally conservative House members.

Their other dining companions were Abramoffand Washington lawyer Julius "Jay" Kaplan, whoselobbying firms collected $440,000 in 1997 and 1998 from an obscure Bahamian firm that helped

organize and indirectly pay for the DeLay trip, in conjunction with the Russians. In disclosure forms, the

stated purpose of the lobbying was to promote the policies of the Russian government.

Kaplan and British lawyer David Sarch had worked together previously. (Sarch died a month before the

$1 million was paid.) Buckham's trip with DeLay was his second to Moscow that year for meetings with

Nevskaya and Koulakovsky; on the earlier one, the DeLay aide attracted media attention by returning

through Paris aboard the Concorde, a $5,500 flight.

Former Abramoff associates and documents in the hands of federal prosecutors state that Nevskaya and

Koulakovsky sought Abramoff's help at the time in securing various favors from the U.S. government,

including congressional earmarks or federal grants for their modular-home construction firm nearMoscow and the construction of a fossil-fuel plant in Israel. None appears to have been obtained by their

firm.

Former DeLay employees say Koulakovsky and Nevskaya met with him on multiple occasions. The

Russians also frequently used Abramoff's skyboxes at local sports stadiums -- as did Kaplan, according

to sources and a 2001 e-mail Abramoffwrote to another client.

Three sources familiar with Abramoff's activities on their behalf say that the two Russians -- who knewthe head of the Russian energy giant Gazprom and had invested heavily in that firm -- partly wanted justto be seen with a prominent American politician as a way of bolstering their credibility with the Russian

government and their safety on Moscow's streets. The Russian oil and gas business at the time had aWild West character, and its executives worried about extortion and kidnapping threats. The anxieties of

Nevskaya and Koulakovsky were not hidden; likemany other business people, they traveled inMoscowwith guards armed with machine guns.

During the DeLays' visit on Aug. 5 to 11, 1997, the congressman met with Nevskaya and was escortedaround Moscow by Koulakovsky, Naftasib's general manager. DeLay told the House clerk that the trip's

sponsor was the National Center for Public Policy Research, but multiple sources told The Post that his

expenses were indirectly reimbursed by the Russian-connected Bahamian company.

DeLay spokesman Kevin Madden said the principal reason for his Moscow trip was "to meet withreligious leaders there." Nevskaya, in a letter this spring, said Naftasib's involvement in such trips was

meant "to foster better understanding between our country and the United States" and denied that the

firm was seeking protection through its U.S. contacts.

Nevskaya added in an e-mail yesterday that Naftasib and its officials were not representing the ministries

of defense and interior or any other government agencies "in connection with meetings or other lobbying

activities in Washington D.C. or Moscow."

A former Abramoff associate said the two executives "wanted to contribute to DeLay" and clearly had

the resources to do it. At one point, Koulakovsky asked during a dinner in Moscow "what would happenif the DeLays woke up one morning" and found a luxury car in their front driveway, the former associate

said. They were told the DeLays "would go to jail and you would go to jail."

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f7

The tax form states that the $1 million came by check on June 25, 1998, from "Nations Corp, James &Sarch co." The Washington Post checked with the listed executives of Texas and Florida firms that have

names similar to Nations Corp, and they said they had no connection to any such payment.

James & Sarch Co. was dissolved in May 2000, but two former partners said they recalled hearing the

names of the Russians at their office. Asked if the firm represented them, former partner PhilipMcGuirk

at first said "it may ring a bell," but later he faxed a statement that he could say no more becauseconfidentiality practices prevent him "from disclosing any information regarding the affairs of a client (orformer client)."

Nevskaya said in the e-mail yesterday, however, that "neither Naftasib nor the principals you mentioned

have ever been represented by a London law firm that you name as James & Sarch Co." She also saidthat Naftasib and its principals did not pay $1 million to the firm, and denied knowing about the

transaction.

Two former Buckham associates said that he told them years ago not only that the $1 milliondonationwas solicited from Russian oil and gas executives, but also that the initial plan was for the donation to be

made via a delivery of cash to be picked up at a Washington area airport.

One of the former associates, a Frederick, Md., pastor named Christopher Geeslin who served as theU.S. Family Network's director or president from 1998 to 2001, said Buckham further told him in 1999

that the payment was meant to influence DeLay's vote in 1998 on legislation that helped make it possible

for the IMF to bailout the faltering Russian economy and the wealthy investors there.

"Ed told me, 'This is the way things work in Washington,' " Geeslin said. "He said the Russians wanted to

give the money first in cash." Buckham, he said, orchestrated all the group's fundraising and spendingand rarely informed the board about the details. Buckham and his attorney, Laura Miller, did not reply to

repeated requests for comment on this article.

The IMF funding legislation was a contentious issue in 1998. The Russian stock market fell steeply inApril and May, and the government in Moscow announced on June 18 -- just a week before the $1

million check was sent by the London law firm -- that it needed $10 billion to $15 billion in new

international loans.

House Republican leaders had expressed opposition through that spring to giving the IMF the money itcould use for new bailouts, decrying what they described as previous destabilizing loans to other

countries. The IMF and its Western funders, meanwhile, were pressing Moscow, as a condition of anyloan, to increase taxes on major domestic oil companies such as Gazprom, which had earlier defaulted on

billions of dollars in tax payments.

On Aug. 18, 1998, the Russian government devalued the ruble and defaulted on its treasury bills. ButDeLay, appearing on "Fox News Sunday" on Aug. 30 of that year, criticized the IMF financing bill,calling the replenishment of its funds "unfortunate" because the IMF was wrongly insistingon a Russiantax increase. "They are trying to force Russia to raise taxes at a time when they ought to be cutting taxes

in order to get a loan from the IMF. That's just outrageous," DeLay said.

In the end, the Russian legislature refused to raise taxes, the IMF agreed to lend the money anyway, and

DeLay voted on Sept. 17, 1998, for a foreign aid bill containing new funds to replenish the IMF account.DeLay's spokesman said the lawmaker "makes decisions and sets legislative priorities based on goodpolicy and what is best for his constituents and the country." He added: "Mr. DeLay has very firm

beliefs, and he fights very hard for them."

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Kaplan did not respond to repeated messages, and through a spokesman for lawyer Abbe Lowell,

Abramoff declined to comment.

No legal bar exists to a $1 million donation by a foreign entity to a group such as the US. FamilyNetwork, according to Marcus Owens, a Washington lawyer who directed the IRS's office of tax-exempt

organizations from 1990 to 2000 and who reviewed, at The Post's request, the tax returns filed by the

US. Family Network.

But "a milliondollars is a staggering amount ofmoney to come from a foreign source" because such adonor would not be entitled to claim the tax deduction allowed for US. citizens, Owens said. "Giving

large donations to an organization whose purposes are as ambiguous as these . . . is extraordinary. Ihaven't seen that before. It suggests something else is going on.

"There are any number of red flags on these returns."

Hailing Indian Tribe's Hiring of Lobbyists

Buckham and Tony Rudy were the first DeLay staffmembers to visit the Choctaw Reservation near

Meridian, Miss., where the tribe built a 500-room hotel and a 90,000-square-foot gambling casino. Theirtrip from March 25 to 27, 1997, cost the Choctaws $3,000, according to statements filed with the House

clerk.

DeLay, his wife and Susan Hirschman -- Buckham's successor in 1998 as chief of staff -- were the next

to go. Their trip from July 31 to Aug. 2, 1998, was described on House disclosure forms as a "site review

and reservation tour for charitable event," and the forms said it cost the Choctaws $6,935.

Buckham, who was then a lobbyist, arranged DeLay's trip, which included a visit to the tribe's golf

course to assess it as a possible location for the lawmaker's annual charity tournament, according to atribal source. Abramofftold the tribe he could not accompany DeLay because of a prior commitment,

the source said.

One day after the DeLays departed for Washington, the US. Family Network registered an initial

$150,000 payment made by the Choctaws, according to its tax return. The tribe made additionalpayments to the group totaling $100,000 on "various" dates the following year, the returns state. The

Choctaws separately paid Abramoff $4.5 million for his lobbying work on their behalf in 1998 and 1999.Abramoff and his wife contributed $22,000 to DeLay's political campaigns from 1997 to 2000, according

to public records.

A former Abramoff associate who is aware of the payments, and who spoke on the condition ofanonymity to protect his clients, said the tribe made contributions to entities associated with DeLay

because DeLay was crucial to the tribe's continuing fight against legislation to allow the taxation of

Indians' gambling revenue.

An attorney for the tribe, Bryant Rogers, said the funds were meant not only to "get the message out"

about the adverse tax law proposals but also to fInance a campaign by Buckham's group within "the

conservative base" against legislation to strip tribes of their control over Indian adoptions. "This was agroup connected to the right-wing Christian movement," Rogers said. "This is Ed Buckham's

connection."

In March 1999, after the tribe had paid a substantial sum directly to the US. Family Network, Buckhamexpressed his general gratitude to Abramoff in an e-mail. "I really appreciate you going to bat for us.

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n

Remember it is the first bit ofmoney that is always the hardest, but means the most," Buckham said,according to a copy. He added: "Pray for God's wisdom. I really believe this is supposed to be what we

are doing to save our team."

During this period, a fundraising letter on the U.S. FamilyNetwork stationery was sent to residents ofAlabama, announcing a petition drive to promote a cause of interest to Abramoff's Indian gambling

clients inMississippi and Louisiana, including the Choctaw casino that drew many customers from

Alabama: the blocking of a rival casino proposed by the Poarch Creek Indians on their land in Alabama.

"The American family is under attack from all sides: crime, drugs, pornography, and one of the least

talked about but equally as destructive -- gambling," said the group's letter, which was signedby

then-Rep. Bob Riley (R), now the Alabama governor. "We need your help today . . . to prevent thePoarch Creek Indians from building casinos in Alabama."

Asked about the letter, Rogers said "none of us have seen" it and "the tribe's contributions have nothing

to do with it." A spokesman for Riley said that he could not recall the circumstances behind the letter,

but that he has long opposed any expansion of gambling in Alabama.

DeLay, meanwhile, saluted Choctaw chief Philip Martin in the Congressional Record on Jan. 3,2001,citing "all he has done to further the cause of freedom." DeLay also attached to his remarks an editorial

that hailed the tribe's gambling income and its "hiring [of] quality lobbyists."

Throughout this period, the U.S. Family Network was paying a monthly fee of at least $10,000 to

Buckham and Alexander Strategy Group for general "consulting," according to a former Buckhamassociate and a copy of the contract. While DeLay's wife drew a monthly salary from the lobbying firm,

she did not work at its offices in the townhouse on Capitol Hill, according to former Buckham associates.

Neither the House nor the Federal Election Commission bars the payment of corporate funds to spousesthrough consulting firms or political action committees, but the spouses must perform real work for

reasonable wages.

"Anytime you [as a congressman] hire your child or spouse, it raises questions as to whether this is athrowback to the time when people used campaigns and government jobs to enrich their families," said

Larry Noble, executive director of the Center for Responsive Politics, a nonpartisan watchdog group,

and a former general counsel of the FEC.

Research editor Lucy Shackelford; researchers Alice Crites, Madonna Lebling, Karl Evanzz and Meg

Smith,' and research database editor Derek Willis contributed to this report.



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hingtonpost.com: DeLay Airfare Was Charged To Lobbyist 's Credi... http://www.washingtonpost.com/ac2/wp-dyn/A12416-2005Ap

• Single Family Ho

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• Manor Townhome

Multiple sources, including DeLay's then-chief of staff Susan Hirschmann, have confirmed that DeLay's

congressional office was in direct contact with Preston Gates about the trip itinerary before DeLay's

departure, to work out details of his travel. These contacts raise questions about DeLay's statement that

he had no way of knowing about the financial and logistical support provided by Abramoff and his firm.

The documents obtained by The Washington Post, including receipts for his hotel stays in Scotland andLondon and billings for his golfing during the trip at the famed St. Andrews course in Scotland,

substantiate for the first time that some ofDeLay's expenses on the trip were billed to charge cards used

by the two lobbyists. The invoice for DeLay's plane fare lists the name ofwhat was then Abramoffs

lobbying firm, Preston Gates & Ellis.

House ethics rules bar lawmakers from accepting travel and related expenses from registered lobbyists.

DeLay, who is now House majority leader, has said that his expenses on this trip were paid by a nonprofit

organization and that the financial arrangements for it were proper. He has also said he had no way of

knowing that any lobbyist might have financially supported the trip, either directly or through

reimbursements to the nonprofit organization.

Yesterday, DeLay's lawyer, Bobby R. Burchfield, said that DeLay's staffwas aware that Preston Gates

was trying to arrange meetings and hotels for the trip but that DeLay was unaware of the "logistics" of bill

payments, and that DeLay "continues to understand his expenses" were properly paid by the nonprofit

organization, the National Center for Public Policy Research.

DeLay's expenses during the same trip for food, phone calls and other items at a golf course hotel in

Scotland were billed to a different credit card also used on the trip by a second registered Washington

lobbyist, Edwin A. Buckham, according to receipts documenting that portion of the trip.

washingtonpost.com

DeLay Airfare Was Charged To Lobbyist's Credit Card

The airfare to London and Scotland in 2000 for then-House Majority Whip Tom DeLay (R-Tex.) was

charged to an American Express card issued to Jack Abramoff, a Washington lobbyist at the center of afederal criminal and tax probe, according to two sources who know Abramoffs credit card account

number and to a copy of a travel invoice displaying that number.

By R. Jeffrey Smith


Sunday, April 24,2005; Page AOI

In 2000, Abramoffwas a board member of the group. In a telephone interview yesterday, Hirschmann

said the contacts between DeLay's office and persons at Preston Gates occurred because Abramoff "was

a board member of the sponsoring organization." Hirschmann added: "We were assured that the National

Center paid for the trip."

House rules do not exempt such nonprofit organization board members from the prohibition on lobbyist

payments for travel. They also state that this prohibition "applies even where the lobbyist . . . will later be

reimbursed for those expenses by a non-lobbyist client."

Burchfield did not dispute that Abramoff used his credi t card to pay for DeLay 's plane fare, but said in a

statement that "the majority leader has always believed and continues to believe that all appropriate expenses for the U'K, trip were

paid by the National Center for Public Policy Research." He said that "to the extent that Mr. Abramoff put the charges on his

personal credit card, Mr. DeLay has no knowledge of this. But that would be consistent with Mr. Abramoff obtaining fullreimbursement from the National Center."

He said further that, in his view, Abramoffs participation on this trip as a board member meant he was permitted to pay for some of

the expenses, subject to reimbursement, and that numerous court decisions recognize that different rules may be applicable to the

same person acting in different capacities.

Andrew Blum, a publicist for Abramoffs lawyer and spokesman for Abramoff, did not respond to questions relating to the use of

Abramoffs credit card for DeLay's plane fare. But he said in a statement yesterday that it was the National Center that "sponsored"

the trip, "not Jack Abramoff."

Blum said that DeLay was "one of the center's honored guests on this trip" and that Abramoff "is being singled out for doing what is

commonly done by lobbyists -- taking trips with members of Congress and their staff so that they can learn about issues that impact

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the Congress and government policy." The center's ability to sponsor "this type of educational trip, using contributor funds, is both

legal and proper," Blum said.

DeLay was admonished three times last year by the House ethics committee for infringing rules governing lawmakers' activities and

their contacts with registered lobbyists. House ethics rules bar the payment by lobbyists for any lawmaker's travel-connected

entertainment and recreational activities costing more than $50; they also require that lawmakers accurately report the sponsor of

their trips and the full cost.

In an art icle last month about the same trip by DeLay, The Post reported that an Indian tribe and a gambling services company

made donations to the National Center for Public Policy Research that covered most of the expenses declared by participants at

that t ime. The article also said these payments were made two months before DeLay voted against legislation opposed by the tribe

and the company. DeLay has said the vote was unrelated to the payments.

The article also reported that Abramoff submitted an expense voucher to Preston Gates seeking a reimbursement of $12,789.73 to

cover expenses for meals, hotels and transportation during the London and Scotland trip incurred by DeLay; his wife, Christine; and

his two aides.

The new receipts add more detail about these expenses, make clear that the total expenses for all of the participants were at least

$50,000 more than was previously known, and connect Abramoffdirectly to the payment of some charges.

For DeLay, the IO-day trip began on May 25 with a flight to London from Dulles a irpor t and ended on June 3 with a return trip

from Europe via Newark and ending in Houston. In between, his itinerary called for stops in Edinburgh, Glasgow, and St. Andrews,

in Scotland. DeLay said the purpose of the trip was to hold meetings with "Conservative leaders" in Britain and Scotland, including

Margaret Thatcher. The former prime minister's office has confirmed that such a meeting occurred.

DeLay's two aides, Tony Rudy and Susan Hirschmann, had an overlapping itinerary; Rudy participated from May 29 to June 3, and

Hirschmann participated from May 22 to June 2. The spouses of Rudy and Buckham also were present.

The travel receipts do not make clear how the expenses for the ent ire trip -- which involved at least 10 people and which two

sources said exceeded $120,000 -- were paid. One source familiar with the billings said yesterday that the National Center

reimbursed Abramofffor the charges incurred by DeLay and his staff that were billed to Abramoffs credit card; but the receipts

themselves do not indicate whether some of the charges incurred by Abramoffwere ultimately reimbursed and, if so, by whom.

The receipts make clear that flights for DeLay and his wife were initially billed to Abramoff. The plane ticket for the husband of

one of DeLay 's a ides -- David Hirschmann -- was billed to the same American Express card used for the DeLay tickets, according

to a copy of the invoice.

Although Amy Ridenour, director of the National Center for Public Policy Research, has said she organized the trip, two othersources said that DeLay's round-trip business-class tickets on Continental Airlines and British Airways were booked by Preston

Gates employees.

The itinerary and invoice for DeLay's trip, prepared by a travel service in Seatt le , was sent by the service to Preston Gates on May

23,2000, according to a copy of the invoice. That was two days before DeLay's departure. The invoice states that DeLay's

business-class tickets on Continental Airlines and British Airways cost $6,938.70.

The records also indicate that the expenses associated with DeLay exceeded those that he declared in a signed statement to the

House clerk on June 30, 2000. That form listed the purpose of the trip as "educational" and gave a tally of$28,106 in expenses for

DeLay and his wife, or an average of $2,800 a day; it s ta ted that all of these charges were paid by the National Center for Public

Policy Research, which provided the data to DeLay.

Receipts from the golfing portion of the trip show that DeLay accumulated additional charges, which, according to fees set by the

tour arranger, amounted to nearly $5,000 for each golfer and totaled in the tens of thousands of dollars for the entire group. Feesassociated with playing golf are not listed on DeLay's travel disclosure form. Burchfield, DeLay's lawyer, said DeLay "personally

paid for two rounds of golf and understands tha t the other two rounds of golf he played were included in his hotel package" and

reimbursed by the National Center.

A copy of the $184 bill for the DeLays' expenses dur ing the trip at a separate hotel in St. Andrews -- the Old Course Hotel Golf

Resort & Spa -- s ta tes that those charges were paid by the same American Express credit card used on the trip by Buckham, the

lobbyist , to pay for his own hotel room at the Glasgow Hilton. Buckham could not be reached by phone at home or his office and

did not respond to an e-mailed request for comment. Burchfield said he cannot explain how this happened and did not know who

owned this credit card; he also said DeLay was unaware of this fact.

Buckham, a former chief of staff to DeLay, was at the time a registered lobbyist for AT&T, Enron Corp., and the Nuclear Energy

Institute. DeLay's wife was employed, at the time of the trip, by Buckham's lobbying firm, the Alexander Strategy Group, and was

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receiving a salary from it, according to DeLay's personal financial disclosure statement for that year, on file with the House clerk.

Abramoff, at the time of the trip, represented eLottery Inc. , a gambling services company that opposed the Internet gambling bill

pending before the House. Preston Gates registered as a lobbyist for eLottery on June 2, 2000, one day before the trip ended; later

in the year, Abramoffregistered as a lobbyist for other clients who opposed the bill, including several Indian tribes. The federal

probe is looking into his handling of his tribal clients and the large fees he was paid.

Hirschmann and her husband ultimately accumulated charges of 2,073 British pounds, or about $3,109 at the prevailing exchange

rate for four nights in their "superior" room at the London Four Seasons Hotel. Those charges included $129 at the hotel lounge,

$75 from the room bar, $34 from the gift shop, and $422 for chauffeured cars, according to a copy of their hotel bill. Hirschmann

said one car was used to reach the meeting with Thatcher.

At least one of the Hirschmanns also played golf at St. Andrews. Susan Hirschmann is now a lobbyist at the Washington finn of

Williams & Jensen; the firm's Web site contains a published claim that DeLay and other House Republican leaders are in frequent

contact with her. As a staffmember at the time of the trip, she would have been covered by the same ethics rules that apply to

DeLay and other House members. Rudy, her staff colleague at the time, now works for Buckham's lobbying firm.

DeLay and his wife, for their part, stayed for four nights in a "conservatory" room at the same hotel in London as Hirschmann,

accumulating charges of roughly $790 a night for rooms that included a glass-enclosed porch overlooking London's Park Lane,

according to a copy of the bill for their stay and the Web site of the hotel.

They also ran up hotel charges of $145 for room service, $13 for a valet pressing and $302 for a private car from Heathrow airport,

the bill states. Their room bill also lists a charge of $434 for six theater tickets, but Burchfield said the DeLays do not recall

attending any plays in London. He said if the hotel charges were being "picked up" by a representative of the National Center,

"they would not necessarily have seen the hotel bill."

DeLay, Burchfield said, "does not know how the logistics . . . [o f the bill payments for the trip] were being effectuated."

House ethics rules contain detailed provisions barring the acceptance of any travel funds from private sources if doing so would

"create the appearance of using public office for private gain." They also obligate lawmakers to "make inquiry on the source of the

funds that will be used to pay" for any travel ostensibly financed by a nonprofit organizat ion -- to rule out the acceptance of

reimbursements that come from one organization when a trip is "in fact organized and conducted by someone else."

Trips outside the United States are also not supposed to exceed a week in length out of concern, the rules state, for "the public

perception that such trips often may amount to paid vacat ions for the Member and his family at the expense of special interest

groups." Research editor Lucy Shackelford and researchers Alice Crites and Madonna Lebling contributed to this report.


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EXHIBITE



ingtonpost.com: Gambling Interests Funded DeLay Trip http://www.washingtonpost.com/ac2/wp-dyn/A28252-2005Mar

washingtonpost.com

Gambling Interests Funded DeLay TripLater in 2000, Lawmaker's Vote Helped Defeat Regulatory Measure

By James Y.Grimaldiand R. JeffreySmithWashingtonPostStaffWritersSaturday, March 12,2005; PageAOI

An Indian tribe and a gambling services company made donations to a Washington public policy groupthat covered most of the cost ofa $70,000 trip to Britain by House Majority Leader Tom DeLay (R-Tex.),

his wife, two aides and two lobbyists in mid-2000, two months before DeLay helped kill legislation

opposed by the tribe and the company.

The sponsor of the week-long trip listed in DeLay's financial disclosures was the nonprofit National

Center for Public Policy Research, but a person involved in arranging Del.ay's travel said that lobbyist

Jack Abramoffsuggested the trip and then arranged for checks to be sent by two of his clients, the

Mississippi Band of Choctaw Indians and eLottery Inc.

The dates on the checks coincided with the day DeLay left on the trip, May 25, 2000, according to grants

documents reviewed by The Washington Post. The Choctaw and eLottery each sent a check for $25,000,

according to the documents. They now say that they were unaware the money was being used to financeDeLay's travels.

But Amy Ridenour, president of the National Center, said that, when the trip was arranged, Abramoff

promised he would secure financial backing. She said that even without Abramoff's efforts, the National

Center would have borne the cost of the trip, which was intended to allow the group to network with

conservative British politicians and included an outing to the famous St. Andrews golfcourse in Scotland.

"We paid for the trip," Ridenour said. "This trip was going to be paid for by the National Center,

regardless of whether we got the donations from the Choctaw or eLottery."

House ethics rules allow lawmakers and their staffs to have travel expenses paid only for officially

connected travel and only by organizations directly connected to the trips. The rules also require that

lawmakers accurately report the people or organizations that pay for the trips. They prohibit payments by

registered lobbyists for lawmakers' travel.

DeLay's spokesman, Dan Allen, said: "The trip was sponsored, organized and paid for by the NationalCenter for Public Policy Research, as our travel disclosures accurately reflect and what the NationalCenter has publicly said."

Abrarnoff's attorney, Abbe David Lowell, declined to comment. Abramoff, the National Center and the

flow of money between them are now being investigated by a federal task force and by the Senate

Committee on Indian Affairs; DeLay was admonished three times last year for infringements ofHouse

ethics rules.

To prove an ethics violation, investigators would have to show that DeLay and his staff knew the

gambling interests were funding the trip, said Jan W. Baran, a Wiley Rein & Fielding LLP ethics lawyer

who often represents Republicans. "I f somebody is doing some backdoor financing, how would themember know?"

oSPA

Abramoff, a member of the National Center's board, joined the DeLays on the May 25 to June 3, 2000, trip, which DeLay'scongressional office has said included a stop in London and a visit with Margaret Thatcher, along with the golfouting at St.

Andrews, where colleagues say Abramoff has a membership.

DeLay, an avid golfer, listed the purpose of the trip on a report filed with the House clerk as "educational." He was majority whip at

the time and brought his wife, Christine, and two top staff members -- Tony Rudy from the whip's off ice and chief of staff Susan

Hirschmann, as well as her husband, David Hirschmann, according to filings with the House clerk that indicated the total cost oftransportation, lodging and meals was $70,265.

Internet Gambling Bill Killed

Two months later, in July 2000, DeLay and 43 other Republicans joined 114 Democrats in killing the Internet Gambling Prohibition

Act, which would have made it a federal crime to place certain bets over the Internet and was opposed by eLottery and the

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Choctaws. The bill was supported by 165 Republicans and 79 Democrats but fell about 25 votes short of passage; because of a

parliamentary maneuver, it required a two-thirds majority vote.

DeLay spokesman Allen said that DeLay voted against the bill because it had exemptions for jai alai and horse and dog racing.

Rudy later that year went to work for Abramoff as a lobbyist.

The Choctaw Indians run a highly profitable casino near Philadelphia, Miss., that bankrolls their community activities and has

subsidized an extensive lobbying effort in Washington. The tribe donated a total of $65,000 to Ridenour's group in 2000 and $1.07

million in 2002.

The Choctaw money was intended to help the center create a program to build support for the idea that Indian casinos could drive

prosperity for poor tribes, Ridenour said. "We were trying to tell the Choctaw story," she said. On its Web site, the center attributes

the following statement to DeLay: "The National Center is The Center for conservative communications."

Asked about the DeLay trip to Bri tain, tribal lawyer Bryant Rogers said: "The tribe did not authorize the use of any money for this

purpose . . . . If it occurred, it occurred without the tribe's knowledge."

ELottery is a Connecticut company that provides Internet services to state lotteries. One version of the gambling legislation

contained a provision that would have severely restricted state lottery sales over the Internet. Edwin 1.McGuinn, president of eLot

Inc., the parent ofeLottery, said the provision would have killed his company. "We wouldn't have been able to operate," he said.

McGuinn said he was unaware that eLottery's $25,000 check was meant to pay for DeLay's trip. Of the donation to the National

Center, he said: "I t certainly was ou r impression that any and all moneys were being positioned to get the attention and focus of our

cause."

DeLay today describes himself as a longtime opponent of any expansion of gambling. But in a House floor speech six months after

his trip to Britain, he praised the head of the Mississippi Band of Choctaw Indians as a "champion of peace and prosperity" and

placed in the Congressional Record an editorial praising chiefPhillip Martin for enriching the tribe through the "construction of a

casino."

The editorial, from the magazine Indian Country Today, noted that Martin had also wisely positioned his tribe "to solidify

friendships with Republican powerhouses." It said -- in an apparent reference to Abramoff -- that the tribe and its chief had hired"quality lobbyists as their new wealth allowed" and successfully persuaded Republican leaders that the tribal revenue from

gambling and other ventures should not be taxed.

Three and a halfweeks after DeLay's Jan. 3, 200 I, speech salut ing Martin "for all he has done to further the cause of freedom," at

least one ofDeLay's aides went on a trip via private je t to the Super Bowl in Tampa arranged and financed by one of Abramoff's

companies. Sources familiar with the trip said the guests were also taken out to an Abramoff-owned gambling ship that was

anchored near Tampa.

No one on DeLay's staff filed a report disclosing the trip, a task required by House rules for "the receipt of travel expenses from

private sources" but not for government-funded or political travel.

DeLay spokesman Allen said: "The staffer went down to participate in a National Republican Congressional Committee party, so it

was considered political travel. The staffer never saw Abramoff during the trip."

The Internet gambling legislation was the only issue Abramoff and his employer at the t ime, Preston Gates Ellis & Rouvelas Meeds

LLP, mentioned in lobbying disclosure records when they reported earning $440,000 in fees from eLottery in 2000. The Internet

gambling bill was one of several legislative issues listed in a separate lobbying disclosure for the firm's efforts on behalf of the

Choctaw, which paid Preston Gates $880,000 in 2000.

Expense Voucher Submitted

The trip to Britain by the DeLays previously attracted notice because Abramoff submitted an expense voucher to Preston Gates

seeking a reimbursement of $I 2,789.73 to cover expenses for meals, hotels and transportation incurred by the DeLays, the

Hirschmanns and a former DeLay chief of staff -- lobbyist Ed Buckham -- who also went on the trip.

House ethics rules prohibit registered lobbyists such as Abramoff from paying for a lawmaker's expenses. But the Preston Gates

records state that Abramoff told his firm he paid $4,285.35 for the DeLays' stay at London's Four Seasons Hotel, plus $5, I74.64 for

the Hirschmanns' stay. He also reported spending $800 on transportation for the group between May 25 and May 29.

The existence of the voucher and a portion of its contents were reported last month in the National Journal. The voucher's tally of

expenses differs from the account given by DeLay in a signed repor t to the House c le rk on June 30, 2000, in which he reported tha t

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total lodging for the couple over nine nights cost Ridenour's group $3,840. Susan Hirschmann's separate, signed report also gave a

different figure from Abramoff; she stated that lodging expenses for her husband and her for this period amounted to $3,360.

Both the DeLays and the Hirschmanns reported their meal expenses during the trip as $2,000 per person, or roughly $200 a day.

Last week, DeLay told reporters that he had repor ted the trip "as we are supposed to do." He said that, to his knowledge, the

National Center "paid for the trip."

DeLay told Cox News Service earlier this month: "1went to London to meet with conservatives in England and Scotland and talk

about the things we had been doing in the Republican, conservative House. They wanted to dialogue to see if they could adopt

some the things that we had done."

A person who went on the trip but spoke on the condition of anonymity because of the controversy said that DeLay talked with

Thatcher about her efforts to help end the Cold War and with others about trade issues. An aide to Thatcher confirmed that the

meeting occurred.

Abramoffwas a member of the board of the National Center from about 1997 until last October, when the center accepted his

resignation.

Stanley Brand, a former Democratic counsel to the House and an ethics specialist, said arrangements in which funds are passed

through an intermediary to pay for a lawmaker's travels breach ethics rules if the lawmaker who benefited "knew or should have

known" the origin of funds.

Brand said the House ethics committee, if it opens an investigation, would have to decide whether the circumstances of the travel

"should have put a reasonable person on notice that it was paid for by someone else."

Researchers Alice Crites, Lucy Shackelford and Don Pohlman contributedto this report.


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EXHIBITF



makers Under Scrutiny in Probe ofLobbyist

r-~ i j t Wtt6ijington JlO,nLawmakers Under Scrutiny in

Probe ofLobbyistNey and DeLay Among the Members ofCongress Said

to Be a Focus of Abramoff Investigation

BySusan Schmidt and James V. GrimaldiWashington Post StaffWriters

Saturday, November 26, 2005

The Justice Department's wide-ranging investigation of

former lobbyist Jack Abramoffhas entered a highly

active phase as prosecutors are beginning to move on

evidence pointing to possible corruption in Congress

and executive branch agencies, lawyers involved in thecase said.

http://www.washingtonpost.com/wp-dyn/content/artiele/200 5

Prosecutors have already told one lawmaker, Rep. Robert W. Ney (R-Ohio), and his former chief of

staffthat they are preparing a possible bribery case against them, according to two sources

knowledgeable about the matter who spoke on the condition of anonymity.

The 35 to 40 investigators and prosecutors on the Abramoffcase are focused on at least halfa dozen

members of Congress, lawyers and others close to the probe said. The investigators are looking at

payments made by Abramoff and his colleagues to the wives of some lawmakers and at actions taken by

senior Capitol Hill aides, some ofwhom went to work for Abramoff at the law firm Greenberg Traurig

LLP, lawyers and others familiar with the probe said.

Former House majority leader Tom DeLay (R), now facing separate campaign finance charges in his

home state of Texas, is one of the members under scrutiny, the sources said. Sen. Conrad Burns

(R-Mont.), Rep. John T. Doolittle (R-Calif.) and other members of Congress involved with Indian affairs,

one of Abramoffs key areas of interest, are also said to be among them.

Prosecutions and plea deals have become more likely, the lawyers said, now that Abramoffs former

partner -- public relations executive Michael Scanlon -- has agreed to plead guilty to conspiracy and to

testify about gifts that he and his K Street colleagues showered on lawmakers, allegedly in exchange for

official favors.

An attorney for DeLay, whose wife worked for a lobbying firm that received client referrals fromAbramoff, said there was no connection between her work and congressional business. A spokesman for

Doolittle, whose wife received payments from Abramoffs lobbying firm, also said there was no

connection with her husband's position. Burns's office has said his actions were consistent with his

support for improving conditions for Indian tribes.

Ney is the congressman whose name has surfaced most prominently in the Abramoff investigation. His

spokesman and attorney have said for weeks that Ney has not been told he is a target of the inquiry,

even while acknowledging that his office has received a grand jury subpoena and that his activities were

mentioned in Scanlon's plea agreement.

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But the sources said that during the third week of October prosecutors told Ney and his former chief ofstaff, Neil Volz, that they were preparing a bribery case based in part on activities that occurred inOctober 2000. Abramoff and another business partner, Adam Kidan, were also told that they are targets

in that case, the sources said.

The five-year statute of limitations for filing charges based on those events expired last month; theprosecutors sought and received a waiver of the deadline from all four men while they continue their

investigation, the sources said. Prosecutors are often able to obtain such waivers by givingthe targets achoice of being indicted right away or granting more time to see if information might surface that

exonerates them.

Ney's attorney, Mark H. Tuohey, did not return calls seeking comment on the waiver. Ney spokesman

Brian Walsh said the office had no comment, as did a lawyer for Volz.

The attorneys ofAbramoff and Kidan did not return calls seeking comment.

The events in 2000 that interest investigators are connected to the purchase by Abramoff and Kidan of

SunCruz Casinos, owner of a fleet of Florida gambling boats. Ney twice placed comments in the

Congressional Record about SunCruz, first criticizing its former owner when Abramoff and Kidan werein difficult purchase negotiations and then, in October, praising Kidan's new management. Abramoff andKidan are facing trial in January on charges of defrauding lenders in their purchase of the casino boats.

The statute of limitations may also soon run out on a 2001 Super Bowl trip sponsored by SunCruz that

sources said investigators have reviewed. The Washington Post reported earlier this year that aides toBurns and DeLay were ferried to Tampa on a SunCruz corporate jet arranged by Abramoff. Ney and hissons were invited to the 2001 Super Bowl outing, former Abramoff associates said, but did not go.

The Hill aides were treated to the game and a night of gambling on a Sun Cruz ship. They were offered

$500 in gambling chips, sources knowledgeable about the trip said.

The Post has reported that Burns, who received $137,000 in contributions from Abramofflobbyists and

their tribal clients, obtained a controversial $3 million school construction grant for one ofAbramoff's

wealthy tribal clients after pressuring the Bureau of Indian Affairs.

Investigators are also gathering information about Abramoff's hiring of several congressional wives,sources said, as well as his referral of clients to Alexander Strategy Group, a lobbying and consultingfirm run by former senior aides to DeLay. Financial disclosure forms show that the firm employed

DeLay's wife, Christine, from 1998 to 2002.

Former Abramoff lobbying associates have said that Abramoff shared some of his high-paying clientswith the group, including Malaysian interests, the Mississippi Choctaw Indian tribe and online gambling

firms. Federal investigators have questioned some former Abramoff associates about whether thosereferrals were related to Christine DeLay's employment there, sources said.

Alexander Strategy Group is run by former DeLay senior staffers Edwin A. Buckham and Tony C.Rudy. Rudy served as DeLay's deputy chief of staff until 2001, when he took a job with Abramoff, and

later moved on to join Buckham.

Investigators are looking into whether Rudy aided Abramoff's lobbying clients while he was workingon

the Hill, the sources said, and are reviewing payments from Abramoff clients and associates to Liberty

Consulting, a political firm founded by Rudy's wife, Lisa. The Washington Post reported last month that

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f 4

Rudy, while on DeLay's staff, helped scuttle a bill opposed by eLottery Inc., an Abramoff client, and

that Abramoff had eLottery pay a foundation to hire Liberty Consulting.

Richard Cullen, an attorney for the DeLays, said Christ ine DeLay was hired by Buckham, an old family

friend, to determine the favorite charity of every member of Congress. She was paid $3,200 to $3,400 a

month for three years, or about $115,000 total , he said.

"It wasn' t like she did this 9 to 5, but it was an ongoing project," Cullen said. He said Christine DeLay'swork was commensurate with the project and had nothing to do with her husband or any official

congressional business. "This was something that she found to be very interesting, very challenging and

very worthwhile," Cullen said.

Rudy and Buckham and their attorneys did not return calls seeking comment.

Abramoff's connections to Doolittle are also of interest to investigators, sources said. Doolittle's former

chiefof staff, Kevin A. Ring, went to work with Abramoff. Doolittle's wife, Julie, owned a consulting

firm that was hired by Abramoff and his firm, Greenberg Traurig, to do fundraising for a charity he

founded. Two sources close to the investigation said that Ring, while working for Abramoff, was an

intermediary in the hiring of Julie Doolittle's firm, Sierra Dominion Financial Solutions Inc., which lastyear received a subpoena from the grand jury investigating Abramoff.

Julie Doolittle's attorney, William L. Stauffer Jr., said Sierra Dominion Financial was hired by Greenberg

Traurig to provide "event planning, marketing and related services, as requested by Mr. Abramoff" for

Abramoff's Capital Athletic Foundation and his Signatures restaurant. Sierra Dominion received a

monthly retainer from Greenberg Traurig from January 2003 until February 2004, at a rate similar to that

paid by other Sierra Dominion clients, Stauffer said.

Abramoff frequently used the athletic foundation as a pass-through organization to run lobbying efforts

and to pay for expenses, records show. Julie Doolitt le was hired to put on a fundraiser for the foundation

at the International Spy Museum, but the event was canceled because it had been scheduled to takeplace just at the Iraq war was commencing, Stauffer said.

"Sierra Dominion primarily performed public relations and other event planning services for the Spy

Museum event," Stauffer said in an e-mail reply to questions. "This included responding to all individuals

calling the Capital Athletic Foundation concerning the Spy Museum event, identifying (and contacting)

possible attendees for the event , and assisting in fund raising strategy and letters."

Doolittle's office denied any connection between the firm's work and official acts.

"In no way did Sierra Dominion's business services work for Greenberg Traurig have any relationship to

Congressman Doolittle's official duties as a member of the House of Representatives," said Doolittle

spokeswoman Laura Blackrnann.

"Congressman Doolittle has never received a subpoena regarding this matter, nor has he ever been

contacted by the Justice Department to provide information or be questioned," she said.

The Justice Department investigation is also looking into Abramoff's influence among executive branch

officials. Sources said prosecutors are continuing to seek information about Abramoff's dealings with

then-Deputy Interior Secretary 1. Steven Griles, including a job offer from the lobbyist at a time when he

was seeking department actions on behalf of his tribal clients.

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wmakers Under Scrutiny in Probe of Lobbyist http://www.washingtonpost.com/wp-dyn/content/artie Ie/2005

The former top procurement official in the Bush administration, David H. Safavian, has already been

charged with lying and obstruction of justice in connection with the Abramoff investigation. Safavian,

who traveled to Scotland with Ney on a golf outing arranged by Abramoff, is accused of concealing from

federal investigators that Abramoff was seeking to do business with the General Services Administration

at the time of the golf trip. Safavian was then GSA chiefof staff.



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10115/201



EXHIBIT G



Cases Highlight Prime Targets' Family Ties - The New York. .. http://query.nytimes .com!gst/fullpage.html?res=9AODE3DE 1

~ , ~ ( i tiTER '.n,'l i·:N :i LY F()::':\1A'!Sf'.D ; , , " : ~ - C ' R t ( ) E:'1

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April 9. 2006

Lobbying Cases Highlight Prime Targets' Family

Ties

By PHILIP SHENON

On Dec. 3, 2003, Aeneas Enterprises opened for business in theWoodland Hills neighborhood

of Los Angeles, and judging by its bank records, the small consulting company with no listed

telephone number was an instant success. Within a month, its records show, Aeneas had taken

in $2.3 million from a single client.

Aeneas is under scrutiny by the Justice Department and Congressional investigators. Its

founder, Robert Abramoff, a lawyer and sometime Hollywood movie producer, is the brother of

JackAbramoff, the Republican lobbyist at the center of aWashington influence-peddling

scandal involving several members of Congress.

The company's records show that the $2.3 million was received from another consulting firm,

GrassRoots Interactive of Silver Spring, Md., which was established by Jack Abramoff and

where he directed some of his huge lobbying fees. Billing statements prepared by Aeneas do

not show what service Robert Abramoff provided to warrant millions of dollars in payments

from his brother's company.

Robert Abramoff did not return phone calls for comment.

His apparent entanglement in his brother 's business is an example ofwhat investigators say is

something remarkable about the criminal inquiry centered on JackAbramoff and his

Washington lobbying network: the degree to which the spouses and other family members of

the investigation's central targets are being caught up in it. Some have dealt with subpoenas

and interviews with the Federal Bureau ofInvestigation, with at least the possibility of facing

civil or criminal charges.

Lawyers with detailed knowledge ofthe Justice Department's investigation, who were granted

anonymity because of rules barring public discussion of grand jury evidence, say that so many

of the wives of lawmakers and lobbyists have become tied up in the investigation that F.B.I.

agents have begun referring to them as "The Wives Club."

At least one of the wives, Julie Doolittle, who is married to Representative John T. Doolittle,

Republican of California, has been subpoenaed in the investigation of Mr. Abramoff and

10119/2010



Cases Highlight Prime Targets' Family Ties - The New York. .. http://query.nytimes.com!gstlfullpage.htm1?res=9AODE3DE1

f 5

questioned by the F.B.I. The June 2004 subpoena sought information about Mrs. Doolittle's

marketing and events-planning work for Mr. Abramoffs lobbying firm and for his Washington

restaurant, Signatures, which he later sold. Her lawyer, William L. Stauffer, said Mrs. Doolittle

was contacted by the Justice Department again last year and asked for additional records.

Mr. Stauffer said that Mrs. Doolittle's consulting firm, Sierra Dominion Financial Solutions,

has "complied fully with the subpoena."

Lisa Rudy, who is married to Tony Rudy, the former deputy chief of staff to Representative Tom

DeLay, Republican ofTexas, received $50 ,000 in consulting fees as a result ofwhat her

husband has acknowledged was a corrupt scheme with Mr. Abramoffto influence the workings

ofMr. DeLay's office and promote the concerns of Mr. Abramoffs clients on Capitol Hill.

Mr. Rudy pleaded guilty to federal conspiracy charges last month. The Justice Department has

said that Mrs. Rudy has agreed to cooperate with the investigation and will sign her own

agreement with prosecutors. The Rudy family's lawyer, Laura A. Miller, did not return phone

calls for comment.

Christine A. DeLay, Mr. DeLay's wife, received $115,000 in consulting fees from 1998 to 2002

from a lobbying firm set up by her husband's former chief of staff, Edwin A. Buckham, who is

also under scrutiny by the Justice Department because of his lobbying contacts with Mr.

DeLay's House office.

Although there is no suggestion of any criminal investigation focused on Mrs. DeLay, lawyers

involved in the investigation say prosecutors have asked about the circumstances of her hiring

by Mr. Buckham and whether it was an effort to influence Mr. DeLay, the former House

majority leader. Mr. DeLay announced this week that he was resigning from Congress, sayinghe wanted to avoid an "ugly" re-election fight this fall that might focus on ethical issues.

A lawyer for the DeLays, Richard Cullen, said Mrs. DeLay had been employed by Mr.

Buckham's firm, the Alexander Strategy Group, to gather information on the favorite charities

of members of Congress. "Christine DeLay is a very talented woman with a keen political mind,

and the project she was working on was one that had substance and added value to

Alexander," he said.

The phone records of the couple's daughter, Dani DeLay Ferro, a political organizer for her

father, were formally requested last yearby a grand jury in Travis County, Tex., where Mr.DeLay is under indictment, accused of violating his home state's election laws.

Mr. Buckham's wife, Wendy, shared more than $1million in consulting fees with her husband

from the U.S. Family Network, a nonprofit group tied to Mr. DeLay. The group has drawn the

scrutiny oflaw enforcement officials because so much of its income was directed to the

Buckham family and appears to have come from Russian businessmen eager to court favor

from Mr. DeLay. The Buckhams did not return phone calls seeking comment.

10/19/2010



bbying Cases Highlight Prime Targets' Family Ties - The New York. .. http://query.nytimes.com/gst/fuIlpage.html?res=9AODE3DEl

f 5

JackAbramoff's wife, Pamela, was tied to at least some of her husband's activities that he has

now acknowledged were crimes.

Although there is no suggestion by the Justice Department that Mrs. Abramoffwas aware of

her husband's criminal acts, she and her husband were the sole directors of a nonprofit group,

the Capital Athletic Foundation, which Mr. Abramoff used illegally to channel millions of

dollars from his clients to pet projects that had nothing to with the charity's supposed mission:sports programs for needy children.

Most ofthe charity's money was spent to underwrite a Jewish school in Maryland that was

founded by Mr. Abramoff and where the couple educated two of their sons. The foundation also

underwrote a 2002 trip to Britain for Representative Bob Ney, an Ohio Republican who is

under investigation by the Justice Department for gifts he received from Mr. Abramoff. Mr. Ney

has denied wrongdoing, saying he was duped by Mr. Abramoff about the financing of the

$150 ,000 trip, which included rounds of golf at the fabled course at St. Andrews in Scotland.

There are also references to Mrs. Abramoff's activities in the indictment of a former seniorWhite House budget official, David F. Safavian. The Justice Department has accused Mr.

Safavian oflying about his ties to Mr. Abramoff, who sought Mr. Safavian's help in trying to

buy government land for himself and clients. Mr. Abramoffhas acknowledged that he sent his

wife to inspect the properties, instructing her not to reveal her real name to government

officials to avoid scrutiny.

A spokesman for Mr. Abramoff's defense team, Andrew Blum, had no comment when asked

whether Mrs. Abramoffhad obtained separate counsel in the investigation. Mr. Blum also

would not comment on Mr. Abramoff's involvement with GrassRoots Interactive, the Maryland

consulting firm, and the lobbyist's business ties to his brother Robert.

The Abramoffbrothers have been in business together for years. They co-wrote -- and Jack

Abramoffproduced -- a poorly reviewed 1989 action movie called "Red Scorpion."

State business records in California show that Robert Abramoff is a director or registered agent

for almost 100 companies, many ofthem with colorful names, including FilmSoup, and

Make-Up Your Mind Inc.

He is also the registered agent for Nicole Richie Inc., an umbrella company for the business

activities of the young Hollywood celebrity. Ms. Richie's spokeswoman, Cindy Guagenti, said

that Mr. Abramoffhad been hired to deal wi th the logistics of the company's incorporation. She

said Ms. Richie "has never met him."

Robert Abramoffappears tohave been drawn into his brother's Washington lobbying network

through Aeneas Enterprises, which shared its offices and phone number with Robert

Abramoff's law office.

Documents gathered from Jack Abramoff's files by government investigators and provided to

10119/2010



Cases Highlight Prime Targets' Family Ties - The New York. .. http://query.nytimes.com/gst/fullpage.html?res=9AODE3DE I

The New YorkTimes show that Robert Abramoffsent an e-mail message to his brother's

accountant on Dec. 19, 2000 -- 16 days after Aeneas was incorporated -- that provided

instructions on wiring money to Aeneas's bank account.

An Aeneas billing statement sent later that month to GrassRoots Interactive shows that $1.4

million was received from GrassRoots on Dec. 26. A January statement shows that an

additional $900 ,000 was received by Aeneas on Jan. 2, 2004.

The one-page statements make no reference to what service, if any, was performed by Robert

Abramoffs company in exchange for the payments, nor do they indicate how Aeneas disbursed

the money.

Chart/Photos: "AFamily Affair"

Spouses and other family members have become integral parts of the Justice Department's

investigation of Jack Abramoff and his Washington lobbying network. A look at how family

members are tied to the scandal, based on indictments and other records collected from the

investigation.

JACK ABRAMOFF AND HIS FAMILY

J adz Abramoff

Pleaded guilty to fraud, tax evasion and conspiracy to bribe public officials.

Robert Abramoff (family member)

Brother

Founded a consulting firm that shares offices and phone number with his law office in

California. His firm received $2.3 million from one of his brother's companies for services not

specified in billing statements.

Pam Abramoff (family member)

Wife

Co-director of a nonprofit group used by her husband to illegally channel money from his

lobbying clients to other projects.

Inspected goverment properties for her husband and his clients without revealing her identity

to officials to avoid scrutiny.

LAWMAKERSAND THEIRWNES

Julie Doolittle (family member)

Did marketing and eventsplanning work for Mr. Abramoff.

Representative John T. Doolittle (R-Calif.)

10/19/2010



Cases Highlight Prime Targets ' Family Ties - The New York. .. http://query.nytimes.com/gst/fullpage.html?res=9AODE3DE I

Received campaign contributions from Mr. Abramoff and his associates.

Representative Tom DeLay (R-Tex.)

Formerly employed Mr. Buckham and Mr. Rudy

Has received campaign contributions from Mr. Abramoff, who has reportedly financed some of

Mr. DeLay's overseas trips.

Christine DeLay (family member)

Received $115,000 in consulting fees from Alexander Strategy over a four-year period.

LOBBYISTS AT THE ALEXANDER STRATEGYGROUP AND THEIRWIVES

Edwin A. Buckharn

Under scrutiny by the Justice Department for his lobbying contacts with Representative Tom

DeLay's House office.

Tony Rudy

Pleaded guilty to charges that he accepted illegal donations and gifts from Mr. Abramoff in

return for influencing legislation and the workings of Mr. DeLay's office.

Wendy Buckharn (family member)

Shared more than $1 million in consulting fees with her husband from the U.S. Family

Network, a nonprofit group with ties to Mr. DeLay. The fees appear to come from Mr.

Abramoffs clients.

Lisa Rudy (family member)

Received consulting fees from Mr. Abramoff, as part of illegal gifts to her husband.

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10/19/2010



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As lobbying scandal drags on, Delay takes a shot

at FBIEx-congressman blasts Justice as 'running amok' in the Abramoff

case

ByMICHAEL HEDGES Copyright 2007 HoustonChronicle Washington BureauMay 9, 2007, 10:10PM

WASHINGTON - Tom Delay is lashing out at federal prosecutorsprobing his ties with disgraced lobbyist Jack Abramoff, challenging

Oig9 them to charge himwith a crime or drop their iengthy investigation,

Yahoo! Buzz "It isa Justice Department that is running amok," the former Sugarland lawmaker said to The Hill, a publication covering Congress,

<@ StumbleUpon "Fish or cut bait. Do something."

Delay, the former House majority leader who resigned his seat inCongress last year after being charged in Texas in an unrelated

Be thefirstof yourfriends to case, has not been accused of wrongdoing inthe Abramoffrecommend this.

investigation.

But one former GOP member of Congress, Bob Ney of Ohio, andtwo former top aides of Delay's have pieaded guilty to corruption

in the wide-ranging grand jury investigation into efforts by Abramoffto gain illegal advantages for his clients in exchange for bribes.

Abramoff has pleaded guilty to corruption charges and is cooperating with investigators.

The inquiry into Delay's actions has focused on payments to his wife, Christine, by two organizations controlledby former Delay chief of staff Edwin Buckham.

After leaving Delay's staff. Buckham ran a lobbying firm called Alexander Strategy Group that paid her about$115,000 between 1998 and 2002.

Christine Delay and Delay's daughter, Dani Ferro, were also paid consulting fees and expenses totalling about$350,000 by Delay's political action committee, ARMPAC, which was also managed by Buckham.

Delay's lawyer, Richard Cullen, said the payments were for legitimate work.

"Clearly the Justice Department is conducting a very thorough investigation into all aspects of Mrs. Delay'semployment," Cullen said. "We have given them documents that demonstrate clearly that she was an integral partof Tom Delay's pol it ical operation, and that she earned every penny- probably more - than she was paid."

The FBI and the Justice Department declined to discuss the ongoing Abramoff investigation Wednesday.

FBI director Robert Mueller, meeting with Washington journalists Wednesday, sidestepped a question on theDelay probe.

But hesaid, "Public corruption has been our No, 1 priority on the criminal side.... We've almost doubled thenumber of convictions in the last year that we had in 2000-2001. We have additional resources addressing publiccorruption (and) I'm comfortable we've taken the steps that are appropriate."

Delay had not voiced frustration or anger at federal investigators before.

But hehas been open with his contempt for Travis County District Attorney Ronnie Earle, who obtained acampaign money laundering indictment of Delay, The former congressman has called the charges a thinly veiledpolitical attack by a Democratic prosecutor.

Cullen said Delay's remarks Tuesday are a spillover from his aggravation at the Texas case.

"I think the frustration is consistent with somebody who believes passionately that he has done nothing wrong,"

Cullensaid. "Tom Delay wants the investigation to be over. That is a very human response."michael, hedges@chron. com

CommentsReaders are solely responsible for the content of the comments they post here. Comments are SUbject to thesite's terms and conditions of use and do not necessarily reflect the opinion or approval of the Houston

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10/19/2010



EXHIBIT I



list in DeLay case reads like a who 's who of political, busine... http://www.statesman.comlnews/texas-politics/subpoena-Iist-i

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Subpoena list in DeLay case reads like a who's who of

political, business interests.Witnesses include associates ofAbramoff,former state House SpeakerCraddick.

By Laylan Copelin

AMERICAN-STATESNIAN STAFF

Updated: 10:18 p.m. Saturday, Oct. 16, 2010

Published: 10:00 p.m. Saturday, Oct. 16,2010

lawyers in the Tom Delay conspiracy trial have subpoenaed a who's who of witnesses, from associates ofdisgraced Washington, D.C., lobbyist Jack Abramoff to former Texas Speaker Tom Craddick, for the biggest

political trial in Austin in years.

The witness list for Travis County prosecutors includes chief executives of companies indicted for donatingcorporate money, several state lawmakers, enough Beltway lobbyists to pack a Capitol hearing andassociates that Delay shared with Abramoff, a former D.C. powerbroker nicknamed "Casino Jack" whopleaded guilty to conspiring to bribe public officials.

Delay's lawyers have countered with their own heavyweights: former Ambassador Tony Garza, Austinlobbyist Buddy Jones and Craddick, the politician who benefited the most from Delay's campaign efforts,which led to the charges that he conspired to launder corporate money - which is illegal in Texascampaigns - during the 2002 elections.

Jury selection begins Oct. 26, and testimony is expected to begin the following week.

Jurors may have to be reintroduced to Delay, known as "the Hammer"and who as U.S. House majorityleader reshaped Texas politics before the conspiracy indictment forced him to retire from Congress. Afterall, it's been five years - a lifetime in politics - since he resigned to become a guest on cable TV talkshows and a contestant, albeit with two broken feet, on "Dancing With the Stars."

Several of the witnesses, particularly those tainted by ties to Abramoff, aren't likely to be called unlessDelay is convicted on the conspiracy charge, allowing prosecutors to bring up allegations that the U.S.Justice Department couldn't prove as an argument for a stiff penalty.

The witness list includes Abramoff associates Edwin Buckham and Michael Scanlon, two former Delay

staffers who, according to the subpoenas, may be asked about "the inner workings of Tom Delay's politicalorganization" as well as the defendant's lobby-paid trips to Russia, Scotland and the Northern Mariana

Islands.

Inthe paperwork, prosecutors cite allegations that Russian energy executives donated $1 million to theU.S. Family Network, a Buckham client, to influence Delay's vote to help the Russian economy. Buckhamis Delay's former chief of staff who created an influential lobbying firm that paid Delay's wife, Christine,$3,200 a month to identify federal lawmakers' favorite charities.

Noneof these allegations are new.

InAugust, the Justice Department suspended its long-running investigation of Delay's and Buckham's tiesto Abramoff, the central figure in a federal investigation that shook Congress five years ago and promptedScanlon and Tony Rudy, another Delay staffer, to plead guilty to corruption charges.

10118/201



bpoena list inDelay case reads like a who's who of political, busine... http://www.statesman.comlnews/texas-politicslsubpoena-list -i

So why bring up allegations so far afield of the conspiracy charges rooted in one transaction duringthe2002 elections?

Travis County prosecutors declined to discuss their strategy because of orders by Judge Pat Priest, asenior judge from San Antonio who's presiding over the case.

Dick DeGuerin, Delay's lawyer, is upset by the wide-ranging and inflammatory subpoenas, but he declinedto comment on the prosecution's tactics.

He also wasn't tipping his hand on how he chose his own witnesses.

Garza served with Delay on an advisory board of Texans for a Republican Majority, the fundraising

committee at the center of the controversy, before President George W. Bush appointed him ambassadorto Mexico. It's unclear why Jones, an Austin lobbyist with a peripheral role to the controversy, will be adefense witness.

As for Craddick, the former Texas speaker could help the defense, but there is a risk that prosecutors might

elicit information unfavorable to Delay under cross-examination.

Travis County prosecutors investigated Craddick at the same time they were pursuing Delay. But theynever sought charges, even though Craddick personally picked upa $100,000 corporate donation for

Delay's committee. Texans for a Republican Majority also routed its donations through Craddick's office toindividual candidates to bolster Craddick's campaign to become speaker of the Texas House.

Those donations allowed Craddick's office to deliver money to grateful candidates who would be voting for a

new House leader after the election.

Putting Craddick on the stand would allow prosecutors to paint a fuller picture of the committee's activities.But the defense also would be able to contrast Craddick's hands-on involvement with what the defensecontends was Delay's limited role with the committee.

The crux of the conspiracy charge is $190,000 of corporate money that Delay's political committee,Texans for a Republican Majority, sent to the Republican National Committee. An arm of the RNC, in turn,

donated the same amount from its noncorporate account to seven Texas candidates.

Texas law prohibits corporate or union money from being donated to candidates.

Jurors must decide whether Delay conspired to launder that corporate money into campaign donations, asthe indictment claims, or whether the exchange was a legal transaction, as Delay says, and that hislieutenants did it without telling him beforehand.

Almost everyone who touched that money - donor or recipient- has been subpoenaed.

Much of the money was raised in Washington D.C., by Delay fundraiser Warren Rabold from corporationswith interests in front of Congress. That's why so many Beltway lobbyists or company CEOs weresubpoenaed. Some of the companies that were indicted got their charges dropped in exchange for

cooperating with prosecutors. One was Questerra Corp., a Charlottesville, Va.-based software company.It's former CEO, Tim Milovich, was subpoenaed to testify.

The seven former and current Texas House members who got donations from Texans for a RepublicanMajority also are on the list, including Austin-area residents Todd Baxter, Jack Stick and Rick Green.

Also subpoenaed are Texas officials who served with Delay on the advisory board of Texans for aRepublican Majority: Sen. Florence Shapiro, R-Plano ; former Rep. Dianne White Delisi, R-Temple; andRep. Beverly Woolley, R-Houston .

Prosecutors also are seeking testimony to paint a broader picture beyond Texans for a Republican Majority.

10118/201



l is t in DeLay case reads l ike a who 's who of political, busine... http://www.statesman.comlnews/texas-politicslsubpoena-Iist -i

For example, Peter Cloeren, a business executive from Orange, is expected to testify about pleadingguiltyto illegally funneling money to a congressional candidate in 1996 at the urging of Delay, an allegation thatDelay denied. Federal authorities never charged Delay in that case, but Cloeren was fined $400,000 andgot two year's probation. Cloeren pleaded guilty to funneling money through his company's employees andout-of-state groups.

Prosecutors also will try to use Delay's own words against him.

They have subpoenaed tapes of several cable news shows on which Delay declared he knew nothingabout the $190,000 transaction until after it happened and professed his general lack of involvement with

Texans for a Republican Majority outside of headlining five fundraisers.

Prosecutors are expected to contrast Delay's public remarks with the evidence they have gathered during

the eight-year investigation.

[email protected]; 445-3617

The crux of the case

In 2001, Tom Delay and several Texas officials created Texans for a Republican Majority, a political action

committee that raised money to elect Republicans to the Texas legislature.

The purpose: A GOP majority in the Texas legislature would redraw the state's congressional districts to

favor Republicans and help Delay maintain his leadership role in Congress.

The hurdle: Texans for a Republican Majority had trouble raising money from Texas business interestsbecause they didn't want to offend Democratic state House Speaker Pete laney, so the GOP committeeturned to corporations with interests before the U.S. Congress.

Key players: Delay's chief political aide, Jim Ellis, oversaw the operation in Washington, D.C., while

associate John Colyandro ran its Austin-based efforts.

The law State law forbids corporate money being donated to Texas candidates.

What happened: Colyandro sent a blank check to Ellis, who filled in the amount and gave it to theRepublican National Committee after meeting with RNC staffers. An arm of the RNC, in turn, sent the same

amount ($190,000) to seven Texas candidates two weeks later.

The legal question: Did Delay conspire with Ellis and Colyandro to launder corporate money intocampaign donations, or was Delay just a fundraiser who was briefed about a legal and routine transactionafter it occurred?

Find this article at:

http://www.statesman.com/news/texas-politics/subpoena-list-in-delay-case-reads-like-a-976216.html

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f3 10118/20



EXHIBIT J



Page 1

Lexist-lexis"

59 of90 DOCUMENTS

Copyright 2005 The Houston Chronicle Publishing Company

All Rights Reserved

The Houston Chronicle

November 22, 2005 Tuesday3 STAR EDITION

SECTION: A; Pg. I

LENGTH: 945 words

HEADLINE: Lobbyist pleads guilty to conspiracy;

Ex-DeLay aide gets jail, fine and agrees to testify in federal probe

BYLINE: MICHAEL HEDGES, Houston Chronicle Washington Bureau, Staff

DATELINE: WASHINGTON

BODY:

WASHINGTON - Lobbyist Michael Scanlon, a former aide to Rep. Tom DeLay, pleaded guilty Monday to at

tempting to bribe a member of Congress and promised to help federal prosecutors in an investigation in which Wash

ington officials are potential targets.

Scanlon, 35, who parlayed his association with lobbyist Jack Abramoffinto a multimillion-dollar public relationsbusiness, agreed to testify in the federal probe into the bilking ofIndian tribes that were seeking federal law changes to

allow them to set up gambling facilities.

Scanlon agreed to serve between 51 and 63 months in prison and pay a $250,000 fine as part of his guilty plea tothe charge of conspiring to commit fraud. He was also ordered to pay restitution of$19.7 million to the defrauded tribes.

The plea agreement filed by federal prosecutors listed 10 actions they said were taken by Rep. Bob Ney, R-Ohio, as

part of a conspiracy with Scanlon and Abramoffaimed at passing legislation to help the lobbyists' Indian clients.

In exchange, Scanlon and Abramoff provided Ney and his staffwith lavish trips, golf outings, tickets to sporting

events and concerts, meals at expensive restaurants and campaign contributions, the plea agreement said.

Scanlon, of Rehobeth, Del., told reporters outside the federal courthouse here, "I really don't have anything (to say)

at this moment. You guys will be seeing me around."

His attorney, Plato Cacheris, interjected, "He's been very regretful and is trying to do what is right ... He is very regretful for what happened to the tribes."

The lawyer said Scanlon has been cooperating with prosecutors for months.

Asked if Scanlon's cooperation with prosecutors presented any jeopardy for other members of Congress besides

Ney, Cacheris said, "I'd rather not comment on that."

Asked specifically whether he believed prosecutors were probing DeLay, he said, "You'd have to ask (DeLay's)lawyers that."



Page 2

Lobbyist pleads guilty to conspiracy; Ex-DeLay aide gets jail, fine and agrees to testify in federal probe The Houston

Chronicle November 22, 2005 Tuesday

Richard Cullen, an attorney for DeLay, said the Sugar Land Republican had nothing to fear from Scanlon's cooper

ation.

"Mr. DeLay has a s trong and clear conscience on this. He has nothing to worry about. He believes when the De

partment of Justice finishes its investigation, he will be cleared."

Cullen said DeLay has offered his cooperation to federal investigators, but has not been subpoenaed or questionedin the case.

So far, no allegation has been leveled against DeLay in the investigation.

Close connections

DeLay had close connections with Scanlon and Abramoff, whom he once called one of his closest friends. Two

years before Ney went to Scotland on a golfing trip that included Abramoff, DeLay took a similar trip with the lobbyist.

In 1998 DeLay traveled to the Northern Marianas Islands on a trip arranged by Abramoff; in 2000, Ney did the same.

Both lawmakers accepted campaign contributions from Abramoff clients.

Tribes from six states, including the Texas Tigua Indians of El Paso, paid Scanlon at least $53 million that Scanlon

admitted Monday was aimed at enriching him and Abramoff. The tribes hoped to gain the rights to gambling casinos

and businesses. But the Indians received little in return for their payments.

Abramoff arranged for Scanlon to do PR work for the tribes, and Scanlon secre tly kicked back half of his fees to

Abramoff, the government alleged. Abramoffhas not been charged in the Indian investigation, but he has been indicted

in an unrelated federal probe.

Another Scanlon attorney, Stephen Braga, had a blunt assessment when asked if Scanlon's cooperation represented

legal jeopardy for Ney:

"Yes," said Braga.

But Ney's attorney, Mark Tuohey, said, "Representative Ney never did any legislative act in exchange for favors.

He is an upr ight member of Congress well-respected for his judgment and integrity."

Prosecutors said in Scanlon's plea agreement that Ney agreed to introduce and promote a bill that would lift an ex

isting ban against commercial gambling in Texas as par t of an effort pushed by Scanlon and Abramoffto help the Ti

guas open a gambling fac ili ty in El Paso.

The federal document said Ney solicited the help of another member of Congress who was not named in the plea

deal.

The Ohio lawmaker also placed statements in the Congressional Record that benefited Abramoff and helped him

get a contract for a cl ient. In 2002, Ney approved a license for an Israeli telecommunications company to install anten

nas for the House. That company paid Abramoff $280,000, and donated $50,000 more to an Abramoff charity.

The connection between Scanlon, Abramoff and Ney surfaced in e-mail released by the Senate Indian Affairs

Committee. Abramoffbragged in the e-mail that he had persuaded Ney to inser t language in a House bill that would

have helped the Tigua tribe ofEl Paso reopen a gambling facility that the state had closed.

Abramoffthen got the Tiguas to make contributions to Ney's re-election campaign and political action committee.

Another controversy

Ney also took a role in another controversy involving Abramoffthat has led to his indic tment by a federal grandjury in South Florida. Abramoff has been charged with fraud in what prosecutors said was a scheme to gain control of a

fleet of gambling boats called SunCruz Casinos.

The Ohio congressman twice put comments in the Congressional Record concerning SunCruz, attacking a rival

bidder for the gambling boats and praising Abramoffs partner, Adam Kidan, who has also been indicted in the case.

Scanlon will next appear in court March I, when prosecutors are expected to give U.S. District Judge Ellen Huvelle

an update on his coopera tion. Unti l then, he remained free on a $5 mill ion unsecured bond, which bas ical ly means that

he promised to forfeit the amount ifhe fled.



Page 3

Lobbyist pleads guilty to conspiracy; Ex-DeLay aide gets jail, fine and agrees to testify in federal probe The Houston

Chronicle November 22, 2005 Tuesday

NOTES: [email protected]

GRAPHIC: Photo: PLEADS GUILTY: Lobbyist Michael Scanlon has agreed to cooperate with a federal investigation

into the bilking of Indian tribes (p. 8)

HARAZN.GHANBAN:AP

LOAD-DATE: November 22,2005



CREW Icitizens .for. r e s p o n ~ i b i l i t yand ethics In washington

October 19,2010

By facsimile: 540-868-4995

Federal Bureau of Investigation

Attn: FOUPA Request

Record/Information Dissemination Section

170 Marcel Drive

Winchester, VA 22602-4843

Re: Freedom of Information Act Request

Dear Sir/Madam:

Citizens for Responsibility and Ethics in Washington ("CREW") makes this request for

records, regardless of format, medium, or physical characteristics, and including electronic

records and information, audiotapes, videotapes and photographs, pursuant to the Freedom of

Information Act ("FOIA"), 5 U.S.C. §§ 552, et seq., and U.S. Department of Justice ("DOJ")

regulations, 28 C.F.R. Part 16.

Specifically, CREW requests any witness statements, investigation reports, prosecution

memoranda, and Federal Bureau ofInvestigation("FBI") 302 reports related to the FBI's and

DOl's investigation of former House Majority Leader Tom DeLay. This includes, but is not

limited to, the FBI's and DOl's investigation of relationships between Mr. DeLay and Christine

DeLay, Dani DeLay, Jack Abramoff, Edwin Buckham, Tony Rudy, Michael Scanlon, SusanHirshmann, the Alexander Strategy Group, the National Center for Public Policy Research,

eLottery, Inc., the U.S. Family Network, Americans for a Republican Majority PAC

("ARMPAC"), Texans for a Republican Majority PAC ("TRMPAC"), and/or the

Commonwealth of the Northern Marianas Islands.

Mr. DeLay was one of the subjects of DOl's extensive investigation into illegal lobbying

activities by Mr. Abramoff and others. See R. Jeffrey Smith, Justice Department Drops

Investigation ofDeLay Ties to Abramoff, Wash. Post, August 17,2010 (attached as Exhibit A).

Among other things, DOJ investigated allegations Mr. Abramoff, Mr. Buckham, and Mr. Rudy

laundered money from entities with interests before Congress through non-profit organizations to

pay for Mr. and Mrs. DeLay's overseas travel. For example, Mr. Abramofffunneled paymentsprovided by eLottery, Inc. and other gambling interests through the National Center for Public

Policy Research to pay for Mr. and Mrs. DeLay's trip to Scotland, and used the same

organization to launder money from a Russian oil company to pay for Mr. and Mrs. DeLay's trip

to Russia. See, e.g., Phil Shenon, Ex-DeLay Aide Pleads Guilty In Lobby Case, N Y Times,

April 1,2006 (attached as Exhibit B); R. Jeffrey Smith, The DeLay-AbramoffMoney Trail,

1400 Eye Street, N.W., Suite 450, Washington, D.C. 20005 I 202.408.5565 phone I 202.588.5020 fax I www.citizensforethic




October 19,2010

Page 2

Wash. Post, December 31,2005 (attached as Exhibit C); R. Jeffrey Smith, DeLay Airfare Was

Charged To Lobbyist's Credit Card, Wash. Post, April 24, 2005 (attached as Exhibit D); JamesV. Grimaldi & R. Jeffrey Smith, Gambling Interests Funded DeLay Trip, Wash. Post, March 12,

2005 (attached as Exhibit E).

DOJ also investigated allegations: (1) the Alexander Strategy Group, a lobbying firm run

byMr. Buckham and Mr. Rudy, employed Mrs. DeLay in an effort to influence Mr. DeLay, see

Susan Schmidt & James V. Grimaldi, Lawmakers Under Scrutiny in Probe of Lobbyist, Wash.

Post, November 26,2005 (attached as Exhibit F); Philip Shenon, Lobbying Cases Highlight

Prime Targets' Family Ties, N. Y Times, April 9, 2006 (attached as Exhibit G); (2) Mrs. DeLay

and the DeLays' daughter Dani improperly were paid $350,000 in consulting fees and expenses

paid by ARMPAC, Mr. DeLay's political action committee, see Michael Hedges, As Lobbying

Scandal Drags On, DeLay Takes a Shot at FBI, Houston Chronicle, May 9,2007 (attached asExhibit H); (3) Mr. Abramoffand Mr. Buckham funneled $1 million from the Russian oil

company through the U.S. Family Network in an effort to influence Mr. DeLay and others, see

Smith, Wash. Post, December 31, 2005; Laylan Copelin, Subpoena List in DeLay Case Reads

Like Who's Who of Political, Business Interests, Austin American-Statesman, October 16, 2010

(attached as Exhibit I); and (4) Mr. DeLay and two associates conspired to illegally lauder

corporate campaign contributions through TRMPAC, id.; and (5) Mr. Abramoff arranged for a

trip to the Commonwealth of the Northern Mariana Islands to influence Mr. DeLay, see Michael

Hedges, Lobbyist Pleads Guilty to Conspiracy, Houston Chronicle, November 22,2005 (attached

as Exhibit J).

DOJ apparently concluded its investigation ofMr. DeLay recently without bringing

charges against him. See Smith, Wash. Post, August 17,2010.

Please search for responsive records regardless of format, medium, or physicalcharacteristics. Where possible, please produce records electronically, in PDF or TIF format on a

CD-ROM. We seek records of any kind, including electronic records, audiotapes, videotapes,and photographs. Our request includes any letters, emails, facsimiles, telephone messages, voice

mail messages, and transcripts, notes, or minutes of any meetings, telephone conversations, or

discussions. Our request also includes any attachments to these records.

If it is your position that any portion of the requested records is exempt from disclosure,CREW requests that you provide it with an index of those documents as required under Vaughn

v. Rosen, 484 F.2d 820 (D.C. Cir. 1973), cert. denied, 415 U.S. 977 (1972). As you are aware, aVaughn index must describe each document claimed as exempt with sufficient specificity "to

permit a reasoned judgment as to whether the material is actually exempt under FOIA."Founding Church ofScientology v. Bell, 603 F.2d 945,949 (D.C. Cir. 1979). Moreover, the

Vaughn index must "describe each document or portion thereof withheld, and for each

withholding it must discuss the consequences of supplying the sought-after information." King v.




October 19,2010

Page 3

us. Dep 't ofJustice, 830 F.2d 210,223-24 (D.C. Cir. 1987) (emphasis added). Further, "the

withholding agency must supply' a relatively detailed justification, specifically identifying thereasons why a particular exemption is relevant and correlating those claims with the particular

part of a withheld document to which they apply. '" ld. at 224 (citing Mead Data Central v. us.

Dep 't of the Air Force, 566 F.2d 242,251 (D.C. Cir. 1977».

In the event that some portions of the requested records are properly exempt from

disclosure, please disclose any reasonably segregable non-exempt portions of the requested

records. See 5 U.S.c. § 552(b). If it is your position that a document contains non-exempt

segments, but that those non-exempt segments are so dispersed throughout the document as to

make segregation impossible, please state what portion of the document is non-exempt, and how

the material is dispersed throughout the document. Mead Data Central, 566 F.2d at 261. Claims

of nonsegregability must be made with the same degree of detail as required for claims ofexemptions in a Vaughn index. If a request is denied in whole, please state specifically that it is

not reasonable to segregate portions of the record for release.

Finally, CREW welcomes the opportunity to discuss with you whether and to what extent

this request can be narrowed or modified to better enable the FBI to process it within the FOIA's

deadlines.

Fee Waiver Request

In accordance with 5 U.S.C. § 552(a)(4)(A)(iii) and 28 C.F.R. § 16.11(k), CREW

requests a waiver of fees associated with processing this request for records. The subject of thisrequest concerns the operations of the federal government and expenditures, and the disclosures

will likely contribute to a better understanding of relevant government procedures by CREW and

the general public in a significant way. Moreover, the request is primarily and fundamentally for

non-commercial purposes. 5 U.S.C. § 552(a)(4)(A)(iii). See, e.g., McClellan Ecological v.

Carlucci, 835 F.2d 1282, 1285 (9th Cir. 1987).

These records are likely to contribute to greater public awareness of alleged malfeasance

and possible criminal behavior by the former maj ority leader of the House of Representatives,

and ofDO]'s recently concluded investigation into Mr. DeLay's activities. Related DOJ

investigations resulted in criminal convictions ofMr. Abramoff, Mr. Rudy, Mr. Scanlon, former

Rep. Bob Ney, and others. While DOJ eventually decided not to prosecute Mr. DeLay, his

activities still may have been illegal or violations of the rules of the House ofRepresentatives,

and the requested records would shed light on them. In addition, other criminal allegations

against Mr. DeLay remain very active - a trial on state charges related to money laundering

through TRMPAC is scheduled to begin on October 26, 2010. See Copelin, Austin American-

Statesman, October 16, 2010. The public unquestionably has a powerful interest in learning the

extent to which a leading member of Congress engaged in illegal or improper behavior. Us.

Dep 't ofJustice v. Reporters Comm. for Freedom of the Press, 489 U.S. 749, 774 (1989)




October 19,2010

Page 4

(suggesting a public interest in documents that would reveal a congressman's allegedly corrupt

behavior).

These documents also would shed light on DOl's conduct in conducting the investigation

ofMr. DeLay, and its apparent decision to close the investigation without bringing charges

against Mr. DeLay.

CREW is a non-profit corporation, organized under section SOl(c)(3) of the Internal

Revenue Code. CREW is committed to protecting the public's right to be aware of the activities

of government officials and to ensuring the integrity of those officials. CREW uses a

combination of research, litigation, and advocacy to advance its mission. The release of

information garnered through this request is not in CREW's financial interest. CREW will

analyze the information responsive to this request, and will share its analysis with the public,either through memoranda, reports, or press releases. In addition, CREW will disseminate any

documents it acquires from this request to the public through its website,

www.citizensforethics.org, which also includes links to thousands of pages of documents CREW

acquired through its multiple FOIA requests as well as documents related to CREW's litigation

and agency complaints, and through www.scribd.com.

News Media Fee Waiver Request

CREW also asks that it not be charged search or review fees for this request because

CREW qualifies as a "representative of the news media" pursuant to the FOIA and SEC

regulation 17C.F.R. § 200.80(e)(10). InNat 'I Sec. Archive v. Us. Dep 't ofDefense, 880 F.2d1381,1386 (D.C. Cir. 1989), the Court ofAppeals for the District of Columbia Circuit found the

National Security Archive was a representative of the news media under the FOIA, relying on the

FOIA's legislative history, which indicates the phrase "representative of the news media" is to be

interpreted broadly; "it is critical that the phrase 'representative of the news media' be broadly

interpreted if the act is to work as expected. . . . In fact, any person or organization which

regularly publishes or disseminates information to the public . . . should qualify for waivers as a

'representative of the news media. '" 132 Congo Rec. S14298 (daily ed. Sept. 30,1986) (emphasis

added), cited in id.

CREW routinely and systematically disseminates information to the public in several

ways. First, CREW maintains a frequently visited website, Vv\V\v.citizensforethics.org, that

received 108,643 visits in September 2010. In addition, CREW posts all of the documents it

receives under the FOIA on www.scribd.com. and that site has received 419,786visits to

CREW's documents since April 14,2010.

Second, since May 2007 CREW has published an online newsletter, CREWCuts, that

currently has 17,322 subscribers. CREWCuts provides subscribers with regular updates

regarding CREW's activities and information the organization has received from government



Federal Bureau ofInvestigation

October 19,2010

Page 5

entities. A complete archive of past CREWCuts is available at

http://www.citizensforethics.org/newsletter.

Third, CREW publishes a blog, Citizens bloggingfor responsibility and ethics in

Washington, that reports on and analyzes newsworthy developments regarding government ethics

and corruption. The blog, located at http://v..'WW.citiznesforethics.org/blog, also provides links

that direct readers to other news articles and commentary on these issues. CREW's blog had

1,772 hits in September.

Finally, CREW has published numerous reports to educate the public about government

ethics and corruption, including agencies' failure to comply with their record keeping

responsibilities. See Record Chaos, which examines agency compliance with electronic record

keeping responsibilities; The Revolving Door, a comprehensive look into the post-governmentactivities of24 former members of President Bush's cabinet; and Those Who Dared: 30 Officials

Who Stood Up For Our Country. These and all other CREW's reports are available at

http://www.citizensforethics.org/repOlis.

Based on these extensive publication activities, CREW qualifies for a fee waiver as a

"representative of the news media" under the ForA and agency regulations.

Request for Expedition

Pursuant to 5 U.S.c. § 552(a)(6)(E)(I) and 28 C.F.R. § 16.5(d)(l)(iv), CREW requests

that your office expedite the processing of this request. As required by DOJ regulations, 28C.F.R. § 16.5(d)(2), CREW is submitting its request for expedition to the director of Public

Affairs. A copy of CREW's request is enclosed.

CREW also requests that DOJ expedite its request pursuant to 28 C.F.R. § 16.5(d)(l)(ii).

As explained above, CREW is engaged primarily in the dissemination of information that it

gathers from a variety of sources, including the FOrA, and seeks the information requested in the

FOrA request for the express purpose of disseminating it to the public . In addition to the

websites on which CREW posts all documents it acquires through the FOrA, CREW's website

contains numerous examples of its efforts, including reports it has published based on

information it receives through the FOrA. For example, CREW's report, Record Chaos: The

Deplorable State ofElectronic RecordKeeping in the Federal Government, was based on

significant part on documents CREW requested under the FOrA from a variety of agencies,

including DOJ.

There is a particular urgency to inform the public about these investigations because, as

noted above, Mr. DeLay's criminal trial on state conspiracy charges is scheduled to begin in one

week. See Copelin, Austin American-Statesman, October 16,2010. Witnesses subpoenaed by

the prosecution for the trial include Mr. Buckham and Mr. Scanlon, who may be questioned




October 19,2010

Page 6

about "'the inner workings of Tom DeLay's political organization' as well as the defendant's

lobby-paid trips to Russia, Scotland and the Northern Marianas Islands" that were the subject ofDOl's investigation. Jd. In light of the importance of this information for Mr. DeLay's criminal

trial, immediate action is required.

Pursuant to 28 C.F.R. § 16.5(d)(3), I hereby certify that the basis for CREW's request for

expedition, as outlined above, is true and correct to the best ofmy knowledge and belief.

Conclusion

If you have any questions about this request or foresee any problems in releasing fully the

requested records please contact me at (202) 408-5565. Also, if CREW's request for a fee

waiver is not granted in full, please contact our office immediately upon making such adetermination. Please send the requested records to Adam J. Rappaport, Citizens for

Responsibility and Ethics in Washington, 1400 Eye Street, N.W., Suite 450, Washington, D.C.

20005.

Sincerely, / :

.: j " " \.7 /

i /" 1 ./---<::--:1 DAdam J. R ~ p p a p ~Senior Counsel

Enclosures