[Congressional Record Volume 144, Number 114 (Wednesday, September 2, 1998)]
[Senate]
[Pages S9891-S9894]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]
INDEPENDENT COUNSEL
Mr. SPECTER. Mr. President, I have sought recognition to comment on
the statements made earlier today by Senator Hatch and Senator Leahy
relating to an independent counsel because there is a specific course
of action which can be taken to break the impasse, in my legal
judgment, and that is with an action for mandamus in the United States
District Court for the District of Columbia to compel Attorney General
Reno to appoint an independent counsel.
There is no doubt about the serious allegations and scandals in
campaign financing. The Governmental Affairs Committee on which I serve
conducted extensive hearings last year which showed beyond any doubt
irregularities of a most important sort, and some even involving
contributions coming from foreign sources traceable to the Government
of China. In the face of this overwhelming evidence, the Attorney
General has declined to appoint an independent counsel.
The remedy is present for a mandamus action, which would be directed
on two legal lines. One is where Attorney General Reno has failed to
carry out a mandatory duty, where the independent counsel statute says
that she shall act on covered persons, and an alternative legal
approach where there is an abuse of a discretionary duty where there is
a conflict of interest, and there is both an actual and an apparent
conflict of interest. Importantly, Attorney General Reno, when
questioned during her confirmation hearing, was a great advocate of an
independent counsel on precisely the kind of circumstances which are
presented here.
The mandamus action was pursued on three individual occasions, and
the United States District Court for the District of Columbia did order
mandamus. All three of those cases were reversed for reasons which are
not applicable here, where there was lack of standing which was
delineated in extensive discussions in the court of appeals on two of
those cases. But those three cases by district court judges did confirm
the legal approach which I am advocating here today, and which is
encompassed in an extensive lawsuit, which has been prepared against
Attorney General Reno, calling for a mandamus action.
In two of the cases they were reversed because of lack of standing,
and that is a legal issue which poses a hurdle which I believe can be
overcome by action by a majority of the majority of the Judiciary
Committee of either the House of Representatives or the U.S. Senate.
The independent counsel statute gives a majority of the majority of
each Judiciary Committee unique positioning to have the requisite
standing to require an answer by the Attorney General on a statement of
facts and a request that independent counsel be appointed. That does
not mean conclusively that there would be standing for a mandamus
action, but it is a very strong argument in support of that standing.
And, in two of the cases where the court of appeals reversed an order
for independent counsel to be appointed, the special standing of
Congress and the special standing of the Judiciary Committee was noted.
In one of the cases, the Court of Appeals for the District of Columbia
referred to congressional oversight, which this would be, and in
another case the Court of Appeals for the District of Columbia referred
to the special positioning, which the Judiciary Committee had.
There is another issue, laying all the cards on the table face up, as
to separation of powers, on matters which were raised in the decision
by the Supreme Court of the United States in the case of Morrison v.
Olson, upholding the constitutionality of the independent counsel
statute. Some of the language of the Supreme Court there has been
cited, from time to time, as raising a hurdle for this kind of a
lawsuit. But I would point out that, on two of the issues which were
raised by the Supreme Court of the United States, the legal argument
runs in favor of this kind of an action.
The Supreme Court there referred to a provision of the statute which
said that there could be ``no judicial review of an action by the
Attorney General appointing independent counsel.'' But the negative
implication there is that review would be possible where the Attorney
General declines to appoint an independent counsel. There is also a
provision in the statute which says that there may be no judicial
review by the special three-judge panel where the Attorney General
decides not to appoint an independent counsel, and again, by negative
implication, there can be review by the United States District Court
for the District of Columbia. The three-judge panel is a special panel
created to make the actual appointment of an independent counsel.
Mr. President, in outlining these legal hurdles, there is no doubt
that there are problems here. But, in my legal judgment, each of these
hurdles and any other can be surmounted. And certainly, where there is
such a pressing reason to move because of what has happened here on a
compelling factual basis, I strongly believe that this effort ought to
be made and that it can be made by a majority of the majority on the
Judiciary Committee of the Senate or a majority of the majority in the
House. And perhaps it would be appropriate for both the House and the
Senate to join together as parties plaintiff to solidify and enforce
the standing issue and the importance of this action.
My views are not those which I express lightly. They did not arise in
the course of the last few days or the last few weeks. My initial
concerns were expressed in a Judiciary oversight hearing back on April
30 of 1997, when Attorney General Reno appeared before the Senate
Judiciary Committee and was questioned extensively by a number of
Members, including myself. At that time I pressed Attorney General Reno
on some of the so-called issue advertisements which were really, by any
legal interpretation, express advocacy.
Now, if they are express advocacy, and if there is coordination with
the Republican National Committee or the Democratic National Committee,
then they violate the law; they violate the Federal election law. And,
in articulating this concern, on a number of occasions I have said that
there is fault on both sides, both by the Republican National Committee
and the Democratic National Committee. But the activities by the
Democratic National Committee stand on a different level because of the
active participation by President Clinton himself in micromanaging the
campaign and in working on these commercials. We know that from the
testimony, statements of Mr. Leon Panetta, Chief of Staff of President
Clinton, and from the statements of Mr. Dick Morris, who was the
President's principal adviser on these campaign matters.
[[Page S9892]]
This is illustrative of what these commercials had to say. This
appeared on advertising:
Head Start, student loans, toxic cleanup, extra police, anti-drug
programs--Dole-Gingrich wanted them cut. Now, they're safe, protected
in the 1996 budget because the president stood firm. Dole-Gingrich--
deadlock, gridlock, shutdowns. The president's plan--finish the job,
balance the budget, reform welfare, cut taxes, protect Medicare.
President Clinton gets it done. Meet our challenge, protect our values.
Under no stretch of the imagination could that kind of advertisement
be classified as articulating an issue only contrasted with
articulating advocacy for the President's campaign.
I asked Attorney General Reno about that specifically on April 30 of
1997. Her response to me was that based on a memorandum of
understanding with the Federal Election Commission, it was up to the
Federal Election Commission.
On the next day, May 1, 1997, I wrote to Attorney General Reno with a
long list of specific advertisements which were conclusively advocacy
ads which, when designated and designed and worked on by the President
himself, would constitute a violation of the law.
On June 17, I received a reply from Attorney General Reno and then
from the Federal Election Commission saying that the Attorney General
was saying it was up to the Federal Election Commission and the Federal
Election Commission said that they would give advisory opinions. That
is something for the future but not something that had already been
done.
Mr. President, I ask unanimous consent that my letter of May 1, 1997,
the reply from the Attorney General, and the letter from the Federal
Election Commission be printed in the Record at the conclusion of my
statement.
The PRESIDING OFFICER (Mr. Brownback). Without objection, it is so
ordered.
(See Exhibit 1.)
Mr. SPECTER. Mr. President, I returned to this issue with Attorney
General Reno when she came in for an oversight hearing on July 15 of
this year and confronted Attorney General Reno with the very basic fact
that the Federal election law, with criminal provisions, is the
responsibility of the Department of Justice to enforce and the
responsibility of the chief enforcement officer, the Attorney General,
to enforce, so that by no stretch of the imagination would it be
plausible for the Attorney General to say that it was a matter for the
Federal Election Commission. Notwithstanding that, the Attorney General
continued to articulate this argument that it was a matter for the
Federal Election Commission, which I submit, and I say this
respectfully, is spurious and facetious on its face. How can it be a
matter for the Federal Election Commission when it is a criminal law,
criminal sanction which is the responsibility of the Attorney General
and the Department of Justice? This was a very, very material matter.
Mr. President, I think it is relevant at this point to display a
couple of charts, one of which is on the issue of covered persons.
Referring to the coordination of advocacy advertisements, President
Clinton made a statement on December 7 of 1995 at a Democratic National
Committee lunch, which is really more than a smoking gun, it is a
firing gun, that is on these advertisements. This is the President's
voice on tape:
Now we have come way back. . . . But one of the reasons has
been. . .we have been running these ads, about a million
dollars a week. . . . So I cannot overstate to you the impact
that these paid ads have had in the areas where they've run.
Now we're doing better in the whole country. . . . [I]n areas
where we've shown these ads we are basically doing ten to
fifteen points better than in areas where we are not showing
them. . . .
The chart shows Leon Panetta confirmed that President Clinton helped
direct expenditures of $35 million in DNC ads, and Dick Morris
confirmed that President Clinton micromanaged the TV ad campaign.
This chart was presented during the Judiciary Committee hearing. In
addition, the instance of the covered persons where a Mr. Warren
Meddoff on October 22, 1996, personally handed President Clinton a
business card with a written message suggesting a $5 million
contribution.
Two days later on October 24 and again on October 26, deputy chief of
staff Harold Ickes solicited Mr. Meddoff, including a call from Air
Force One.
On October 29 and 30, Mr. Ickes called Mr. Meddoff and asked for an
immediate contribution of $1.5 million within 24 hours.
There are two other instances depicted on this chart, and this chart
only covers a very limited amount of information which was disclosed in
the hearings of the Governmental Affairs Committee. One of them was a
coffee which was held in the Oval Office. The President had received a
memorandum from the Democratic National Committee which bore the
President's writing, so we know that it was actually seen by the
President.
This memorandum identified five individuals who, according to the
memo, would be good for a contribution of $100,000 each. They were
accorded a coffee in the White House. On May 1, there was this coffee
in the Oval Office. Within the course of the week, four of the
individuals contributed $100,000 each. That is not in the living
quarters. That is not in any way, shape or form justifiable.
When I asked Attorney General Reno about this specifically--and bear
in mind that at Judiciary Committee hearings, we have a very limited
amount of time. It is not like a speech on the Senate floor where there
is unlimited debate. Attorney General Reno said to me, when I asked her
if this did not constitute where four people came in--bear with me. Let
me read the specific information as to the question I put to the
Attorney General, whether this wasn't specific and credible evidence
which would satisfy the test of the independent counsel statute.
At page 193 of the record:
Attorney General Reno: I will be happy to review it with
the task force and get back to you, Senator.
Senator Specter. Well, OK. I would ask you to review the
balance of it. We will provide you with more of the specific
and credible evidence, but don't you have a judgment today,
Madam Attorney General?
Attorney General Reno: I will review it with the task
force.
The other specific bit of evidence was a June 18, 1996, coffee. In
the presence of President Clinton, John Huang solicited the attendees
saying:
Elections cost money, lots and lots of money, and I am sure
that every person in this room will want to support the re-
election of President Clinton.
This language is important because it was stated in the presence of
the President in the White House. We know that from the testimony of a
former official in the National Security Council who was sitting on one
side of the President, a greater distance from the individual who made
the statement and the comment was heard.
Again, when confronted with this specifically, the Attorney General
declined to give an opinion but said she would get back to me.
That was on July 15 of this year. And more than 45 days have passed,
and we still do not have the information.
Very briefly--I will not belabor the point--this was another chart
presented at Judiciary Committee hearings which shows the alternative
approach on the legal issue, and that is, conflict of interest, where
you have Johnny Chung, who contributed some $366,000 to the Democratic
National Committee, you have the connection with the President, Vice
President, and Mr. Glicken. You have a connection with President
Clinton and Pauline Kanchanalak, the connection between President
Clinton and John Huang, the connection between Vice President Gore and
Maria Hsia, the connection between President Clinton and Charlie Trie.
In all of these matters there is a conflict of interest where these
individuals have been indicted. All except for Mr. Huang, there is the
delicate matter of plea bargaining and a matter where there ought to be
independent counsel not being directed by the Attorney General, who is
the appointee of the President.
As outlined in some detail earlier by Senator Hatch--and I will not
go over that ground--this evidence has been so compelling that FBI
Director Louis Freeh has taken the public position that independent
counsel ought to be appointed, not an easy thing to do for the FBI
Director, who is a subordinate of the Attorney General. But the FBI
Director made that statement.
Then you have the legal judgment of Mr. Charles LaBella, who is the
chief prosecutor, also to the effect that independent counsel ought to
be appointed.
[[Page S9893]]
Then when Mr. LaBella was expected to be appointed as U.S. Attorney
for the Southern District of California, he was skipped over--a
question which needs to be answered in terms of whether his candid
approach, disagreeing with the Attorney General of the United States,
was a causal factor in his being passed over.
Mr. President, what I have outlined here is a very, very brief
statement of very, very compelling evidence of irregularities in
campaign finance. And when you deal with the issue of how Federal
elections for the Presidency, for the Senate, and the House of
Representatives are financed, that goes right to the core of our
democratic institutions.
There is an enormous amount of skepticism in America today with the
way we have political activities. I just finished, during the course of
August, some 12 to 15 town meetings. In every meeting I was asked about
campaign finance reform. And there was obvious cynicism by my
constituents and really disgust with the way the system is run. And I
was asked whether there would be campaign finance reform.
On a number of occasions it was noted that the House of
Representatives had taken the bull by the horns and had passed campaign
finance reform. And when asked whether it would be done in the Senate,
I candidly said it was highly doubtful that 8 additional Senators could
be found to join the 52 of us who have voted for cloture in order to
have campaign finance reform.
If independent counsel were appointed and we got to the bottom of
these issues--and many, many more--I think there would be a tidal wave
of public insistence on campaign finance reform which is very necessary
for the integrity of the electoral process.
When Senator Hatch, the chairman of the Judiciary Committee, speaks
at great length about his frustration in what the Attorney General has
not done, that is a frustration I think shared by most of Americans.
Certainly it is a frustration which I share, and I think is shared by
most of the members of the Judiciary Committee and most of the Members
of the Congress of the United States.
In preparing this complaint in mandamus, we have a course of action
which has a realistic chance of success. Is it a guarantee? No. There
are many lawsuits which are filed, litigation, matters which are
initiated which are not absolute guarantees. But when you have very,
very compelling factual circumstances, as you do here, it is my legal
judgment that the hurdles which have to be overcome can be overcome.
And certainly it is an alternative which ought to be tried. It is my
hope that the Attorney General will respond and appoint independent
counsel. When she has, again, taken steps to have an additional
investigation for 90 days, it is not totally insufficient, but it is a
sharp indication that she has no intention to go to the core problems,
some of which I have outlined here today.
When she activates a 90-day period of an investigation of Vice
President Gore on the telephone calls, that is really a red herring, an
effort to show some action which is totally--totally--insufficient.
When she activates, as she did the day before yesterday, a 90-day
period on Deputy Chief of Staff Ickes on a very limited phase, that
again is totally insufficient.
What is necessary is to pick up the broad range of investigative
leads identified by to the Director of the Federal Bureau of
Investigation, Louis Freeh, and the broad range of leads identified by
the chief counsel on the matter, Charles LaBella, to proceed. And if
the Attorney General does not proceed, then it is my strong
recommendation that the Judiciary Committee, a majority of the
majority, take the bull by the horns and move to take action to compel
the appointment of independent counsel through a mandamus act.
The draft copy of the complaint of mandamus--may I add that this is
not carved in stone, that we are actively working to update it and to
improve the complaint of mandamus, will outline the legal bases and is
an outline of the evidentiary base for such an action.
Exhibit 1
U.S. Senate,
Committee on the Judiciary,
Washington, DC, May 1, 1997.
Hon. Janet Reno,
Attorney General, Department of Justice, Washington, DC.
Dear Attorney General Reno: Following up on yesterday's
hearing, please respond for the record whether, in your legal
judgment, the text of the television commercials, set forth
below, constitutes ``issue advocacy'' or ``express
advocacy.''
The Federal Election commission defines ``express
advocacy'' as follows:
``Communications using phrases such as ``vote for
President,'' ``reelect your Congressman,'' ``Smith for
Congress,'' or language which, when taken as a whole and with
limited reference to external events, can have no other
reasonable meaning than to urge the election or defeat of a
clearly identified federal candidate.'' 11 CFR 100.22
The text of the television commercials follows:
``American values. Do our duty to our parents. President
Clinton protects Medicare. The Dole/Gingrich budget tried to
cut Medicare $270 billion. Protect families. President
Clinton cut taxes for millions of working families. The Dole/
Gingrich budget tried to raise taxes on eight million of
them. Opportunity. President Clinton proposes tax breaks for
tuition. The Dole/Gingrich budget tried to slash college
scholarships. Only President Clinton's plan meets our
challenges, protects our values.
``60,000 felons and fugitives tried to buy handguns--but
couldn't--because President Clinton passed the Brady Bill--
five-day waits, background checks. But Dole and Gingrich
voted no. One hundred thousand new police--because President
Clinton delivered. Dole and Gingrich? Vote not, want to
repeal 'em. Strengthen school anti-drug programs. President
Clinton did it. Dole and Gingrich? No again. Their old ways
don't work. President Clinton's plan. The new way. Meeting
our challenges, protecting our values.
``America's values. Head Start. Student loans. Toxic
cleanup. Extra police. Protected in the budget agreement; the
president stood firm. Dole, Gingrich's latest plan includes
tax hikes on working families. Up to 18 million children face
healthcare cuts. Medicare slashed $167 billion. Then Dole
resigns, leaving behind gridlock he and Gingrich created. The
president's plan: Politics must wait. Balance the budget,
reform welfare, protect our values.
``Head Start. Student loans. Toxic cleanup. Extra police.
Anti-drug programs. Dole, Gingrich wanted them cut. Not
they're safe. Protected in the '96 budget--because the
President stood firm. Dole, Gingrich? Deadlock. Gridlock.
Shutdowns. The president's plan? Finish the job, balance the
budget. Reform welfare. Cut taxes. Protect Medicare.
President Clinton says get it done. Meet our challenges.
Protect our values.
``The president says give every child a chance for college
with a tax cut that gives $1,500 a year for two years, making
most community colleges free, all colleges more affordable .
. . And for adults, a chance to learn, find a better job. The
president's tuition tax cut plan.
``Protecting families. For millions of working families,
President Clinton cut taxes. The Dole-Gingrich budget tried
to raise taxes on eight million. The Dole-Gingrich budget
would have slashed Medicare $270 billion. Cut college
scholarships. The president defended our values. Protected
Medicare. And now, a tax cut of $1,500 a year for the first
two years of college. Most community colleges free. Help
adults go back to school. The president's plan protects our
values.''
Sincerely,
Arlen Specter.
____
Office of the Attorney General,
Washington, DC, June 19, 1997.
Hon. Arlen Specter,
U.S. Senate, Washington, DC.
Dear Senator Specter: I have received your letter of May 1,
1997, asking that I offer you my legal opinion as to whether
the text of certain television commercials constitutes
``express advocacy'' within the meaning of regulations of the
Federal Election Commission (``FEC''). For the reasons set
forth below, I have referred your request to the FEC for its
consideration and response.
Under the Federal Election Campaign Act, the FEC has
statutory authority to ``administer, seek to obtain
compliance with, and formulate policy with respect to'' FECA,
and exclusive jurisdiction with respect to civil enforcement
of FECA. 2 U.S.C. Sec. 437c(b)(1), See 2 U.S.C. Sec. 437d(e)
(FEC civil action is ``exclusive civil remedy'' for enforcing
FECA). The FEC has the power to issue rules and advisory
opinions interpreting the provisions of FECA. 2 U.S.C.
Sec. Sec. 437f, 438. The FEC may penalize violations of FECA
administratively or through bringing civil actions. 2 U.S.C.
Sec. 437g. In short, ``Congress has vested the Commission
with `primary and substantial responsibility for
administering and enforcing the Act.' '' FEC v. Democratic
Senatorial Campaign Comm., 454 U.S. 27, 37 (1981), quoting
Buckley v. Valeo, 424 U.S. 1, 109 (1976).
The legal opinion that you seek is one that is particularly
within the competence of the FEC, and not one which has
historically been made by the Department of Justice.
Determining whether these advertisements constitute ``express
advocacy'' under the FEC's rules will require consideration
not only of their content but also of the timing and
circumstances under which they were distributed. The FEC has
considerably more experience than the Department in making
such evaluations. Moreover, your request involves
interpretation of a rule promulgated by the
[[Page S9894]]
FEC itself. Indeed, it is the standard practice of the
Department to defer to the FEC in interpreting its
regulations.
There is particular reason to defer to the expertise of the
FEC in this matter, because the issue is not as clear-cut as
you suggest. In FEC v. Colorado Republican Federal Campaign
Comm., 839 F. Supp. 1448 (D. Colo. 1993), rev'd on other
grounds, 59 F.3d 1015 (10th Cir. 1995), vacated, 116 S.Ct.
2309 (1996), the United States District Court held that the
following advertisement, run in Colorado by the state
Republican Federal Campaign Committee, did not constitute
``express advocacy'':
``Here in Colorado we're used to politicians who let you
know where they stand, and I though we could count on Tim
Wirth to do the same. But the last few weeks have been a real
eye-opener. I just saw some ads where Tim Wirth said he's for
a strong defense and a balanced budget. But according to his
record, Tim Wirth voted against every new weapon system in
the last five years. And he voted against the balanced budget
amendment.
``Tim Wirth has a right to run for the Senate, but he
doesn't have a right to change the facts.''
839 F. Supp. at 1451, 1455-56. The court held that the
``express advocacy'' test requires that an advertisement ``in
express terms advocate the election or defeat of a
candidate.'' Id. at 1456. The Court of Appeals reversed the
District Court on other grounds, holding that ``express
advocacy'' was not the appropriate test, and the Supreme
Court did not reach the issue.
Furthermore, a pending matter before the Supreme Court may
assist in the legal resolution of some of these issues; the
Soliciter General has recently filed a petition for
certiorari on behalf of the FEC in the case of Federal
Election Commission v. Maine Right to Life Committee, Inc.,
No. 96-1818, filed May 15, 1997. I have enclosed a copy of
the petition for your information. It discusses at some
length the current state of the law with respect to the
definition and application of the ``express advocacy''
standard in the course of petitioning the Court to review the
restrictive definition of the standard adopted by the lower
courts in that case.
It appears, therefore, that the proper legal status of
these advertisements under the regulations issued by the FEC
is a question that is most appropriate for initial review by
the FEC.
Accordingly, I have referred your letter to the FEC for its
consideration. Thank you for your inquiry on this important
matter, and do not hesitate to contact me if I can be of any
further assistance.
Sincerely,
Janet Reno.
____
Office of the Assistant Attorney General, U.S. Department
of Justice,
Washington, DC, June 19, 1997.
Hon. John Warren McGarry,
Chairman, Federal Election Commission, Washington, DC.
Dear Mr. Chairman: Enclosed for the attention and whatever
further reply the Federal Election Commission (FEC) finds to
be appropriate is a copy of an exchange of correspondence
between the Attorney General and Senator Arlen Specter of
Pennsylvania concerning the application of the Commission's
rules governing issue advocacy by political parties to a
specific advertisement. The Department of Justice regards the
subject matter of this inquiry as properly within the primary
jurisdiction of the FEC.
If we can assist the Commission in any way in this matter,
please let me know.
Sincerely,
Mark M. Richard,
Acting Assistant Attorney General.
____
Federal Election Commission,
Washington, DC, June 26, 1997.
Hon. Arlen Specter,
U.S. Senate, Washington, DC.
Dear Senator Specter: Your letter of May 1, 1997 to
Attorney General Reno has been referred by the Department of
Justice to the Federal Election Commission. Your letter asks
for a legal opinion on whether the text of certain
advertisements constitutes ``issue advocacy'' or ``express
advocacy''.
As the Attorney General's June 19, 1997 letter to you
correctly notes, the Federal Election Commission has
statutory authority to ``administer, seek to obtain
compliance with, and formulate policy with respect to'' the
Federal Election Campaign Act (``FECA''). 2 U.S.C.
Sec. 437c(b)(1). The Commission's policymaking authority
includes the power to issue rules and advisory opinions
interpreting the FECA and Commission regulations. 2 U.S.C.
Sec. Sec. 437f and 438.
Your May 1 letter notes that the Commission has promulgated
a regulatory definition of ``express advocacy'' at 11 CFR
100.22. While the Commission may issue advisory opinions
interpreting the application of that provision, the FECA
places certain limitations on the scope of the Commission's
advisory opinion authority. Specifically, the FEC may render
an opinion only with respect to a specific transaction or
activity which the requesting person plans to undertake in
the future. See 2 U.S.C. 437f(a) and 11 CFR 112.1(b). Thus,
the opinion which you seek regarding the text of certain
advertisements does not qualify for advisory opinion
treatment, since the ads appears to be ones previously aired
and do not appear to be communications that you intend to air
in the future. Moreover, ``[n]o opinion of an advisory nature
may be issued by the Commission or any of its employees
except in accordance with the provisions of [section 437f].''
2 U.S.C. Sec. 437f(b).
While the FECA's confidentiality provision precludes the
Commission from making public any information relating to a
pending enforcement matter, I note that past activity such as
the advertisements you describe may be the subject of
compliance action. If you believe that the advertisements in
question involve a violation of the FECA, you may file a
complaint with the Commission pursuant to 2 U.S.C.
Sec. 437g(a) noting who paid for the ads and any additional
information in your possession that would assist the
Commission's inquiry. The requirements for filing a complaint
are more fully described in the enclosed brochure.
I hope that this information proves helpful to your
inquiry. Please feel free to contact my office or the Office
of General Counsel if you need further assistance.
Sincerely,
John Warren McGarry,
Chairman.
Mr. SPECTER. Mr. President, that concludes my remarks and I see staff
bringing me the concluding papers, which I shall present.
____________________