[House Report 104-876]
[From the U.S. Government Publishing Office]



                                                       Calendar No. 289
104th Congress                                                   Report
                        HOUSE OF REPRESENTATIVES

 2d Session                                                     104-876
_______________________________________________________________________

 
         IN THE MATTER OF REPRESENTATIVE BARBARA-ROSE COLLINS

                               __________

                              R E P O R T

                                 OF THE

                              COMMITTEE ON
                     STANDARDS OF OFFICIAL CONDUCT
                        HOUSE OF REPRESENTATIVES




  January 2, 1997.--Referred to the House Calendar and ordered to be 
                                printed


               COMMITTEE ON STANDARDS OF OFFICIAL CONDUCT

  NANCY L. JOHNSON, Connecticut, 
             Chairman
JIM McDERMOTT, Ranking Minority MemberIM BUNNING, Kentucky
BENJAMIN L. CARDIN, Maryland         PORTER J. GOSS, Florida
NANCY PELOSI, California             DAVID L. HOBSON, Ohio
ROBERT A. BORSKI, Pennsylvania       STEVEN SCHIFF, New Mexico
THOMAS C. SAWYER, Ohio
 Theodore J. Van Der Meid, Chief 
              Counsel
   Virginia H. Johnson, Counsel
     David H. Laufman, Counsel
      Bernard Raimo, Counsel
  Charles J. Willoughby, Counsel
        John Vargo, Counsel


                            C O N T E N T S

                              ----------                              
                                                                   Page
 I.  Introduction.....................................................1
II.  Conduct of the Investigation.....................................2
III. Relevant Standards of Conduct....................................4

IV.  Results of Investigation.........................................6
        A. Count I (Improper Campaign Activity by House 
          Employees).............................................     7
            1. Mismanagement of Campaign Finance Operations......     7
            2. Organization of Campaign Events...................    11
        B. Count II (Use of Official Funds for Campaign Purposes)    12
        C. Count III (Performance of Personal Services by House 
          Employees).............................................    14
            1. Payment of Personal Bills.........................    14
            2. Retrieval of Personal Mail........................    15
            3. Cleaning Representative Collins' Home.............    15
            4. Liaison With Vendors..............................    16
            5. Miscellaneous Personal Services...................    16
        D. Count IV (Improper Use of Vouchered Postage Stamps)...    17
        E. Count V (Use of Official Funds for Personal Purposes).    18
        F. Count VI (Commingling and Conversion of Campaign 
          Resources).............................................    19
            1. Checks Issued by Campaign Committee...............    19
            2. Funds Derived from Campaign Resources.............    19
                a. Cashier's Check for $8,500.00.................    19
                b. Cashier's Check for $2,400.00.................    21
            3. Purchase of Personal Appliances...................    21
        G. Count VII (Expenditure of Campaign Funds Not 
          Attributable to Bona Fide Campaign or Political 
          Purposes)..............................................    23
            1. Loan to House Employee............................    23
            2. Expenditures Relating to Trip to Africa...........    24
            3. Personal Cleaning Services........................    26
        H. Count VIII (Misuse of Scholarship Funds)..............    26
        I. Count IX (Maintenance of Unofficial Account)..........    32
        J. Count X (Employee Raises Not Commensurate With 
          Official Duties).......................................    34
        K. Count XI (Improper Solicitation)......................    36

                                APPENDIX

A. October 24, 1994, letter from Representatives Nancy L. Johnson 
  and Jim McDermott to Representative Barbara-Rose Collins.......    39
B. November 22, 1995, and December 1, 1995, letters from 
  Representative Barbara-Rose Collins to Committee on Standards 
  of Official Conduct............................................    41
C. December 4, 1995, Resolution of Preliminary Inquiry...........    43
D. February 29, 1996, letter from Representatives Jim Bunning and 
  Robert Borski to Hon. Saul A. Green, United States Attorney for 
  the Eastern District of Michigan...............................    44
E. March 27, 1996, letter from Representatives Jim Bunning and 
  Robert Borski to Lynn Helland, Chief, Special Prosecutions 
  Unit, Office of the U.S. Attorney..............................    45
F. January 26, 1996, and February 7, 1996, letters from Cornelius 
  Pitts, Esq. to the Hon. Nancy L. Johnson.......................    47
G. February 28, 1996, letter from Representatives Jim Bunning and 
  Robert A. Borski to Cornelius Pitts, Esq.......................    50
H. March 8, 1996, letter from Cornelius Pitts, Esq. to the Hon. 
  Jim Bunning and the Hon. Robert A. Borski; March 14, 1996, 
  letter from Representatives Jim Bunning and Robert A. Borski to 
  Cornelius Pitts, Esq...........................................    53
I. March 18, 1996, motion to quash subpoena by Respondent 
  Barbara-Rose Collins, and accompanying memorandum in support of 
  motion.........................................................    56
J. March 22, 1996, letter from Representative Nancy L. Johnson to 
  Cornelius Pitts, Esq...........................................    63
K. June 27, 1996, letter from Jonathan S. Feld, Esq. to David H. 
  Laufman, Esq...................................................    65
L. July 25, 1996, letter from Representatives Jim Bunning and 
  Robert A. Borski to Jonathan S. Feld, Esq......................    66
M. August 6, 1996, letter from Jonathan S. Feld, Esq. to David 
  Laufman........................................................    68
N. September 12, 1996, letter from Representatives Jim Bunning 
  and Robert A. Borski to Jonathan S. Feld, Esq..................    69
O. July 25, 1996, letter from Representatives Jim Bunning and 
  Robert A. Borski to Representative Barbara-Rose Collins........    71
P. August 26, 1996, letter from Jonathan S. Feld, Esq. to the 
  Hon. Jim Bunning and the Hon. Robert A. Borski.................    81
Q. September 12, 1996, Statement of Alleged Violation............    82
R. September 17, 1996, letter from Representatives Jim Bunning 
  and Robert Borski to Representative Barbara-Rose Collins.......    93
S. October 2, 1996, Motion and Memorandum of Points and 
  Authorities in Support of Request for Bill of Particulars by 
  Representative Barbara-Rose Collins............................    95
T. October 7, 1996, letter from Representatives Jim Bunning and 
  Robert A. Borski to Jonathan Feld, Esq.........................   100
U. October 24, 1996, letter from Jonathan S. Feld, Esq. to David 
  Laufman........................................................   102
V. October 25, 1996, memorandum from Representatives Jim Bunning 
  and Robert A. Borski to Hon. Nancy L. Johnson and Hon. Jim 
  McDermott......................................................   103


                                                       Calendar No. 289
104th Congress                                                   Report
                        HOUSE OF REPRESENTATIVES

 2d Session                                                     104-876
_______________________________________________________________________



          IN THE MATTER OF REPRESENTATIVE BARBARA-ROSE COLLINS

                                _______
                                

  January 2, 1997.--Referred to the House Calendar and ordered to be 
                                printed

_______________________________________________________________________


  Mrs. Johnson, from the Committee on Standards of Official Conduct, 
                        submitted the following

                              R E P O R T

                            I. Introduction

    The Committee on Standards of Official Conduct 
(``Committee'') submits this report pursuant to House Rule X, 
Clause 4(e)(2), which authorizes the Committee to investigate 
any alleged violation, by a Member, officer, or employee of the 
House, of the Code of Official Conduct or of any law, rule, 
regulation, or other standard of conduct applicable to the 
conduct of such Member, officer, or employee.
    In the summer and fall of 1995, newspapers in Detroit and 
Washington, D.C. published allegations by former House 
employees that Representative Barbara-Rose Collins had misused 
official House resources, campaign funds, and the resources of 
a scholarship fund bearing her name. Those allegations, made by 
former staff from Representative Collins' district 
congressional office in Detroit, included charges that:
          Congressional staff routinely were instructed to 
        perform campaign-related tasks in the congressional 
        office and/or at times when they should have been 
        performing their official duties, such as collecting 
        and depositing campaign contribution checks, issuing 
        campaign checks, and maintaining campaign financial 
        records;
          Congressional staff were required to perform personal 
        services for Representative Collins at times when they 
        should have been performing their official duties;
          Representative Collins misused official resources by, 
        among other things, routinely purchasing postage stamps 
        with official funds and using those stamps for personal 
        and campaign purposes; and
          Representative Collins used money from her campaign 
        treasury and from a community scholarship fund for 
        personal purposes.
    On September 20, 1995, the Committee authorized staff to 
interview former employees of Representative Collins' district 
office to verify the published allegations. In early October 
1995, two Committee staff attorneys traveled to Detroit and 
interviewed two former employees of Representative Collins' 
district office, who corroborated the information reported in 
the press.
    On October 24, 1995, the Committee notified Representative 
Collins that it was seeking to determine whether these 
allegations merited further inquiry, and invited her to provide 
a written response to the allegations.1 Representative 
Collins responded in letters dated November 22, 1995, and 
December 1, 1995, in which she denied the allegations.2
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    \1\ App. A.
    \2\ App. B.
---------------------------------------------------------------------------
    On December 5, 1995, the Committee voted to initiate a 
Preliminary Inquiry regarding allegations that Representative 
Collins misused official, campaign, and scholarship fund 
resources.3 Subsequently, an Investigative Subcommittee 
(``Subcommittee'') was established consisting of 
Representatives Jim Bunning, Robert Borski, David Hobson, and 
Thomas Sawyer. The Committee notified Representative Collins of 
the adoption of the Resolution of Preliminary Inquiry and the 
establishment of the Subcommittee, as required by Committee 
rules.
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    \3\ App. C.
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                    II. Conduct of the Investigation

    The Subcommittee employed the full range of investigative 
techniques during the investigation. It obtained sworn 
testimony in Executive Session from former and current members 
of Representative Collins' congressional staff. The 
Subcommittee also obtained a sworn affidavit from an official 
associated with Comerica Bank regarding the purchase of a 
cashier's check from that bank. In some instances, Committee 
staff conducted informal interviews, sometimes by telephone.
    The Subcommittee also obtained relevant documents and 
records by written requests for voluntary compliance and by the 
issuance of subpoenas. Documents obtained by the Subcommittee 
included bank records concerning Representative Collins' 
personal bank account, campaign account, and a scholarship and 
community service fund bearing Representative Collins' name; 
filings with the Federal Election Commission by Representative 
Collins' campaign organization, ``Friends of Barbara-Rose 
Collins''; corporate and other records relating to the 
scholarship and community service fund; and records from the 
House Office of Finance concerning official expenditures by 
Representative Collins' congressional office and authorizations 
for staff salary increases.
    In conducting its investigation, the Subcommittee was 
concerned about the possibility of interfering with an ongoing 
criminal investigation by the Department of Justice 
(``Department'') relating to Representative Collins. In 
February 1996, the Subcommittee notified the Department by 
letter that it had initiated an investigation of Representative 
Collins, specifying the allegations under review.4 In 
March 1996, the Subcommittee sent a second letter to the 
Department.\5\ In those letters, the Subcommittee advised the 
Department that it had issued subpoenas to several persons who 
might be of interest to the grand jury in the government's 
investigation, and asked if the Department had any objection to 
the Subcommittee's proceeding with its investigation of 
Representative Collins. The Department did not respond to the 
Subcommittee's letters, and at no time did the Department 
subsequently request that the Committee suspend or limit its 
investigation.
---------------------------------------------------------------------------
    \4\ App. D.
    \5\ App. E.
---------------------------------------------------------------------------
    The existence of a parallel criminal investigation impeded 
the Subcommittee's access to information from certain 
witnesses. In response to subpoenas for their testimony, 
certain material witnesses asserted their right under the Fifth 
Amendment to the U.S. Constitution to avoid testifying before 
the Subcommittee.
    Representative Collins filed two motions with the 
Subcommittee during the early stages of the investigation. In 
letters dated January 26, 1996, and February 7, 1996, 
Representative Collins, through her counsel, requested a stay 
of the Subcommittee's investigation pending the outcome of the 
criminal investigation by the Department.\6\ On February 28, 
1996, the Subcommittee notified counsel for Representative 
Collins that it was denying the request for a stay.\7\ The 
Subcommittee also denied a subsequent motion for 
reconsideration of its denial of a stay.\8\
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    \6\ App. F.
    \7\ App. G.
    \8\ App. H.
---------------------------------------------------------------------------
    On March 21, 1996, Representative Collins filed a motion to 
quash a documentary subpoena issued by the Committee on 
February 28, 1996.9 The Subcommittee denied that motion on 
March 22, 1996.10
---------------------------------------------------------------------------
    \9\ App. I.
    \10\ App. J.
---------------------------------------------------------------------------
    On June 27, 1996, counsel for Representative Collins 
requested exculpatory information obtained by the Subcommittee 
pursuant to Committee Rule 21.11 On July 25, 1996, the 
Subcommittee provided a letter to Representative Collins 
containing certain exculpatory information.12 The 
Subcommittee received a second request for exculpatory 
information on August 6, 1996.13 Based on further evidence 
obtained by the Subcommittee, the Subcommittee provided 
additional exculpatory information to Representative Collins on 
September 12, 1996.14
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    \11\ App. K.
    \12\ App. L.
    \13\ App. M.
    \14\ App. N.
---------------------------------------------------------------------------
    The Subcommittee twice invited Representative Collins to 
submit information by testimony or in writing regarding the 
allegations under investigation. On July 25, 1996, the 
Subcommittee transmitted a letter to Representative Collins 
pursuant to Committee Rule 17(a)(3), in which the Subcommittee 
provided Representative Collins with extensive information that 
it had obtained, and afforded her an opportunity to submit a 
statement, orally or in writing, regarding the allegations and 
any other relevant questions arising out of the 
investigation.15 On August 26, 1996, counsel for 
Representative Collins declined in writing to provide any 
information under Committee Rule 17(a)(3).16 In addition, 
counsel asked the Subcommittee to declare its investigation 
moot because of Representative Collins' primary election defeat 
on August 6, 1996. The Subcommittee denied counsel's request.
---------------------------------------------------------------------------
    \15\ App. O.
    \16\ App. P.
---------------------------------------------------------------------------
    On September 12, 1996, the Subcommittee voted to adopt a 
Statement of Alleged Violation against Representative Collins, 
consisting of eleven counts of alleged violations of law and 
House rules.17 Consistent with Committee Rule 17(d), 
members of the Subcommittee stressed that the Statement of 
Alleged Violation manifested only a ``reason to believe'' that 
Representative Collins committed violations within the 
jurisdiction of the Committee, rather than a finding of guilt.
---------------------------------------------------------------------------
    \17\ App. Q.
---------------------------------------------------------------------------
    On September 17, 1996, the Subcommittee transmitted the 
Statement of Alleged Violation to Representative Collins, and 
advised her of her right, under Committee Rule 18, to submit an 
answer in writing and under oath.18 On October 2, 1996, 
Representative Collins filed a motion for a bill of 
particulars, in which she sought additional information 
regarding various counts of the Statement of Alleged 
Violation.19 The Subcommittee granted her motion in part 
on October 7, 1996.20
---------------------------------------------------------------------------
    \18\ App. R.
    \19\ App. S.
    \20\ App. T.
---------------------------------------------------------------------------
    On October 24, 1996, Representative Collins, through her 
counsel, formally declined to file an answer to the Statement 
of Alleged Violation.21 Pursuant to Committee Rule 18(a), 
the Investigative Subcommittee regarded Representative Collins' 
failure to submit an answer as a denial of each count in the 
Statement of Alleged Violation.
---------------------------------------------------------------------------
    \21\ App. U.
---------------------------------------------------------------------------
    On October 25, 1996, the Chairman and Ranking Member of the 
Investigative Subcommittee transmitted the Statement of Alleged 
Violation to the Chairman and Ranking Minority Member of the 
Committee pursuant to Committee Rule 18(g).22 In doing so, 
the Investigative Subcommittee recommended that no adjudicative 
subcommittee be established, and that no further action be 
taken in this matter. The Subcommittee based its recommendation 
on the fact that Representative Collins had lost her primary 
election in August 1996, and that the Committee therefore would 
lose its jurisdiction over her on January 3, 1997, before an 
adjudicative proceeding could be completed. The Committee 
subsequently approved the Subcommittee's recommendation.
---------------------------------------------------------------------------
    \22\ App. V.
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              III. Relevant Standards of Conduct and Laws

    At all times relevant to the violations hereafter alleged, 
the pertinent provisions of House Rules and laws stated as 
follows:

        A. House Rule XLIII, Clause 1 (Code of Official Conduct)

    ``A Member, officer or employee of the House of 
Representatives shall conduct himself at all times in a manner 
which shall reflect creditably on the House of 
Representatives.''

        B. House Rule XLIII, Clause 6 (Code of Official Conduct)

    ``A Member of the House of Representatives shall keep his 
campaign funds separate from his personal funds. A Member shall 
convert no campaign funds to personal use in excess of 
reimbursement for legitimate and verifiable campaign 
expenditures and shall expend no funds from his campaign 
account not attributable to bona fide campaign or political 
purposes.''

        C. House Rule XLIII, Clause 8 (Code of Official Conduct)

    ``A Member or officer of the House of Representatives shall 
retain no one under his payroll authority who does not perform 
official duties commensurate with the compensation received in 
the offices of the employing authority.''

                           D. House Rule XLV

    ``No Member may maintain or have maintained for his use an 
unofficial office account.'' According to the Committee's 
interpretation of Rule 45, ``outside private donations, funds, 
campaign contributions, or in-kind services may not be used to 
support the activities of, or pay the expenses of, a 
congressional office.'' 23 Private funds may be used 
``only to support private or political, and not official, 
activities.'' 24
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    \23\ Committee on Standards of Official Conduct, House Ethics 
Manual, 102d Cong., 2d Sess. 217 (1992) (hereafter House Ethics 
Manual).
    \24\ Id. at 218; see also id. at 221.
---------------------------------------------------------------------------

                       E. 31 U.S.C. Sec. 1301(a)

    ``Appropriations shall be applied only to the objects for 
which the appropriations were made except as otherwise provided 
by law.''

   F. Committee on House Administration, ``Congressional Handbook,'' 
  Regulations for Allowances and Expenses of Members, Committees and 
                         Employees (June 1993)

    Salary adjustments of an employee of a Member ``should 
reflect services performed during the particular pay period or 
may reflect exceptional performance during the course of an 
allowance year. Increases should be made only when the services 
of the individual(s) warrant.'' (Page 7)
    ``Each Member is authorized an Official Expenses Allowance 
to pay ordinary and necessary business expenses incurred by the 
Member (and/or the Member's employees) . . . in support of the 
conduct of the Member's official and representational duties to 
the district from which he/she was elected. . . . This 
allowance may not be used to defray any personal, political or 
campaign related expenses . . . or expenses related to the 
conduct of other than official and representational business.'' 
(Page 23)
    ``Each Member and his/her clerk-hire employees may be 
reimbursed for travel expenses incurred in support of the 
conduct of the Member's official and representational duties to 
the district from which the Member was elected.'' (Page 36)
    ``Travel expenses incurred by someone other than the Member 
or his/her employees are not payable from the Official Expenses 
Allowance.'' (Page 36)
    ``Travel expenses incurred in support of the conduct of 
personal, political, or campaign-related business . . . or in 
support of the conduct of other than official and 
representational business are not payable from the Official 
Expenses Allowance.'' (Page 36)

 G. Committee on House Oversight, ``Members' Congressional Handbook,'' 
 Regulations Governing the Members' Representational Allowance of the 
                  U.S. House of Representatives (1995)

    ``All Members have one `Members' Representational 
Allowance' (MRA) available to support the conduct of official 
and representational duties to the district from which elected. 
. . . The MRA may not be used to pay for any personal, 
political, campaign, or committee expenses.'' (Page 1) 
(Emphasis in original)
    ``Members may adjust, in any month, a Clerk Hire employee's 
salary to reflect exceptional, meritorious, or less than 
satisfactory service.'' (Page 9)
    ``Travel expenses incurred by someone other than Members or 
their Clerk Hire employees are not reimbursable from the MRA.'' 
(Page 46) (Emphasis in original)

   H. Regulations Regarding Solicitation Promulgated by Committee on 
                     Standards of Official Conduct

    The House Ethics Manual states that ``Members, officers, 
and employees of the House may solicit funds on behalf of 
charitable organizations qualified under Sec. 170(c) of the 
Internal Revenue Code, provided that no official resources are 
used, no official endorsement is implied, and no direct 
personal benefit results.
    No solicitation may bear official letterhead, the Great 
Seal, or the terms `Congress of the United States,' `House of 
Representatives,' or `official business.' . . . Questions 
regarding solicitations on behalf of entities that are not 
charities qualified under Sec. 170(c) should be addressed to 
the Committee.'' 25 That guidance is based on an October 
9, 1990, memorandum from the Committee on Standards of Official 
Conduct to all Members, officers, and employees of the House of 
Representatives. In addition to the guidance discussed above, 
that memorandum states: ``The Committee will address on a case-
by-case basis the extent to which a Member, officer, or 
employee may personally control the distribution of funds from 
a charity for which he or she solicits funds.'' 26
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    \25\ House Ethics Manual, supra, at 51 (emphasis in original).
    \26\ Id. at 65.
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                      IV. Results of Investigation

    This section of the report presents detailed information 
received by the Subcommittee during its investigation of 
Representative Collins in the context of the individual counts 
comprising the Statement of Alleged Violation. The section does 
not reflect the totality of information received by the 
Subcommittee during its investigation.
    The Committee has placed primary emphasis on explaining the 
evidentiary basis for the Statement of Alleged Violation. Where 
appropriate, the Committee also has cited testimony or other 
evidence that is contrary to the evidence relied on by the 
Subcommittee in adopting a particular count, and evidence that 
could be viewed as exculpatory.

       A. Count I (Improper Campaign Activity by House Employees)

    The Subcommittee obtained credible evidence that employees 
of Representative Collins' congressional offices in Washington, 
D.C. and Detroit provided extensive assistance to her campaign 
organization in contravention of law and House rules, and that 
such assistance occurred with the knowledge and approval of 
Representative Collins. The campaign-related activities in 
which congressional staff were improperly involved ranged from 
day-to-day management of campaign finance operations to the 
organization of campaign events, including fund-raising events.

1. Management of campaign finance operations

    The Subcommittee received credible testimonial evidence 
that campaign contribution checks routinely were brought into 
Representative Collins' congressional office in Detroit.27 
Sometimes, senior staff from the Washington, D.C. office, such 
as Meredith Cooper, who served as Staff Director of the 
Subcommittee on Postal Operations and Services and Chief of 
Staff to Representative Collins in 1994 and 1995, brought 
checks to the Detroit office if they were visiting the 
district, and gave the checks to district office staff.28 
More often, an employee in the Washington congressional office 
(often Meredith Cooper) mailed campaign contributions checks 
received in Washington to a post office box in Detroit 
maintained by Representative Collins' campaign 
committee.29
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    \27\ Deposition of Joyce Smith, Apr. 17, 1996, at 18 (hereafter 
``Smith Dep.'').
    \28\ Deposition of Edith Lee Payne, March 29, 1996, at 11 
(hereafter ``Payne Dep.'').
    \29\ Payne Dep. at 10-11; Smith Dep. at 20.
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    Joyce Smith, who served as office manager in the Detroit 
congressional office from approximately May 1994 to February 
1995, testified that either she or another office employee, 
Milton Harris, retrieved mail each morning from the campaign's 
post office box, including campaign contribution checks.30 
Ms. Smith's testimony was corroborated by Edith Lee Payne, who 
served as liaison for community relations in the Detroit office 
from March to August 1994.31 Ms. Payne testified that 
Milton Harris regularly retrieved campaign contribution checks 
and other mail from the campaign's post office box and brought 
them to the congressional office.32
---------------------------------------------------------------------------
    \30\ Smith Dep. at 20.
    \31\ Payne Dep. at 4.
    \32\ Id. at 10.
---------------------------------------------------------------------------
    Milton Harris acknowledged that he retrieved mail from a 
post office box and brought it to the congressional office, 
although he testified he was unaware that the box was 
maintained by Representative Collins' campaign.33 He also 
testified that he opened mail from the post office box that 
contained checks.34
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    \33\ Deposition of Milton Harris, May 1, 1996, at 10-11 (hereafter 
``Harris Dep.'').
    \34\ Id. at 12-13.
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    After the district office received campaign contribution 
checks, district office staff routinely performed various tasks 
in the congressional office concerning the checks at times when 
they should have been performing official duties.35 Edith 
Lee Payne testified that it was her responsibility to ``log'' 
incoming checks, list them on a bank deposit slip, copy them, 
and deposit them into the campaign's account at a bank in 
Detroit.36 According to Ms. Payne, she was also 
responsible for copying the bank deposit receipt and forwarding 
that receipt and copies of contribution checks to Meredith 
Cooper in Washington, D.C.37
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    \35\ Payne Dep. at 7; Smith Dep. at 13.
    \36\ Payne Dep. at 9-10, 19-20.
    \37\ Id. at 10, 20.
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    Ms. Payne testified that Representative Collins personally 
gave her instructions on how to make the deposits and what 
follow-up actions to take. \38\ She also testified that she 
performed the above-described tasks (with the exception of the 
deposit itself) in the congressional office using office 
equipment, and that she was not instructed to do otherwise. 
\39\
---------------------------------------------------------------------------
    \38\ Id. at 20.
    \39\ Id. at 11.
---------------------------------------------------------------------------
    Ms. Payne's testimony was corroborated in detail by Joyce 
Smith, who testified that she performed the same tasks 
regarding campaign contributions as those described above by 
Ms. Payne.40 Ms. Smith also advised the Subcommittee that 
District Director Jerry Springs sometimes personally 
transmitted campaign contribution checks to her at the 
congressional office and instructed her to process them.41 
In addition, Ms. Smith advised the Subcommittee that she 
sometimes told Mr. Springs during normal business hours that 
she was leaving the congressional office to make a deposit on 
behalf of the campaign, and that Mr. Springs did not ask her to 
take leave for the time she was out of the office.42
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    \40\ Smith Dep. at 18.
    \41\ Committee Counsel interview with Joyce Smith, July 18, 1996 
(hereafter ``Smith Int. I'').
    \42\ Id.
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    Ms. Payne's version was partially corroborated by Priscilla 
Waters, who worked as Executive Administrator in the district 
office from August 1993 to approximately April 1994. Ms. Waters 
advised Committee staff that she performed campaign bookkeeping 
chores in the congressional office, but that she usually 
performed such activities after business hours and on 
weekends.43 Ms. Waters' account was corroborated by a 
March 10, 1994, campaign check made payable to her in the 
amount of $16.63 for a ``log--campaign finance,'' co-signed by 
Representative Collins and her daughter, campaign treasurer 
Cynthia Simpson.
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    \43\ Committee Counsel interview with Priscilla Waters, July 12, 
1996 (hereafter ``Waters Int.'').
---------------------------------------------------------------------------
    Testimony by district congressional staff regarding the 
deposit of campaign contribution checks also was corroborated 
by a document captioned ``Job Duties,'' which Ms. Smith 
provided to the Subcommittee. That document, which Ms. Smith 
received from Ms. Payne,44 consists of a typed list of job 
responsibilities, including duties expressly characterized as 
``[c]ampaign-related.'' The ``deposit of checks'' is the first 
item specified in the list of campaign-related duties.
---------------------------------------------------------------------------
    \44\ Smith Dep. at 12.
---------------------------------------------------------------------------
    Congressional staff also paid the campaign's bills. Bank 
documents show that Joyce Smith was authorized to sign checks 
drawn on the account of Friends of Barbara-Rose Collins.45 
Ms. Smith testified that she routinely wrote campaign checks in 
the congressional office in payment of the campaign's utility 
bills and other expenses.46 She also testified that she 
reconciled the campaign bank account in the congressional 
office and mailed checks to payees.47
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    \45\ Smith Dep. at 17.
    \46\ Id. at 13.
    \47\ Id. at 11-12, 16.
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    The Subcommittee obtained credible evidence that the 
issuance of campaign checks by congressional staff from the 
congressional office, during official business hours, occurred 
with the knowledge and approval of Representative Collins. 
First, the evidence indicates that Representative Collins 
personally exercised oversight over the expenditure of funds 
from her campaign's bank account. According to Valerie Nicholas 
and Gloria Dorsey, former staff in the Washington, D.C. 
congressional office, Representative Collins kept a campaign 
checkbook in the desk of her private office in 
Washington.48 Representative Collins was among several 
authorized signers of campaign checks,49 and copies of 
canceled campaign checks obtained from Comerica Bank in Detroit 
indicate that she signed numerous checks drawn on the 
campaign's account.
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    \48\ Deposition of Valerie Nicholas, March 29, 1996, at 32-33, 51 
(hereafter ``Nicholas Dep.''); Deposition of Gloria Dorsey, Apr. 16, 
1996, at 16 (hereafter ``Dorsey Dep.'').
    \49\ Smith Dep. at 17-18.
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    Under the terms of the campaign's account at Comerica Bank, 
two signatures were required to issue a campaign check.50 
After Joyce Smith began writing campaign checks in Detroit, the 
Washington congressional office sometimes sent checks to the 
Detroit office that Representative Collins had pre-signed for a 
second signature by Ms. Smith.51 According to Ms. Smith, 
the Washington office also sometimes sent blank campaign checks 
for her to sign and send back to the Washington office, usually 
by Federal Express shipments charged to the account of the 
congressional office.52 In some instances, Representative 
Collins personally telephoned Ms. Smith and asked her to sign 
blank campaign checks and return them by Federal Express to the 
Washington office.53
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    \50\ Smith Dep. at 17-18.
    \51\ Smith Dep. at 17; Smith Int. I.
    \52\ Smith Int. I.
    \53\ Id.
---------------------------------------------------------------------------
    Joyce Smith testified that Representative Collins sometimes 
personally directed her to sign campaign checks at times when 
she otherwise would have been performing official 
duties.54 At other times, Meredith Cooper or District 
Director Jerry Springs (Ms. Smith's immediate supervisor) so 
instructed her.55 In addition, Ms. Smith advised the 
Subcommittee that Representative Collins personally made it 
clear to her that she was responsible for performing 
bookkeeping functions for the campaign account.56 At no 
time, according to Ms. Smith, did Representative Collins 
indicate to her that she should take leave to perform such 
duties or perform them on her own time.57
---------------------------------------------------------------------------
    \54\ Smith Dep. at 13, 15-16.
    \55\ Id. at 13.
    \56\ Smith Int. I.
    \57\ Id.
---------------------------------------------------------------------------
    District Director Jerry Springs provided testimony at odds 
with the testimony of Joyce Smith and Edith Lee Payne. 
Initially, Mr. Springs denied any knowledge of campaign 
contributions coming into the congressional office.58 
Subsequently, he testified that checks came into the 
congressional office ``on occasion,'' but said that the 
district office either returned those checks to the sender with 
a request to send them to the campaign office, or forwarded 
them immediately to the campaign treasurer.59 Mr. Springs 
denied any knowledge that district office staff performed 
campaign bookkeeping tasks in the congressional office60 
or mailed campaign contribution checks to the Washington 
congressional office.61 He also denied instructing staff 
to make disbursements on behalf of the campaign.62
---------------------------------------------------------------------------
    \58\ Deposition of Jerry Springs, May 1, 1996, at 23-25 (hereafter 
``Springs Dep. I'').
    \59\ Deposition of Jerry Springs, Aug. 1, 1996, at 101 (hereafter 
``Springs Dep. II'').
    \60\ Springs Dep. I at 26-27; Springs Dep. II at 102-03.
    \61\ Springs Dep. I at 28; Springs Dep. II at 105.
    \62\ Springs Dep. I at 46; Springs Dep. II at 106.
---------------------------------------------------------------------------
    Mr. Springs' testimony also was inconsistent with a 
document that he himself created.63 That document consists 
of a memorandum on Representative Collins' official stationery 
dated January 24, 1995, from ``Jerry Springs, District 
Director'' to ``Joyce Smith, Office Manager,'' regarding 
``Preliminary Performance Assessment.'' 64 Mr. Springs 
produced two versions of the memorandum, each bearing the date 
of January 24, 1995.65 The first version of the memorandum 
began as follows:
---------------------------------------------------------------------------
    \63\ Springs Dep. II at 119.
    \64\ Id.
    \65\ Id. at 125.
---------------------------------------------------------------------------
          This memorandum serves notice that your performance 
        has been under review and deemed unsatisfactory at this 
        stage of your tenure.
          Several recent incidences have ocurred [sic] under 
        your direct involvement that created confusion and/or a 
        negative reflection of the Congresswoman. Specifically, 
        those incidences were as follows:
                  A. Mishandling of the Friend's account that 
                resulted in incomplete transaction entries and 
                balances of the account: there was absolutely 
                no follow-up on what was started on December 
                23, 1995 and no communications with the 
                Congresswoman as to when the assignment would 
                be completed. [Emphasis added.] As of today, 
                those transactions are still incomplete.
                  B. Improper documentation and mailing of a 
                $2,500.00 check.
The memorandum proceeded to criticize Ms. Smith for also 
allegedly committing scheduling errors and taking unapproved 
leave from the office. Mr. Springs concluded the memorandum by 
stating:
          As a result of the above recent incidences, I am 
        placing your appointment on a 60 day probationary 
        status. This will give you ample time to demonstrate a 
        willingness and a commitment to fulfill your duties as 
        an appointee to the 15th Congressional district office. 
        [Emphasis added.] I am more than willing to work with 
        you in any and all areas needing improvement.
    Mr. Springs subsequently revised the memorandum. In the 
second version, he deleted Paragraph B, which referred to the 
``[i]mproper documentation and mailing of a $2,500.00 check.'' 
Mr. Springs claimed that the document's references to errors in 
the performance of campaign tasks by Ms. Smith related to 
``volunteer'' work that she was performing for the 
campaign,66 and he denied that Ms. Smith was expected to 
perform those tasks as part of her congressional duties.67 
He explained that he deleted mention of the $2,500.00 check 
because he had concluded it was inappropriate to cite the 
handling of that check in an official performance 
assessment.68
---------------------------------------------------------------------------
    \66\ Springs Dep. II at 113, 124.
    \67\ Id. at 114-15, 122-24.
    \68\ Id. at 127.
---------------------------------------------------------------------------

 2. Organization of campaign events

    The Subcommittee obtained credible evidence that 
congressional staff helped to organize and prepare for 
campaign-related events in violation of House rules. Edith Lee 
Payne and Joyce Smith testified that they devoted substantial 
time in the Detroit congressional office to coordinating mass 
mailings consisting of fund-raising solicitations, at times 
when they otherwise would have been performing official 
duties.69 In one case concerning a fund-raising event held 
at Halloween, Ms. Smith and other district office staff 
prepared a campaign mailing to approximately 2,300 persons 
using office equipment and other official resources.70 
According to Ms. Smith, the campaign letterhead used for that 
mailing consisted of stationery that had been created on the 
district office computer.71 Ms. Smith also recalled that 
Jerry Springs instructed office staff to assemble the mailing, 
and that he personally participated in the project.72
---------------------------------------------------------------------------
    \69\ Smith Dep. at 6-7; Payne Dep. at 18.
    \70\ Smith Dep. at 6, 11.
    \71\ Id. at 7, 11.
    \72\ Id. at 7.
---------------------------------------------------------------------------
    In another example, several district office staff were 
instructed to report to the new campaign headquarters of 
Representative Collins during normal business hours to prepare 
for a picnic.73 Ms. Payne and Ms. Smith testified that 
male staff were required to paint the facility, install ceiling 
fans, and cut the grass, while female staff were required to 
prepare food.74 Ms. Payne recalled that these instructions 
came from District Office Director Jerry Springs,75 while 
Ms. Smith testified her instructions came from Meredith 
Cooper.76
---------------------------------------------------------------------------
    \73\ Payne Dep. at 23-24.
    \74\ Payne Dep. at 23; Smith Dep. at 5.
    \75\ Payne Dep. at 24.
    \76\ Smith Dep. at 5.
---------------------------------------------------------------------------
    In a third example, Representative Collins and Meredith 
Cooper directed the Washington office manager, Valerie 
Nicholas, to accompany Ms. Cooper to Detroit to staff a fund-
raising event in mid-1994.77 Ms. Nicholas testified that 
she and members of the district office staff distributed 
identification to invitees when they arrived and performed 
other administrative functions.78 Ms. Nicholas also 
recalled being directed to coordinate and staff other fund-
raising events in Washington, D.C. during normal business 
hours.79
---------------------------------------------------------------------------
    \77\ Nicholas Dep. at 82-83.
    \78\ Id. at 83.
    \79\ Id. at 86.
---------------------------------------------------------------------------

       B. Count II (Use of Official Funds for Campaign Purposes)

    The Subcommittee obtained credible evidence that the office 
of Representative Collins used funds of the House of 
Representatives for campaign-related purposes in 1995. The 
record indicates that on or about April 4, 1995, District 
Director Jerry Springs traveled from Detroit to Washington. A 
hotel bill from the Best Western Skyline Hotel in Washington, 
D.C. shows that Mr. Springs and one other person (later learned 
to be Korey Hall, another employee of the Detroit district 
office 80) checked into the hotel on the night of April 4, 
1995, and incurred $200.61 in charges. A monthly statement for 
Representative Collins' government American Express card, dated 
April 26, 1995, shows that the government card was used on 
April 6, 1995, to pay the hotel bill, and Representative 
Collins' office submitted a voucher to the House of 
Representatives, dated April 3, 1995, seeking reimbursement of 
$200.61 for Mr. Springs' stay at the hotel for ``official 
business.''
---------------------------------------------------------------------------
    \80\ Springs Dep. II at 85-86.
---------------------------------------------------------------------------
    The Subcommittee obtained credible evidence that 
Representative Collins signed and approved that voucher. The 
signature ``Barbara-Rose Collins'' appears at the bottom of the 
voucher in the space designated for the Member's signature, and 
that signature corresponds to the signature appearing on checks 
drawn on Representative Collins' personal bank account. In 
addition, two members of her staff who were responsible for 
preparing vouchers testified that Representative Collins 
personally signed vouchers.81 Jerry Springs testified that 
he recognized the signature on the voucher regarding his April 
1995 trip to Washington as the signature of Representative 
Collins.82
---------------------------------------------------------------------------
    \81\ Nicholas Dep. at 6; Dorsey Dep. at 6-7.
    \82\ Springs Dep. II at 94.
---------------------------------------------------------------------------
    The Subcommittee obtained evidence that Mr. Springs' visit 
to Washington in April 1995 coincided with a fund-raising event 
in Washington held on behalf of Representative Collins' 
campaign. On the night of April 5, 1995, Friends of Barbara-
Rose Collins sponsored an event at a Washington, D.C. hotel 
described on the invitation as the ``4th Annual Straight From 
the Soul Food Feast honoring Congresswoman Barbara-Rose 
Collins.'' The invitation indicated that campaign contributions 
were solicited in connection with the event.
    Mr. Springs acknowledged that he attended the event and 
that the event was a fundraiser,83 but he testified that 
he did not know the event was campaign-related until his 
arrival at the event.84 He also said that his principal 
reason for coming to Washington was to meet with Meredith 
Cooper to provide an update on activities in the district 
office, including casework matters.85
---------------------------------------------------------------------------
    \83\ Id.at 79-82.
    \84\ Id.at 80-81.
    \85\ Id.at 82-83, 96-97.
---------------------------------------------------------------------------
    The Subcommittee determined that the record as a whole 
supports a finding that Mr. Springs came to Washington 
primarily to attend the campaign event on April 5, 1996. Mr. 
Springs' hotel bill indicates that he checked into the hotel at 
6:47 p.m. on April 4, 1996, and checked out at 7:16 a.m. on 
April 6. Thus, the only full day that he spent in Washington 
was April 5, the day of the campaign event, and he left early 
in the morning after the event. In addition, as discussed above 
regarding Count I, the Subcommittee obtained substantial 
evidence that Mr. Springs was involved in campaign-related 
activities.
    The Subcommittee also obtained evidence of additional 
misuse of official funds in connection with the above-
referenced campaign event held in Washington on April 5, 1995. 
In that regard, the Subcommittee investigated published 
allegations that Representative Collins' office submitted a 
fraudulent voucher to the House of Representatives in 
connection with that campaign event.86 Specifically, the 
Subcommittee investigated allegations that Leon Robinson, 
reportedly a personal friend of Representative Collins',87 
used an airline ticket purchased in the name of district office 
employee Milton Harris to travel from Detroit to Washington to 
attend the campaign event.
---------------------------------------------------------------------------
    \86\ Pekkanen, ``Rep. B. Collins Used Congressional Credit Card to 
Fly Personal Friend from Detroit to D.C.,'' The Hill, Feb. 21, 1996, at 
4.
    \87\ Committee Counsel interview with Michael McQuerry, Feb. 21, 
1996 (hereafter ``McQuerry Int. I'').
---------------------------------------------------------------------------
    Evidence obtained by the Subcommittee corroborated the 
published allegations. Copies of a Northwest Airlines ticket 
and related purchase forms provided to the Subcommittee by the 
House Office of Finance indicate that the congressional office 
of Representative Collins, using the office's government 
American Express card, purchased a $436.00 round-trip airline 
ticket in the name of district office employee Milton Harris on 
or about April 5, 1995. The ticket indicates that Mr. Harris 
was scheduled to fly from Detroit to Washington on April 5, 
1995--the day on which the fund-raising event was held in 
Washington--and return to Detroit on April 6. Correspondingly, 
the congressional office of Representative Collins submitted a 
voucher to the House of Representatives seeking reimbursement 
in the amount of $436.00 for round-trip air travel by Milton 
Harris from Detroit to Washington, D.C. during the period of 
April 5-6, 1995. The voucher, which appears to bear the true 
signature of Representative Collins, is dated May 22, 1995 
(i.e., after the campaign event), and identified the purpose of 
Mr. Harris' travel as ``official business.''
    Both Jerry Springs and Michael McQuerry, a former employee 
in Representative Collins' Washington office, confirmed that 
Leon Robinson attended the April 5, 1995, campaign event in 
Washington.88 Mr. McQuerry, who was working in the 
Washington congressional office during the relevant time 
period, told Committee staff that Mr. Harris did not come to 
Washington for the April 5, 1995, campaign event.89 Mr. 
McQuerry's recollection is corroborated by the fact that no 
voucher was submitted for lodging or other expenses for Mr. 
Harris, whereas the round-trip airline ticket purchased in Mr. 
Harris' name indicated that he would be staying overnight in 
Washington on April 5.
---------------------------------------------------------------------------
    \88\ Springs Dep. II at 99; McQuerry Int. I; Committee Counsel 
interview with Michael McQuerry, July 24, 1996 (hereafter ``McQuerry 
Int. II'').
    \89\ McQuerry Int. I; McQuerry Int. II.
---------------------------------------------------------------------------
    The Subcommittee obtained credible information that 
Meredith Cooper knew the office was submitting a false voucher 
to the House Office of Finance regarding Mr. Harris' purported 
air travel to Washington. Mr. McQuerry advised Committee staff 
that another employee in the Washington office, Anthony Martin, 
told him during the vouchering process that Mr. Robinson had 
used the ticket purchased in Mr. Harris's name.90 
According to Mr. McQuerry, Mr. Martin advised him that Chief of 
Staff Meredith Cooper had instructed Mr. Martin to process a 
voucher regarding an airline ticket for Mr. Harris despite the 
fact that Mr. Robinson, rather than Mr. Harris, had used the 
ticket.91 Mr. McQuerry also identified the signature 
``Barbara-Rose Collins'' on the airline ticket purchase form as 
the handwriting of Meredith Cooper. Finally, testimony from 
former congressional staff indicates that Representative 
Collins shared a close personal and professional relationship 
with Meredith Cooper.92 Ms. Cooper corroborated that 
description of the relationship to some extent by testifying 
that she had daily face-to-face contact with Representative 
Collins.93
---------------------------------------------------------------------------
    \90\ McQuerry Int. II.
    \91\ Id.
    \92\ Nicholas Dep. at 7, 9, 34, 44; Dorsey Dep. at 57; Deposition 
of Miniard Culpepper, March 27, 1996, at 42 (hereafter ``Culpepper 
Dep.''); Committee Counsel interview with Lillian German, March 25, 
1996 (hereafter ``German Int.'').
    \93\ Deposition of Meredith Cooper, June 25, 1996, at 6.
---------------------------------------------------------------------------
    Based on the foregoing, and particularly because 
Representative Collins apparently signed the vouchers in 
question, the Subcommittee found reason to believe that 
Representative Collins knew that official funds were used to 
pay for Mr. Springs' lodging to attend the campaign event in 
Washington, D.C. on April 5, 1995. The Subcommittee also found 
reason to believe that Representative Collins knew that 
official funds were used to pay for the travel of Leon Robinson 
to attend the same campaign event, and that Mr. Harris did not 
attend that event.

   c. count iii (performance of personal services by house employees)

    The Subcommittee obtained substantial credible evidence 
that members of Representative Collins' congressional staff 
routinely performed personal services for Representative 
Collins at times when they should have been performing official 
duties, with the knowledge and approval of Representative 
Collins.

1. Payment of personal bills

    Valerie Nicholas and Gloria Dorsey provided credible 
testimony that they paid Representative Collins' personal bills 
in the Washington congressional office at times when they 
otherwise would have been performing official duties.94 
Ms. Nicholas, who worked in Representative Collins' office from 
June 1994 until March 1995, testified that she inherited the 
bill-paying function from another district office employee in 
the summer of 1994 and paid at least ten bills each 
month.95 She told the Subcommittee that some personal 
bills were mailed to Representative Collins' home in Virginia, 
while others were mailed directly to the congressional 
office.96 Ms. Nicholas testified that Representative 
Collins brought personal bills to the office that she had 
received at home and gave them directly to Ms. Nicholas.97 
To facilitate Ms. Nicholas' preparation of checks, 
Representative Collins provided Ms. Nicholas with her personal 
checkbook from the Wright Patman Federal Congressional Credit 
Union (``Credit Union'') in Washington, D.C.98 Ms. 
Nicholas wrote out the checks, gave them to Representative 
Collins to sign, and mailed them.99 According to Ms. 
Nicholas, at no time did Representative Collins or Meredith 
Cooper discuss with her whether it was appropriate to pay the 
personal bills in the congressional office, or at times when 
she should be performing official duties.100
---------------------------------------------------------------------------
    \94\ Dorsey Dep. at 9-12, 52, 55-56; Nicholas Dep. at 6, 8-15.
    \95\ Nicholas Dep. at 8, 12-13.
    \96\ Id. at 10.
    \97\ Id. at 9-10.
    \98\ Id. at 10.
    \99\ Id. at 10-11.
    \100\ Id. at 13-14.
---------------------------------------------------------------------------
    Ms. Nicholas' testimony was corroborated by Gloria Dorsey, 
who began working for Representative Collins in the Washington 
office in May 1995. Ms. Dorsey recalled that she began paying 
Representative Collins' personal bills in the fall of 1995 
after she became the office manager, and that Meredith Cooper 
told her she would be responsible for that function.101 
According to Ms. Dorsey, she was never given the option of 
paying Representative Collins' personal bills on her own 
private time.102
---------------------------------------------------------------------------
    \101\ Dorsey Dep. at 9, 11.
    \102\ Id. at 56.
---------------------------------------------------------------------------
    Ms. Dorsey testified that she sometimes consulted 
Representative Collins directly if she was uncertain about 
whether to pay a given bill or the amount of money to 
remit.103 She also testified that Representative Collins 
personally signed the checks she had prepared, sometimes in her 
presence.104
---------------------------------------------------------------------------
    \103\ Id. at 11, 13.
    \104\ Id. at 12.
---------------------------------------------------------------------------

2. Retrieval of personal mail

    Priscilla Waters, the former Executive Administrator in the 
Detroit congressional office, told Committee staff that she was 
in possession of the keys to Representative Collins' personal 
mailbox in Detroit.105 She recalled that, at the request 
of Administrative Assistant Miniard Culpepper, she retrieved 
personal mail from Representative Collins' mailbox every few 
days.106
---------------------------------------------------------------------------
    \105\ Waters Int.
    \106\ Id.
---------------------------------------------------------------------------

3. Cleaning Representative Collins' home

    Valerie Nicholas testified that Representative Collins 
personally directed her to clean Representative Collins' home 
in the Washington area, and specified the particular 
housecleaning tasks that Ms. Nicholas should perform.107 
Representative Collins personally paid Ms. Nicholas $50.00 in 
cash to clean her home.108
---------------------------------------------------------------------------
    \107\ Nicholas Dep. at 15-17.
    \108\ Id. at 18-19.
---------------------------------------------------------------------------
    Ms. Nicholas testified that she regularly went to 
Representative Collins' home and ``would clean her bathrooms, 
her toilets, vacuum her floors, water her plants, wash her 
clothes, make up her bed, change her linen . . . [and] 
straighten her closets out.'' 109 Miniard Culpepper, a 
senior employee of the Washington office, testified that he 
sometimes brought cleaning supplies to Representative Collins' 
home and saw Ms. Nicholas in the midst of her cleaning 
duties.110
---------------------------------------------------------------------------
    \109\ Id. at 16.
    \110\ Culpepper Dep. at 22-23.
---------------------------------------------------------------------------
    Ms. Nicholas told the Subcommittee that Representative 
Collins did not specify a particular time when Ms. Nicholas 
should clean her home.111 She recalled, however, that she 
cleaned the home on weekdays when she otherwise would have been 
at the congressional office performing official duties, and 
that Representative Collins sometimes instructed her to leave 
the office to clean Representative Collins' home.112 In 
contrast, Mr. Culpepper told the Subcommittee that on the 
occasions he saw Ms. Nicholas at Representative Collins' home, 
it was usually in the evening.113
---------------------------------------------------------------------------
    \111\ Nicholas Dep. at 17.
    \112\ Id. at 18.
    \113\ Culpepper Dep. at 23.
---------------------------------------------------------------------------
    Ms. Nicholas indicated that it took several hours to clean 
Representative Collins' home, and testified that on some 
occasions she did not return to the office after concluding her 
cleaning duties.114 At no time did Representative Collins 
ask Ms. Nicholas to take leave for the time she was out of the 
office.115
---------------------------------------------------------------------------
    \114\ Nicholas Dep. at 18.
    \115\ Id.
---------------------------------------------------------------------------

4. Liaison with vendors

    Priscilla Waters told Committee staff that she served as a 
point of contact with vendors or service-providers concerning 
Representative Collins' personal affairs in Detroit, including 
an interior decorator working on Representative Collins' 
residence.116 Ms. Waters had received keys to 
Representative Collins' residence from either Representative 
Collins or Chief of Staff Miniard Culpepper, and she also went 
to Representative Collins' home to admit the interior decorator 
or persons making deliveries.117
---------------------------------------------------------------------------
    \116\ Waters Int.
    \117\ Id.
---------------------------------------------------------------------------
    Ms. Waters' account was corroborated by a typed document 
captioned ``Job Duties,'' which the Subcommittee obtained from 
Joyce Smith. One category of duties listed on that document is 
characterized as ``BRC Personal,'' and consists of ``liason 
[sic] with vendors for her personal accounts, anything related 
to her apartment (maintenance of her keys).''

5. Miscellaneous personal services

    The Subcommittee also obtained credible testimony that 
Representative Collins knowingly misused congressional staff in 
other ways. In one particularly vivid account, Valerie Nicholas 
testified that Meredith Cooper once directed her to curl 
Representative Collins' hair.118 Ms. Nicholas recalled 
that this conversation occurred in Representative Collins' 
private congressional office and in her presence.119 She 
also recalled that Ms. Cooper threatened to fire her if she 
``burned'' Representative Collins' hair.120
---------------------------------------------------------------------------
    \118\ Nicholas Dep. at 21-22.
    \119\ Id. at 21.
    \120\ Id.
---------------------------------------------------------------------------
    Ms. Nicholas also testified that, at Representative 
Collins' request, she made shopping trips on behalf of 
Representative Collins, such as visits to department stores, 
grocery stores, and furniture stores to pick up items for 
Representative Collins.121 Ms. Nicholas advised the 
Subcommittee that she made these shopping expeditions 
``[d]uring work hours.'' 122
---------------------------------------------------------------------------
    \121\ Id. at 23-24.
    \122\ Id. at 24.
---------------------------------------------------------------------------

         d. count iv (improper use of vouchered postage stamps)

    According to data compiled by the Clerk of the House, the 
office of Representative Collins purchased a total of 
approximately 7,900 first-class postage stamps with official 
funds during calendar years 1994 and 1995, at a total cost of 
approximately $2,380.00.123 According to the Clerk's 
records, and to copies of corresponding vouchers, 
Representative Collins' office almost always made these 
purchases in amounts of 500 stamps. Based on testimonial 
evidence obtained by the Subcommittee, Representative Collins 
signed most of the vouchers submitted for the purchase of 
postage stamps.124
---------------------------------------------------------------------------
    \123\ The data was published in quarterly Reports of the Clerk of 
the House of Representatives for expenditures occurring in 1994 and 
1995.
    \124\ Dorsey Dep. at 6-7.
---------------------------------------------------------------------------
    Valerie Nicholas testified that, at the direction of 
Meredith Cooper, she prepared vouchers each month to purchase 
500 stamps.125 As evidenced by the vouchers and by her own 
testimony, Ms. Nicholas often personally submitted these 
vouchers to the Office of Finance.126 She retained 250 
stamps from each purchase in the Washington congressional 
office, and mailed the remaining 250 stamps to the Detroit 
congressional office.127
---------------------------------------------------------------------------
    \125\ Nicholas Dep. at 12, 27; see Dorsey Dep. at 4-6.
    \126\ Nicholas Dep. at 53.
    \127\ Id. at 12, 27; see Smith Dep. at 8; Dorsey Dep. at 5.
---------------------------------------------------------------------------
    Congressional staff in the Washington office who prepared 
payments for Representative Collins' personal bills routinely 
used postage stamps purchased with official funds to mail those 
bills.128 Gloria Dorsey testified that Meredith Cooper 
directed her to use first-class postage stamps in the 
congressional office to pay Representative Collins' personal 
bills.129 Although Ms. Dorsey was uncertain about the 
origin of some of the stamps she used to pay the personal 
bills, she acknowledged that she personally purchased 500 
first-class postage stamps with vouchered funds on one 
occasion.130 In addition, former office manager Valerie 
Nicholas testified that, to her knowledge, there were no 
postage stamps in the congressional office other than the 
stamps purchased with official funds.131 Ms. Nicholas also 
testified that Representative Collins never gave her stamps to 
use to pay Representative Collins' personal bills, or gave her 
money to buy stamps for that purpose.132
---------------------------------------------------------------------------
    \128\ Nicholas Dep. at 11-12, 27; Dorsey Dep. at 13-14.
    \129\ Dorsey Dep. at 14.
    \130\ Id. at 4-5.
    \131\ Nicholas Dep. at 41.
    \132\ Id. at 55-56.
---------------------------------------------------------------------------
    In addition to using vouchered stamps to pay Representative 
Collins' personal bills, congressional staff used them for 
other non-official purposes. Valerie Nicholas and Joyce Smith, 
who worked in the Detroit congressional office, each testified 
that they used vouchered stamps for mailings related to 
campaign fund-raising events.133 Ms. Nicholas also advised 
the Subcommittee that, with the knowledge of Meredith Cooper, 
she used vouchered stamps to send a letter in 1994 soliciting 
contributions to the Collins Congressional Community 
Scholarship Committee in connection with the ``Michigan Bash,'' 
a party sponsored by Representative Collins in connection with 
an annual conference held by the Congressional Black Caucus 
Foundation.134
---------------------------------------------------------------------------
    \133\ Id. at 12, 27; Smith Dep. at 8.
    \134\ Nicholas Dep. at 40.
---------------------------------------------------------------------------

        E. Count V (Use of Official Funds for Personal Purposes)

    The Subcommittee obtained documentary evidence that the 
office of Representative Collins expended official funds to 
send items by overnight mail relating to Representative 
Collins' personal affairs. Vouchers obtained from the Office of 
Finance, supplemented by attached invoices, show that the 
congressional offices in Detroit and Washington used official 
funds to pay for Federal Express shipments of items on several 
occasions in 1994 and 1995 to Rose Reiter, a jewelry store in 
New York City. In addition, documents obtained from the Office 
of Finance indicate that Representative Collins' congressional 
office in Washington vouchered the cost of a Federal Express 
shipment in March 1994 to send something to Dwayne Porter in 
Detroit.
    The Subcommittee's determination that such expenses were 
personal in nature was corroborated by checks drawn on 
Representative Collins' personal account at the Credit Union 
that were payable to Rose Reiter and Dwayne Porter. Priscilla 
Waters, who formerly worked in the Detroit district office, 
told Committee staff that she sometimes admitted an interior 
decorator by the name of Dwayne Porter into Representative 
Collins' apartment.135
---------------------------------------------------------------------------
    \135\ Waters Int.
---------------------------------------------------------------------------
    Documents obtained by the Subcommittee indicate that the 
office of Representative Collins used Federal Express to remit 
payments or make deposits for personal items purchased by 
Representative Collins. For example, on approximately November 
2, 1994, Representative Collins issued a check to ``Rose Reiter 
Jewelry, Inc.'' in the amount of $2,000.00 for ``Deposit.'' A 
Federal Express invoice indicates that the Detroit 
congressional office sent an item by Federal Express to Rose 
Reiter on November 3, 1994. On approximately November 21, 1994, 
Representative Collins issued a personal check to Rose Reiter 
Jewelry in the amount of $1,000.00. A Federal Express invoice 
indicates that on the same day, Valerie Nicholas sent an item 
by Federal Express from the Washington congressional office to 
Rose Reiter. In both cases, the congressional office 
subsequently vouchered the cost of the Federal Express 
shipment.
    Similarly, Representative Collins issued a personal check 
in the amount of $300.00 to Dwayne Porter dated March 24, 1994, 
characterized on the check as ``Deposit.'' A Federal Express 
invoice indicates that on March 23, 1994, Representative 
Collins' congressional office in Washington sent something to 
Dwayne Porter in Detroit.

     F. Count VI (Commingling and Conversion of Campaign Resources)

1. Checks issued by campaign committee

    Bank documents show that, on or about June 30, 1994, 
Representative Collins' campaign committee issued a check in 
the amount of $3,911.00 payable to ``Barbara-Rose Collins,'' 
for the stated purpose of ``Reimbursement.'' That check 
corresponds to a July 15, 1994, filing with the Federal 
Election Commission (``FEC'') by Friends of Barbara-Rose 
Collins, which reported a disbursement on June 30, 1994, of 
$3,911.00 to Barbara-Rose Collins for ``Reimbursement for 
Precinct Delegate Picnic Catering.'' Representative Collins 
subsequently endorsed that check, and records obtained from the 
Credit Union show that the amount of $3,911.00 was deposited 
into her personal checking account at the Credit Union on July 
1, 1994.
     Irregularities in the campaign's financial bookkeeping 
contributed to the Subcommittee's concern about this particular 
campaign disbursement. The check stub corresponding to the 
check issued to Representative Collins shows a payment of 
$3,911.00 to district office employee George Stanton, not 
Representative Collins, for ``precinct delegate picnic 
catering.''
    Approximately one month later, a similar sequence of events 
occurred. On or about August 3, 1994, the Collins campaign 
issued a check in the amount of $2,900.00 payable to ``Cash'' 
for various ``Fundraisers'' and the ``NAACP.'' That check bears 
the endorsement of ``Barbara-Rose Collins,'' and records 
obtained from the Credit Union show that a check in the amount 
of $2,900.00 was deposited into Representative Collins' 
personal checking account at the Credit Union on August 5, 
1994. The corresponding check stub simply repeats the 
information contained on the check itself, and the pertinent 
FEC filing states only that the disbursement was made to the 
``NAACP'' (and no other recipients) for ``fundraisers.''

2. Funds derived from campaign resources

    The Subcommittee obtained credible evidence that 
Representative Collins improperly converted campaign funds to 
personal use with respect to two cashier's checks.
            a. Cashier's check for $8,500.00
    Bank records indicate that on or about November 8, 1994, 
the Collins campaign issued a check in the amount of $8,500.00 
to District Director Jerry Springs for ``election day 
expenses.'' The check was co-signed by Representative Collins 
and Joyce Smith and was endorsed by Jerry Springs. According to 
documentary evidence and other information obtained from 
Comerica Bank in Detroit, Mr. Springs cashed the check on the 
same day, November 8.
    Mr. Springs testified that he received a campaign check in 
the amount of $8,500.00 from campaign treasurer Cynthia 
Simpson, and that he cashed the check.136 According to Mr. 
Springs, he and Ms. Simpson used the cash proceeds to pay poll 
workers on the day of the general election, to provide 
transportation to the polls for constituents, and to purchase 
refreshments.137 Mr. Springs also stated his belief that 
he and Ms. Simpson disbursed the entirety of the $8,500.00 in 
cash, and that the disbursements were made on November 8, 1994, 
the day of the election.138
---------------------------------------------------------------------------
    \136\ Springs Dep. I at 59-60; Springs Dep. II at 4-5, 7.
    \137\ Springs Dep. I at 60-61; Springs Dep. II at 5, 31.
    \138\ Springs Dep. I at 61-62.
---------------------------------------------------------------------------
    Mr. Springs' testimony was inconsistent with other evidence 
obtained by the Subcommittee. Bank documents and sworn 
testimony by a knowledgeable bank official indicate that Mr. 
Springs purchased a cashier's check payable to Barbara-Rose 
Collins in the amount of $8,500.00 from Comerica Bank in 
Detroit on or about November 14, 1994, six days after the 
campaign check in the same amount was issued.139 The 
record also indicates that Mr. Springs used cash to purchase 
that cashier's check.140 On or about November 15, 1994--
one day after the cashier's check was purchased--the same 
cashier's check purchased by Mr. Springs was deposited into 
Representative Collins' personal checking account at the Credit 
Union, according to Credit Union records and testimony by an 
official associated with Comerica Bank in Detroit, which issued 
the cashier's check.141
---------------------------------------------------------------------------
    \139\ Affidavit of Nancy Asaro, Internal Services Dept., Comerica 
Inc. para.para. 8, 12, 14, 17, 22 (hereafter ``Asaro Aff.'').
    \140\ Id. para.para. 11-12, 14.
    \141\ Id. para.para. 15-21.
---------------------------------------------------------------------------
    Mr. Springs denied any knowledge that proceeds from the 
$8,500.00 campaign check issued to him inured to the personal 
benefit of Representative Collins.142 After being shown a 
copy of the cashier's check in question, he also denied any 
knowledge of any connection between the $8,500.00 cashier's 
check payable to Representative Collins and the $8,500.00 
campaign disbursement that he received.143
---------------------------------------------------------------------------
    \142\ Springs Dep. I at 146; Springs Dep. II at 29-30.
    \143\ Springs Dep. I at 64; Springs Dep. II at 8-9, 11.
---------------------------------------------------------------------------
    Bank records reflect a difference between the serial number 
of the cashier's check and the serial numbers of the 
corresponding check purchase form and another related bank 
document. Specifically, the serial number printed on the 
cashier's check ends in ``55-1,'' whereas the serial number 
handwritten on the check purchase form and the other bank 
document ends in ``56-0.'' 144 After reviewing the bank 
records in question, a Comerica Bank official informed the 
Subcommittee that she had determined the discrepancy was 
apparently due to human error in recording the serial number, 
and that she was convinced the check purchase form signed by 
Mr. Springs was used to purchase the cashier's check in the 
amount of $8,500.00.145
---------------------------------------------------------------------------
    \144\ Asaro Aff. para.para. 15-16.
    \145\ Id. para.para. 17-21.
---------------------------------------------------------------------------
    Additionally, Committee staff were advised by Joyce Smith, 
who was working on election day in 1994, that Mr. Springs was 
in possession of envelopes at the district office on election 
day that contained cash to pay poll workers.146 Ms. Smith 
told Committee staff that she distributed three or four 
envelopes to poll workers containing mostly amounts between 
$10.00 and $40.00, although she recalled that one or two 
envelopes contained $100.00.147
---------------------------------------------------------------------------
    \146\ Smith Int. I.
    \147\ Id.
---------------------------------------------------------------------------
    While Mr. Springs denied any connection between the 
campaign check and the cashier's check, and Ms. Smith 
corroborated Mr. Springs' testimony that cash payments were 
made to poll workers on election day in 1994, the Subcommittee 
nonetheless found reason to believe that Representative Collins 
converted $8,500.00 in campaign funds to her personal use. The 
Subcommittee based that finding on the identical amount of the 
two checks and the proximity in time between the campaign's 
disbursement of the check to Mr. Springs and the deposit of 
$8,500.00 into Representative Collins' personal account.
            b. Cashier's check for $2,400.00
    On or about March 6, 1995, the Collins campaign issued a 
check payable to ``Comerica'' in the amount of $2,400.00. That 
check was co-signed by Representative Collins and Joyce Smith, 
and was endorsed by Representative Collins. The check contains 
no annotation regarding its purpose, and the corresponding stub 
in the check register is blank. On the same day, Comerica Bank 
in Detroit issued a cashier's check payable to Barbara-Rose 
Collins in the amount of $2,400.00. On or about March 9, 1995, 
that cashier's check was deposited into Representative Collins' 
personal checking account at the Credit Union.
    Filings with the FEC by the Collins campaign dated 
September 25, 1995, and January 8, 1996, reported a 
disbursement of $2,400.00 on March 6, 1995, to ``E & H Printing 
Services'' in Detroit for printing services concerning a fund-
raising event. The campaign check register, however, does not 
reflect any campaign checks issued to E & H Printing on March 
6, 1995. Neither campaign financial records nor records 
concerning Representative Collins' personal checking account at 
the Credit Union indicate that Representative Collins paid 
$2,400.00 to E & H Printing on behalf of the campaign, or that 
she subsequently sought or obtained reimbursement for such an 
expenditure.

3. Purchase of personal appliances

    Documentary evidence and specific information from a 
credible source indicate that Representative Collins used 
campaign funds to purchase personal appliances in August 1995. 
A salesman at ABC Warehouse in Southfield, Michigan told 
Committee staff that Barbara-Rose Collins personally came to 
the store on or around August 7, 1995, and, by means of a 
check, purchased a freezer, electric clothes dryer, and 
oven.148 According to the salesman, Representative Collins 
asked that the oven and dryer be delivered to her ``cottage'' 
at Shay Lake, Michigan. Subsequently, she personally telephoned 
the salesman and gave him the street address of her home at 
Shay Lake.149
---------------------------------------------------------------------------
    \148\ Committee Counsel interviews with Darnell Castelow, ABC 
Warehouse, Inc., July 17, 1996, and Sept. 11, 1996.
    \149\ Committee Counsel interview with Darnell Castelow, July 17, 
1996.
---------------------------------------------------------------------------
    The salesman advised Committee staff that he subsequently 
learned that Representative Collins' home at Shay Lake was 
outside of the delivery range of ABC Warehouse, and that he so 
advised an employee of Representative Collins' congressional 
office in Detroit by telephone.150 That employee advised 
the salesman that someone from the congressional office would 
pick up the appliances and transport them to Representative 
Collins' home at Shay Lake.151 Accordingly, the salesman 
revised the store invoice to indicate that the customer would 
pick up the appliances from the store. Subsequently, two men 
came to the ABC Warehouse location in Southfield to confirm 
arrangements to pick up the merchandise purchased by 
Representative Collins.152 According to the salesman, one 
of the men signed a form and then departed with the other man 
in a truck, bound for the ABC Warehouse location in Pontiac 
where the merchandise was located.
---------------------------------------------------------------------------
    \150\ Id.
    \151\ Id.
    \152\ Committee Counsel interviews with Darnell Castelow, ABC 
Warehouse, Inc., July 17, 1996, and Sept. 11, 1996.
---------------------------------------------------------------------------
    Information obtained from the ABC Warehouse salesman was 
corroborated by campaign financial records and documents 
provided by ABC Warehouse. The Subcommittee obtained a campaign 
check dated August 7, 1995, in the amount of $913.72, payable 
to ABC Warehouse for ``Appliances.'' That check was signed only 
by Barbara-Rose Collins, and endorsed by ABC Appliance, Inc. 
Correspondingly, a February 1, 1996, FEC filing by the Friends 
of Barbara-Rose Collins reported that on August 7, 1995, the 
campaign disbursed $913.72 to ABC Warehouse in Southfield, 
Michigan for ``Freezer & Stove'' for ``appliances for Hdq.''
    The Subcommittee obtained a copy of the original invoice 
from ABC Warehouse dated August 7, 1995, indicating that the 
store received payment for a freezer, oven, and dryer by means 
of a check matching the serial number of the campaign check 
referenced above. The Subcommittee also obtained an amended ABC 
Warehouse invoice dated August 16, 1995, noting ``Customer 
Picking Up ABC Pontiac'' with respect to an oven and dryer, and 
bearing the signature ``Jerry Springs.''
    Documents concerning the refund of a delivery charge by ABC 
Warehouse also indicate that the purchases were at least 
partially personal in nature. On or about September 1, 1995, 
ABC Warehouse issued a refund check in the amount of $42.40 in 
recognition of the fact that the purchaser had made 
arrangements after initially paying a delivery fee to pick up 
the merchandise. The check was payable to ``Barbara Collins'' 
and was mailed to 8120 East Jefferson, Apartment 2F, Detroit, 
Michigan, her personal residence. Representative Collins 
subsequently endorsed the check, and documents provided by ABC 
Warehouse indicate that the check cleared the bank on September 
13, 1995.
    Mr. Springs testified that he (rather than Representative 
Collins) tendered payment for the merchandise.153 He 
denied that he picked up an oven, dryer, or any other appliance 
from ABC Warehouse on behalf of Representative Collins or her 
campaign organization.154 In that regard, he testified 
that he did not know who picked up the appliances from ABC 
Warehouse, and had no knowledge that they were subsequently 
transferred to Representative Collins' home at Shay 
Lake.155
---------------------------------------------------------------------------
    \153\ Springs Dep. II at 75-77.
    \154\ Id. at 73.
    \155\ Id. at 78.
---------------------------------------------------------------------------
    Approximately two months after the original purchase of the 
appliances from ABC Warehouse, Representative Collins took 
steps to reimburse the campaign for the oven and dryer, at 
least partially. On or about October 3, 1995, Representative 
Collins issued a personal check in the amount of $345.00 
payable to her campaign. According to ABC Warehouse, the total 
cost of the oven and dryer was $506.68, including a delivery 
charge of $42.40. Thus, the total cost without delivery was 
$464.28, approximately $119.00 more than the amount 
Representative Collins remitted to the campaign.

 G. Count VII (Expenditure of Campaign Funds Not Attributable to Bona 
                  Fide Campaign or Political Purposes)

    The Subcommittee found credible evidence of at least three 
instances where Representative Collins' campaign apparently 
expended funds for purposes not attributable to bona fide 
campaign or political purposes.

1. Loan to house employee

    Joyce Smith, who formerly worked in the district office in 
Detroit, testified that she personally asked Representative 
Collins for a loan to pay her home electric bill in the fall of 
1994.156 According to Ms. Smith, Representative Collins 
subsequently caused a campaign check to be made available to 
her in the amount of $1,000.00, payable to Detroit 
Edison.157 A copy of the check obtained by the 
Subcommittee states that the purpose of the payment was to 
``Reconnect 19713 Ridgemont St. Clair Shores.'' A campaign 
filing with the FEC dated January 8, 1996, lists a disbursement 
on October 26, 1994, to Detroit Edison in the amount of 
$1,000.00 to ``[r]econnect 19731 Ridgemont constituents.'' Ms. 
Smith testified that the address on the check corresponded to 
her personal residence, and that she was not a constituent of 
Representative Collins at the time of the disbursement.158
---------------------------------------------------------------------------
    \156\ Smith Dep. at 31.
    \157\ Id.
    \158\ Smith Dep. at 31-32.
---------------------------------------------------------------------------
    Ms. Smith testified that when Representative Collins made 
the $1,000.00 in campaign funds available to her, 
Representative Collins stressed the need for Ms. Smith to pay 
back the loan in full to the campaign committee.159 When 
Ms. Smith later approached Representative Collins to repay the 
loan, she asked Representative Collins if she should pay in 
cash or write a check to the campaign account.160 
According to Ms. Smith, Representative Collins instructed her 
to pay in cash, and she personally gave Representative Collins 
$500.00 in cash.161 Ms. Smith advised the Subcommittee 
that she has no knowledge that Representative Collins 
transferred that cash to the campaign treasury.162 
Subsequently, Ms. Smith personally gave Representative Collins 
an additional $500.00 in cash to pay off the balance of the 
loan.163
---------------------------------------------------------------------------
    \159\ Id. at 46.
    \160\ Id.
    \161\ Id. at 32, 46.
    \162\ Id. at 46-47.
    \163\ Id. at 32, 46.
---------------------------------------------------------------------------
    Ms. Smith testified that when she made the latter payment, 
Representative Collins said that she was planning to use those 
funds for spending money on an upcoming trip to Africa.164
---------------------------------------------------------------------------
    \164\ Id. at 47.
---------------------------------------------------------------------------

2. Expenditures relating to trip to Africa

    In early December 1994, Representative Collins traveled to 
Ghana with approximately twenty people, including several 
members of her congressional staff.165 The congressional 
staff who accompanied Representative Collins included Valerie 
Nicholas, Joyce Smith, Jerry Springs, George Stanton, and Korey 
Hall.166 Mr. Stanton's wife and two of Representative 
Collins' grandchildren also participated in the trip.167
---------------------------------------------------------------------------
    \165\ Springs Dep. II at 37.
    \166\ Smith Dep. at 27; Deposition of George Stanton, May 22, 1996, 
at 16 (hereafter ``Stanton Dep.''); Nicholas Dep. at 66; Springs Dep. I 
at 68-70.
    \167\ Stanton Dep. at 31; Smith Dep. at 29.
---------------------------------------------------------------------------
    Credible testimony and documentary evidence indicate that 
the trip to Africa did not serve a bona fide campaign or 
political purpose. Rather, the principal purpose and 
centerpiece event of the trip was the ``crowning'' of 
Representative Collins as the ``Queen Mother'' of a local 
community in Ghana on December 11, 1994.168 Jerry Springs 
testified that he understood the purpose of the trip was to 
``foster relationships with the country of Ghana,'' and that 
``many of the events'' during the trip ``involved'' Ghanaian 
dignitaries, such as a ``tribal chief,'' President Jerry 
Rawlings, and cabinet ministers.169 In that regard, a 
January 8, 1996, filing with the FEC by the Collins campaign 
reported $272.95 in campaign expenditures for ``refreshments'' 
for a ``meeting with African leaders and business people to 
discuss econ devel & trade with Detroit.'' In contrast, Valerie 
Nicholas testified that she and Representative Collins were 
together during much of the trip, and that she was unaware of 
any meetings with Ghanaian government officials.170 In any 
event, the record as a whole suggests that any meetings between 
Representative Collins and Ghanaian government officials were 
incidental to the trip, and that the trip was mostly personal 
in nature for Representative Collins and the members of her 
entourage.171 George Stanton, for example, testified that 
``[i]t was a personal trip for me. I went purely for the 
enjoyment of going to Africa.'' 172
---------------------------------------------------------------------------
    \168\ Nicholas Dep. at 70-71; Smith Dep. at 27; Springs Dep. I at 
70-71; Stanton Dep. at 16.
    \169\ Springs Dep. II at 36; see also Stanton Dep. at 17-18.
    \170\ Nicholas Dep. at 69.
    \171\ Nicholas Dep. at 68-69; Stanton Dep. at 17.
    \172\ Stanton Dep. at 18.
---------------------------------------------------------------------------
    The Subcommittee received credible documentary and 
testimonial evidence that the Collins campaign expended several 
thousand dollars in campaign funds in connection with the trip 
to Africa. For example, the Subcommittee obtained a campaign 
check issued on or about December 6, 1994, in the amount of 
$4,000.00, payable to Jerry Springs. The check itself contained 
only the annotation ``for 1840-30096-4.'' A campaign filing 
with the FEC dated January 8, 1996, represented that the 
purpose of the disbursement concerned a ``reception'' for the 
``Panafest event,'' and the corresponding entry in the campaign 
check register indicated that the payment related to the 
``Panafest Reception.'' According to testimony by congressional 
staff who participated in the trip, the term ``Panafest'' 
refers to a music and cultural festival in Ghana held 
approximately every two years, which occurred during 
Representative Collins' trip to Africa.173
---------------------------------------------------------------------------
    \173\ Nicholas Dep. at 71; Stanton Dep. at 16; Springs Dep. I at 
77.
---------------------------------------------------------------------------
    Mr. Springs endorsed the check and cashed it on December 7, 
1994, prior to his departure for Africa.174 According to 
Mr. Springs, he subsequently gave the entire $4,000.00 in cash 
proceeds to campaign treasurer Cynthia Simpson, Representative 
Collins' daughter.175 Mr. Springs testified that he did 
not recall who directed him to give the cash proceeds to Ms. 
Simpson.176
---------------------------------------------------------------------------
    \174\ Springs Dep. II at 34-35, 41.
    \175\ Id. at 35, 41.
    \176\ Id. at 42.
---------------------------------------------------------------------------
    Mr. Springs testified that he was unsure what Ms. Simpson 
did with the cash, and that he did not discuss with 
Representative Collins or anyone else how the funds would be 
used ``because it didn't concern me.'' 177 Based upon an 
itinerary prepared before the trip, however, Mr. Springs told 
the Subcommittee that it was his understanding that 
Representative Collins would use the funds to pay for 
receptions, luncheons, and other events during the 
trip.178 Mr. Springs testified that he did not receive any 
personal benefit from the cash proceeds of the check.179 
Joyce Smith, who co-signed the check with campaign treasurer 
Cynthia Simpson, recalled that Jerry Springs used a portion of 
the $4,000.00 in proceeds from the check to purchase gifts for 
Representative Collins to give to local dignitaries in Ghana, 
and that Representative Collins took the remainder of the funds 
with her on the trip.180
---------------------------------------------------------------------------
    \177\ Id. at 44, 46.
    \178\ Id. at 35, 43-44.
    \179\ Id. at 47, 50.
    \180\ Smith Dep. at 38.
---------------------------------------------------------------------------
    On or about January 20, 1995, the Collins campaign issued a 
check in the amount of $8,043.11, co-signed by Representative 
Collins and Joyce Smith and payable to American Express for the 
``Golden Tulip Hotel'' and other expenses. Other information 
obtained by the Subcommittee, including an FEC filing by the 
campaign dated January 8, 1996, indicates that the Golden Tulip 
Hotel is an establishment in Accra, Ghana.
     Finally, according to a separate FEC filing also dated 
January 8, 1996, the Collins campaign disbursed $1,673.00 to 
the ``African Art Market [in] Accra, Ghana'' on February 10, 
1995, for ``Art objects for offices'' in ``DC/District.'' 
Although the FEC filing represented that the disbursement was 
made in February 1995, the record suggests that the art 
purchases were made during Representative Collins' trip to 
Ghana in December 1994. The Subcommittee found no record of 
this disbursement in the campaign check register or in the 
campaign's monthly bank statements, suggesting that cash 
transactions may have occurred.

 3. Personal cleaning services

    The Subcommittee obtained credible evidence that 
Representative Collins used campaign funds to pay for her 
personal residence in Detroit to be cleaned. Joyce Smith 
advised Committee staff that she used petty cash located in the 
district congressional office to pay a woman by the first name 
of ``Mary'' to clean Representative Collins' residence.181 
According to Ms. Smith, that petty cash consisted of funds from 
the campaign's bank account.182 She advised Committee 
staff that she prepared and co-signed campaign checks payable 
to Jerry Springs for petty cash, and that Mr. Springs 
subsequently informed her that he had cashed such checks for 
petty cash and had placed the cash in his office desk.183 
Ms. Smith told Committee staff that she customarily went to 
Representative Collins' residence to pay the cleaning lady and 
lock up the residence after the cleaning lady had completed her 
work, and that she would advise Mr. Springs of what she had 
done.184 Before leaving the district office, she would ask 
Mr. Springs for cash to pay the cleaning lady, and he would 
provide her with cash from the petty cash fund.185 On some 
occasions, according to Ms. Smith, Mr. Springs personally went 
to Representative Collins' residence to pay the cleaning 
lady.186
---------------------------------------------------------------------------
    \181\ Smith Int. I; Committee Counsel interview with Joyce Smith, 
Dec. 9, 1996 (hereafter ``Smith Int. II'').
    \182\ Smith Int. II.
    \183\ Id.
    \184\ Smith Int. I; Smith Int. II.
    \185\ Smith Int. II.
    \186\ Id.
---------------------------------------------------------------------------
    Other evidence obtained by the Subcommittee confirms 
information provided by Joyce Smith. First, Jerry Springs 
acknowledged that the Collins campaign maintained a petty cash 
fund. He testified that most of the petty cash funds derived 
from the campaign account were kept in a secure location 
outside of the district congressional office, and that he 
brought only ``a couple [of] hundred dollars'' into the 
district office ``just in case something came up.'' 187 He 
also testified that if someone needed money from the petty cash 
fund, he or she came directly to Mr. Springs.188 Second, 
on or about February 9, 1995, the Collins campaign issued a 
check in the amount of $300.00 to ``Mary Pointer'' for 
``services rendered,'' co-signed by Representative Collins and 
Joyce Smith. An amended FEC filing dated January 8, 1996, 
characterized the purpose of the $300.00 disbursement as 
``maintenance campaign mtgs.'' Joyce Smith advised Committee 
staff, however, that congressional staff in the district office 
were responsible for cleaning the campaign facility.189
---------------------------------------------------------------------------
    \187\ Springs Dep. II at 52, 64-65.
    \188\ Id. at 62-63.
    \189\ Smith Int. II.
---------------------------------------------------------------------------

               H. Count VIII (Misuse of Scholarship Funds)

    In connection with allegations that Representative Collins 
misused resources of a scholarship fund bearing her name, the 
Subcommittee sought information about the purpose and 
activities of that fund. The Subcommittee learned that on or 
about December 17, 1992, an organization by the name of the 
``Collins Congressional-Community Scholarship Committee'' 
(``CCCSC'') was incorporated in the District of Columbia as a 
private, non-profit corporation. Article Three of the Articles 
of Incorporation indicated that the organization would seek 
tax-exempt status. It stated that the corporation ``is 
organized exclusively for charitable [purposes], including, for 
such purposes, the making of distribution to the organizations 
that qualify as exempt organizations under section 501(c)(3) of 
the Internal Revenue Code, or the corresponding section of any 
future federal tax code.'' Article Five stated that ``[n]o part 
of the net earnings of the corporation shall inure to the 
benefit of, or be distributable to its members, trustees, 
officers, or other private persons, except that the corporation 
shall be authorized and empowered to pay reasonable 
compensation for services rendered and to make payments and 
distributions in furtherance of the purposes set for in Article 
[Three] hereof.''
    The articles of incorporation identified Barbara-Rose 
Collins as the registered agent of the CCCSC, listing her 
address as 301 G Street, S.W., Apt. 620, Washington, D.C. 
20004. Representative Collins also was among the initial 
directors of the corporation, which included her daughter 
Cynthia Simpson and one other person.
    On approximately December 22, 1992, the CCCSC applied to 
the Internal Revenue Service (``IRS'') for tax-exempt status 
under Section 501(c)(3) of the Internal Revenue Code.
    The record indicates that Representative Collins signed the 
application as ``President'' of the CCCSC. In its application 
for exempt status, the CCCSC provided information regarding its 
proposed activities and operations. The organization indicated 
that it planned to distribute food baskets during the Christmas 
season in Detroit and Washington, D.C. The CCCSC stated that 
the food distribution would ``be initiated from the Detroit 
area by the Collins Congressional Community-Scholarship 
Committee to needy families provided by church and community 
organizations.'' In addition, the CCCSC indicated that it would 
award annual scholarships to persons in the Detroit area. It 
stated in the application that ``[s]cholarships will be 
distributed annually, prior to the college fall semester of the 
college school year, to benefit students who meet a certain 
criteria set by the Committee. The activity will be initiated 
from the Detroit area by the Collins Congressional Community-
Scholarship Committee.''
    The CCCSC stated in the application that its ``sources of 
financial support'' would be ``Public Support, Fundraisers, 
Donations, and Direct Solicitation.'' It also stated that 
``[t]he organization's fundraising program will consist of 
Direct solicitation.''
    The IRS advised Committee staff that it could not locate in 
its files any ``exemption letter'' concerning the CCCSC, 
indicating that it had never granted exempt status to the 
organization under any subpart of Section 501(c) of the 
Internal Revenue Code. The Subcommittee also learned that the 
Department of Consumer and Regulatory Affairs of the District 
of Columbia revoked the CCCSC corporate charter in September 
1994 for failing to file an annual report.
    Bank records indicate that persons working on behalf of the 
CCCSC successfully raised several thousand dollars in 
contributions to the CCCSC, mostly from corporations in the 
Detroit area. On September 30, 1994, for example, the CCCSC 
checking account balance at Riggs Bank totaled $38,257.61.
    Evidence obtained by the Subcommittee indicates that 
Representative Collins exercised direct personal control over 
CCCSC finances. Valerie Nicholas testified that Representative 
Collins maintained the CCCSC checkbook in her congressional 
office in Washington, D.C.190 Ms. Nicholas' testimony is 
corroborated by records obtained from Riggs Bank in Washington, 
D.C., which indicate that Representative Collins routinely 
signed checks drawn on the CCCSC account. In addition, records 
from Riggs Bank indicate that on October 27, 1995, 
Representative Collins personally closed the CCCSC bank 
account.
---------------------------------------------------------------------------
    \190\ Nicholas Dep. at 51.
---------------------------------------------------------------------------
    Bank records and testimonial evidence indicate that CCCSC 
funds were expended at least partly for purposes consistent 
with the original corporate charter and the application for 
exempt status. Canceled checks, for example, indicate that in 
December 1993 and December 1994, Representative Collins caused 
CCCSC checks to be issued for several hundred dollars in 
purchases relating to the ``Festival of Giving,'' such as the 
purchase of turkeys and fruit baskets.191 In addition, 
canceled checks indicate that the CCCSC awarded a total of at 
least $7,500.00 in scholarship funds to at least twelve persons 
in 1994 and 1995.192 District office employee George 
Stanton, who testified that he was extensively involved in 
CCCSC operations, told the Subcommittee that the purpose of the 
scholarship program was to ``try and help needy students in the 
district with their college costs.'' 193
---------------------------------------------------------------------------
    \191\ See Smith Dep. at 30-31; Stanton Dep. at 57, 68.
    \192\ See Payne Dep. at 31-32.
    \193\ Stanton Dep. at 56.
---------------------------------------------------------------------------
    At the same time, however, the record indicates that 
several thousand dollars in CCCSC funds were commingled with 
personal funds of Representative Collins and converted for 
personal use, as detailed below.
          On or about May 3, 1994, Representative Collins 
        signed a check drawn on the account of the CCCSC in the 
        amount of $9,800.00, payable to ``Cash'' for 
        Scholarships. The record indicates that Representative 
        Collins endorsed that check and, on or about May 4, 
        1994, caused it to be deposited into her personal 
        checking account at the Credit Union, raising the 
        account balance to approximately $34,630.00. 
        Approximately three weeks later, Representative Collins 
        wrote $500.00 in checks for scholarship awards to five 
        recipients, and in October 1994, she signed three 
        additional scholarship checks totaling $3,000.00. In 
        December 1994, Representative Collins signed another 
        scholarship check in the amount of $500.00. All of 
        those checks, however, were drawn on the CCCSC account, 
        not on Representative Collins' personal account. The 
        Subcommittee found no evidence that Representative 
        Collins caused any of the CCCSC funds transferred to 
        her personal account to be used for scholarship 
        purposes or for the Festival of Giving.
          On or about August 15, 1994, Representative Collins 
        signed a check drawn on the CCCSC account in the amount 
        of $1,200.00, payable to ``Kande Dean.'' The canceled 
        check and other bank records indicate that 
        Representative Collins personally endorsed the check 
        and cashed it on the same day, August 15. The 
        Subcommittee did not obtain any evidence indicating a 
        relationship between this check and either scholarships 
        or the Festival of Giving. The Subcommittee was unable 
        to obtain any information about ``Kande Dean,'' or 
        about the actual use of the funds transferred to 
        Representative Collins' personal account.
          On or about October 24, 1994, Representative Collins 
        signed a check drawn on the CCCSC account in the amount 
        of $3,812.11, payable to American Express for ``AC 
        3728-334-213-25001.'' According to other information 
        obtained by the Subcommittee, the account number listed 
        on the check corresponds to Representative Collins' 
        personal American Express account. The Subcommittee did 
        not receive any evidence indicating that Representative 
        Collins used her American Express credit card on behalf 
        of the CCCSC, or that she was obtaining legitimate 
        reimbursement for such expenditures.
          On or about November 9, 1994, Representative Collins 
        signed a check drawn on the CCCSC account in the amount 
        $8,000, payable to House employee Valerie Nicholas for 
        the stated purpose of the ``Festival of Giving.'' Ms. 
        Nicholas testified that one evening, Representative 
        Collins called Ms. Nicholas into her office, handed her 
        a check that already had been written, and instructed 
        Ms. Nicholas to cash it.194 Ms. Nicholas further 
        testified that Representative Collins directed her to 
        cash the check the next morning and to bring the cash 
        proceeds to her home in Virginia.195 According to 
        Ms. Nicholas, Representative Collins said nothing about 
        why the check was payable to Ms. Nicholas, why she had 
        not made the check payable to cash and cashed it 
        herself, or why she wanted Ms. Nicholas to bring the 
        cash proceeds to her at her home.196 Nor did 
        Representative Collins mention the Festival of Giving 
        in connection with the check.197 The next morning, 
        November 10, Ms. Nicholas cashed the check at Riggs 
        Bank in Washington, D.C. and brought the cash proceeds 
        to Representative Collins at her home in 
        Virginia.198 Ms. Nicholas had no personal 
        knowledge regarding the ultimate purpose of the cash 
        proceeds, but she testified that she was required to 
        help Representative Collins pack for a trip to India 
        when she delivered the money to her at her home in 
        Virginia.199 In addition, the Subcommittee 
        obtained documentary evidence that Representative 
        Collins traveled to India in November 1994, and that 
        she purchased merchandise in India valued at nearly 
        $2,000.00.
---------------------------------------------------------------------------
    \194\ Nicholas Dep. at 58.
    \195\ Id. at 59-61.
    \196\ Id. at 59-60.
    \197\ Id. at 62.
    \198\ Id. at 61.
    \199\ Id. at 61, 63.
---------------------------------------------------------------------------
          The record indicates that Representative Collins used 
        CCCSC funds to purchase home furnishings for her 
        personal residence. On or about May 7, 1995, 
        Representative Collins issued a check drawn on her 
        personal account at the Credit Union in the amount of 
        $5,000.00, payable to ``Classic Consignments.'' The 
        Subcommittee learned that ``The Classic Consignment 
        Company'' (hereafter ``Classic Consignment'') is a 
        business in Palm Desert, California specializing in the 
        sale of luxury second-hand home furnishings and other 
        merchandise.200 On or about May 9, 1995, 
        Representative Collins caused a check to be issued from 
        the CCCSC bank account in the amount of $8,900.00, 
        payable to ``Comerica/Cash'' for ``Classic 
        Consignments.'' She signed and endorsed the check. Bank 
        records indicate that on the same day, she caused the 
        check to be deposited into her personal account at 
        Comerica Bank in Detroit.
---------------------------------------------------------------------------
    \200\ Committee Counsel interview with Ed Mann, Classic 
Consignments, May 29, 1996 (hereafter ``Mann Int.'').
---------------------------------------------------------------------------
          A store invoice, supplemented by information from a 
        co-owner who assisted Representative Collins, indicates 
        that on May 13, 1995, Representative Collins purchased 
        $4,440.00 in merchandise from Classic Consignment, 
        including a Tiffany lamp valued at $1,000.00, a French 
        crystal lamp valued at $2,250, and two chandeliers. 
        According to the invoice and information from the store 
        official, Representative Collins directed that the 
        merchandise be shipped to her personal residence in 
        Detroit at a cost of approximately $1,048.00, bringing 
        the total amount of the purchase and shipping to 
        approximately $5,646.00.201 On or about July 1, 
        1995, Representative Collins issued a subsequent 
        personal check to Classic Consignment in the amount of 
        $645.81, designated ``Final Payment.''
---------------------------------------------------------------------------
    \201\ Mann Int.
---------------------------------------------------------------------------
          The record indicates that Representative Collins 
        subsequently reimbursed the CCCSC account for the 
        $8,900.00 in CCCSC funds previously deposited to her 
        personal account. On or about June 1, 1995, 
        Representative Collins caused a check to be issued on 
        her personal account at the Credit Union in the amount 
        of $8,900.00, payable to the CCCSC. That check contains 
        the handwritten annotation ``Reimburse Ch#1081,'' 
        corresponding to the serial number of the check drawn 
        on the CCCSC account on May 9, 1995. On or about 
        September 20, 1995--nearly three months later--
        Representative Collins' personal check in the amount of 
        $8,900.00 was deposited into the CCCSC account at Riggs 
        Bank in Washington, D.C.
    On or about October 3, 1995, a check drawn on the account 
of the CCCSC was issued in the amount of $3,888.90, payable to 
American Express for ``CBC Week Hotel Expenses & Misc. Hyatt 
Regency.'' Representative Collins signed the check.
          Testimony from members of Representative Collins' 
        congressional staff, supplemented by information from a 
        former official with the Congressional Black Caucus 
        Foundation (``Foundation''), indicates that the 
        annotation on the above check relates to an annual 
        conference in Washington, D.C. held by the 
        Foundation.202 According to Clinton Lawson, then 
        the Executive Director of the Foundation, the 
        conference consists of four days of policy workshops, 
        receptions, and fundraising events.203 Several 
        thousand African-Americans attend the conference, 
        including elected officials and educators.204
---------------------------------------------------------------------------
    \202\ Dorsey Dep. at 23; Nicholas Dep. at 37; Committee Counsel 
interview with Clinton Lawson, Executive Director, Congressional Black 
Caucus Foundation, Apr. 16, 1996 (hereafter ``Lawson Int.'').
    \203\ Lawson Int.
    \204\ Id.
---------------------------------------------------------------------------
          According to congressional staff, it was 
        Representative Collins' practice to sponsor an annual 
        party during the Foundation's annual conference, known 
        as the ``Michigan Bash.'' 205 Valerie Nicholas 
        testified that in 1994, Representative Collins used 
        contributions to the CCCSC to fly in family members to 
        Washington, D.C. and pay for their lodging at the Grand 
        Hyatt Hotel.206 The Subcommittee obtained no 
        evidence indicating that the use of CCCSC funds to pay 
        for hotel accommodations and other related expenses 
        furthered the purposes of the CCCSC.
---------------------------------------------------------------------------
    \205\ Nicholas Dep. at 37; Dorsey Dep. at 23; German Int.
    \206\ Nicholas Dep. at 46.
---------------------------------------------------------------------------
    Bank documents indicate that on October 27, 1995, 
Representative Collins closed the CCCSC account at Riggs Bank. 
To close the account, Representative Collins caused a check 
drawn on the account to be issued in the amount of $12,367.91 
(the balance in the account), made payable to ``Riggs/Barbara-
Rose Collins.'' Representative Collins signed and endorsed that 
check. Bank documents indicate that on the same day, 
Representative Collins cashed that check and used the cash 
proceeds to purchase a cashier's check in the amount of 
$6,853.91, payable to ``Barbara R. Collins.'' Bank documents 
also indicate that Representative Collins endorsed that check 
and transferred it to another unidentified person, who also 
endorsed the check. Riggs Bank apparently did not pay the check 
until December 4, 1995. The Subcommittee was unable to 
determine the ultimate disposition of the check proceeds.
          Representative Collins also used cash--apparently 
        from the proceeds from the cashier's check in the 
        amount of $12,367.91--to purchase two additional 
        cashier's checks on October 27, 1995. One of those 
        checks was made payable to ``Operation Get Down'' in 
        the amount of $4,000.00. According to Ceceilia Walker, 
        the deputy district director, ``Operation Get Down'' is 
        an organization in Detroit that provides food, 
        clothing, and mentoring to underprivileged and 
        disadvantaged persons.207
---------------------------------------------------------------------------
    \207\ Deposition of Ceceilia Walker, May 22, 1996, at 55-66 
(hereafter ``Walker Dep.'').
---------------------------------------------------------------------------
          Representative Collins endorsed the $4,000.00 check. 
        Beneath her endorsement is the handwritten annotation, 
        ``Not Used For Purpose Intended.'' Bank records 
        indicate that Riggs Bank did not pay that check until 
        November 15, 1995. The Subcommittee was unable to 
        obtain any information concerning the disposition of 
        the proceeds from that check.
          The other cashier's check purchased by Representative 
        Collins on October 27, 1995, was in the amount of 
        $1,500.00, payable to Lillian German, a staffer in 
        Representative Collins' Washington congressional 
        office. Ms. German advised Committee staff that she 
        received a ``certified'' check from Riggs Bank in the 
        amount of $1,500.00 from Royal Hart, the Deputy Chief 
        of Staff in the Washington office.208 According to 
        Ms. German, she cashed the check at the Credit 
        Union.209 She then purchased a money order with 
        some of the cash proceeds and used that money order to 
        buy books on women's health that Representative Collins 
        had asked her to obtain on behalf of ``Men and Women of 
        Destiny,'' a group of supporters in Detroit.210 
        Ms. German told Committee staff that she returned the 
        remainder of the cash proceeds from the cashier's check 
        to Representative Collins, placing them on her office 
        chair in an envelope.211 The Subcommittee found no 
        evidence that the expenditure of CCCSC funds for the 
        purchase of books for ``Men and Women of Destiny'' 
        constituted a use of CCCSC funds for Representative 
        Collins' personal use. The Subcommittee was unable to 
        determine the amount or disposition of the funds 
        returned to Representative Collins by Ms. German.
---------------------------------------------------------------------------
    \208\ German Int.
    \209\ Id.
    \210\ Id.
    \211\ Id.
---------------------------------------------------------------------------

            i. count ix (maintenance of unofficial account)

    In addition to obtaining evidence regarding the 
disbursement of campaign funds for petty cash expenses 
represented as legitimate campaign expenditures, as discussed 
above, the Subcommittee learned that campaign funds also were 
used to capitalize a petty cash fund used at least partly for 
expenses relating to Representative Collins' district 
congressional office. Ceceilia Walker, then the deputy district 
director, testified that the need for petty cash relating to 
district office activities first arose in the fall of 1995, 
when she learned that she could not use official funds to 
purchase frames for certificates awarded to constituents in 
Detroit for outstanding community service or personal 
achievement.212 At that time, Ms. Walker purchased frames 
totaling $13.78 with her personal funds and was reimbursed, 
consistent with House rules, by the Collins campaign.213 
According to Ms. Walker, the fact that funds were not more 
readily available to purchase the frames led to a discussion 
within the congressional office about the need for a source of 
funds for petty cash expenses relating to the office.214
---------------------------------------------------------------------------
    \212\ Walker Dep. at 10-13, 28, 42.
    \213\ Id. at 11.
    \214\ Id. at 28.
---------------------------------------------------------------------------
    Subsequently, in early October 1995, District Director 
Jerry Springs transmitted to Ms. Walker a sealed envelope from 
Representative Collins containing a check in the amount of 
$500.00, along with other documents from Representative 
Collins.215 That check, dated October 6, 1995, was drawn 
on the campaign's account and was payable to Ms. 
Walker.216 A handwritten annotation on the check indicated 
that the check was to be used for ``petty cash,'' and Jerry 
Springs subsequently told Ms. Walker that she should use the 
proceeds from the check for petty cash purposes.217
---------------------------------------------------------------------------
    \215\ Id. at 23-26.
    \216\ Id. at 26.
    \217\ Id. at 26-27.
---------------------------------------------------------------------------
    Ms. Walker testified that she cashed the check and kept 
some of the cash proceeds in a file cabinet at the district 
congressional office.218 Although Ms. Walker did not 
recall whether she received specific instructions regarding how 
to use the funds--other than to use them for petty cash--she 
testified that she was ``under the impression . . . from Mr. 
Springs and . . . the Congresswoman that we could purchase . . 
. certain items . . . for office use or for meetings or 
whatever, provided that we kept very accurate records and 
receipts, and I did that.'' 219 While Ms. Walker 
understood that the funds were to be used for expenses related 
to the congressional office, she testified that Representative 
Collins did not tell her specifically that the funds should be 
used for the district office.220 Rather, she recalled that 
Representative Collins ``just said petty cash.'' 221 Ms. 
Walker added that at no time did either Representative Collins 
or Jerry Springs instruct her not to use the petty cash fund 
for expenses related to the district office.222
---------------------------------------------------------------------------
    \218\ Id. at 29.
    \219\ Id. at 21, 28-29, 32.
    \220\ Id. at 43.
    \221\ Id.
    \222\ Id. at 49-50.
---------------------------------------------------------------------------
    Ms. Walker maintained an organized record-keeping system 
regarding the petty cash fund. District office staff submitted 
receipts to her for reimbursement from the petty cash fund, 
which she kept in the office.223 She also devised a ledger 
to log petty cash expenditures and reflect the balance of the 
petty cash fund.224 The initial entry on that ledger 
reflects a balance of $500.00, corresponding to the campaign 
check that she received from Jerry Springs.225
---------------------------------------------------------------------------
    \223\ Id. at 30-31.
    \224\ Id. at 31-33.
    \225\ Id. at 33-34.
---------------------------------------------------------------------------
    Neither the ledger maintained by Ms. Walker nor attached 
receipts provide a basis for determining the precise purpose of 
petty cash expenses reimbursed from the fund capitalized by the 
$500.00 campaign check. In reviewing the ledger and receipts at 
her deposition, Ms. Walker identified several expenses that, in 
her judgment, were unrelated to the district office, such as 
the repair of a fax machine for $185.00.226 She based her 
conclusion regarding the fax machine on the fact that the 
congressional office had a pre-existing maintenance contract 
for repairs to the office fax machine.227 Ms. Walker 
recalled that the voucher for the repair of the fax machine had 
been submitted to her by Mr. Springs, who informed Ms. Walker 
that Representative Collins had approved the reimbursement from 
petty cash.228
---------------------------------------------------------------------------
    \226\ Id. at 34-35.
    \227\ Id.
    \228\ Id. at 35-36.
---------------------------------------------------------------------------
    Before the $500.00 in petty cash funds was depleted, Ms. 
Walker received another check drawn on the campaign's account 
in the amount of $1,000.00 to replenish the account.229 
Ms. Walker received the check directly from Representative 
Collins during a meeting with Representative Collins at her 
personal residence in Detroit.230 She recalled that during 
the meeting, Representative Collins inquired about the status 
of the petty cash fund, and that she advised Representative 
Collins that the fund was almost depleted.231 According to 
Ms. Walker, Representative Collins subsequently gave her a 
$1,000.00 check drawn on the campaign account and told her to 
use it for petty cash.232 Ms. Walker could not recall 
whether she discussed with Representative Collins whether funds 
from the $1,000.00 check could be used to purchase items for 
the district office, but she interpreted Representative 
Collins' reference to ``petty cash'' to mean that the funds 
would be used for the district office.233
---------------------------------------------------------------------------
    \229\ Id. at 40-43.
    \230\ Id. at 40.
    \231\ Id.
    \232\ Id. at 41-42.
    \233\ Id. at 42-43.
---------------------------------------------------------------------------
    Documents obtained by the Subcommittee corroborated Ms. 
Walker's testimony. The Subcommittee obtained a canceled 
campaign check in the amount of $1,000.00, dated October 30, 
1995, and payable to Ceceilia Walker for ``Petty Cash fund.'' 
The corresponding check stub represented that the payment was 
for ``Petty Cash (misc. ofc. supplies).'' The petty cash ledger 
created by Ms. Walker for the period of October 19-November 29, 
1995, reflects an infusion of $1,000.00.234 In addition, a 
FEC filing by the Collins campaign dated February 1, 1996, 
reported a disbursement on October 30, 1995, to Ceceilia Walker 
in the amount of $1,000.00 for ``supplies.''
---------------------------------------------------------------------------
    \234\ Id. at 46.
---------------------------------------------------------------------------
    Ms. Walker deposited the check into her personal bank 
account, later withdrawing cash for the petty cash 
fund.235 Receipts and reimbursement vouchers associated 
with the subsequent use of the petty cash fund indicate that 
the fund was used at least partly for purposes related to the 
district office. Ms. Walker purchased several items (other than 
frames) related to certificate awards, such as cleaning 
supplies and ribbons totaling approximately $51.00.236 The 
record also includes receipts and vouchers for purchases of 
labels totaling approximately $92.00, at least some of which 
were obtained for the district office's ``legislative update 
mailing.'' 237
---------------------------------------------------------------------------
    \235\ Id. at 43-44.
    \236\ Id. at 46-47.
    \237\ Id. at 47-48.
---------------------------------------------------------------------------
    The Subcommittee also obtained evidence that campaign funds 
were used to purchase furnishings for the congressional offices 
in Detroit and Washington. Ms. Walker testified that, at 
Representative Collins' express request, she used the petty 
cash fund to purchase a pedestal to display art in the district 
office, at a cost of approximately $108.00.238 A February 
1, 1996, campaign filing with the FEC reported that the 
campaign disbursed $500.00 to ``Open Market'' in New Delhi, 
India on January 2, 1995, for a ``Floor Rug'' for the ``D.C. 
Office.'' According to a FEC filing by the Collins campaign 
date February 1, 1996, the campaign made separate disbursements 
of $200.00 and $70.00 to the ``Senegal Art Market'' in Senegal 
on May 16, 1995, for ``art carvings'' for the ``D.C. Office'' 
and ``Det. office,'' respectively. The Subcommittee could not 
confirm whether African art purchased with campaign funds 
actually was placed in either congressional office, although 
Gloria Dorsey testified that African art was on display in 
Representative Collins' personal office in Washington.239
---------------------------------------------------------------------------
    \238\ Id. at 50-51.
    \239\ Dorsey Dep. at 33-34.
---------------------------------------------------------------------------

   J. Count X (Employee Raises Not Commensurate With Official Duties)

    The Subcommittee obtained credible testimonial and 
documentary evidence that Representative Collins awarded raises 
to members of her congressional staff to enable them to 
participate in a December 1994 trip to Africa that apparently 
was personal in nature.240 Valerie Nicholas testified that 
Representative Collins personally asked her if she wanted to 
accompany her to Africa.241 According to Ms. Nicholas, she 
replied that ``I would love to go but I don't have money to 
go.'' 242 Representative Collins told Ms. Nicholas that 
she would award a bonus to Ms. Nicholas to enable her to go on 
the trip.243 According to Ms. Nicholas, Representative 
Collins said that she could not pay for all of Ms. Nicholas's 
travel expenses, but would pay for half of them.244 At no 
time did Representative Collins indicate to Ms. Nicholas that 
her bonus was in recognition for the performance of her 
official duties.245
---------------------------------------------------------------------------
    \240\ See discussion above.
    \241\ Nicholas Dep. at 65.
    \242\ Id. at 66.
    \243\ Id.
    \244\ Id.
    \245\ Id. at 67.
---------------------------------------------------------------------------
    The linkage between Ms. Nicholas's salary increase and the 
trip to Africa was further evidenced by a subsequent exchange 
she had with Representative Collins regarding the possibility 
that she might not be able to participate in the trip. When Ms. 
Nicholas asked Representative Collins what would happen if she 
did not participate in the trip, Representative Collins replied 
that, in that event, ``I want my money back.'' 246
---------------------------------------------------------------------------
    \246\ Id.
---------------------------------------------------------------------------
    Joyce Smith testified that she also had a personal 
conversation with Representative Collins about traveling to 
Africa.247 In addition to recalling that Representative 
Collins specifically linked a salary increase to the Africa 
trip, Ms. Smith recalled that Representative Collins advised 
her to change her withholding exemptions so that she could 
receive the maximum amount of money.248 According to Ms. 
Smith, Representative Collins did not tell her that the salary 
increase was in any way related to the performance of her 
official duties.
---------------------------------------------------------------------------
    \247\ Smith Dep. at 27-29.
    \248\ Id. at 29.
---------------------------------------------------------------------------
    When Representative Collins invited George Stanton to 
participate in the trip to Africa, he inquired if he would be 
receiving his usual year-end bonus.249 According to Mr. 
Stanton, he advised Representative Collins that his ability to 
go on the trip would depend on the amount of his bonus.250 
Mr. Stanton testified that Representative Collins indicated to 
him that it was ``more likely than not'' that he would receive 
a bonus.251 Mr. Stanton also had a follow-up conversation 
with Representative Collins to confirm that he would be 
receiving a bonus, as he was interested in bringing his wife 
with him on the trip.252 According to Mr. Stanton, he and 
Representative Collins shared a mutual understanding that his 
travel to Africa with his wife was contingent on the size of 
his bonus.253 Mr. Stanton told the Subcommittee, however, 
that Representative Collins did not mention the Africa trip 
when she confirmed that he would receive a bonus, and that she 
said she was giving him a bonus because of his job performance 
during the year.254
---------------------------------------------------------------------------
    \249\ Stanton Dep. at 22.
    \250\ Id.
    \251\ Id. at 23.
    \252\ Id. at 23-24.
    \253\ Id. at 25-26.
    \254\ Id. at 25.
---------------------------------------------------------------------------
    Jerry Springs provided an account similar to that of Mr. 
Stanton. He testified that Representative Collins at no time 
told him that she would increase his salary to enable him to 
finance his travel to Africa.255 According to Mr. Springs, 
Representative Collins recommended him for a bonus in late 1994 
because of his performance.256 Mr. Springs also testified 
that he did not discuss with other staff participating in the 
trip whether they received salary increases to enable them to 
pay for their travel, and that he had no knowledge of such 
increases.257
---------------------------------------------------------------------------
    \255\ Springs Dep. I at 76-77.
    \256\ Id. at 76.
    \257\ Id. at 80-81.
---------------------------------------------------------------------------
    Information compiled by the Clerk of the House confirms not 
only that the congressional staff who traveled to Africa with 
Representative Collins received year-end salary increases, but 
that they were the only members of her staff to receive such 
increases.
          Valerie Nicholas' annual salary increased from 
        $30,000 in September 1994 to $85,000 in October 1994. 
        Her annual salary was reduced to $35,000 in November 
        1994.
          Joyce Smith's annual salary increased from $35,000 in 
        October 1994 to $80,000 in November 1994. Her annual 
        salary then diminished to $30,000.
          Jerry Springs' annual salary changed from $36,000 in 
        August 1994 to $80,000 in September 1994, remained at 
        $80,000 in October 1994, then declined to $45,000.
          George Stanton, who was earning an annual salary of 
        $35,000 in August 1994, received an increase to $93,000 
        in September 1994. His salary remained at $93,000 in 
        October 1994 before reverting to $35,000 in November 
        1994.
          Korey Hall, who earned an annual salary of $26,000 in 
        August 1994, received an increase to $70,000 in 
        September 1994. His annual salary was reduced to 
        $30,000 in October 1994.
    The staff members benefiting from these temporary salary 
increases received real increases in income apparently 
substantial enough to finance their travel to Africa. Based on 
the last quarter of 1994 prior to any salary increase, the 
staff received the following total increases in income (rounded 
to the nearest dollar): George Stanton, $10,667; Valerie 
Nicholas, $5,417; Korey Hall, $6,000; Joyce Smith, $4,167; and 
Jerry Springs, $8,833.
    The record indicates that Representative Collins personally 
was involved in implementing the salary increases. Valerie 
Nicholas testified that Representative Collins personally 
directed her to prepare forms for submission to the House 
Office of Finance to effect the salary increases.258 Ms. 
Nicholas testified that she prepared the forms, and that 
Representative Collins signed them.259
---------------------------------------------------------------------------
    \258\ Id. at 66-67.
    \259\ Id.
---------------------------------------------------------------------------

                  K. Count XI (Improper Solicitation)

    On or about August 3, 1994, the congressional office of 
Representative Collins sent letters to private corporations 
soliciting financial contributions to sponsor an event known as 
the ``Michigan Bash,'' scheduled to be held in Washington, D.C. 
on September 16, 1994.260 Based on the text of the letter 
and testimony from congressional staff familiar with the event, 
the Subcommittee determined that the ``Michigan Bash'' was a 
``gala reception'' organized by Representative Collins during 
the ``Legislative Weekend'' sponsored by the Congressional 
Black Caucus Foundation in Washington, D.C. from September 13-
17, 1994.261
---------------------------------------------------------------------------
    \260\ Nicholas Dep. at 34-35.
    \261\ Nicholas Dep. at 37; German Int.; Dorsey Dep. at 23.
---------------------------------------------------------------------------
    The letter sought donations of ``at least $2,000, to assist 
in defraying the cost of this year's reception. . . .'' It 
directed recipients to make checks payable to the ``Collins 
Congressional Community Service Committee'' and to mail their 
donations to Representative Collins' congressional office in 
the Longworth House Office Building. According to Valerie 
Nicholas, Meredith Cooper drafted the letter, and Ms. Nicholas 
typed it.262 Representative Collins signed the 
letter.263
---------------------------------------------------------------------------
    \262\ Nicholas Dep. at 34.
    \263\ Id. at 38.
---------------------------------------------------------------------------
    The Subcommittee found reason to believe that the 
solicitation letter violated the rules governing solicitations 
by Members of the House. First, in light of the fact that the 
IRS did not grant exempt status to the CCCSC, the CCCSC 
apparently was not an organization qualified under Section 
170(c) of the Internal Revenue Code. Second, Committee records 
contain no indication that Representative Collins or any member 
of her staff obtained the Committee's prior approval to 
disseminate the solicitation letter. Third, the stationery used 
for the solicitation improperly featured the words ``Congress 
of the United States'' and ``House of Representatives, 
Washington, D.C. 20515,'' and it included in the top left 
margin the words ``Barbara-Rose Collins'' over ``Fifteenth 
District'' and ``Michigan.''
    The Subcommittee also determined that the letter apparently 
misrepresented the disposition of donations for the Michigan 
Bash. The letter represented that checks would be ``deposited 
directly into an account set up specifically for the 
reception.'' The Subcommittee found no evidence that a separate 
fund was established for the deposit of contribution checks. 
Rather, bank records and testimony by Valerie Nicholas indicate 
that contribution checks were deposited into the existing 
account of the CCCSC at Riggs Bank in Washington, D.C., an 
account over which Representative Collins exercised personal 
control.264
---------------------------------------------------------------------------
    \264\ Id. at 40.
---------------------------------------------------------------------------
    Bank records concerning deposits to the CCCSC account 
indicate that the office of Representative Collins received 
approximately $30,000.00 in donations for the Michigan Bash. 
The Subcommittee was unable to determine the actual cost of the 
event.
                               APPENDIX A

                              ----------                              

                          House of Representatives,
                Committee on Standards of Official Conduct,
                                  Washington, DC, October 24, 1995.
Hon. Barbara-Rose Collins,
House of Representatives, Cannon House Office Building,
Washington, DC.
    Dear Representative Collins: The Committee on Standards of 
Official Conduct has recently become aware of allegations 
regarding certain activities in your district and Washington 
congressional offices. These allegations concern the use of 
congressional resources (including office space, materials, 
personnel, and equipment) for the performance of campaign and 
personal activities. Additional allegations concern your use of 
campaign and scholarship funds. The allegations are described 
below.
    The Committee is presently in the process of determining 
whether the allegations merit further inquiry. We invite you to 
provide a written response to any or all of the allegations, 
and to provide any additional information that you believe 
would be of assistance to the Committee. If you choose to 
provide a response, we request that you do so within 30 days of 
the date of this letter.
Allegations
    The allegations were reported in: The Hill newspaper on 
August 9, August 16, September 6, and September 13, 1995; and 
the Detroit News & Free Press on August 19, and September 10, 
1995.
    The allegations consist of reports that:
    a. former staffers, working in your district and Washington 
officers in 1994, claimed that they were routinely instructed 
to perform campaign related tasks. In the performance of the 
campaign activities, office equipment including Xerox machines 
and computers were used.
    b. a former staffer claimed that during regular office 
hours she served as the contact person for fund-raisers, 
collected and deposited checks and logged them into office 
computers before sending copies to you, and that in the period 
of time near to a fund-raiser, 80% of her time could be spend 
on campaign or fund-raising activities while on the 
congressional payroll.
    c. staffers in your district office were given a list 
detailing personal and campaign related tasks they were 
instructed to perform while on congressional time. The tasks 
that the staffers were instructed to perform included 
depositing checks for campaign contributions, preparation of 
donor lists, paying campaign bills, handling your personal 
accounts, and maintenance of your apartment keys.
    d. a memorandum written on your congressional letterhead 
chastised a staffer for mishandling your campaign account by 
among other things, improperly documenting and mailing of a 
$2500 campaign contribution as part of his or her official 
duties.
    e. former staffers claimed that you misused official 
resources by among other things, routinely purchasing stamps 
with official funds and using the stamps for personal and 
campaign mailings.
    f. a staffer, among other campaign related chores, was 
required to pay campaign bills on official time.
    g. in 1994, you used monies from your campaign and 
community scholarship fund for personal purposes.
    h. a $1000 payment in campaign funds was listed on your 
federal Election Commission filing as having been paid to 
Detroit Edison, but Detroit Edison claims never to have 
received the payment.
    If you would like to discuss any of these allegations, 
please contact either of us, or the Committee's Chief Counsel, 
Ted Van Der Meid.
            Sincerely,
                                   Nancy L. Johnson,
                                           Chairman.
                                   Jim McDermott,
                                           Ranking Democratic Member.
                               APPENDIX B

                              ----------                              

                                  House of Representatives,
                                 Washington, DC, November 22, 1995.
Committee on Standards of Official Conduct,
House of Representatives, U.S. Capitol--Suite HT-2,
Washington, DC.
    Dear Committee: I write in response to your letter dated 
October 24, 1995, which invited me to respond to any or all of 
certain press allegations against me that have appeared in the 
press. Please consider the following.
    I do not instruct my staff to perform campaign activities 
by making use of official resources of any kind, equipment, 
stamps, time, or anything else. Moreover, I do not and would 
not condone such conduct by them. Anyone on my staff who 
chooses to participate in matters related to my campaign is to 
do so on his or her own time.
    An allegation noted in your letter mentioned a ``list 
detailing * * * personal and campaign related tasks.'' Neither 
I, nor anyone acting with my knowledge or under my authority, 
created any such list. I first heard of it from the press. The 
same is true of the memorandum chastising a staffer, described 
as having been written on my congressional letterhead.
    The allegation that in 1994 I used monies from my campaign 
and community scholarship fund for ``personal purposes'' is 
simply not true. And, contrary to the allegation regarding 
Detroit Edison, on October 26, 1994, I wrote $1,000 dollar 
check to Detroit Edison. I have a copy of the returned check.
    One thing the press has correctly reported is that in 1994, 
my office experienced significant turnover in personnel. 
Unfortunately, some of those who were let go bear me and my 
office ill will. I am sure this will be considered in 
evaluating the allegations and their sources.
    Please contact me if I can provide anything further to 
assist you in this process.
            Sincerely,
                                              Barbara-Rose Collins.
                                ------                                

                                  House of Representatives,
                                  Washington, DC, December 1, 1995.
Committee on Standards of Official Conduct,
U.S. House of Representatives, U.S. Capitol--Suite HT-2,
Washington, DC.
    Dear Committee: I write concerning the allegation in 
paragraph (d) of your letter of October 24, 1995 about a 
memorandum chastising a staffer for mishandling a campaign 
account. Since my letter to the Committee of November 22, 1995, 
my District Director has informed me for the first time that in 
fact he did issue a memorandum containing such a criticism, 
among other criticisms properly directed at congressional staff 
work, to a staffer in the district office in January 1995.
    The memorandum was issued without my knowledge or 
authority. I am informed that the District Director recognized 
he had made an error by including such a criticism in the 
memorandum. Nonetheless, I am taking appropriate action with my 
District Director to insure no repetition of such an 
occurrence.
    Please contact me if I can provide anything further to 
assist in your review.
            Sincerely,
                                              Barbara-Rose Collins.
                               APPENDIX C

                          House of Representatives,
                Committee on Standards of Official Conduct,
                                  Washington, DC, December 5, 1995.

                   resolution of preliminary inquiry

    Whereas information has been provided to the Committee on 
Standards of Official Conduct alleging the misuse of official, 
campaign, and scholarship fund resources by Representative 
Barbara-Rose Collins; and
    Whereas this information raises questions as to whether 
Representative Collins may have committed violations of the 
Code of Official Conduct, or a law, rule, regulation, or other 
standard of conduct applicable to the conduct of a Member of 
Congress in the performance of her duties or in the discharge 
of her responsibilities;
    Now, therefore, be it resolved, That the Committee 
determines, pursuant to Committee Rule 16(a), that these 
allegations merit further inquiry; and
    It is further resolved, That this Committee conduct a 
Preliminary Inquiry pursuant to Committee Rule 17 to determine 
whether there is reason to believe that Representative Collins 
violated the Code of Official Conduct, or a law, rule, 
regulation, or other standard of conduct applicable to the 
conduct of a Member of Congress in the performance of her 
duties or in the discharge of her responsibilities; and
    It is further resolved, That Representative Collins be 
immediately notified of this action and informed of her rights 
pursuant to the Rules of this Committee.
                               APPENDIX D

                          House of Representatives,
                Committee on Standards of Official Conduct,
                                 Washington, DC, February 29, 1996.
Hon. Saul A. Green,
United States Attorney for the Eastern District of Michigan, Detroit, 
        MI.
    Dear Mr. Green: This is to advise you of investigative 
actions taken by a committee of the United States Congress that 
may relate to an ongoing criminal investigation by the United 
States Attorney's Office for the Eastern District of Michigan.
    On December 5, 1995, the Committee on Standards of Official 
Conduct (``Committee'') of the U.S. House of Representatives 
voted to commence a Preliminary Inquiry regarding whether 
Representative Barbara-Rose Collins misused official, campaign, 
and scholarship fund resources. At that time, the Committee 
voted to conduct a Preliminary Inquiry ``to determine whether 
there is reason to believe that Representative Collins violated 
the Code of Official Conduct, or a law, rule, regulation, or 
other standard of conduct applicable to the conduct of a Member 
of Congress in the performance of her duties or in the 
discharge of her responsibilities. * * * ''
    An investigative subcommittee established to conduct the 
Preliminary Inquiry is now conducting an investigation into 
alleged misconduct by Representative Collins. Among other 
actions it has taken, the subcommittee has issued subpoenas to 
several individuals who may be of interest to the grand jury in 
the government's criminal investigation, including 
Representative Collins.
    Should you have any comments or questions regarding this 
matter, please contact the Committee's Chief Counsel, Theodore 
J. Van Der Meid, at (202) 225-7103.
            Sincerely,
                                   Jim Bunning,
                                           Chairman.
                                   Robert A. Borski,
                                           Ranking Democratic Member.
                               APPENDIX E

                          House of Representatives,
                Committee on Standards of Official Conduct,
                                    Washington, DC, March 27, 1996.
Lynn Helland,
Chief, Special Prosecutions Unit, Office of the U.S. Attorney, Detroit, 
        MI.
    Dear Mr. Helland: We are writing as a follow-up to our 
letter of February 29, 1996, to U.S. Attorney, Saul A. Green, 
and pursuant to a telephone conversation between Faith Burton 
of the Justice Department and the Committee's Chief Counsel, 
Ted Van Der Meid, on March 13, 1996. As was stated in our 
correspondence to Mr. Green, the Committee has commenced a 
Preliminary Inquiry to determine whether there is reason to 
believe that Representative Barbara-Rose Collins violated the 
Code of Conduct of the House or any law, rule, regulation or 
other standard of conduct in the performance of her duties as a 
Member of Congress by misusing ``official, campaign, and 
scholarship fund resources''. Further, we informed Mr. Green 
that an investigative subcommittee that was established for 
this purpose, had, as part of its investigation into alleged 
misconduct of Representative Collins, issued subpoenas to 
several individuals who may be of interest to the grand jury in 
the government's criminal investigation, including 
Representative Collins. We also invited any ``comments or 
questions'' regarding the matter.
    Ms. Burton has requested that we provide you with the 
general areas of our investigation, a list of the witnesses 
being subpoenaed, and a list of the physical and documentary 
items being subpoenaed. Ms. Burton also expressed concern about 
the granting of immunity by the subcommittee and inquired if 
any witnesses, who testified in an employment related matter 
before the Office of Fair Employment Practices of the House, 
were granted immunity.
    Under House and Committee rules, no information received by 
the Committee or subcommittee may be disclosed unless 
specifically authorized by the Committee. To maintain the 
integrity of its proceedings, the Committee customarily does 
not authorize the disclosure of information during the course 
of a Preliminary Inquiry. For this reason, we are unable to 
furnish your office with the names of witnesses or a list of 
documents that have been subpoenaed.
    However, it should be noted that the general areas of our 
investigation are stated in the Committee's Resolution of 
Preliminary Inquiry, a public document, and restated in the 
subcommittee's February 29 correspondence to Mr. Green and 
above. The Committee's policy as to the acceptance or 
requesting of originals of documents is not to accept originals 
of documents when there is reason to believe that such 
originals may be part of an investigation by a United States 
Attorneys' office. Further, it should be noted that the 
Committee traditionally has not granted immunity and if the 
issue does arise we would consult your office.
    Finally, the Committee does not wish to interfere with or 
impede the ongoing criminal investigation. However, we have 
determined that it is important to the interests of the House 
of Representatives to conduct the Committee's inquiry. 
Therefore, if you have any objections to the Committee's 
investigation of Representative Collins, we request that you 
formally advise us of such. Should you have any questions or 
comments regarding this matter, please contact Mr. Van Der Meid 
at 202-225-7103.
            Sincerely,
                                   Jim Bunning,
                                           Chairman, Investigative 
                                               Subcommittee.
                                   Robert A. Borski,
                                           Ranking Democratic Member, 
                                               Investigative 
                                               Subcommittee.
                               APPENDIX F

                                   Cornelius Pitts,
                                           Attorney at Law,
                                     Detroit, MI, January 26, 1996.
Attn: Theodore J. Van Der Meid, Chief Counsel.
Re: The Honorable Barbara-Rose Collins.
Hon. Nancy L. Johnson,
Chairman, Committee on Standards of Official Conduct,
House of Representatives, Washington, DC.
    Dear Mr. Van Der Meid: Please be advised that this office 
has been retained to represent the above-captioned 
Congresswoman, Barbara-Rose Collins, who, we have reason to 
believe, is the target of a Federal Grand Jury Investigation; 
presently under way in the City of Detroit.
    We are also aware that the Committee on Standards of 
Official Conduct likewise has undertaken an investigation into 
certain activities, in the Congresswoman's district and 
Washington congressional offices.
    As the subject matter of the local Grand Jury Investigation 
is unknown, it is reasonable to assume that the material, 
information and/or evidence sought or presented may be the same 
desired, needed or wanted by the committee.
    While the Congresswoman continues in her desire to be as 
cooperative as possible, counsel must be concerned about the 
full and complete protection of her constitutional rights. And 
with the over-lapping of the two (2) aforementioned 
investigation, an obvious conflict is presented.
    Consequently, it is respectfully requested that the 
continuation of your investigation be adjourned or stayed, 
pending the outcome of the Grand Jury Investigation.
    With our appreciation for the consideration given, we 
remain,
            Sincerely,
                                                   Cornelius Pitts.

                                   Cornelius Pitts,
                                           Attorney at Law,
                                     Detroit, MI, February 7, 1996.
Re Committee Letter of January 24, 1996, Request for Records, etc. 
        Congresswoman Barbara-Rose Collins.
Hon. Jim Bunning,
House of Representatives, Chairman, Investigative Subcommittee of the 
        Committee on Standards of Official Conduct, Washington, DC.
    and
Hon. Robert A. Borski,
House of Representatives, Ranking Democratic Member of the 
        Investigative Subcommittee of the Committee on Standards of 
        Official Conduct, Washington, DC.
    Dear Congressmen Bunning and Borski: Reference is made to 
your letter of January 24, 1996 to your colleague, 
Congresswoman Barbara-Rose Collins and ours of January 26, 
1996, addressed to the Honorable Nancy L. Johnson, Chairperson 
of the Committee on Standards of Official Conduct and to the 
Honorable Jim McDermott, Ranking Democratic Member of said 
committee.
    As you can note, our correspondence of January 26, 1996 
requests an adjournment or stay of your investigation, pending 
the outcome of a Federal Grand Jury Investigation re: 
Congresswoman Collins; which we now have confirmation is 
underway. Having definitively learned the existence of said 
Grand Jury and its purpose yesterday, February 6, 1996, we 
contacted Mr. Theodore J. Van Der Meid, Chief Counsel of your 
committee to request a similar delay in complying with your 
letter of January 24, 1996. Mr. Van Der Meid, having been 
informed of the circumstances, was not receptive to our request 
and indicated that if there was not compliance, a Subpoena 
would be sought.
    In view of the aforementioned, Congresswoman Collins has no 
alternative other than to bring the urgency of this matter to 
your attention. This, because our discussions (of course, 
informally) with both sitting Members of the House and Retirees 
disclosed that in the past such adjournments or stays, under 
similar circumstances, have been routinely granted.
    With this in mind, it is respectfully requested that your 
Subcommittee, at your earliest opportunity, consider 
Congresswoman Collins' request that the Committee's 
investigation of her actions either be adjourned or stayed, 
pending the outcome of the Federal Grand Jury Investigation. If 
that is not acceptable, another option would be to continue the 
investigation BUT without the requirement of the Congresswoman 
producing her records.
    While there are, obviously, other options, it is again 
respectfully requested that your body favorably consider 
Congresswoman Collins' request. Finally, with the deadline 
being February 8, 1996 and with the House of Representatives in 
recess, I am Faxing a copy of this letter to your respective 
staffs, for their immediate attention.
    With our deepest appreciation for the consideration given, 
we remain,
            Sincerely,
                                                   Cornelius Pitts.
                               APPENDIX G

                          House of Representatives,
                Committee on Standards of Official Conduct,
                                 Washington, DC, February 28, 1996.
Cornelius Pitts, Esq.
Detroit, MI.
    Dear Mr. Pitts: We are in receipt of your correspondence of 
February 7, 1996, on behalf of Congresswoman Barbara-Rose 
Collins, in which you request that the Subcommittee's 
investigation concerning the Congresswoman be adjourned or 
stayed pending the outcome of the Federal Grand Jury 
investigation currently being conducted in Detroit. We are also 
in receipt of your correspondence of February 8, 1996, in which 
you informed the Subcommittee that upon your advice, the 
Congresswoman would not voluntarily comply with the 
Subcommittee's request for documents of January 24, 1996 at 
this time.
    Pursuant to section 14(g) of the Rules of the Committee on 
Standards of Official Conduct, the Committee may defer action 
on allegations of misconduct when it has reason to believe that 
such conduct is being reviewed by law enforcement or regulatory 
authorities. The practice of the Committee has been to make the 
determination on whether to defer on a case-by-case basis, 
taking into consideration the particular circumstances of each 
case.
    At its meeting yesterday, the Investigative Subcommittee 
considered your request on behalf of Representative Collins. 
The Subcommittee voted to deny the request and to proceed with 
the issuance of subpoenas for documents. A copy of the subpoena 
issued to Representative Collins is enclosed.
    If you have any further questions, please contact the 
Committee's Chief Counsel, Ted Van Der Meid.
            Sincerely,
                                   Jim Bunning
                                           Chairman, Investigative 
                                               Subcommittee.
                                   Robert A. Borski,
                                           Ranking Democratic Member, 
                                               Investigative 
                                               Subcommittee.

                         [Subpoena Duces Tecum]

By Authority of the House of Representatives of Congress of the United 
                           States of America

To: Representative Barbara-Rose Collins, U.S. House of Representatives, 
        401 Cannon House Office Building, Washington, DC 20515.

    You are hereby commanded to produce before the 
Investigative Subcommittee of the Committee on Standards of 
Official Conduct of the House of Representatives of the United 
States, of which the Honorable Jim Bunning is chairman, in 
Suite HT-2 of the Capitol, in the city of Washington, by no 
later than 5:00 p.m. on March 13, 1996, the things identified 
on the attached schedule concerning matters of inquiry 
committee to said Subcommittee.
    Witness my hand and the seal of the House of 
Representatives of the United States, at the city of 
Washington, this 28th day of February, 1996.
                                   Nancy L. Johnson,
                                           Chairman, Committee on 
                                               Standards of Official 
                                               Conduct.
                                   Jim McDermott,
                                           Ranking Minority Member, 
                                               Committee on Standards 
                                               of Official Conduct.
    Attest:
                                            Robin H. Carle,
                                                Clerk of the House.

                                schedule

    All records, correspondence, memoranda, papers, and 
documents for calendar years 1994 and 1995, including 
electronic mail and other computerized records, in your 
district and Washington offices, and in your personal 
possession, custody, or control, pertaining to:
    1. Documents showing annual leave and leave without pay 
taken by staff, and the home address and telephone numbers of 
staff.
    2. Staff duties and assignments.
    3. Staff payroll, including documents relating to increases 
and decreases in staff salaries.
    4. Postage stamps purchased with appropriated funds, 
including the use of such stamps.
    5. Fundraising events for your 1994 reelection campaign.
    6. The solicitation, receipt, logging, or deposit of 
campaign contributions by district or Washington office staff.
    7. Any work on your 1994 reelection campaign performed at 
any time by district or Washington office staff.
    8. Post office boxes leased or maintained by you, your 
Washington office, the Detroit district office, or staff in 
either office, in connection with your congressional office or 
the Friends of Barbara-Rose Collins.
    9. the use of congressional staff, at any time, to perform 
personal tasks, favors, or chores for you.
    10. Scholarship funds with which you are, or have been, 
associated, including but not limited to the Collins 
Congressional Community Scholarship Committee, and including 
documents or records concerning (1) withdrawals from, and 
deposits to, financial accounts relating to such funds 
(including cancelled checks and check registers, logs, and 
stubs); (2) scholarship awards; and (3) the staffing or 
administration of such funds.
    11. Checking or savings accounts in the name of ``Friends 
of Barbara-Ross Collins,'' and any other financial accounts 
relating to your 1994 reelection campaign, including records 
concerning withdrawals from, and deposits to, such accounts.
    12. Any repairs or renovations made to any homes or 
residences in which you have an ownership or lessee interest, 
including any homes or residences used for vacation purposes.
    13. A trip to Africa in 1994 by yourself and members of 
your staff.
    14. Your trip to New York City in October or November 1994, 
including records pertaining to purchases of clocks and any 
other items during that trip, and the subsequent disposition of 
any items purchased.
                               APPENDIX H

                                   Cornelius Pitts,
                                           Attorney at Law,
                                        Detroit, MI, March 8, 1996.
Re investigation concerning Rep. Barbara-Rose Collins.

Hon. Jim Bunning,
Chairman, Investigative Subcommittee, Committee on Standards of 
        Official Conduct, House of Representatives, Washington, DC.
    and
Hon. Robert A. Borski,
Ranking Minority Member, Investigative Subcommittee, Committee on 
        Standards of Official Conduct, House of Representatives, 
        Washington, DC.
    Honorable Sirs: On February 8, 1996, I asked that your 
committee ``stay or adjourn'' the proceedings concerning Rep. 
Collins, in light of the ongoing Grand Jury investigation in 
the Eastern District of Michigan. By letter of February 28, you 
informed me that the Investigative Subcommittee had met and, 
treating my request as one to defer action under Sec. 14(g) of 
the Committee's rules, had voted to deny it. On that day, a 
subpoena was issued to Rep. Collins; additional subpoenas, I 
have learned, have also been issued to members of her staff. 
The subpoena to Rep. Collins calls for her to produce a lengthy 
list of documents, and is returnable March 13, 1996.
    I am writing this letter to apprise you of additional facts 
not available to me at the time of my letter of February 7, and 
to request that, in light of these additional facts, you 
reconsider my request to defer action on this matter.
    Since my letter of February 7, we have learned that the 
Detroit Grand Jury has issued additional subpoenas, calling not 
only for the production of documents, but for testimony as 
well. Although we cannot, of course, determine with any degree 
of precision what the exact scope of the Grand Jury's 
investigation may be, subpoenas issued by your Investigative 
Subcommittee and the Grand Jury call, in several instances, for 
identical categories of documents, leading me to believe that 
there is a substantial overlap in the inquiries. Thus, while it 
may not have been so previously, it now seems eminently clear 
that there is good ``reason to believe'' that the conduct under 
scrutiny by the Committee ``is being reviewed by appropriate 
law enforcement . . . authorities,'' within the meaning of Rule 
14(g).
    I recognize that, under that rule, a decision to defer 
action is discretionary. However, recent events in Rep. 
Collins' personal life should, I believe, move you to exercise 
that discretion in favor of deferring action at this time. 
Towards the end of February, Rep. Collins became ill. On 
Friday, March 1, she was admitted to Harper Hospital in 
Detroit, for treatment and testing. She remains hospitalized as 
of this writing, and it is uncertain when she will be released. 
Obviously, her illness and hospitalization have made it 
impossible for her to turn her full attention to the question 
of compliance with the February 28 subpoena, so that compliance 
with it by March 13 would be difficult, if not impossible. 
Moreover, her medical condition is such that I cannot 
adequately consult with her regarding the various legal options 
open to her. Accordingly, I believe it would be unfair to 
insist that the investigation proceed at this time.
    If there is any other or further information I may offer, I 
will be pleased to do so on request. In light of the return 
date of the subpoena issued to Rep. Collins, I await the favor 
of a response at your very earliest convenience.
            Respectfully,
                                                   Cornelius Pitts.
                                ------                                

                          House of Representatives,
                Committee on Standards of Official Conduct,
                                    Washington, DC, March 14, 1996.
Cornelius Pitts, Esq.,
Detroit, MI.
    Dear Mr. Pitts: This responds to your letter of March 8, 
1996 requesting reconsideration by the Investigative 
Subcommittee of your request to defer action in the matter 
pertaining to Representative Barbara-Rose Collins because of 
the pending Federal Grand Jury investigation and the recent 
hospitalization of Representative Collins. This letter also 
responds to your request through Committee Counsel, David 
Laufman, for an extension of time for the production of records 
by Riggs National Bank. We understand that subsequent to your 
letter of March 8 Representative Collins was released from the 
hospital.
    As you were informed by Committee Counsel, Charles J. 
Willoughby, on March 11, 1996, your request for reconsideration 
is denied. However, based solely on your inability to 
adequately consult with Representative Collins because of her 
recent hospitalization, as represented in your March 8 
correspondence, a ten day extension is granted for 
Representative Collins to submit the documents in question. 
Since the due date, March 23, will fall on a Saturday, 
Representative Collins will have until 5:00 P.M. on March 25, 
1996 to comply with the subpoena. In light of the fact that the 
Subcommittee initially requested the production of the 
documents by February 8, 1996, the Subcommittee will not be 
inclined to grant any further extensions. Finally, please be 
advised that your request for an extension of time for the 
production of documents by Riggs National Bank is denied.
    If you have any further questions, please contact either 
Mr. Willoughby or Mr. Laufman at 202-225-7103.
            Sincerely,
                                   Jim Bunning,
                                           Chairman, Investigative 
                                               Subcommittee.
                                   Robert A. Borski,
                                           Ranking Democratic Member, 
                                               Investigative 
                                               Subcommittee.
                               APPENDIX I

                                   Cornelius Pitts,
                                           Attorney at Law,
                                       Detroit, MI, March 18, 1996.
Re: Motion to Quash Subpoena Duces Tecum issued to Rep. Barbara-Rose 
        Collins.

Nancy J. Johnson,
Chairperson, Committee on Standards of Official Conduct, House of 
        Representatives, Washington, DC.
    Honorable Madame: Enclosed please find for your 
consideration, pursuant to Rule 17(a)(5) of the Rules of the 
Committee on Standards of Official Conduct, a Motion to Quash 
the Subpoena Duces Tecum issued to my client, Representative 
Barbara-Rose Collins, along with a Memorandum in support of 
that motion.
    If there is any other or further information which you may 
require in the premises, I will of course be happy to provide 
it upon request.
            Respectfully yours,
                                           Cornelius Pitts,
                                         Attorney for Rep. Collins.

 In the United States House of Representatives, Committee on Standards 
                          of Official Conduct

In re: Subpoena Duces Tecum issued to Rep. Barbara-Rose Collins.

                  motion to quash subpoena duces tecum

    Now comes United States Representative Barbara-Rose 
Collins, by and through her Attorney, Cornelius Pitts, and, 
pursuant to Rule 17(a)(5) of the Rules of the Committee on 
Standards of Official Conduct, moves to quash the Subpoena 
Duces Tecum issued to her, and in support of said Motion says 
as follows:
    1. That on February 28, 1996, a Subpoena Duces Tecum was 
issued by this Committee, apparently on the application of an 
Investigative Subcommittee consisting of Representatives Jim 
Bunning and Robert A. Borski. (A copy of the said Subpoena and 
the attachment thereto is attached hereto as Exhibit 1 and 
incorporated herein by reference.)
    2. That the said subpoena was originally returnable on or 
before March 13, 1996, but, on application of undersigned 
counsel, and apparently in consideration of Movant's recent 
hospitalization, the return date was extended to March 23.
    3. That on three occasions, undersigned counsel advised 
this Committee and the Investigative Subcommittee that the 
conduct which is apparently the subject of the investigation 
herein is also apparently the subject of an investigation being 
conducted by a United States Grant Jury sitting in the Eastern 
District of Michigan. (See letters of January 26, February 7 
and March 8, 1996, attached hereto as Exhibits 2, 3 and 4, 
respectively, and incorporated herein by reference.)
    4. That on February 7 and March 8, after the matter had 
been referred to the Investigative Subcommittee, undersigned 
counsel requested that the proceedings herein be stayed, 
adjourned or deferred pursuant to Rule 14(g) of the Rules of 
this Committee, which allows for such action when ``the 
Committee has reason to believe [the] conduct [under 
investigation] is being reviewed by appropriate law enforcement 
. . . authorities.''
    5. That the Investigative Subcommittee, acting on its own 
initiative, and without referring the matter to the Committee 
itself, refused to honor these requests. (See letter of 
February 28, from Representatives Bunning and Borski to 
undersigned counsel, attached hereto as Exhibit 5, and 
incorporated herein by reference.)
    6. That under Rule 14(g), the discretion to defer action 
resides in the Committee itself, not the Investigative 
Subcommittee: therefore, the Investigative Subcommittee was 
without the authority to deny the requests for deferral, and 
the issuance of the Subpoena Duces Tecum, without consideration 
of the requests to defer action under Rule 14(g) by the 
Committee itself was in violation of the Rules of this 
Committee.
    7. That the said subpoena is overbroad, and compliance with 
it would be burdensome, unreasonable and oppressive: it 
intrudes into wholly private matters, and seeks access to 
documents, records, papers and things which are not, and could 
not, be relevant to any legitimate and properly authorized 
investigation which this Committee is empowered to conduct.
    8. That in addition, in light of the pendency of the 
parallel grand jury investigation, it would be unfair, 
unreasonable and oppressive for this Committee to insist on 
compliance with the subpoena herein at this time; while Movant 
might otherwise wish to submit the records in question to this 
Committee, and otherwise to respond to and participate in its 
review of whatever allegations may have been made against her, 
upon advice of undersigned counsel she cannot responsibly do so 
with the grand jury investigation actively proceeding; 
accordingly, if the Committee in fact wishes to have Movant's 
active cooperation with this inquiry, at the very least it 
should, in the informed exercise of the discretion allowed 
under Rule 14(g), defer proceedings in regard to the instant 
Subpoena Duces Tecum.
    9. That the production of the documents called for in the 
said Subpoena Duces Tecum would entail compelled testimonial 
self-incrimination, because the act of producing any such 
documents would admit the documents' existence, authenticity 
and Movant's possession of them; in addition, because the 
attachment to the subpoena does not describe the documents to 
be produced in an objective manner, compliance with it would 
require the Movant to discriminate between documents, and in 
furnishing any such documents, to provide information that 
would be testimonial in nature, and therefore subject to 
Movant's invocation of the Fifth Amendment privilege.
    10. That because of the pendency of the grand jury 
investigation, undersigned counsel has advised Movant that the 
only responsible course of action open to her is to assert her 
Fifth Amendment privilege against self-incrimination with 
respect to the requests for production contained in the 
attachment to the instant Subpoena Duces Tecum, and it is the 
intention of Movant to follow that advice.
    11. That if the Committee is not now willing to defer 
proceedings in regard to the instant investigation, or at least 
in regard to the Subpoena Duces Tecum issued to Movant, the 
said Subpoena should be quashed because of its overbreadth, 
and, in addition, because to require Movant to produce the 
documents called for by it would violate the privilege against 
self-incrimination afforded her by the Fifth Amendment to the 
United States Constitution.
    WHEREFORE, Movant respectively prays that under the 
authority of Rule 17(g) of the Rules of this Honorable 
Committee, the previously issued subpoena be quashed.
                                           Cornelius Pitts,
                            Attorney for Rep. Barbara-Rose Collins.

 In the United States House of Representatives, Committee on Standards 
                          of Official Conduct

In re: Subpoena Duces Tecum issued to Rep. Barbara-Rose Collins.

     MEMORANDUM IN SUPPORT OF MOTION TO QUASH SUBPOENA DUCES TECUM

    While this Committee's investigative authority is no doubt 
broad, it is equally certainly subject to certain inherent 
limitations of the sort which circumscribe the activities of 
all investigative bodies functioning under the Constitution and 
laws of the United States. The motion in support of which this 
memorandum is written suggests that recognition of certain of 
those limitations requires that the Subpoena Duces Tecum 
heretofore issued to Representative Collins be quashed.
    The words of Chief Justice Warren, writing for the majority 
in Watkins v. United States. 354 U.S. 178.187 (1957), are still 
an appropriate starting place for any discussion on the nature 
(and limitations) of the investigative authority of Congress, 
and of this Committee:

          We start with several basic premises on which there 
        is general agreement. The power of the Congress to 
        conduct investigations is inherent in the legislative 
        process. That power is broad. It encompasses inquiries 
        concerning the administration of existing laws as well 
        as proposed or possibly needed statutes. It includes 
        surveys of defects in our social, economic or political 
        system for the purpose of enabling the congress to 
        remedy them. It comprehends probes into departments of 
        the Federal government to expose corruption, 
        inefficiency or waste. But, broad as is this power of 
        inquiry, it is not unlimited. There is no general 
        authority to expose the private affairs of individuals 
        without justification in terms of the functions of the 
        Congress. * * * Nor is the Congress a law enforcement 
        or trial agency. These are functions of the executive 
        and judicial departments of government. No inquiry is 
        an end in itself: it must be related to, and in 
        furtherance of, a legitimate task of the Congress. 
        Investigations conducted solely for the personal 
        aggrandizement of the investigations or to punish those 
        investigated are indefensible.

    As Watkins cautions. ``[a]buses of the investigative 
process may imperceptibly lead to abridgment of protected 
freedoms.'' 354 U.S. at 196. Thus, it has been uniformly 
understood that the subject of a congressional investigation, 
or the recipient of a congressional subpoena, retains the same 
panoply of rights and protections afforded those whose lives 
are touched by other investigative bodies. See. e.g. Watkins, 
supra. 354 U.S. at 193-200: United States v. Rumely. 345 U.S. 
41 (1953).
    A Congressional Committee's controlling charter and the 
``pertinency'' of its inquiry delimit its right to compel 
testimony, Gojack v United States. 384 U.S. 702.708. (1966), 
and authorities cited above. In addition, a Committee is bound 
to follow its own rules, and actions taken in violation of 
those rules are not enforceable. Yellin v United States, 374 
U.S. 109. 114 (1963).
    As noted in the motion in support of which this memorandum 
is written. (and as the attached letters from undersigned 
counsel evidence), a Federal Grand Jury sitting in Detroit is 
actively conducting an investigation that, as has become 
increasingly apparent, substantially overlaps the inquiry which 
has been undertaken by this Committee. The pendency of such a 
parallel investigation is obviously of overwhelming 
significance to a person in the position of Rep. Collins, and 
of necessity has an overwhelming impact on any response to this 
Committee's inquiries. Under the circumstances, no responsible 
attorney would advise anything but the highest degree of 
circumspection, and any desire which she might otherwise have 
to cooperate with the work of this committee of her fellows 
must, under the circumstances, bow to her need to follow the 
advice of counsel.
    It is undoubtedly in recognition of such considerations 
that this Committee adopted Rule 14(g), which provides:

          The Committee may defer action on a complaint against 
        a Member, officer, or employee of the House of 
        Representatives when the Committee has reason to 
        believe such conduct is being reviewed by appropriate 
        law enforcement or regulatory authorities.

    On February 7, undersigned counsel wrote to the 
Investigative Subcommittee, asking that the instant inquiry by 
``stayed or adjourned'' in light of the Detroit grand jury 
investigation. On February 28, the Subcommittee responded, in 
essence, that it had considered the request in light of Rule 
14(g), and voted to deny it, and caused the instant subpoena to 
issue. A more detailed request, specifically referring to Rule 
14(g), was made on March 7, and also denied by the 
Subcommittee. (See Exhibits 3, 4 and 5).
    The Rule, however, speaks of discretion to defer 
proceedings as residing in the Committee, not the Subcommittee. 
Thus, under the Rule, Movant has a right to consideration of 
her request by the full Committee. The Investigative 
Subcommittee did not have the authority to deny the request for 
deferral on its own, but it presumed to do so, without 
referring the request to the full Committee for action. 
Accordingly, it is Movant's first contention that the 
Subcommittee's action in pursuing the issuance of subpoenas 
(including the subpoena to the Member herself) is in violation 
of the Rules of the Committee, and that the Subpoena Duces 
Tecum issued to her should therefore be quashed on this ground.
    In a broader sense, however, the Subpoena should be quashed 
for the same reason that the Committee's inquiry should be 
deferred under Rule 14(g); because it would be unreasonable, 
oppressive and burdensome to require her to finish the 
information sought under the shadow of the parallel grand jury 
investigation.
    In addition, the Subpoena violates the ``pertinency'' 
limitations on the power of this Committee to inquire, because, 
in addition to documents which at least arguably touch on Rep. 
Collins' official conduct, it also demands records and 
information relating solely to her personal and private 
affairs--areas which are in no way relevant to any proper or 
legitimate area of this Committee's investigation.
    Moreover, the ``Schedule'' which itemizes the ``records, 
correspondence, memoranda, papers and documents'' to be 
produced does so by calling for documents which ``pertain to'' 
broadly defined subjects, rather than by objective descriptions 
of particular documents. Accordingly, the assembling of records 
which might fit into the enumerated categories would be more 
than a merely mechanical procedure. It would call for the 
exercise of judgment by a person with knowledge of the 
significance of all the documents from which the documents to 
be turned over might be selected, as well as the matters to 
which they might or might not ``pertain,'' and a process of 
discrimination as to whether any particular document 
``pertained'' to any of the generally described subjects. The 
production of any document would carry with it the implicit 
statement that, whatever its contents, it was ``pertinent'' to 
one or another of the subjects identified in the Schedule; and 
the nonproduction of any other documents would constitute an 
assurance that the documents not produced did not concern the 
matters spoken of in the Schedule, but rather, concerned other 
matters. In addition, of course, the production of any 
documents would carry with it the assurance that the documents 
produced were in fact authentic, and that Rep. Collins had 
dominion and control over them.
    In short, compliance with the Subpoena Duces Tecum would 
require acts which would clearly be testimonial in nature, and 
therefore subject to a claim of privilege under the Fifth 
Amendment to the United States Constitution.
    In Fisher v. United States, 425 U.S. 391 (1976), the 
Supreme Court held that the Fifth Amendment shields only 
compelled testimonial acts, and that the contents of documents 
not prepared in response to governmental behest cannot 
constitute compelled testimony; however, as the Court 
recognized, the act of producing documents in response to a 
subpoena ``has communicative aspects of its own, wholly aside 
from the contents of the papers produced.'' Id. at 410. Such 
``communicative aspects,'' the Court noted, may relate to the 
existence of the documents, their possession or control, their 
authenticity, or their meaning or character. Id. at 410-413. 
With respect to the instant subpoena, all of these categories 
are implicated.
    That the instant Subpoena Duces Tecum implicates Movant's 
Fifth Amendment rights is well illustrated by the decision of 
the Eighth Circuit in In re Grand Jury Proceedings, 41 F.3d 
377, 380-381 (8th Cir. 1994), in which the court upheld a claim 
of privilege in response to a grand jury subpoena calling for 
``documents regarding financial transactions'' during specified 
years:

          Turning over documents in response to the subpoenas 
        authenticates the documents and reveals that some of 
        the documents relate to financial transactions.
          * * * * * * *
          Furthermore, compliance with the subpoenas, in this 
        case, would involve a testimonial act because of the 
        broad-sweeping scope of the subpoenas. The act of 
        turning over documents in response to a broad-sweeping 
        subpoena may involve discretionary judgments about the 
        documents themselves. The question is whether a 
        subpoena requires the witness to discriminate among 
        documents, thereby identifying information relevant to 
        the authenticity of the documents. This determination 
        is fact specific and dependent on the particular 
        wording of the subpoena in question--the broader, more 
        general, and subjective the language of the subpoena, 
        the more likely compliance with the subpoena would be 
        testimonial. Cf. United States v. Fox, 721 F.2d 32, 38 
        (2d Cir. 1983) (holding that enforcement of IRS summons 
        of sole proprietorship would result in compelled 
        testimonial communication and refusing to enforce 
        broad-sweeping summons); [United States v.] Porter, 711 
        F.2d [1397] at 1401 [[(7th Cir. 1983)]. See generally 
        Robert P. Mosteller, Simplifying Subpoena Law: Taking 
        the Fifth Amendment Seriously. 73 Va.L.Rev. 1, 12-13 
        (1987).
           * * * * * * *
          The language does not specifically describe the 
        requested documents in an objective manner. Compliance 
        with this broad language would require the witness to 
        discriminate among documents, thereby providing 
        identifying information that is relevant to the 
        authenticity of the documents. ``[A] subpoena compels 
        the person receiving it by his own response to identify 
        the documents delivered as the ones described in the 
        subpoena.'' United States v. Blank, 459 F.2d 383, 385 
        (6th Cir.), cert. denied, 409 U.S. 887, 93 S. Ct. 111, 
        34 L.Ed.2d 143 (1972). In addition, testimonial conduct 
        may be compelled if the subpoena requires a person to 
        select documents used for a particular purpose. See 
        United States v. Beattie, 522 F.2d 267, 268 (2d Cir. 
        1975), vacated, 425 U.S. 967, 96 S. Ct. 2163, 48 
        L.Ed.2d 791, cert. denied, 425 U.S. 970, 96 S.Ct. 2165, 
        48 L.Ed.2d 793, modified, 541 F.2d 329 (1976) (subpoena 
        requiring the production of accountant's workpapers 
        used in the preparation of tax returns).

    Were it not for the pendency of the Detroit grand jury 
investigation, Rep. Collins might well not elect to claim her 
Fifth Amendment privilege; given the fact of that 
investigation, however, undersigned counsel has advised her 
that she has no choice but to do so, and she feels bound to 
heed that advice. In the face of that claim, her compliance 
with the Subpoena Duces Tecum cannot be required.
    The motion in support of which this Memorandum is written 
is directed, as required by Rule 17(a)(5), to the Chairperson 
of the Committee, and is framed as a Motion to Quash. While a 
decision to quash the Subpoena Duces Tecum would be 
appropriate, for all the reasons outlined above, the Movant 
would also be satisfied if it were treated as a request to 
defer under Rule 14(g), which might be granted after 
appropriate consultation with the Committee itself. In any 
event, it is clear that, under the circumstances Rep. Collins 
cannot be compelled to comply with the Subpoena Duces Tecum 
which has been issued to her, and that Subpoena must be 
quashed.
            Respectfully submitted,
                                           Cornelius Pitts,
                            Attorney for Rep. Barbara-Rose Collins.
                               APPENDIX J

                          House of Representatives,
                Committee on Standards of Official Conduct,
                                    Washington, DC, March 22, 1996.
Cornelius Pitts, Esq.,
Penobscot Building,
Detroit, MI.
    Dear Mr. Pitts: The Committee is in receipt of your Motion 
to Quash Subpoena Duces Tecum on behalf of Representative 
Barbara-Rose Collins dated March 18, 1996 and received March 
21, 1996.
    As grounds for the Motion, you asserted that the Subpoena 
Duces Tecum issued to Representative Collins on February 28, 
1996, was: overly broad and burdensome in that it requires the 
production of documents that could not legitimately and 
properly fall within the jurisdiction of this Committee; that 
production of the documents in question would violate the Fifth 
Amendment rights of Representative Collins; and that in light 
of the pendency of the ``parallel grand jury investigation it 
would be unfair, unreasonable and oppressive * * * to insist on 
compliance with the subpoena''. Further, you assert that 
pursuant to Committee 14(g), the Investigative Subcommittee 
lacked authority to deny the previous requests for deferral. 
Finally, in the alternative, your requested that the Motion be 
treated as a request to defer to the full Committee.
    After consideration of the motion and the grounds therefor, 
I have determined that it fails to adequately establish a basis 
for quashing the subpoena in question. I find that the subpoena 
is not overly broad in that it requests the production of 
documents that relate to allegations that Representative 
Collins misused official, campaign, and scholarship fund 
resources, matters that fall within the jurisdiction of this 
Committee and the Resolution of Preliminary Inquiry voted by 
the Committee on December 5, 1995. Production of the documents 
in question do not appear to fall within the protections of the 
Fifth Amendment. I do not find that the mere pendency of a 
parallel grand jury investigation, without more, demonstrates 
that compliance with the subpoena would be unfair, unreasonable 
and oppressive to the Member.
    Finally, in regard to the contention that the Investigative 
Subcommittee lacked jurisdiction to deny Representative 
Collins' previous requests for deferral, is should be noted 
that Committee Rule 14(g) applies to the initial consideration 
by the Committee in determining whether a complaint merits 
further inquiry. Once the determination is made that a matter 
merits further inquiry and an investigative subcommittee is 
established, all investigative authority, except that which is 
specified in the Committee's rules, rests with the 
investigative subcommittee. Thus, the previous action taken by 
the Investigative Subcommittee of denying Representative 
Collins' request for deferral conforms to Committee rules.
    Accordingly, for the reasons stated herein, the Motion To 
Quash the Subpoena Duces Tecum issued to Representative Collins 
is denied.
            Sincerely,
                                        Nancy L. Johnson, Chairman.
                               APPENDIX K

                                      Brand, Lowell & Ryan,
                                     Washington, DC, June 27, 1996.
Re House inquiry concerning Hon. Barbara-Rose Collins.
David H. Laufman, Esq.,
Counsel, Committee on Standards of Official Conduct, House of 
        Representatives, the Capitol, Washington, DC.
    Dear Mr. Laufman: Pursuant to Rule 21 of the Rules, 
Committee on Standards of Official Conduct, this letter 
formally requests the immediate disclosure of any exculpatory 
information in connection with the inquiry concerning Hon. 
Barbara-Rose Collins.
    Thank you for your cooperation.
            Sincerely yours,
                                                  Jonathan S. Feld.
                               APPENDIX L

                          House of Representatives,
                Committee on Standards of Official Conduct,
                                     Washington, DC, July 25, 1996.
Hon. Barbara-Rose Collins,
 House of Representatives, Cannon House Office Building,
Washington, DC.
    Dear Colleague: We are in receipt of your counsel's 
correspondence of June 27, 1996, requesting exculpatory 
information that the Investigative Subcommittee has received in 
the course of its Preliminary Inquiry concerning your conduct.
    Pursuant to Committee Rule 21, the subcommittee is required 
to provide you with any exculpatory information that it 
receives during the course of its investigation. Consequently, 
at this time, we are writing to inform you that the 
subcommittee, thus far, has received the following exculpatory 
information.

                      misuse of official resources

    Certain staff have advised the subcommittee that:

          They did not perform personal or campaign-related 
        tasks on official time or in the congressional office;
          They did not recall observing other staffers 
        performing campaign related chores or tasks on 
        congressional time, in or outside of the congressional 
        office, including the logging in of campaign 
        contributions, paying campaign bills, circulating 
        political or campaign petitions, painting or cleaning 
        the campaign headquarters, or assisting in the 
        preparation of campaign mailings;
          If staffers performed any campaign-related chores or 
        tasks, such work was supposed to be performed outside 
        of the office and on the staffer's own time;
          The policy of your congressional office was not to 
        allow the performance of campaign activities either on 
        congressional time or in congressional space, and 
        sometime in March or April of 1994, you indicated on at 
        least one occasion that campaign activities were not to 
        be performed in the office. On other occasions, 
        supervisory personnel informed staff that no campaign-
        related work was to be performed on congressional time 
        or in the congressional office;
          Requests for leave were required to be submitted to 
        the office manager, and staffers were charged leave to 
        work on the campaign;
          You never asked them to perform campaign work on 
        official time and the performance of campaign work was 
        not discussed at staff meetings; and
          You did not inform them that they would receive 
        bonuses to help them pay for a trip to Africa with you 
        in December, 1994.

                      misuse of campaign resources

    While campaign funds were used to purchase appliances from 
ABC Warehouse in August, 1995, and those appliances appear to 
have been converted to your personal use, it also appears that 
in October, 1995, you partially reimbursed the campaign in the 
amount of $354 for the appliances.

                    misuse of scholarship resources

    While it appears that $8900 in funds from the Riggs Bank 
account were used to purchase personal items from Classic 
Consignment in May, 1995, it appears that you did reimburse the 
Riggs Bank account for $8900 in June, 1995.
    While it appears that $2000 in funds from the Riggs Bank 
account were deposited into your personal account at the Wright 
Patman Credit Union in July, 1995, documents suggest that the 
payment was a reimbursement for an expenditure of $2000 for the 
Queen's Community Workers from your personal account at Wright 
Patman in June, 1995.
    Should the subcommittee receive any further information 
that is determined to be exculpatory, we shall make such 
information available to you. If you or your counsel have any 
questions, please contact Committee Counsel, Charles J. 
Willoughby or David H. Laufman.
            Sincerely,
                                   Jim Bunning,
                                           Chairman, Investigative 
                                               Subcommittee.
                                   Robert A. Borski,
                                           Ranking Democratic Member, 
                                               Investigative 
                                               Subcommittee.
                               APPENDIX M

                                      Brand, Lowell & Ryan,
                                    Washington, DC, August 6, 1996.
Re Barbara-Rose Collins.
David Laufman,
Counsel, Committee on Standard of Official Conduct, House of 
        Representatives, the Capitol, Washington, DC.
    Dear Mr. Laufman: This letter confirms my telephone call 
with you. Pursuant to Rule 21 of the Rules of the Committee on 
Standard of Official Conduct, I am again requesting all 
exculpatory information relating to the preliminary inquiry of 
the Hon. Barbara-Rose Collins.
    While I have received some information, I have not received 
any information regarding petty cash expenditures. Several of 
the Committee's questions ask for confirmation that the funds 
were used for staff members for office expenses. (See, e.g. 
Committee letter at p. 10). I specifically request any 
testimony by Jerry Springs, George Stanton, or Cecilia Walker 
or other witnesses that confirm the use of petty cash funds for 
the purposes described in the questions or that they have no 
knowledge of any petty cash being improperly used. Furthermore, 
I request any testimony or information that an employee of the 
district office stated that the check registers were accurate 
or had no reason to question the checking account records.
    I look forward to receiving this information as soon as 
possible. Please let me know if you have any questions.
            Sincerely yours,
                                                  Jonathan S. Feld.
                               APPENDIX N

                          House of Representatives,
                Committee on Standards of Official Conduct,
                                Washington, DC, September 12, 1996.
Hon. Barbara-Rose Collins,
House of Representatives, Cannon House Office Building,
Washington, DC.
    Dear Colleague: We are in receipt of your counsel's 
correspondence of August 6, 1996, requesting exculpatory 
information regarding petty cash expenditures that the 
Investigative Subcommittee has received in the course of its 
Preliminary Inquiry concerning your conduct.
    As we noted in our correspondence of July 25, 1996, 
pursuant to Committee Rule 21, the subcommittee is required to 
provide you with any exculpatory information that it receives 
during the course of its investigation. Further, at that time, 
we indicated that you would be informed of any additional 
information that was determined to be exculpatory. 
Consequently, at this time, we are writing to inform you of 
additional exculpatory information that the subcommittee was 
received. The subcommittee has received the following 
exculpatory information, since our correspondence of July 25, 
1996.
    Regarding the allegations of the misuse of campaign 
resources, the subcommittee has been advised by a certain 
staffer that a petty cash fund comprise of campaign funds was 
used to:
          pay for advertisements in publications of political 
        groups for their events;
          pay for postage and stationery to respond to 
        invitations and other correspondence from your 
        political supporters and political groups; and
          to purchase food and toys for the Festival of Giving 
        in Detroit.
    Additionally, regarding the disbursement on or about 
November 8, 1994 of campaign funds for election day expenses, 
the subcommittee has received information that funds were 
distributed to poll workers.
    Should the subcommittee received any further information 
that is determined to be exculpatory, we shall make such 
information available to you. If you or your counsel have any 
questions, please contact Committee Counsel, Charles J. 
Willoughby or David H. Laufman.
            Sincerely,
                                   Jim Bunning,
                                           Chairman, Investigative 
                                               Subcommittee.
                                   Robert A. Borski,
                                           Ranking Democratic Member, 
                                               Investigative 
                                               Subcommittee.
                               APPENDIX O

                          House of Representatives,
                Committee on Standards of Official Conduct,
                                     Washington, DC, July 25, 1996.
Hon. Barbara-Rose Collins,
House of Representatives, Cannon House Office Building,
Washington, DC.
    Dear Colleague: As you have been previously informed, an 
investigative subcommittee of the Committee on Standards of 
Official Conduct is conducting a Preliminary Inquiry into 
certain allegations regarding your conduct as a Member of the 
House. Specifically, the subcommittee is investigating 
allegations concerning the misuse of official, campaign, and 
scholarship fund resources.
    Pursuant to Committee Rule 17(a)(3), the subcommittee 
hereby affords you an opportunity to submit a statement to the 
subcommittee, orally or in writing, ``regarding the allegations 
and any other relevant questions arising out of the Preliminary 
Inquiry.'' Any statement you submit under Rule 17(a)(3) must be 
under oath or affirmation. You may accompany your statement 
with any documents that you have not previously furnished to 
the subcommittee.
    Set forth below for your response thereto is information in 
support of the allegations described above, as well as 
additional information developed during the investigation 
concerning possible violations of House Rules or laws. 
Incorporated within the information provided are questions 
relating to selected expenditures, transactions, events, and 
organizations.
    Any written statement that you may wish to provide should 
be submitted by no later than Friday, August 17, 1996. If you 
prefer to respond orally in person, the subcommittee will 
receive your statement by means of sworn testimony during the 
week of September 2, 1996. Further, if you choose to appear in 
person, you should so notify the subcommittee through Committee 
counsel by no later than 5:00 P.M. on August 17, 1996.

                    i. misuse of official resources

A. Performance of campaign work
    During 1994 and 1995, members of your congressional staff 
in your Detroit district office and/or your Washington, D.C. 
office performed campaign work during office hours without 
being charged leave. Such campaign work included:
          (1) Logging checks comprising campaign contributions;
          (2) Depositing campaign contribution checks;
          (3) Using office copy machines to copy campaign 
        contribution checks;
          (4) Using postage stamps purchased with official 
        funds to send copies of campaign contribution checks 
        from the Detroit district office to the Washington 
        office;
          (5) Writing checks drawn on the campaign's account at 
        Commercial Bank in Detroit;
          (6) Using the office Federal Express account to send 
        blank checks drawn on the account of Friends of 
        Barbara-Rose Collins to and from the Detroit and 
        Washington offices;
          (7) Collecting names for petitions to place your name 
        on an election ballot;
          (8) Preparing for campaign events, including one 
        event where Detroit office staff were required to 
        prepare food and clean and paint the premises during 
        office hours; and
          (9) Distributing campaign literature on behalf of 
        other candidates during office hours.
    In approximately January 1995, the District Office Director 
admonished the office manager for ``mishandling'' her 
``duties'' as a House employee regarding the processing of 
campaign contribution checks.
    Official funds, including a government American Express 
card, were used to pay for travel to Washington, D.C. by 
District Office Directory Jerry Springs to attend an April 1995 
campaign fundraiser, as well as to pay for his hotel 
accommodations in Washington. In addition, the subcommittee has 
obtained the information that official funds were used to pay 
for round-trip travel by Leon Robinson from Detroit to 
Washington to attend the same event, and that a false voucher 
was submitted to the House Finance Office in connection with 
Mr. Robinson's travel to Washington.
    On or about October 6, 1995, your campaign issued check 
#2119 in the amount of $500.00, payable to Deputy District 
Director Cecilia Walker for ``Petty Cash.'' (The corresponding 
check stub indicates the payment was made for ``petty cash (ofc 
supplies & refreshments).'' The check was signed only by 
Cynthia Simpson, and endorsed by Ms. Walker. Similarly, on or 
about October 30, 1995, the campaign issued check #2131 in the 
amount of $1,000.00, payable to Cecilia Walker for ``Petty Cash 
fund,'' signed only by Cynthia Simpson, and endorsed by Ms. 
Walker. The corresponding check stud indicates the payment is 
for ``petty cash (misc. ofc. supplies).'' For which office were 
these funds intended: the campaign office, the congressional 
district office, or both? Why were these checks made payable to 
an employee of the District office, rather than to Cynthia 
Simpson? What arrangements were made to log or record petty 
cash expenditures, and who was responsible for maintaining the 
petty cash fund? Please state whether any proceeds from those 
checks were used, directly or indirectly, to purchase goods or 
services on behalf of the congressional district office. Please 
describe any such purchases with specificity.
    Filings with the Federal Election Commission by your 
campaign in connection with your 1994 election campaign reflect 
numerous disbursements to employees of your district office in 
Detroit, many of which are characterized as reimbursements. For 
example, on March 10, 1994, your campaign issued check #1643 in 
the amount of $16.63, payable to Priscilla Waters for ``log--
campaign finance.'' (The corresponding check stub states that 
the payment was for ``log-book campaign finance.'') The check 
was co-signed by you and Cynthia Simpson. The number of such 
disbursements raises additional questions about whether 
congressional staff were conducted campaign-related work during 
office hours.
B. Performance of personal services
    During 1994 and 1995, congressional staff were required to 
perform various personal chores or activities on your behalf, 
including:
          (1) The regular payment of your personal bills during 
        hours when they were supposed to be performing 
        congressional duties. With your knowledge and approval, 
        postage stamps purchased with official funds were often 
        used to pay your personal bills.
          (2) During office hours, district office staff were 
        required to go to your home in Detroit to facilitate 
        the entry, departure, and payment of a cleaning lady.
    The subcommittee has received information that 
congressional staff, during congressional office hours, 
performed personal tasks related to your Shay Lake property in 
1995. Certain documents, for example, indicate that District 
Office Director Jerry Springs assisted you in obtaining 
contract estimates for construction-related work. In addition, 
on or about July 5, 1995, you wrote a personal check (#2942) 
drawn on your account at Wright Patman Congressional Credit 
Union (hereafter ``Credit Union'') in the amount of $1,200.00, 
payable to Jerry Springs for ``Shay Lake.''

C. Use of official funds for trip to Africa

    During the latter part of 1994, you awarded bonuses to 
several congressional staff to enable them to accompany you on 
a non-official trip to Africa.

D. Use of official funds for personal expenses

    During 1994 and 1995, the Detroit and Washington offices 
sent several items to the Rose Reiter Jewelry store in New York 
by means of the office Federal Express account. In another 
instance in 1994, the Washington office sent a priority letter 
to Dewayne Porter, an interior decorator in Detroit, by means 
of the office Federal Express account. The subcommittee 
understands that Mr. Porter has provided interior decorating 
services to you.

E. Solicitation of contributions

    Employees of your congressional office in Washington, D.C. 
used official resources, including official congressional 
letterhead, to solicit private contributions to sponsor the 
``Michigan Bash'' event in September 1994.

                    II. MISUSE OF CAMPAIGN RESOURCES

A. Commingling and conversion of campaign funds

    On or about June 30, 1994, your campaign issued check #1719 
in the amount of $3,911.00, payable to Barbara-Rose Collins for 
``Reimbursement.'' The check bears your endorsement and was 
deposited into your personal checking account at the Credit 
Union on or about July 1, 1994. A campaign filing with the 
Federal Election Commission dated July 15, 1994, shows a 
disbursement of $3,911.00 to Ms. Collins in ``Reimbursement for 
Precinct Delegate Picnic Catering.'') But the corresponding 
check stub shows a $3,911.00 payment to District office 
employee George Stanton for ``precinct delegate picnic 
catering.''
    On or about August 3, 1994, your campaign issued check 
#1732 in the amount of $2,900.00 payable to ``Cash'' for 
``Fundraisers--Clyde Cleveland--Mich Spanish Dem.--Abe Cherry & 
NAACP.'' The check bears your endorsement. On or about August 
5, 1994, $2,900.00 was deposited into your personal bank 
account at the Credit Union.
    On or about September 19, 1994, your campaign issued check 
#1735 in the amount of $1,661.90 payable to American Express 
for account #372833432-75001, which the subcommittee 
understands to be your personal account.
    On or about October 24, 1994, your campaign issued check 
#1783 in the amount of $6,242.89 payable to American Express 
for account #372833423-75001.
    On or about November 8, 1994, your campaign issued check 
#1796 in the amount of $8500.00, payable to Jerry Springs for 
``election day expenses.'' On or about November 16, 1994, a 
deposit that included a check in the amount of $8500.00 was 
made to your personal checking account at the Credit Union.
    On or about November 25, 1994, your campaign issued check 
#1816 (co-signed by yourself) in the amount of $5663.52, 
payable to American Express for account #372833412-75001. The 
corresponding check stub states that the purpose of the payment 
was ``Reimbursement to Congresswoman for air, hotel & meals.''
    On or about January 20, 1995, your campaign issued check 
#1833 in the amount of $8043.11 for ``Golden Tulip Hotel,'' 
payable to American Express. As the subcommittee understands 
that your trip to Africa in December 1994 was personal in 
nature, it appears that this payment by the campaign was for 
personal expenses.
    On or about February 9, 1995, your campaign issued check 
#1840 in the amount of $300.00, payable to Mary Pointer. That 
check was co-signed by yourself and Joyce Smith. A handwritten 
annotation states that the check is for ``Services Rendered,'' 
while a campaign filing with the FEC dated January 8, 1996, 
states that the disbursement was for ``maintenance campaign 
mtgs.'' The subcommittee has received information that the 
payee was your personal cleaning lady in Detroit, and that 
campaign funds were used to pay her to clean your home in 
Detroit.
    On or about March 6, 1995, your campaign issued check #1849 
in the amount of $2,400.00, payable to ``Comerica.'' The check 
bears your signature and your endorsement. On or about the same 
day, Comerica Bank issued a cashier's check payable to Barbara-
Rose Collins in the amount of $2,400.00. On or about March 9, 
1995, $2,400.00 was deposited into your checking account at the 
Credit Union.
    On or about March 28, 1995, your campaign issued check 
#1865 to American Express in the amount of $75.00 for ``Annual 
Mbr. Dues.'' Although neither the check nor corresponding check 
stub identify the number of the pertinent American Express 
account, the subcommittee is concerned that the payment in 
question was made in connection with your personal American 
Express account.
    On or about June 21, 1995, your campaign issued check #1893 
in the amount of $7168.10, payable to American Express for 
``#3728-334213-75001.''
    On or about August 7, 1995, you purchased a freezer, oven, 
and electric dryer from ABC Warehouse in Southfield, Michigan 
using campaign funds. You signed a campaign check (#2132) in 
the amount of $913.72, payable to ABC Warehouse, to effect 
those purchases. In addition, you instructed a salesperson at 
ABC Warehouse to have the oven and dryer delivered to your 
cottage at Shay Lake, Michigan. Based on other information it 
has obtained, the subcommittee has reason to believe that the 
oven and dryer subsequently were delivered to your home at Shay 
Lake by employees of your Detroit district office.

B. Expenditures not attributable to bona fide campaign or political 
        purposes

    On or about October 26, 1994, your campaign issued check 
#1793 in the amount of $1,000.00 payable to Detroit Edison to 
``Reconnect 19713 Ridgemont St. Clair Shores,'' an address 
where Joyce Smith--an employee of your Detroit district office 
and not a constituent--then resided. The subcommittee 
understands that the utility payment was made as a loan to Ms. 
Smith. The subcommittee also understands that subsequently, Ms. 
Smith personally and directly repaid you, rather than the 
campaign, in two separate cash payments of $500.00 each. The 
subcommittee has no evidence indicating that the campaign was 
reimbursed for the loan.
    On or about December 6, 1994, your campaign issued check 
#1823 to District Office Director Jerry Springs in the amount 
of $4,000.00. The corresponding check stub states that the 
payment was for the ``Panafest Reception,''relating to your 
trip to Africa.
    According to a campaign filing with the FEC dated January 
8, 1996, on or about February 10, 1995, your campaign disbursed 
$272.95 to the Golden Tulip Hotel in Accra, Ghana for 
`'refreshments'' for a ``meeting with African leaders and 
business people to discuss econ devel & trade with Detroit.''

C. Questionable campaign expenditures

    Please explain how the following expenditures by your 1994 
campaign were attributable to bona fide campaign or political 
purposes, and provide any supporting documentation. In 
addition, please answer any additional questions stated below.
    On or about November 28, 1994, your campaign issued check 
#1801 in the amount of $1,500.00 payable to ``Cash'' for 
``Petty Cash.'' The check was cosigned by yourself and Joyce 
Smith. According to an FEC filing dated January 8, 1996, your 
campaign issued a check on or around November 25, 1994, to 
district office staffer George Stanton in ``reimbursement for 
camcorder and tapes.'' The corresponding check stub for check 
#1801 shows a payment of ``petty cash'' on November 25, 1994, 
for ``camcorder & tapes.'' But the check is endorsed by Jerry 
Springs, not George Stanton, and contains no mention of a 
camcorder or reimbursement. Please explain these discrepancies. 
Also, please explain the purpose of the purchase of a 
camcorder, and how it was used. In particular, please state 
whether you or members of your congressional staff used the 
camcorder during your December 1994 trip to Africa.
    According to the campaign filing with the FEC dated 
February 7, 1996, on or about January 2, 1995, your campaign 
disbursed $500.00 to ``Open Market'' in New Delhi, India for a 
``Floor Rug'' for the ``D.C. Office.'' (You may also wish to 
comment on the fact that neither the campaign register nor 
canceled checks or bank statements from Comerica Bank manifest 
any record of such a disbursement.)
    According to a campaign filing with the FEC dated January 
8, 1996, on February 10, 1995, your campaign disbursed 
$1,673.00 to ``African Art Market'' in Accra, Ghana for ``Art 
objects for offices'' in ``DC/District.'' (You may also wish to 
comment on the fact that there is no record of this 
disbursement in the campaign check register or in monthly bank 
statements pertaining to the campaign's account at Comerica 
Bank.)
    According to an FEC filing dated January 8, 1996, on or 
about April 17, 1995, your campaign disbursed $78.04 to Knossos 
Art Shop in Crete, Greece for ``art object'' re: 
``fundraiser.'' On the same date, your campaign disbursed 
$147.00 to Antique Art Shop in Athens, Greece for ``art 
object'' for ``fundraiser''; $24.00 to Opsis Art Shop in 
Athens, Greece for ``art objects'' for ``fundraiser''; and 
$357.43 to Mazarakis & Sons, Ltd. in Athens, Greece for ``art 
object'' for ``fundraiser.'' Please be advised that there is no 
record of any of the above disbursements in either the campaign 
check register or in monthly bank statements of the campaign 
account at Comerica Bank. Who made those expenditures, and for 
what purpose? What was the disposition of the art purchased in 
Greece? Please provide information regarding any fundraising 
event at which art purchased in Greece was either sold or 
auctioned, including the date and location of the fundraiser 
and the amount of contributions received.
    According to an FEC filing dated January 8, 1996, on or 
about May 16, 1995, your campaign disbursed the following 
amounts to ``Senegal Art Market'' in Senegal: $3,198.57 for 
``art objects'' for a ``fundraiser''; $650.00 for ``art 
carving'' for a ``fundraiser''; $200.00 for ``art carvings'' 
for ``D.C. Office''; and $70.00 for ``art carvings'' for 
``Dist. Office.''  Did you travel to Senegal in 1995? If so, 
please describe the purpose of the travel, and explain how the 
purpose related to your campaign. Who made those expenditures, 
and for what purpose? What was the disposition of the art 
objects purchased? Please provide information regarding any 
fundraising event at which art purchased in Senegal was either 
sold or auctioned, including the date and location of the 
fundraiser and the amount of contributions received.
    According to an FEC filing dated January 8, 1996, on or 
about May 31, 1995, your campaign made the following 
disbursements: $813.20 to National Palace Museum, Taipei, 
China, for ``art objects'' for ``fundraiser''; $20.47 to 
National Palace Museum, Taipei, China, for ``art object'' for 
``fundraiser''; $161.38 to National Palace Museum in Taipei, 
China, for ``art object'' for ``fundraiser''; $82.68 to DFS 
Taiwan, Ltd. in Taiwan for ``art object'' for ``fundraiser''; 
$177.42 to Taiwan Handicraft in Taiwan for ``art objects'' for 
``fundraiser''; and $179.67 to Taiwan Handicraft in Taiwan for 
`'art objects'' for ``fundraiser.'' Who made those 
expenditures, and for what purpose? What was the disposition of 
the art objects purchased? Please provide information regarding 
any fundraising event at which art purchased in Taipei was 
either sold or auctioned, including the date and location of 
the fundraiser and the amount of contributions received.

D. Miscellaneous campaign expenditures

    On or about March 3, 1994, your campaign issued check #1626 
in the amount of $3,282.00, payable to ``Cash'' for 
``Reimbursement.'' The check was co-signed by yourself and 
Cynthia Simpson, and was endorsed by you. The corresponding 
check stub indicates the purpose of the check relates to the 
``Hyatt Regency'' for ``Reimbursement.'' Please explain the 
purpose of this check and provide a full accounting of any 
expenses that you personally incurred for which you sought 
reimbursement from the campaign.
    On or about August 31, 1994, your campaign issued check 
#1757 in the amount of $6,000.00, payable to Samric Agencies, 1 
Kennedy Square, Detroit, for ``public relations.'' The 
subcommittee understands that Samric Agencies was operated at 
the time by Lamar and Lydia Richardson, your bother and sister-
in-law. Please provide documentation concerning any services 
provided by Samric Agencies in connection with this campaign 
disbursement.
    On or about October 24, 1994, your campaign issued check 
#1790 in the amount of $3,000.00, payable to Cynthia Simpson, 
for ``Staff Salaries for Poll Workers 11-8-95 Elex.'' The check 
was co-signed by Cynthia Simpson and Eugene Pettis and was 
endorsed by Ms. Simpson. Please explain why the campaign needed 
to spend $3,000 in salaries for poll workers for a general 
election in which, for all practical purposes, you were 
unopposed. Also, please provide a full accounting of what 
Cynthia Simpson did with the $3,000.00 check and the proceeds 
therefrom.
    On or about November 1, 1994, your campaign issued check 
#1759 in the amount of $948.00, payable to Delta Fashion Watch 
for ``Inner Circle gifts.'' Plese explain the nature and 
purpose of this expenditure, and identify the recipients of the 
clocks. Also, please explain why, in the FEC filing dated 
December 8, 1994, your campaign reported that the cost of these 
clocks was $8,500.00.
    On or about November 8, 1994, your campaign issued check 
#1797 in the amount of $3,000.00, payable to your brother Lamar 
Richardson for ``services rendered.'' Please specify the 
services rendered and provide supporting documentation.
    On or about November 11, 1994, your campaign issued check 
#1800 in the amount of $1,000.00, payable to Jerry Springs for 
``Petty Cash.'' Contrary to bank signature requirements, the 
check was signed by only one person, Joyce Smith, and was 
endorsed by Mr. Springs. What was the purpose of this check? 
What types of ``petty'' expenses did the campaign incur? Why 
did the campaign need so large an infusion of petty cash after 
the general election? Why was a campaign check for ``petty 
cash'' made payable to your District Office Director? Why did 
only one person sign the check? What did Mr. Springs do with 
the proceeds from the check?
    On or about January 25, 1995, your campaign issued check 
#1837 in the amount of $2,400.00, payable to ``Cash'' for ``E & 
H Printing.'' The corresponding check stub indicates that the 
disbursement pertained to the purchase of ``stationery.'' 
Contrary to bank signature requirements, the check was signed 
by only one person--yourself--and was endorsed by Jerry 
Springs. Please confirm the purpose of this disbursement. Why 
was the disbursement made payable to cash, rather than directly 
to E & H Printing? Why was the check endorsed by Mr. Springs, 
rather than by the campaign treasurer, Cynthia Simpson?
    On or about January 31, 1995, your campaign issued check 
#1834 in the amount of $1,000.00, payable to Jerry Springs for 
``petty cash.'' The corresponding campaign check stub states 
that the payment was for ``petty cash,'' while the FEC filing 
dated January 8, 1996, reported that the purpose of the 
disbursement was ``office supplies, coffee, tea, cups, sugar . 
. .'' relating to ``constituents, visits.'' The check was co-
signed by you and Joyce Smith and was endorsed by Jerry 
Springs. Please confirm the purpose of this disbursement. Why 
was the check made payable to Jerry Springs? What did Mr. 
Springs do with the proceeds of the check?
    On or about March 28, 1995, your campaign issued check 
#1855 in the amount of $1,500.00, payable to ``Cash'' for 
``Petty Cash.'' The check was co-signed by yourself and Cynthia 
Simpson and was endorsed by both Cynthia Simpson and Jerry 
Springs. Please explain why $1,500 in additional funds were 
necessary for petty cash less than two months after $1,000.00 
was disbursed for petty cash purposes. In addition, please 
explain why this check was endorsed by Mr. Springs, and provide 
a full accounting of how this money was spent.
    On or about July 7, 1995, your campaign issued check #1879 
in the amount of $1,500.00, payable to ``Cash'' for ``Petty 
Cash.'' The check was co-signed by yourself and Eugene Pettis 
and was endorsed by Jerry Springs. Please explain why this 
check was endorsed by Jerry Springs, and provide a full 
accounting of how this money was spent.

               iii. misuse of scholarship fund resources

    On or about May 3, 1994, the Collins Congressional 
Community Scholarship Committee (CCCSC) issued check #1053 in 
the amount of $9,800.00, drawn on its account at Riggs National 
Bank in Washington, D.C. The check was payable to ``cash'' for 
``Scholarships,'' and was signed and endorsed by you. On or 
about May 4, 1994, the check was deposited into your personal 
checking account at the Credit Union.
    On or about August 15, 1994, the CCCSC issued check #1050 
in the amount of $1,200.00, payable to Barbara-Rose Collins for 
``Kande Dean.'' The check was signed and endorsed by yourself.
    On or about October 24, 1994, the CCCSC issued check #1058 
in the amount of $3812.11, payable to American Express for 
``AC# 3728-334-213-25001'' [sic], which appears to be your 
personal account.
    On or about November 9, 1994, the CCCSC issued check #1073 
in the amount of $8,000, payable to ``Valerie Nicholas'' for 
``Festival of Giving.'' The check was signed by you and 
endorsed by Valerie Nicholas, then an employee of your 
Washington, D.C. office. The subcommittee has received 
information that, on your instructions, Ms. Nicholas cashed the 
check and gave the proceeds directly to you. The subcommittee 
also has learned that you received the cash proceeds one or two 
days before you and Meredith Cooper departed the United States 
for a trip to India.
    On or about May 9, 1995, the CCCSC issued check #1081 in 
the amount of $8900.00, payable to ``Comerica/Cash'' for 
``Classic Consignments.'' The check was signed by you. On or 
about the same date, the check was deposited into your personal 
bank account (account #0933802290) at Comerica Bank in Detroit. 
This check appears to relate to your purchase of personal items 
from Classic Consignments, a business located in California. On 
or about May 7, 1995, you wrote a check (check #2898) drawn on 
your account at the Credit Union in the amount of $5,000.00, 
payable to Classic Consignments. The subcommittee has obtained 
information that you purchased a lamp, chandeliers, and other 
personal items from Classic Consignments. In addition, the 
subcommittee is aware that on or about June 1, 1995, you wrote 
a personal check (check #9685) drawn on Comerica Bank account 
#0933-80229-0 in the amount of $8,900, payable to the CCCSC for 
``Reimburse Ch#1081.'' Bank records indicate that the latter 
check was not deposited into the CCCSC account at Riggs Bank 
until September 20, 1995, and that Comerica Bank did not pay 
the check until September 21, 1995.
    On or about October 3, 1995, you wrote a check drawn on the 
Riggs Bank account of the CCCSC (check #1091) in the amount of 
$3888.90, payable to American Express for ``CBC Week Hotel 
Expenses & Misc. Hyatt Regency.''
    On or about October 27, 1995, you closed the Riggs Bank 
account of the CCCSC in Washington, D.C. The balance of the 
account when it was closed was $12,367.91. On or about the same 
day, you obtained a cashier's check from Riggs Bank in 
Washington, D.C. in the amount of $6,853.91 (check #1550748), 
payable to you. Also on the same day, you obtained a cashier's 
check from Riggs Bank (check #1550745) in the amount of $4,000, 
payable to ``Operation Get Down.'' That cashier's check bears 
your endorsement and the handwritten note, ``Not used for 
purpose intended.''
    In addition to the foregoing, the Committee requests that 
you respond to the following questions:
    1. What was the purpose of the ``Michigan Bash'' events 
held in Washington, D.C. in 1994 and 1995? How did that purpose 
relate to the purpose of the CCCSC? Why were financial sponsors 
of the 1994 Michigan Bash directed to make their contributions 
to the CCCSC?
    2. What is (or was) the relationship between the Collins 
Congressional Community Scholarship Committee and: (1) the 
Congressional Black Caucus Foundation; (2) ``Operation Get 
Down''; and (3) the ``Festival of Giving?'' How do those 
organizations or events further the purposes of the CCCSC? What 
is your relationship to those organizations or events?
    3. On or about June 25, 1995, you caused a check (#2939) 
drawn on your personal account at the Credit Union to be issued 
to the Queen's Community Workers in the amount of $2,000.00. On 
July 28, 1995, you wrote a check drawn on the CCCSC account 
(#1088) in the amount of $2,0000.00, payable to cash for 
``Scholarship--Queen's Community Workers.'' On or about July 
28, 1995, that check was deposited into your personal account 
at the credit union. Please explain why you wrote a personal 
check for scholarship, instead of a check drawn on the account 
of the CCCSC. In addition, please identify the Queen's 
Community Workers and the individuals who receive scholarships 
based in any way on the $2,000.00 disbursement.
    4. Were any CCCSC funds used, directly or indirectly, to 
pay for travel to Washington, D.C. by Leon Robinson to attend 
any event related to the Congressional Black Caucus, or for any 
hotel accommodations for Mr. Robinson during such a visit?
                               APPENDIX P

                                      Brand, Lowell & Ryan,
                                   Washington, DC, August 26, 1996.
Re Hon. Barbara-Rose Collins.
Hon. Jim Bunning,
Chairman, Investigative Subcommittee, House of Representatives, 
        Committee on Standards of Official Conduct, Washington, DC.

Hon. Robert A. Borski,
Investigative Subcommittee, House of Representatives, Committee on 
        Standards of Official Conduct, Washington, DC.
    Dear. Representative Bunning and Representative Borski: 
Rep. Barbara-Rose Collins submits this letter pursuant to Rule 
17(a) of the Rules of the Committee on Standards of Official 
Conduct of the U.S. House of Representatives. At this time, 
Rep. Collins, upon the advice of counsel, respectfully declines 
the Committee's invitation to present, orally or in writing, a 
statement regarding the questions arising out of the 
Preliminary Inquiry as set forth in the Committee's letter 
dated July 25, 1996.
    Additionally, Rep. Collins requests that the Committee 
declare its inquiry to be moot in light of the primary election 
results for her district.
            Respectfully submitted,
                                                  Jonathan S. Feld.
                               APPENDIX Q

 Investigative Subcommittee of the Committee on Standards of Official 
      Conduct in the Matter of Representative Barbara-Rose Collins

                     statement of alleged violation

                      (Adopted September 12, 1996)

I. Revelant standard of conduct and laws
    At all times relevant to the violations hereafter alleged, 
the pertinent provisions of House Rules and laws stated as 
follows:

        a. house rule xliii, clause 1 (code of official conduct)


    ``A member, officer or employee of the House of 
Representatives shall conduct himself at all times in a manner 
which shall reflect creditably on the House of 
Representatives.''


        b. house rule xliii, clause 6 (code of official conduct)


    ``A Member of the House of Representatives shall keep his 
campaign funds separate from his personal funds. A Member shall 
convert no campaign funds to personal use in excess of 
reimbursement for legitimate and verifiable campaign 
expenditures and shall expend no funds from his campaign 
account not attributable to bona fide campaign or political 
purposes.''


        c. house rule xliii, clause 8 (code of official conduct)


    ``A Member or officer of the House of Representatives shall 
retain no one under his payroll authority who does not perform 
official duties commensurate with the compensation received in 
the offices of the employing authority.''


                           d. house rule xlv


    ``No Member may maintain or have maintained for his use an 
unofficial office account.'' According to the Committee's 
interpretation of Rule 45, ``outside private donations, funds, 
campaign contributions, or in-kind services may not be used to 
support the activities of, or pay the expenses of. a 
congressional office.'' (House Ethics Manual at 217.) Private 
funds may be used ``only to support private or political, and 
not official, activities.'' (Id. at 218; see also id. at 221.)


                       e. 31 u.s.c. Sec. 1301(a)


    ``Appropriations shall be applied only to the objects for 
which the appropriations were made except as otherwise provided 
by law.''


     f. committee on house administration, congressional handbook, 
  regulations for allowances and expenses of members, committees and 
                         employees (june 1993)


    Salary adjustments of an employee of a Member ``should 
reflect services performed during the particular pay period or 
may reflect exceptional performance during the course of an 
allowance year. Increases should be made only when the services 
of the individuals(s) warrant.'' (Page 7)
    ``Each Member is authorized an Official Expenses Allowance 
to pay ordinary and necessary business expenses incurred by the 
Member (and/or the Member's employees) . . . . in support of 
the conduct of the Member's official and representational 
duties to the district from which he/she was elected. . . . 
This allowance may not be used to defray any personal, 
political or campaign related expenses . . . or expenses 
related to the conduct of other than official and 
representational business.'' (Page 23)
    ``Each Member and his/her clerk-hire employees may be 
reimbursed for travel expenses incurred in support of the 
conduct of the Member's official and representational duties to 
the district from which the Member was elected. (Page 36)
    ``Travel expenses incurred by someone other than the Member 
or his/her employees are not payable from the Official Expenses 
Allowance.'' (Page 36)
    ``Travel expenses incurred in support of the conduct of 
personal, political, or campaign-related business . . . or in 
support of the conduct of other than official and 
representational business are not payable from the Official 
Expenses Allowance.'' (Page 36)


   g. committee on house oversight, member's congressional handbook, 
 regulations governing the members' representational allowance of the 
                  u.s. house of representatives (1995)


    ``All Members have one `Members' Representational 
Allowance' (MRA) available to support the conduct of official 
and representational duties to the district from which elected. 
. . . The MRA may not be used to pay for any personal, 
political, campaign, or committee expenses. (Page 1) (Emphasis 
in original)
    ``Members may adjust, in any month, a Clerk Hire employee's 
salary to reflect exceptional, meritorious, or less than 
satisfactory service.'' (Page 9)
    ``Travel expenses incurred by someone other than Members or 
their Clerk Hire employees are not reimbursable from the MRA.'' 
(Page 46) (Emphasis in original)

   H. Regulations Regarding Solicitation Promulgated by Committee on 
                     Standards of Official Conduct

    The House Ethics Manual states that ``Members, officers, 
and employees of the House may solicit funds on behalf of 
charitable organizations qualified under Sec. 170(c) of the 
Internal Revenue Code, provided that no official resources are 
used, no official endorsement is implied, and no direct 
personal benefit results. No solicitation may bear official 
letterhead, the Great Seal, or the terms `Congress of the 
United States,' `House of Representatives,' or `official 
business.' . . . . Questions regarding solicitations on behalf 
of entities that are not charities qualified under Sec. 170(c) 
should be addressed to the Committee.'' (House Ethics Manual at 
51) (emphasis in original). That guidance is based on an 
October 9, 1990, memorandum from the Committee on Standards of 
Official Conduct to all Members, Officers, and Employees of the 
House of Representatives. In addition to the guidance discussed 
above, that memorandum states: ``The Committee will address on 
a case-by-case basis the extent to which a Member, officer, or 
employee may personally control the distribution of funds from 
a charity for which he or she solicits funds.'' (House Ethics 
Manual at 65)

II. Alleged violations

   Count I--Misuse of official resources (Campaign activity by House 
                               employees)

    The record indicates that during calendar years 1994 and 
1995, House employees in the district and Washington, D.C. 
congressional offices of the Respondent, Representative 
Barbara-Rose Collins, regularly performed work for the 
Respondent's campaign at times when they should have been 
performing official duties, and often in the congressional 
office, with the Respondent's knowledge and approval. Such 
activities included: (1) collecting campaign contribution 
checks from a campaign post office box; (2) depositing campaign 
contribution checks; (3) maintaining the financial records of 
the Respondent's campaign organization; (4) paying the 
campaign's bills; and (5) organizing campaign events. Because 
the Respondent permitted appropriations to be applied to 
objects other than those for which the appropriations were 
made, the Committee has reason to believe that the Respondent 
violated 31 U.S.C. Sec. 1301(a) and corresponding Regulations 
of the Committee on House Administration and the House 
Committee on Oversight. Because of the frequency with which 
employees of the Respondent performed campaign-related 
activities in the manner described above, and the Respondent's 
knowledge and approval of such activities, the Committee also 
has reason to believe that the Respondent conducted herself in 
a manner that does not reflect creditably on the House of 
Representatives, in violation of the Code of Official Conduct 
as set forth in Clause 1 or Rule XLIII of the House of the 
Representatives.

   Count II--Misuse of official resources (Use of official funds for 
                           campaign purposes)

    The record indicates that on or about April 4, 1995, Jerry 
Springs, an employee of the Respondent's congressional office 
in Detroit, traveled to Washington D.C. for the primary purpose 
of attending a fundraising event benefiting the Respondent's 
campaign committee. The record also indicates that, with the 
Respondent's knowledge and approval, official funds of the 
House of Representatives were used to pay for Mr. Springs' 
lodging in Washington. The record indicates that the 
Respondent's congressional office in Washington, D.C. submitted 
a voucher to the House Office of Finance regarding Mr. Springs' 
lodging expenses, which represented that the purpose of the 
travel was ``official business.'' The record also indicate that 
the Respondent signed and approved that voucher.
    The record further indicates that the Respondent's 
congressional office, with the knowledge and approval of the 
Respondent, used official funds of the House of Representatives 
to purchase a round-trip airline ticket form Detroit to 
Washington, D.C. in the name of Milton Harris, another employee 
of the Respondent's Detroit congressional office. The record 
indicates that the Respondent's congressional office submitted 
a voucher to the House Office of Finance regarding the cost of 
Mr. Harris' round-trip air transportation, which represented 
that the purpose of the travel was ``official business.'' The 
record also indicates that the Respondent signed and approved 
that voucher. The record indicates that Mr. Harris did not use 
the airline ticket purchased in his name, and that instead, the 
ticket was used by Leon Robinson, a personal friend of the 
Respondent's who was not employed by the House of 
Representatives, with the knowledge and approval of the 
Respondent.
    Because the Respondent permitted appropriations to be 
applied to objects other than those for which the 
appropriations were made, the Committee has reason to believe 
that the Respondent violated 31 U.S.C. Sec. 1301(a) and 
corresponding Regulations of the Committee on House 
Administration and the House Committee on Oversight. For the 
reasons cited above, the Committee also has reason to believe 
that the Respondent acted in a manner that does not reflect 
creditably on the House of Representatives, in violation of the 
Code of Official Conduct as set forth in Clause 1 of Rule XLIII 
of the House of the Representatives.

   Count III--Misuse of official resources (Performance of personal 
                      services by House employees)

    The record indicates that during calendar years 1994 and 
1995, House employees in the Respondent's congressional offices 
in Detroit and Washington, D.C. regularly performed personal 
services for the Respondent at times when they should have been 
performing official duties, within the Respondent's knowledge 
and approval. Such personal services included: (1) paying the 
Respondent's personal bills; (2) picking up the Respondent's 
personal mail; (3) cleaning the Respondent's personal 
residence; and (4) affording access to the Respondent's 
personal residence for deliveries and the performance of 
personal services. Because the Respondent permitted 
appropriations to be applied to objects other than those for 
which the appropriations were made, the Committee has reason to 
believe that the Respondent violated 31 U.S.C. Sec. 1301(a) and 
corresponding Regulations of the Committee on House 
Administration and the House Committee on Oversight. Because of 
the regularity with which House employees performed personal 
services for the Respondent, the Committee also has reason to 
believe that the Respondent conducted herself in a manner that 
does not reflect creditably on the House of Representatives, in 
violation of the Code of Official Conduct as set forth in 
Clause 1 of Rule XLIII of the House of Representatives.

   Count IV--Misuse of official resources (Improper use of vouchered 
                            postage stamps)

    The record indicates that during calendar years 1994 and 
1995, the Washington, D.C. congressional office of the 
Respondent purchased first-class postage stamps with official 
funds that were used by employees of the Respondent's 
congressional offices to pay the Respondent's personal bills 
and bills incurred by the Respondent's campaign committee, with 
the knowledge and approval of the Respondent. Because the 
Respondent permitted appropriations to be applied to objects 
other than those for which the appropriations were made, the 
Committee has reason to believe that the Respondent violated 31 
U.S.C. Sec. 1301(a) and corresponding Regulations of the 
Committee on House Administration and the House Committee on 
Oversight. Because the record indicates that the above-
described use of vouchered postage stamps occurred with the 
knowledge and approval of the Respondent, the Committee also 
has reason to believe that the Respondent did not conduct 
herself in a manner that reflects creditably on the House of 
Representatives, in violation of the Code of Official Conduct 
as set forth in Clause 1 of Rule XLIII of the House of 
Representatives.

   Count V--Misuse of official resources (Use of official funds for 
                           personal purposes)

    The record indicates that during calendar years 1994 and 
1995, the congressional offices of the Respondent used official 
funds to send several packages by overnight mail concerning the 
Respondent's personal affairs, with the Respondent's knowledge 
and approval. Because the Respondent permitted appropriations 
to be applied to objects other than those for which the 
appropriations were made, the Committee has reason to believe 
that the Respondent violated 31 U.S.C. Sec. 1301(a) and 
corresponding Regulations of the Committee on House 
Administration and the House Committee on Oversight. Because 
the record indicates that official funds were used in the 
manner described with the knowledge and approval of the 
Respondent, the Committee also has reason to believe that the 
Respondent did not conduct herself in a manner that reflects 
creditably on the House of Representatives, in violation of the 
Code of Official Conduct as set forth in Clause 1 of Rule XLIII 
of the House of Representatives.

  Count VI--Misuse of campaign resources (Commingling and conversion)

    The record indicates that funds from the Respondent's 
campaign committee improperly were used for the Respondent's 
personal purposes on several occasions during calendar years 
1994 and 1995, with the knowledge and approval of the 
Respondent.
    1. The record indicates that on or about June 30, 1994, the 
Respondent's campaign committee, ``Friends of Barbara-Rose 
Collins,'' issued a check in the amount of $3,911.00 payable to 
Barbara-Rose Collins, purportedly for reimbursement of expenses 
concerning a campaign event. The record also indicates that the 
Respondent endorsed that check and, on or about July 1, 1994, 
caused it to be deposited in her personal checking account at 
the Wright Patman Congressional Credit Union (``Credit 
Union'').
    2. The record indicates that on or about August 3, 1994, 
Friends of Barbara-Rose Collins issued a check in the amount of 
$2,900.00 payable to ``Cash'' in connection with fundraising 
events and the NAACP. The record also indicates that the 
Respondent endorsed the check and, on or about August 5, 1994, 
caused it to be deposited in her personal checking account at 
the Credit Union.
    3. The record indicates that:
          a. On or about November 8, 1994, Friends of Barbara-
        Rose Collins issued a check in the amount of $8,500.00 
        payable to Jerry Springs, District Director of the 
        Respondent's congressional office in Detroit, 
        purportedly for election day poll workers and other 
        election day expenses.
          b. On the same day November 8, 1994, Mr. Springs 
        cashed the same $8,500.00 check at Comerica Bank in 
        Detroit.
          c. On or about November 14, 1994, Mr. Springs used 
        cash to purchase a cashier's check at Comerica Bank in 
        Detroit in the amount of $8,500.00, made payable to 
        Barbara-Rose Collins.
          d. On or about November 15, 1994, the same cashier's 
        check purchased by Mr. Springs in the amount of 
        $8,500.00 was deposited into the Respondent's personal 
        checking account at the Credit Union.
    4. The record indicates that:
          a. On or about March 6, 1995, Friends of Barbara-Rose 
        Collins issued a check in the amount of 2,400.00, 
        payable to ``Comerica.'' That check was co-signed and 
        endorses by the Respondent.
          b. On or about the same day, March 6, 1995, Cosmerica 
        Bank in Detroit issued a cashier's check payable to 
        Barbara-Rose Collins in the amount of $2,400.00.
          c. On or about March 9, 1995, $2,400.00 was deposited 
        into the Respondent's checking account at the Credit 
        Union.
    5. The record indicates that:
          a. On or about August 7, 1995, the Respondent 
        purchased a freezer, oven, and electric dryer from ABC 
        Warehouse in Southfield, Michigan.
          b. The Respondent effected that purchase by means of 
        a check in the amount of $913.72 drawn on the account 
        of Friends of Barbara-Rose Collins and signed by the 
        Respondent.
          c. The Respondent instructed a salesperson at ABC 
        Warehouse to have the oven and dryer delivered to her 
        vacation home at Shay Lake, Michigan.
          d. Employees of the Respondent's congressional office 
        in Detroit subsequently delivered the oven and dryer to 
        the Respondent's home at Shay Lake, Michigan.
          e. On or about October 3, 1995, the Respondent issued 
        a personal check in the amount of $354.00 payable to 
        the Friends of Barbara-Rose Collins in partial 
        reimbursement for the campaign's purchase of the oven 
        and dryer.
    Based on the foregoing, the Committee has reason to believe 
that the Respondent commingled campaign and personal funds, and 
converted campaign funds to personal use, in violation of the 
Code of Official Conduct as set forth in Clause 6 of Rule XLIII 
of the House of Representatives. In addition, the Committee has 
reason to believe that the Respondent conducted herself in a 
manner that does not reflect creditably on the House of 
Representatives, in violation of the Code of Official Conduct, 
as set forth in Clause 1 of Rule XLIII of the House of the 
Representatives.

Count VII--Misuse of campaign funds (Expenditure of campaign funds not 
       attributable to bona fide campaign or political purposes)

    The record indicates that the Respondent's campaign 
committee made numerous expenditures during calendar years 1994 
and 1995 that were not attributable to bona fide campaign or 
political purposes, with the knowledge and approval of the 
Respondent.
    1. The record indicates that on or about October 26, 1994, 
the Respondent caused a check to be issued on the account of 
her campaign committee in the amount of $1,000.00, payable to 
Detroit Edison. A handwritten annotation on the check indicated 
that the purpose of the check was to ``Reconnect 19713 
Ridgemont St. Clair Shores,'' while a campaign filing with the 
Federal Election Commission (``FEC'') dated January 8, 1996, 
indicated that the purpose of the disbursement was to 
``reconnect 19731 Ridgemont constituents.'' The $1,000.00 
campaign expenditure was made on behalf of Joyce Smith, an 
employee of the Respondent's Detroit congressional Office, for 
the purpose of enabling Ms. Smith to pay her residential 
electric bill. Ms. Smith was not a constituent at the time of 
the payment, and she later reimbursed the Respondent in two 
direct cash payments of $500.00 each.
    2. The record indicates that on or about December 6, 1994, 
a check drawn on the account of the Respondent's campaign 
committee was issued in the amount of $4,000.00, payable to 
Jerry Springs, District Director of the respondent's 
congressional office in Detroit. The record indicates that Mr. 
Springs cashed the check on or about December 7, 1994. A 
campaign filing with the FEC dated January 8, 1996, represented 
that he purpose the expenditure related to the ``Panafest 
event,'' while the check register corresponding to the 
$4,000.00 check stated that the purpose of the payment 
concerned the ``Panafest Reception.'' The record indicates that 
the term ``Panafest'' pertains to an event that occurred in 
Ghana during a personal visit there in December 1994 by the 
Respondent and members of her congressional staff, including 
Mr. Springs.
    3. The record indicates that:
          a. On or about January 20, 1995, a check drawn on the 
        account of the Respondent's campaign committee, co-
        signed by the Respondent, was issued in the amount of 
        $8,043.11, payable to American Express.
          b. That payment to American Express related at least 
        in part to personal expenses incurred by the Respondent 
        at the ``Golden Tulip Hotel,'' which, according to the 
        record, is a hotel in Ghana that the Respondent visited 
        during her December 1994 trip to Africa.
          c. According to documents filed with the FEC by the 
        Respondent's campaign committee, on or about February 
        10, 1995, the Respondent's campaign committee disbursed 
        $1,673.00 to ``African Art Market in Accra, Ghana'' for 
        ``Art objects for offices'' in ``DC/District.''
    4. On or about February 9, 1995, a check drawn on the 
account of the Respondent campaign committee was issued in the 
amount of $300.00, payable to ``Mary Pointer'' for ``Services 
Rendered.'' The corresponding check register also stated that 
the purpose of the expenditure was ``services rendered,'' while 
a campaign filing with the FEC dated January 8, 1996, 
represented that he purpose concerned ``maintenance campaign 
mtgs.'' The record indicates that the $300.00 in campaign funds 
were used to pay for the cleaning of the Respondent's personal 
residence in Detroit.
    Based on the foregoing, the Committee has reason to believe 
that the Respondent violated the Code of Official Conduct as 
set forth in Clause 6 of Rule XLIII of the House of 
Representatives. In addition, the Committee has reason to 
believe that the Respondent conducted herself in a manner that 
does not reflect creditably on the House of representatives, in 
violation of the Code of Official Conduct as set forth in 
Clause 1 of Rule XLIII of the House of Representatives.

           Count VIII--Misuse of Scholarship Committee Funds

    The record indicates that the Respondent commingled with 
personal funds, and converted to personal use, funds of the 
Collins Congressional Community Scholarship Committee 
(``CCCSC'') on several occasions during calendar years 1994 and 
1995.
    1. The record indicates that on or about May 3, 1994, a 
check drawn on the account of the CCCSC was issued in the 
amount of $9,800.00, payable to ``Cash'' for ``Scholarships.'' 
The record indicates that the Respondent signed and endorsed 
that check. The record further indicates that on or about May 
4, 1994, the same check in the amount of $9,800.00 was 
deposited into the Respondent's personal checking account at 
the Credit Union.
    2. The record indicates that on or about August 15, 1994, a 
check drawn on the account of the CCCSC was issued in the 
amount of $1,200.00, payable to Barbara-Rose Collins for 
``Kande Dean.'' The record indicates that the Respondent signed 
and endorsed that check, and that the check was cashed on or 
about August 15, 1994.
    3. The record indicates that on or about October 24, 1994, 
a check drawn on the account of the CCCSC was issued in the 
amount of $3,812.11, payable to American Express. The record 
also indicates that this payment was made in connection with 
the Respondent's personal American Express account.
    4. The record indicates that on or about November 9, 1994, 
a check drawn on the account of the CCCSC was issued in the 
amount of $8,000.00, signed by Barbara-Rose Collins and payable 
to Valerie Nicholas for ``Festival of Giving.'' At the time, 
Ms. Nicholas was an employee of the Respondent's congressional 
office in Washington, D.C. The Respondent directed Ms. Nicholas 
to cash the check on behalf of the Respondent, and to bring the 
cash to the Respondent at her home. On or about November 10, 
1994, Ms. Nicholas cashed the $8,000.00 check at Riggs Bank in 
Washington, D.C. and delivered the cash proceeds to the 
Respondent at her home in Virginia.
    5. The record indicates that:
          a. On or about May 7, 1995, the Respondent issued a 
        check drawn on her personal account at the Credit Union 
        in the amount of $5,000.00, payable to ``Classic 
        Consignments.'' Classic Consignments is a business in 
        Palm Desert, California, that sells second-hand home 
        furnishings and other merchandise.
          b. On or about May 9, 1995, a check drawn on the 
        account of the CCCSC was issued in the amount of 
        $8,900.00, payable to ``Comercia/Cash'' for ``Classic 
        Consignments.'' The Respondent signed the check.
          c. On or about May 9, 1995, the same $8,900 check 
        drawn on the account of the CCCSC was deposited into 
        the Respondent's personal account at Comerica Bank in 
        Detroit.
          d. On or about May 13, 1995, the Respondent purchased 
        several personal items from Classic Consignments, 
        including chandeliers and a Tiffany lamp, at a cost of 
        $4,440.00. The Respondent ordered the delivery of the 
        items to her home in Detroit, bringing the total cost 
        of the transaction to approximately $5,646.00.
          e. On or about June 1, 1995, the Respondent issued a 
        check drawn on her personal account at the Credit Union 
        in the amount of $8,900.00, payable to the CCCSC in 
        reimbursement for $8,900.00 drawn from the CCCSC 
        account on or about May 9, 1995. On or about September 
        20, 1995, that check was deposited into the CCCSC 
        account at Riggs Bank in Washington, D.C.
    6. On or about October 3, 1995, a check drawn on the 
account of the CCCSC was issued in the amount of $3,888.90, 
payable to American Express for ``CBC Week Hotel Expenses & 
Misc. Hyatt Regency.'' Respondent signed the check. The record 
indicates that the proceeds from the check were used in 
connection with an annual social event in Washington, D.C. 
relating to the Congressional Black Caucus.
    7. The record indicates that on or about October 27, 1995, 
the Respondent closed the bank account of the CCCSC at Riggs 
Bank in Washington, D.C. In closing the account, Respondent 
issued a check drawn on the account in the amount of 
$12,367.91, made payable to ``Riggs/Barbara-Rose Collins.'' On 
or about the same day, the Respondent cashed the check in the 
amount of $12,367.91 and used the cash proceeds to purchase a 
cashier's check from Riggs Bank in the amount of $6,853.91, 
payable to herself. The Respondent also purchased a second 
cashier's check from Riggs Bank in the amount of $4,000.00, 
payable to ``Operation Get Down.'' The latter cashier's check 
bears the Respondent's endorsement and, beneath the 
endorsement, the handwritten annotation, ``Not used for purpose 
intended.''
    Based on the foregoing, the Committee has reason to believe 
that the Respondent conducted herself in a manner that does not 
reflect creditably on the House of Representatives, in 
violation of the Code of Official Conduct as set forth in 
Clause 1 of Rule XLIII of the House of Representatives.

              Count IX--Maintenance of unofficial account

    1. The record indicates that in early October 1995, Jerry 
Springs, the District Director of the Respondent's 
congressional office in Detroit, transmitted a check in the 
amount of $500.00, drawn on the account of the Respondent's 
campaign committee, to Deputy District Director Cecilia Walker. 
A handwritten annotation on the check indicates that the 
purpose of the check was to provide a fund for ``petty cash'' 
expenses, and the record indicates that Mr. Springs advised Ms. 
Walker that the check was to be used for petty cash purposes. 
In addition, in late October or early November 1995, the 
Respondent personally gave a check in the amount of $1,000.00, 
drawn on her campaign committee's account, to Ms. Walker with 
instructions to use the money for petty cash expenses. The 
Respondent directed Ms. Walker to use petty cash consisting of 
campaign funds for expenditures concerning the district 
congressional office. The record also indicates that the petty 
cash fund was used to purchase items for the Respondent's 
congressional office in Detroit.
    2. The record indicates that on or about May 16, 1995, the 
Respondent's campaign committee disbursed $270.00 to the 
``Senegal Art Market'' to purchase ``art carvings'' for the 
Respondent's congressional offices in Washington, D.C. and 
Detroit.
    Because outside donations, including campaign 
contributions, may not be used to support the activities of, or 
pay the expenses of, a congressional office, the Committee has 
reason to believe that the Respondent violated Rule XLV of the 
House of Representatives. Because the Respondent conducted 
herself in a manner that does not reflect creditably on the 
House of Representatives, the Committee also has reason to 
believe that the Respondent violated the Code of Official 
Conduct as set forth in Clause 1 of Rule XLIII of the House of 
the Representatives.

  Count X--House employee raises not commensurate with official duties

    The record indicates that in the summer and fall of 1994, 
the Respondent awarded substantial bonuses to several members 
of her congressional staff in the form of temporary salary 
increases. The record further indicates that each of the House 
employees who received these salary adjustments traveled to 
Africa with Representative Collins in December 1994, that the 
trip to Africa was personal in nature, and that the purpose of 
the adjustments was to enable those employees to pay for their 
travel to Africa. The Committee therefore has reason to believe 
that the compensation awarded to the House employees in 
question was not commensurate with the performance of their 
official duties, and that Representative Collins violated the 
Code of Official Conduct as set forth in Clause 8 of Rule XLIII 
of the House of Representatives. Because the Respondent 
conducted herself in a manner that does not reflect creditably 
on the House of Representatives, the Committee also has reason 
to believe that the Respondent violated the Code of Official 
Conduct as set forth in Clause 1 of Rule XLIII of the House of 
the Representatives.

                    Count XI--Improper solicitation

    The record indicates that on or about August 3, 1994, the 
Respondent's congressional office in Washington, D.C. sent 
letters to private corporations soliciting financial 
contributions to sponsor the ``Michigan Bash IV,'' described in 
the solicitation letter as a ``gala reception'' occurring on 
September 16, 1994, in connection with the Congressional Black 
Caucus. The letter was sent on Representative Collins' official 
congressional letterhead bearing the term ``Congress of the 
United States,'' and it was signed by Representative Collins. 
The letter directed that contribution checks ``should be made 
payable to the Collins Congressional Community Service 
Committee, and forwarded to 1108 Longworth HOB, Washington, 
D.C. 20515''--the location of Representative Collins' 
congressional office at that time. In addition, the letter 
stated that ``[c]hecks will be deposited directly into an 
account set up specifically for the reception.''
    The record indicates that the ``Collins Congressional 
Community Service Committee'' is the same organization known as 
the ``Collins Congressional-Community Scholarship Committee'' 
(``CCCSC''). In addition, the record indicates that (1) the 
CCCSC was not an organization qualified under Sec. 170 of the 
Internal Revenue Code; (2) neither Representative Collins nor 
any member of her congressional staff obtained permission from 
the Committee on Standards of Official Conduct to solicit 
contributions to the CCCSC; (3) a separate financial account 
was not established for the deposit of contribution checks for 
the ``Michigan Bash IV''; (4) several thousand dollars in 
contributions were received as a result of the solicitation for 
the ``Michigan Bash IV''; (5) checks were deposited into the 
pre-existing bank account of the CCCSC in Washington, D.C.; and 
(6) Representative Collins personally exercised control over 
funds in the bank account of the CCCSC.
    Based on the foregoing, the Committee has reason to believe 
that the Respondent violated applicable House rules governing 
solicitations. The Committee also has reason to believe that by 
soliciting private donations to a fund that she controlled, the 
Respondent conducted herself in a manner that does not reflect 
creditably on the House of Representations, in violation of the 
Code of Official Conduct as set forth in Clause 1 of Rule XLIII 
of the House of Representatives.
                               APPENDIX R

                          House of Representatives,
                Committee on Standards of Official Conduct,
                                Washington, DC, September 17, 1996.
Hon. Barbara-Rose Collins,
House of Representatives, Cannon House Office Building,
Washington, DC.
    Dear Representative Collins: On September 12, 1996, the 
Investigative Subcommittee (Subcommittee'') established to 
investigate allegations concerning your conduct as a Member of 
Congress adopted a Statement of Alleged Violation based on 
information that it received during its Preliminary Inquiry. 
Pursuant to Rule 17(d) of the Committee on Standards of 
Official Conduct, the Subcommittee hereby transmits to you the 
attached Statement of Alleged Violation.
    The Statement of Alleged Violation is based on the 
Subcommittee's determination, pursuant to Committee Rule 17(d), 
that there is ``reason to believe'' that violations of laws and 
House rules have occurred.
    Under Committee Rule 18(a)(1), you may submit an answer to 
the Statement of Alleged Violation within 30 days after its 
transmittal. The failure to file an answer within the time 
prescribed will be considered a denial of each count in the 
Statement of Alleged Violation.
    If you submit in answer, it must be in writing and under 
oath, and it must be signed by both you and your attorney. 
Committee Rule 18(a)(2) states that the answer ``shall contain 
an admission to or denial of each count set forth in the 
Statement of Alleged Violation and may include negative, 
affirmative, or alternative defenses and any supporting 
evidence or other relevant information.''
    Under Committee Rule 18(b), you also have the option of 
filing a Motion for a Bill of Particulars within 15 days of 
transmittal of the Statement of Alleged Violation. Should you 
file such a motion, you will not be required to file an answer 
until 15 days after the Subcommittee has replied to the motion.
    In addition, under Committee Rule 18(c)(1), you may file a 
Motion to Dismiss within 15 days after the date of transmittal 
of the Statement of Alleged Violation or, if a Motion for a 
Bill or Particulars has been filed, within 15 days after the 
date of the Subcommittee's reply to the Motion for a Bill of 
Particulars. Under Committee Rule 18(c)(2), a Motion to Dismiss 
``may be made on the grounds that the Statement of Alleged 
Violation fails to state facts that constitute a violation of 
the Code of Official Conduct or other applicable law, rule, 
regulation, or standard of conduct, or on the grounds that the 
Committee lacks jurisdiction to consider the allegations 
contained in the Statement.'' If you file a Motion to Dismiss, 
you will not be required to file an answer until 15 days after 
the Subcommittee has replied to that motion.
    Please be advised that under Committee Rule 18(d), any 
motion that you may file with the Subcommittee must be 
accompanied by a Memorandum of Points and Authorities.
    If you have any questions, you may contact Committee 
Counsel David H. Laufman or Charles J. Willoughby.
            Sincerely,
                                   Jim Bunning,
                                           Chairman.
                                   Robert A. Borski,
                                           Ranking Democratic Member.
    Attachment.
                               APPENDIX S

                                      Brand, Lowell & Ryan,
                                   Washington, DC, October 2, 1996.
Re Representative Barbara-Rose Collins.
David Laufman,
Counsel, Committee on Standards of Official Conduct, House of 
        Representatives, the Capitol, Washington, DC.
    Dear Mr. Laufman: Enclosed please find Rep. Collins' Motion 
for a Bill of Particulars and Supporting Memorandum. As we 
discussed, you agreed to accept service by facsimile and I will 
mail an additional copy.
    Thank you for your cooperation.
            Sincerely yours,
                                                  Jonathan S. Feld.
    Enclosures.

   U.S. House of Representatives, Committee on Standards of Official 
                                Conduct

 Motion and Memorandum of Points and Authorities in Support of Request 
                        for Bill of Particulars

                            a. introduction

    The Honorable Barbara-Rose Collins respectfully submits the 
following motion and memorandum of points and authorities in 
support of her request for a Bill of Particulars. Despite 
having many months to review the documents, financial accounts 
and interview witnesses, the Subcommittee on Standards of 
Official Conduct (``Subcommittee'') has presented a Statement 
of Alleged Violations (``Statement'') that does not adequately 
apprise Rep. Collins of the specific theories and information 
necessary for her to respond. By utilizing generalizations and 
conclusory terms, the Subcommittee has created the distinct 
probability that Rep. Collins will be unfairly surprised and 
unable to respond meaningfully to the charges.
    Rep. Collins seeks a limited bill of particulars in order 
to protect against this problem. She requests certain specific, 
limited information which will enable her to adequately defend 
herself, prevent unfair surprise, and prevent the unfair 
shifting or altering theories at any adjudicative hearing. 
Listed below are the particularized requests and a supporting 
memorandum.

                          bill of particulars

    The Hon. Barbara-Rose Collins, pursuant to Rule 18b of the 
Rules, Committee on Standards of Official Conduct, seeks the 
following information.
Count I
    (1) Specify the campaign contribution checks that were 
collected and deposited.
    (2) Specify the financial records that were maintained and 
the work that was done in connection with these records.
    (3) Specify the particular campaign bills that were 
allegedly paid.
    (4) Identify the House employees involved in the conduct 
described in Count I.
    (5) Specify the particular events that were organized and 
what particular activities were done to ``organize'' these 
terms.
    (6) Explain the phrase ``when they [House employees] should 
have been performing official duties.''
    (7) Specify the frequency and dates with which employees 
worked on the campaign related activities.
    (8) Explain how Rep. Collins knew and approved of such 
activities.
Count II
    (1) Specify the reasons and evidence supporting that ``the 
primary purpose'' for Jerry Springs' trip to Washington was to 
attend a fund raising event benefiting Rep. Collins' committee.
    (2) Explain what records specify that official funds of the 
House of Representatives were used to pay for Mr. Springs' 
lodging.
    (3) Explain what activities Mr. Springs engaged in in 
Washington, DC.
    (4) Specify the records that show that Milton Harris did 
not use the ticket purchased for him.
    (5) Specify the basis for the allegation that Rep. Collins 
knew that the ticket purchased in the name of Milton Harris, 
was intended to be used by Leon Robinson.

Count III

    (1) Explain and describe the terms ``official duties'' and 
``personal services'' as used in this Count.
    (2) Identify the House employees involved in the conduct 
and the amount of time devoted by each to the ``personal 
services.''
    (3) Specify the time of day when employees used personal 
time to perform the alleged ``personal services,'' and the 
amount of business hours worked by each House employee 
involved.
    (4) Specify the dates, frequency and amount of time 
involved when House employees (a) paid Rep. Collins' personal 
bills; (b) picked up Rep. Collins' personal mail; (c) cleaned 
Rep. Collins' personal residence; and (d) provided access for 
others for the delivery or performance of personal services.
    (5) Explain with precision the term ``regulatory'' as used 
these allegations.

Count IV

    (1) Specify the dates on which official funds were used to 
purchase postage stamps and the total value of the postage.
    (2) Specify how it is determined that ``official funds'' 
were used to purchase the stamps.
    (3) Specify whether stamps were purchased with official 
funds and were used for mailing of official business.
    (4) Identify the personal correspondence on which such 
stamps were placed.
    (5) Explain how postage stamps were used by House employees 
to pay personal bills of Respondent and bills incurred by the 
campaign committee.
    (6) Explain how Rep. Collins knew and approved of these 
practices.

Count V

    (1) Identify and provide dates when the packages were sent 
by overnight mail concerning Rep. Collins' personal affairs for 
which official funds were used as payments.
    (2) Explain the term ``personal affairs'' as used in Count 
V.
    (3) Explain how Rep. Collins knew and approved of this 
conduct.

Count VI

    (1) Specify how the expenditures in subparts (1) and (2) 
did not qualify for reimbursement pursuant to House Rules.
    (2) Explain how personal funds and campaign funds were co-
mingled.
    (3) Specify the cost of the oven and dryer.

Count VII

    (1) Specify the dates that Ms. Smith was a constituent of 
Rep. Collins.
    (2) Explain the basis for determining that the travel to 
Africa constituted a ``personal visit''.
    (3) Explain the basis for determining when a meeting 
qualifies for an expenditure of campaign funds.
    (4) Specify whether Mr. Springs paid for any expenses, and 
the amount, relating to the ``Panafest event.''
    (5) Specify whether campaign activities were ever held at 
Rep. Collins' residence.

Count IX

    (1) Specify the expenditures that were paid for with 
``petty cash'' funds.
    (2) Specify the political or campaign activities that were 
paid from the ``petty cash'' fund.
    (3) Explain what office activities and expenses may be paid 
by campaign funds.
    (4) Explain whether the purchases of ``art carvings'' for a 
congressional office is an ``activity'' or ``expenses'' that is 
reimbursable from official funds.

Count X

    (1) Specify the evidence which indicates that the 
Congressional staff was not properly entitled to receive the 
adjustments in salary.
    (2) Specify the basis on which bonuses and promotions 
should have been made.
    (3) Explain the basis for determining that the trip to 
Africa ``was personal in nature''.
    (4) Explain and specify the evidence that show the 
promotions were solely to enable employees to pay for their 
travel to Africa.
    (5) Specify those employees who received ``substantial 
bonuses'' or ``temporary salary increases'' and did not travel 
to Africa.
    (6) Explain the evaluation system that was used to show 
that the compensation awarded ``was not commensurate with the 
performance of their [House employees] official duties.''

Count XI

    (1) Specify the evidence that shows that Rep. Collins 
instructed that the letter related to Michigan Bash should be 
printed on official stationery.
    (2) Specify any additional times that official stationery 
was used for improper solicitations.
    (3) Explain how the funds in the Collins Congressional 
Community Service Committee or Collins Congressional-Community 
Scholarship Committee were used and the names of the 
recipients.

  Memorandum of Points and Authority in Support of Motion for Bill of 
                              Particulars

 argument--a bill of particulars is mandated by fundamental principles 
                              of fairness

    Rule 18(b) of the Rules of Committee on Standards of 
Official Conduct provides for the filing of a bill of 
particulars. Analogizing to federal practice, the purpose of a 
bill of particulars is multi-faceted: ``[T]o inform the 
[respondent] of the charge[s] . . . with sufficient precision 
to allow [for preparation] of [her] defense, to minimize 
surprise at trial, and to enable [her] to plead double jeopardy 
in the event of a later prosecution for the same offense.'' 
United States v. Cole, 755 F.2d 748, 760 (11th Cir. 1985) 
(citations omitted); see also United States v. Giese, 597 F.2d 
1170, 1180, (9th Cir.), cert. denied, 444 U.S. 979 (1979); 
Yeargin v. United States, 314 F.2d 881, 882 (9th Cir. 1963). A 
bill of particulars, properly viewed, is to provide the 
information necessary for Rep. Collins to defend herself at a 
hearing.
    The object and purpose of a bill of particulars is not to 
supplement charges but to better apprise an individual of the 
pending charges. United States v. Pipkin, 243 F.2d 491 (5th 
Cir. 1957). Since respondents should be presumed innocent, it 
cannot be assumed that they know the particular information 
sought and can only be considered ``ignorant of the facts on 
which the pleader founds his charges.'' Fontana v. United 
States, 262 F. 283, 286 (8th Cir. 1919); United States v. 
Smith, 16 F.R.D. 372, 375 (W.D. Mo. 1954).
    The granting of a bill of particulars is within the 
Subcommittee's power. Such authority should be liberally 
exercised because a statement may be sufficient to state an 
offense, yet be insufficient to adequately inform a 
Representative of the charges to enable the preparation of a 
defense and to avoid prejudicial surprise. United States v. 
Peelle, 122 F. Supp. 923, 924, (E.D.N.Y. 1954) (The charges may 
meet the notice requirements but inform the defendant only as 
to the general nature of the charges against him. The bill of 
particulars is ``meant to remedy just a situation''). Accord, 
United States v. Solomon, 26 F.R.D. 397, 407 (S.D.N.Y. 1960), 
(``[w]hen a Bill of Particulars is warranted, its scope will 
vary from case to case, depending upon the complexity of the 
charges laid in the indictment.'')
    In this case, the Subcommittee has spent at least six 
months reviewing complex transactions, examining copies of 
banking records and receiving testimony on a wide-ranging set 
of matters that encompass a two year period. The breadth of the 
Statement, and the many transactions referenced therein, alone 
justifies Rep. Collins' motion for a bill of particulars. 
However, when the broad scope of the Statement is combined with 
the conclusory language in several of the Counts, Rep. Collins' 
motion for a bill of particulars is compelling. Without it, she 
will be unable to prepare adequately for her response.
    For example, the Statement claims that Rep. Collins knew 
and approved of certain conduct. The Subcommittee failed to 
explain the basis for Rep. Collins' alleged knowledge and 
approval of the conduct. The alleged knowledge constitutes an 
integral--if not the integral--part of the Subcommittee's case, 
but fails to give any adequate explanation. It replies on mere 
assertions. Without a bill of particulars, Rep. Collins will be 
forced to speculate about the theory on which the Statement is 
predicated.
    Similarly, the Statement asserts that bonuses or promotions 
to her Congressional employees were not warranted or 
``commensurate with their duties''. Notable by its absence as 
an explanation for the basis for the Subcommittee's 
determination that promotions within a Representative were not 
allowed under the House Rules. Furthermore, the Bill of 
Particulars fails to give any articulable definition of 
``personal affairs'', or the standard used to distinguish 
between ``campaign related activities'' and ``official 
duties''.
    These examples are but a sample of the conclusory 
allegations and ambiguous terms that permeate the Statement. 
Simply put, Rep. Collins is entitled to know the exact theories 
and evidence relied upon by the Subcommittee for each and every 
allegation. Given the importance of this matter, she should not 
be forced to guess at the theories behind the Statement.

                               conclusion

    Rep. Collins' Bill of Particulars is fully justified to 
identify the Subcommittee's charges.
                                      Brand, Lowell & Ryan,
                                        A Professional Corporation.
    By: Jonathan S. Feld, counsel for respondent, Hon. Barbara-
Rose Collins.
                               APPENDIX T

                          House of Representatives,
                Committee on Standards of Official Conduct,
                                   Washington, DC, October 7, 1996.
Re motion for bill of particulars.
Jonathan Feld, Esq.,
Brand, Lowell & Ryan,
Washington, DC.
    Dear Mr. Feld: This is in response to a Motion and 
Memorandum of Points and Authorities in Support of Request for 
Bill of Particulars (``Motion'') filed on October 2, 1996, on 
behalf of Representative Barbara-Rose Collins.
    In the Motion, you assert that the Statement of Alleged 
Violations (``Statement'') transmitted to Representative 
Barbara-Rose Collins on September 16, 1996, ``does not 
adequately apprise [Ms. Collins] of the specific theories and 
information necessary for her to respond.'' You further assert 
that the Statement consists of ``generalizations and conclusory 
terms'' that have ``created the district probability that Rep. 
Collins will be unfairly surprised and unable to respond 
meaningfully to the charges.'' In accordance with those 
assertions, you seek additional information about ten of the 
eleven counts in the Statement.
    Pursuant to my authority under Rule 17(b)(2) of the 
Committee on Standard of Official Conduct, I deny 
Representative Collin's motion with respect to Counts II, III, 
IV, VI, VII, IX, X, and XI of the Statement on the grounds that 
the information contained in those counts is sufficient to 
advise Representative Collins of the allegations against her, 
and to afford her a meaningful opportunity to respond to those 
allegations.
    As set forth below, the Investigative Subcommittee is 
providing additional information concerning Counts I and V.

                                count i

    With respect to campaign-related events organized by House 
employees, the Subcommittee provides the following additional 
information:
    The record indicates that in the spring or summer or 1994, 
House employees employed by the Detroit congressional office of 
Representative Collins were instructed to help prepare for a 
picnic at the campaign headquarters of Friends of Barbara-Rose 
Collins. Male employees of the congressional office painted the 
campaign headquarters, cut the grass, and installed ceiling 
fans. Female employees prepared food for the picnic.
    The record also indicates that in 1994, employees of 
Representative Collins' congressional office in Washington, 
D.C. inspected facilities for upcoming campaign fund-raising 
events and took steps to ensure that appropriate food and 
supplies were available for those events.

                                count v

    With respect to the use of official funds for personal 
purpose, the Subcommittee provides the following additional 
information:
    The record indicates that on or about March 23, 1994, the 
Washington, D.C. office of Representative Collins sent an item 
by Federal Express to ``Dwayne Porter'' in Detroit, Michigan, 
at a net cost of $5.23. The record further indicates that this 
mailing related to interior decorating service that Mr. Porter 
provided to Representative Collins in connection with her 
personal residence. On or about April 22, 1994, Representative 
Collins' office in Washington, D.C. submitted a voucher to the 
House of Representatives for reimbursement of this expense, 
signed by Representative Collins.
    The record indicates that on or about November 3, 1994, the 
Detroit congressional office of Representative Collins sent an 
item by Federal Express to Rose Reiter Jewelry, Inc. in New 
York, New York, at a net cost of $5.23. On or about November 
17, 1994. Representative Collins' office in Washington, D.C. 
submitted a voucher to the House of Representatives for 
reimbursement of this expense, signed by Representative 
Collins.
    The record indicates that on or about November 21, 1994, 
the Washington, D.C. congressional office of Representative 
Collins sent an item by Federal Express to Rose Reiter, 
Jewelry, Inc. in New York, New York at a net cost of $3.75. On 
or about January 11, 1995, Representative Collins' office in 
Washington, D.C. submitted a voucher to the House of 
Representatives for reimbursement of this expense, signed by 
Representative Collins.
    The record indicates that on or about November 28, 1994, 
the Detroit congressional office of Representative Collins sent 
an item by Federal Express to ``Rose Reiter'' in New York, New 
York, at a net cost of $5.23. On or about January 11, 1995, 
Representative Collins's office in Washington, D.C. submitted a 
voucher to the House of Representatives for reimbursement of 
this expense, signed by Representative Collins.
    The record indicates that on or about December 22, 1994, 
the Detroit congressional office of Representative Collins sent 
an item by Federal Express to the Rose Reiter jewelry store in 
New York, at a new cost of $6.16. On or about January 11,1995, 
Representative Collins' office submitted a voucher to the House 
of Representative for reimbursement of this expense, signed by 
Representative Collins.
    The record indicates that on or about April 11, 1995, the 
Detroit congressional office of Representative Collins sent an 
item by Federal Express to the Rose Reiter Jewelry store in New 
York. New York, at a new cost of $5.23. On or about May 1, 
1995, Representative Collins' office submitted a voucher to the 
House of Representatives for reimbursement of this mailing, 
signed by Representative Collins.
    This concludes the Subcommittee's response to the above 
Motion.
                        Sincerely,
                                               Jim Bunning,
                              Chairman, Investigative Subcommittee.
                               APPENDIX U

                                      Brand, Lowell & Ryan,
                                  Washington, DC, October 24, 1996.
Re Representative Barbara-Rose Collins.
David Laufman,
Counsel, Committee on Standards of Official Conduct, House of 
        Representatives, the Capitol, Washington, DC.
    Dear Mr. Laufman: This letter confirms our conversation 
which I informed you that the Honorable Barbara-Rose Collins 
will not file an answer to the Statement of Alleged violations 
pursuant to Rule 18(a)(1) of the Rules of Committee on 
Standards of Official Conduct.
            Sincerely yours,
                                                  Jonathan S. Feld.
                               APPENDIX V

                          House of Representatives,
                Committee on Standards of Official Conduct,
                                  Washington, DC, October 25, 1996.

                               Memorandum

To: Hon. Nancy L. Johnson, Chairman and Hon. Jim McDermott, Ranking 
        Minority Member.
From: Hon. Jim Bunning, Chairman, Investigative Subcommittee Concerning 
        Rep. Barbara-Rose Collins and Hon. Robert A. Borski, Ranking 
        Minority Member.
Subject: Transmittal of Statement of Alleged Violation.
    Pursuant to Committee Rule 18(g), the Investigative 
Subcommittee concerning Representative Barbara-Rose Collins 
hereby transmits a Statement of Alleged Violation in connection 
with the Resolution of Preliminary Inquiry adopted by the 
Committee on December 5, 1995. The Subcommittee also transmits 
a Motion for a Bill of Particulars filed by the respondent and 
the Subcommittee's response to that motion.
    The respondent chose not to file an answer within the time 
prescribed by Committee rules, and so advised the Subcommittee. 
(See the attached letter.) Under Rule 18(a)(1), her failure to 
file an answer must be regarded as a denial of each count of 
the Statement of Alleged Violation.
    Because the Committee and the House soon will lose 
jurisdiction over the respondent, the Subcommittee unanimously 
recommends that the full Committee not establish an 
adjudicatory subcommittee, and that no further action be taken 
in this matter.

                                
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