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Judicial Watch • HW06 Hillary-FEC-Complaint

HW06 Hillary-FEC-Complaint

HW06 Hillary-FEC-Complaint

Page 1: HW06 Hillary-FEC-Complaint


Number of Pages:5

Date Created:January 10, 2006

Date Uploaded to the Library:July 29, 2013

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Judicial 12: L.

Because one above the law! 
July 16, 2001 HAND DELIVERY 
Office the General Counsel Federal Election Commission 999 Street, Washington, 20463 
False Federal Election Contributions. 
Senator Hillary Rodham Clinton, Hillary Rodham Clinton for 
U.S. Senate Committee, Inc., New York Senate 2000 Committee, David Rosen, 
Edward Rendell, Stephanie Berger, James Levin and William Jefferson Clinton. 
Dear Sir/Madam: INTRODUCTION. 
Judicial Watch, Inc., (hereinafter "Judicial Watch") non-profit, public interest law firm that investigates and prosecutes government abuse and conuption. Judicial Watch client, Mr. Peter Paul, the public interest, and based upon his personal knowledge, complains the Federal Election Commission, accordance with C.F.R. 111.4 and U.S.C. 437 (g)(a)(l), against: Senator Hillary Rodham Clinton, Hillary Rodham Clinton for U.S. Senate Committee, Inc., New York Senate 2000 Committee, David Rosen, Edward Rendell, Stephanie Berger, James Levin and William Jefferson Clinton. Specifically, the aforementioned individuals and organizations appear violation of: U.S.C. 431, seq. (Definitions). U.S.C. 434(b) (Reporting Requirements). C.F.R. 104.3 (Contents Reports). C.F.R. 110.9(a) (Violation Limitations) C.F.R. 110.9(b) (Fraudulent Misrepresentation) 
501 School Street, Suite 725 "'Washinqton, 20024 Tel: (202) 646-5172  (888) JW-ETHIC Pax: (202) 646-5199 email: info@judicialwatch.orq Web Site: www.JudicialWatch.orq 

Peter Paul Calabasas, California, acclaimed Hollywood executive with extensive experience event production, entertainment marketing, and media positioning. 1999, co-founded Stan Lee Media, Inc.("SLM"), branded global entertainment company; early 2000, SLM was publicly traded the NASDAQ stock exchange and enjoyed market capitalization approximately $350 million. order further increase the business prospects SLM, Mr. Paul sought build his business partner, Mr. Stan Lee, whom considered the "Walt Disney the comics industry," into major cultural and branded ente1taimnent figure. Mr. Paul believed that one way achieve this goal was through politics. 
Mr. Paul contributed approximately $1.9 million dollars cash and "in-kind" direct contributions Hillary Rodham Clinton for her federal election campaign for the United States Senate. Mr. Paul's contributions to, and behalf Hillaiy Rodham Clinton were specifically for the purpose influencing the outcome federal election. Mr. Paul Rodham Clinton's early 2000, Mr. Paul was approached former protege, Aaron Tonken, about elevating Stan Lee's public profile, recognition and acceptance contributing money the Democratic Paiiy. After being introduced the President and Mrs. Clinton and Vice President and Mrs. Gore Denise Rich small reception held Mrs. Rich's home October 1999, Tonken had become trusted producer for the Democratic National Committee ("DNC"), providing support and widely-recognized Hollywood talent for DNC fundraising activities with President Clinton and other prominent Democratic Paiiy politicians. Tonken had worked directly with DNC Chairman Edward Rendell and DNC Southern California Finance Chairwoman Stephanie Berger these fundraising activities. 
Tonken induced Mr. Paul contribute $30,000 the DNC co-host fundraiser 
featuring President Clinton Cafe Des A1tistes Hollywood, California. The dinner, held 
February 17, 2000, was chaired California Governor Gray Davis. addition Mr. Paul, 
other co-hosts included entertainer "Babyface" Edwards, actress Calista Flockhart and two real 
estate developers. 

Mr. Paul was led reasonably believe Tonken, Rendell and Berger that his substantial contribution the DNC would enable Mr. Paul better position himself enlist the President's suppo1t for recognizing Stan Lee's significant contributions literacy and global popular culture, including Kennedy Center Honor and White House presentation Presidential Medal Freedom. 
Mr. Paul, who admittedly had experience direct knowledge about major campaign contributions federal campaign finance regulations, was prepared commit significant portion his family share holdings SLM, then valued approximately $90 million, order achieve his strategy elevating Stan Lee's public profile, recognition and acceptance through the good offices The White House, and was thereby induced become major contributor. 
Mr. Paul was seated with President Clinton the Cafe Des Altistes event. Mr. Paul also was introduced Governor Davis, DNC Chairman Edward Rendell and California DNC 

Finance Chairwoman Stephanie Berger. 
During the Cafe Des Artistes event, Mr. Paul, Rendell, Berger and others began discussions about Mr. Paul providing more substantial suppmt for the Democrats. pa1ticular, Rendell and Berger suggested that Mr. Paul and Stan Lee co-host DNC fundraiser support Vice President Gore's presidential campaign. Rendell and Berger also suggested that Mr. Paul and Stan Lee co-host DNC fundraiser Mr. Paul's home Los Angeles, California attended President Clinton. 
California DNC Finance Chairwoman Stephanie Berger and David Rosen, the Director Finance for Mrs. Clinton's Senate campaign, asked Mr. Paul make $150,000 commitment co-host luncheon for Mrs. Clinton Spago Beverly Hills June 2000. Mr. Paul agreed suppoli Mrs. Clinton's U.S. Senate campaign, however, making $55,000 payment towards satisfying $150,000 commitment co-host the June 2000 luncheon and tea with Stan Lee. Thereafter, Mr. Paul was introduced David Rosen Jim Levin, friend and fundraiser for President and Mrs. Clinton from the Chicago area. Mr. Paul's Contributions Rodham Clinton's Election The Senate 

Over the following month, Mr. Paul became increasingly involved with DNC operatives and members Mrs. Clinton's campaign staff concerning fundraising for Mrs. Clinton's election the U.S. Senate. July 11, 2000, Mr. Paul pruticipated conference call with Rosen and other fundraisers for Mrs. Clinton discuss Paul's ru1d Stan Lee's sponsoring fundraiser for Mrs. Clinton just prior the Democratic National Convention Los Angeles, California. Mr. Paul suggested Hollywood Tribute the President, the proceeds which would used elect Mrs. Clinton the U.S. Senate. The event was held the grounds the home radio magnate Ken Robe1ts, Brentwood, California. 
Mr. Paul agreed finance the Hollywood Tribute fundraiser. All funds raised from persons attending the fundraiser would constitute net contributions Mrs. Clinton's U.S. Senate campaign. agreeing finance the event, Mr. Paul's sole and exclusive intention was influence the outcome Mrs. Clinton's U.S. Senate campaign, not any other election campaign. point did Mr. Paul ever intend influence the outcome any other election benefit any candidate other that Mrs. Clinton. The President and Mrs. Clinton knew this the case because Mr. Paul was specifically induced the President and his agents assist and boost Senator Clinton's campaign favor the President. the Hollywood Tribute fundraiser drew closer, Mr. Paul became concerned about the increasing cost the event, which was exceeding million. Mr. Paul complained Rosen, Levin and others repeatedly about the cost. Rosen told Mr. Paul not discuss the mounting costs the fundraiser because, for public relations purposes, Mrs. Clinton's U.S. Senate campaign did not want the true cost the fundraiser become known. Rosen also told Mr. Paul that certain fundraising ratios required federal can1paign finance laws would skewed the true cost the fundraiser became known. all times, President Clinton, Mrs. Clinton, Levin, Rosen and many others knew that Mr. Paul, not SLM, Stan Lee, anyone else, was paying for the Hollywood Tribute fundraiser. Mr. Paul repeatedly told Rosen that this was the case, did SLM Chief Executive Officer and President Ken Williams. SLM General Counsel Ric Madden also told Rosen that SLM could not and would not incur any costs for the fundraiser. Rosen also witnessed Mr. Paul writing checks 

for costs associated with the fund.raiser, and fact had Mrs. Clinton join negotiating Gary Smith's production fee $850,000 behalf Mr. Paul. 
The Hollywood Tribute fundraiser for Mrs. Clinton's U.S. Senate campaign proceeded planned August 12, 2000. August 14, 2000, Mrs. Clinton called Mr. Paul home thank him for paying for the Hollywood Tribute fundraiser. fact, the President and Mrs. Clinton had made several calls Mr. Paul encourage his supp011 and thank him for the event. August 18, 2000, both President Clinton and Mrs. Clinton wrote thank you notes Mr. Paul for the Hollywood Tribute fundraiser. President Clinton expressly thanked Mr. Paul for giving the event itself and for "the boost gave Hillary's campaign." See Exhibit 
Mr. Paul conceived, designed, organized, produced, conducted and paid for the August 12, 2000 Hillary Rodham Clinton fundraising event entitled Hollywood Tribute President William Jefferson Clinton." Mr. Paul personally financed the entire event. total, Mr. Paul spent approximately $1.9 million his own personal funds for the Hollywood Tribute fundraiser, which Mr. Paul was told netted Senator Clinton approximately $1.5 million dollars direct contributions for her campaign. False Mr. Peter Paul's Contributions Rodham Clinton's Election The U.S. Senate 
Attached Exhibit are the Year 2000 reported political campaign contributions 
Peter Paul rep011ed the Federal Election Commission and made publically available 
the Internet. 

FEC records indicate Mr. Paul's federal election contributions for year 2000 total only 

Mr. Paul's contributions, both cash and "in-kind," have been improperly and/or inaccurately reported Mrs. Clinton and her federal election campaign committees. There clear and compelling evidence that Mrs. Clinton and her staff intentionally failed report direct "in kind" contributions, accordance with federal election law. When asked the media about Mr. Paul's contributions, they lied.1 
Attached Exhibit are Mr. Paul's checks and statements, detailing and documenting the itemized expenditures Mr. Paul made Mrs. Clinton's election. light the above, Mr. Paul has demanded that Mrs. Clinton return the contributions Mr. Paul has made her. copy this demand letter attached Exhibit and incorporated herein reference. 

'Lloyd Grove; "Hillary Returns Bucks Ex-Felon," The Washington Post, August 17, 2000, Page COl (Attached Exhibit 3). 
Mr. Peter Paul made cash and in-kind contributions the federal election orunpa.lgn Hillary Rodham Clinton for the U.S. Senate seat representing the State New York, 1otaling almost million dollars. lvtr. Paul solely and e:clusively intended his contributions HillaryRod.ham Clinto11 influence the outcome federal election, favor Hillary Rodham Clinton's election. 
Federal Election Corti mission records for year 2000 reported political contributions Peter Paul reflect total contribution $2000.00, which was returned. 
The Federal Election Com.mission obligated investigate false and misleadingreporting Senator Hillw:y Ro