EC2013 Liu Thacher Report Final FOIL Distribution

8/22/2019 EC2013 Liu Thacher Report Final FOIL Distribution

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CONFIDENTIAL

REPORT TO THE

NEW YORK CITYCAMPAIGN FINANCE BOARD

JULY 15, 2013

QTHACHERa!iJ ASSOCIATES


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I. EXECUTIVE SUMMARY ......................................................................................5A. Thacher Associates' Assignment ..................................................................................................................... 5B. Selection of Contributors to Interview ........................................................................................................... 6C. Overview of Interviews .................................................................................................................................... 7

i. Employers Reimbursed Contributions Made by Their Employees .......................................................... 7ii. Some Contributors Did Not Live at Their Reported Addresses ............................................................... 8iii. Some Contributors Did Not Know Their Reported Intermediary ........................................................... 8iv. Some Contributors Made Significant Contributions Despite Evidence of Low Income ......................... 9v. Some Contributors' Denials of Reimbursement Were Not Credible ....................................................... 9vi. Some Contributors Contributed After Jenny Hou Resigned as Campaign Treasurer. ......................... 9vii. Some Contributors Had Connections to Events and/or Individuals That Were Part of the Trial of

Jenny Hou and Oliver Pan ........................................................................................................................... 9viii. Further Investigation is Likely to Reveal Additional Potential Violations of Campaign Finance Laws

...................................................................................................................................................................... 10

II. INTERVIEW SUMMARIES .................................................................................11A. Great Wall Supermarket Summary ............................................................................................................. 13

i. General Information ................................................................................................................................... 13ii. Information Provided to the CFB ............................................................................................................. 13iii. Contributor Was Reimbursed By He r Employer .................................................................................... 13iv. Contributions to Other Candidates ........................................................................................................... 14v.vi.

1.2.3.4.5.6.7.8.9.10.11.12.

, .............................................................................................................................................. 14Interview Summaries .................................................................................................................................. 14

................................................................................................................................. 15, .............................................................................................................................. 17...............................................................................................................................19

.................................................................................................................................20.............................. :: ............................................ : ................................................... 21

. ................................................................................................................................. 22. ..................................................................................................................................... 22

.....................................................................................................................................23. .................................................................. ............................................................23. ............................................................................................................................... 23

...........................................................................................................................................24...........................................................................................................................................25

B. McCormick & O'Brien, LLP Summary ..................................................................................................... 26i. Information Provided to the CFB ............................................................................................................. 26ii. Contributors Were To Be Reimbursed By Their Employer ................................................................... 26iii. Interview Summaries .................................................................................................................................. 27

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1.2.3.4.5.

............................................................................................................................. 28

.............................................................................................................................29. ...................................................................................................................... 30

. ...................................................................................................................31. ........................................................................................................ 33

C. Yang Shing Trading Co. Summary ..............................................................................................................38i. Information Provided to the CFB .............................................................................................................. 38ii. Contributor was Reimbursed .................................................................................................................... 38iii. Interview Summaries .................................................................................................................................. 39

1. . ....................................................................................................................402.3.4.5.6.7.8.9.10.l l .12.

....................................................................................................................... 42. ................................................................................................................ 43

. ................................................................................................................... 43. .................................................................................................................. 45. .................................................................................................................. 46. ................................................................................................................ 46

. ............................................................................................................ 47

. ............................................................................................................ 47. ........................................................................................................................... 48

. ......................................................................................................................... 48. ........................................................................... ; ................................................................. 49

D. Farwell International Summary ................................................................................................................... 50i. Information Provided to the CFB ............................................................................................................. 50ii. Overview of Interviews ............................................................................................................................... 52iii. Interview Summaries .................................................................................................................................. 52

1. . ...................................................................................................................532.3.4.5.

................................................................................................................... 55. ........................................................................................................................... 56

. ................................................................................................................... 56. ................................................................................................................ 56

E. Jennan Comprehensive Medical Summary ................................................................................................. 57i. General Information ................................................................................................................................... 57ii. Information Provided to the CFB ............................................................................................................. 57iii. Overview of Interviews ............................................................................................................................... 57iv. Interview Summaries ............................. .................................................................................................... 57

1. ................................................................................................................................582. .........................................................................................................................603. ......................................................................................................................604. ................................................................................................................615. , ................................................................................................................ 62

F. Fly iger Plumbing & Heating ........................................................................................................................ 63i. Information Provided to the CFB .............................................................................................................. 63



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ii.iii.

1.2.3.4.

G.i.ii.iii.

1.2.3.4.5.6.7.8.9.

H.i.ii.iii.iv.

1.2.

Overview of Intervi ews ............................................................................................................................... 63Interview Sum maries .................................................................................................................................. 63

. ................................................................................................................................. 64................................................................................................................................. 66. .............................................................................................................................. 66

. ........................................................................................................................ 68i Summary ................................................................................................. ........................... 69

Information Provided to the CFB ............................................................................... .: .......................... 69Overview of Interviews ................................................................................................................................ 69Interview Summaries .................................................................................................................................. 69

.......................................................................................................................... 70"................ . " . , ........ .... , . , ....... , .......................................... .:: . , ............. , ... , ... 71

. ......... " .... , ................. " ... " ............. ........... , ...... , .......... , ..... , .. , ............... , ... , ... , ...... 72. ....... , .... , .. , ........ , .. ,,', .......... , ... , .. ,., .. ,., ............. ....... , ....... , ........... ............. ..... 73.. ................. .. " ............... , ..... "." ............ ....... , ..... , ... , ........... , .... , ... , ........... .... ,.74

, ................................ . "., . " ... , .. .......... , ..... , . ............ ..... ., .... , .... , . , ... ....... , ......... 74. ... , ........... ., ............ , .... , ........ , ........ ........... ....... ., ............ , ......... , .... .............. ..... 75: . , . , .. ................ .... , ......... , ..... ,.,', ........... ....... ., .... ,., .... , ..... ................. . , .......... ., ... 75

. . , ........... ........... "., . , ............ , ... , .. , . ................ , ..... , ... , .... ............... , ...... ........ 76. Summary ............................................................................................................................ 77

General Information , .. ......... , ............... , ............... ,', .... , .. ............ ..... ., ...... , .......... ........... ........... ........... . 77Information Provided to the CFB ....... , ............... , ............. ........... .... , .......... .............. ., .. , .... , ..... ............ 77Public Housing Income Limits ................... ,., ... ".,., . , .................. ., .... , ....... ......... , ... , ..... ............ ............ . 78Interview Summaries ................. ..... , .. , ....... , .......... , .... , ........................... , ........ ............ : ......................... 78

. ....................................................................................................................... 79................................................................................................................. 79

I. China Grand Buffet ....................................................................................................................................... 80i.ii.iii.

1.2.3.4.5.6.7.8.9.10.11.

Information Provided to the CFB ............................................................................................................. 80Overview of Interviews ............................................................................................................................... 80Interview S ummaries .................................................................................................................................. 80

. ................................................................... , ............................................... 81.................................................................................................................... 82

.............................................................................................................83. ............................................................................................................ 84

. ................. ................................................................ ....................................... 84..........................................................................................................................85

....................................................................................................................... 85...................................................................................................................... 86. ..................................................................................................................... 86

. ...................................................................................................................... 87i . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . .. . . . .87

J. Ng Fook Funeral Group ................................................................................................................................ 88



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i. General Information ...................................................................................................................................88ii. Information Provided to the CFB ............................................................................................................. 88iii. Overview of Interviews ............................................................................................................................... 88iv. Interview Summaries .................................................................................................................................. 88

1. .............................................................................................................................. 892. . ........................................................................................................................... 903. . ................................................................................................................... 904. .. ..................................................................................................................915. . ..............................................................................................................................916. . ............................................................................................................................. 927. . ....................................................................................................................... 928. . ....................................................................................................................... 92

K. Hua Yang Development Corp ....................................................................................................................... 93i. Information Provided to the CFB .............................................................................................................. 93ii. Overview of Interviews ............................................................................................................................... 93iii. Interview Summaries ..................................................................................................................................93

1. ....................................................................................................................................... 942. . ................................................................................................................................. 943. . ....................................................................................................................... ... 944. ...................................................................................................................................955. . ................................................................................................................................. 956. . .............................................................................................................................. 96

L. : Summary ....................................................................................................................................... 97i. Information Provided to the CFB ............................................................................................................. 97ii. Overview of Interviews ............................................................................................................................... 97iii. Interview Summaries ..................................................................................................................................97

1. ........................................................................................................................... 982. . ......................................................................................................................... 983. . ............................................................................................................................. 994. . .......................................................................................................................... 995. . ........................................................................................................................ 100

M. Stone Computer Summary .......................................................................................................................... 101i. Information Provided to the CFB ............................................................................................................ 101ii. Overview of Interviews ............................................................................................................................. 101iii. Interview Summaries ................................................................................................................................ 101

1. ! . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . 1022. ............................................................................................................................ 1043. ......................................................................................................................... 105



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I. EXECUTIVE SUMMARY

Thacher Associates (liTA"} was retained by the New York City Campaign Finance Board ("CFB") to assistthe CFB in determining, pursuant to the its legal mandate, the eligibility fo r public matching funds ofJohn Liu's campaign fo r New York City Mayor in 2013 (the "campaign" or the "Liu campaign") and tosupplement the CFB's investigation of possible violations of campaign finance laws. The CFB providedTA with reported contribution data covering the period December 2010 - January 2013 and directed TAto identify, research, and interview contributors to the Liu campaign.

Thacher Associates' research and interviews found evidence of potential campaign finance lawviolations, including reimbursed contributions and falsified documents. In addition, Thacher Associatesfound evidence that raised concerns regarding the reporting of campaign activity by the Liu campaign.The interviews and research conducted by TA at the behest of the CFB also suggest that furtherinvestigation could reveal additional potential violations of campaign finance law.Additional information regarding contributions to and fund raising by the Liu campaign can be found inaudit work conducted by the CFB and in the record of the recent trial of the Liu campaign's formertreasurer, Jia Hou (aka Jenny Hou) and a fundraiser, Xing Wu Pan (aka Oliver Pan). This reportsupplements those sources of information. 1

A. Thacher Associates' AssignmentThe CFB had done a preliminary analysis of most of the contribution data it provided to TA and, basedon this preliminary analysis, the CFB directed TA to focus its review on specific types of contributions(described below). TA was specifically directed to focus on contributions other than those that would beat issue at the trial of Jenny Hou and Oliver Pan. The CFB also placed limits on the amount of time andwork that could be expended on this assignment as the CFB needed most of the work completed byJune 10, 2013 and authorized a limited budget. In addit ion, as it became evident that TA wouldcomplete most of its research and analysis of contributions and contributors, and be prepared toconduct interviews, close to start of the trial of Hou and Pan, the CFB and TA agreed that interviewswould not be conducted until after the trial had been completed.

1 Hou and Pan were prosecuted by the United States Attorney's Office, Southern District of New York, and on May2, 2013, were found guilty after trial. The charges against Hou and Pan stemmed, in part, from their role in a strawdonor scheme for some of the contributions made to the Liu campaign. At trial, witnesses described straw donorschemes that were designed to fraudulently increase the amount of CFB matching funds that the Liu campaignwould receive. The trial testimony also demonstrated that employers who had their employees act as strawdonors coached them and others to lie about the contributions.



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B. Selection of Contributors to InterviewThe CFB provided TA with contribution data, as reported by the Liu campaign, fo r about 6,500contributions made between December 2010 and January 2013 and documentation fo r specifictransactions. The CFB's preliminary analysis of the data had flagged approximately 550 contributions:

For which common employers, common intermediaries, or common received dates werereported;

For which discrepancies had been noted between the documentation and reporting (e.g., thecampaign reporting to the CFB a different home address or employment information than wason a contributor's contribution card);

For which there were indicia on documentation that suggested intermediary activity but forwhich no intermediaries were reported (e.g., no intermediary being reported but contributioncards having handwritten on them the initials of a principal of the business fo r which thecontributors worked); and/or

For which there were other issues (e.g., signatures on a check and contribution card not being inthe same handwriting and contribu tions being made with starter checks).

TA was directed to focus on those contributions, other than approximately 50 that would be at issue atthe trial of Hou and Pan. TA further analyzed the contribution data, focusing on the contributionsflagged by the CFB but also doing a limited review of all contributions, in part because the CFB had notflagged every contribution that met one or more of the criteria listed above. TA had multiplediscussions with the CFB to identify contributors to interview. We focused on contributions for whichthere were matching funds claims and we excluded those contributors whose home addresses, asreported by the campaign, we could not verify through online and database research or for whom wecould not identify an alternative address. This excluded a significant number of contributors; of an initialselection of 70 contributors, we could not identify an address for 20 of them, or just less than 30%.

Finally, to be efficient, since we planned to conduct most interviews at contributors' homes, we alsoexcluded, fo r logistical reasons, contributors whose home addresses were not near other contributorswe planned to interview.



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C. Overview of InterviewsIn total, TA interviewed or attempted to interview 85 select contributors based on the criteria set forthabove, many of whom were reported as having common employers. Of the 85, we interviewed 22contributors and 19 family members of contributors. Below is an overview of the results of ourinterviews.

i. Employers Reimbursed Contributions Made by Their EmployeesThacher Associates received information that at least three of the employers in our selectionreimbursed, or said they would reimburse, employees or, in one case, a non-employee fo r whom a keyperson in the company was identified as the intermediary. At least one of the contributors whoadmitted that he had been reimbursed signed a contribution card affirming that he was not beingreimbursed.

Great Wall Supermarket - A former cashier told Thacher Associates that her $800contribution had been reimbursed by her boss. This contributor did not know the nameJohn Liu and said that she had only contributed because her boss had asked her to and hadtold her that he would reimburse her. This contribution was one of 15 made by Great Wallemployees, each of which was for $800.

McCormick & O'Brien, LLP - A former bookkeeper fo r this law firm informed ThacherAssociates that she had been directed by one of the firm's partners to tell employees thatthey were required to contribute to the Liu campaign but that they would be reimbursed.Three employees made $800 contributions and subsequently cancelled them, reportedly asa result of concerns a paralegal raised regarding the campaign, including Jenny Hou havingbeen investigated in connection with campaign donations.

Yang Shing Trading Co. - A contributor for whom a key employee of Yang Shing Trading Co.was identified as the intermediary also informed Thacher Associates that he had beenreimbursed fo r his $800 cont ribut ion. Although this contributor does not work for YangShing and said that he did not know his reported intermediary, he informed ThacherAssociates that he thought that his boss, who had reimbursed him, also owned Yang Shing.The same intermediary was reported fo r contributions by 13 Yang Shing employees and fiveother individuals, each of whom made one $800 contribution.

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ii. Some Contributors Did Not Live at Their Reported AddressesContributions for which matching claims are made are only matched with public funds if they are fromindividual New York City residents. Thacher Associates found that New York City home addresses thatthe campaign reported fo r some contributors were not accurate.Since we specifically did not attempt to interview contributors wtlO met our selection criteria but whosehome addresses, as reported by the campaign, we could not verify through online and databaseresearch or for whom we could not identify an alternative address, we do not know how many of theirreported addresses were not accurate.However, at five of the contributor addresses that we had verified, we were told that the contributor didnot live there, and it appeared the contributor had not lived there at the time of the contribution:

at three addresses, a relative said that the contributor only received mail but did not livethere;

at another address, a relative said that the contributor, fo r whose contribution matchingfunds were claimed, only stayed at that address in Brooklyn for part of the week and thatthe contributor's family lived on Long Island; and

at another address, a house with three apartments, the landlord said he did not know thecontributor but that a lo t of people received mail at the contributor's reported apartment.

For each contributor who contributes $100 or more, campaigns are also required to provide the CFBwith the contributor's employment information - occupation, employer name and employer address.We were unable to verify reported employment information fo r many cont ributo rs because: (i) mostemployment information could not be verified through online research; (ii) at many of the contributors'homes, either the contributor was not home or no one else was home who could verify employmentinformation; and (iii) we did not attempt to interview those contributo rs for whom we could no t verify ahome address.

iii. Some Contributors-Did Not Know Their Reported IntermediaryOf the 22 contributors Thacher Associates interviewed, 13 had an intermediary reported for theircontribution to the campaign. Thacher Associates asked nine of those 13 if they knew the intermediaryand/or how they had submitted their contribution (some contributors ended an interview before one or. both of these questions could be asked). Seven of the nine contributors said that they did not know theintermediary reported with their contribution or said that they had given their contribution to someoneother than the reported intermediary.



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While there may be legitimate reasons fo r this, we note that these seven contributors include two whoinformed Thacher Associates that they had been reimbursed fo r their contributions and twocontributors who worked fo r an employer who reportedly told employees that they would bereimbursed. Since an intermediary solicits contributions for a campaign, with the campaign'sknowledge, and/or delivers contributions to a cam paign, this suggests that, at best, in five instances theintermediary did not solicit the contribution but delivered to the campaign a lawful contribution that thecontributor had given to someone else. We note that campaigns are required to maintain clear andaccurate records sufficient to show an audit trail that demonstrates compliance with the CFB's rules.

iv. Some Contributors Made Significant Contributions Despite Evidence of Low IncomeWe are by no means suggesting that individuals living in public or low-income housing or havingtraditionally low-income occupations are not capable of contributing to campaigns. However, we foundthat four individuals with residential addresses in public housing buildings and other individuals living inlow-income housing and/or working in traditionally low-income occupations (e.g., housekeeper, cashier)contributed $800 or more to the li u campaign - in some cases amounts that may have exceeded theirmonthly rent.

v. Some Contributors' Denials of Reimbursement Were Not CredibleThe three Thacher Associates employees who conducted these interviews have extensive experienceconducting interviews as prosecutors, attorneys and investigators in the public and private sectors,including conducting interviews with interpreters and conducting many prior interviews for the CFB.Their professional opinion, based on over six decades of experience, is that some of the contributorsinterviewed were not credible when they stated that they had no t been reimbursed for theircontributions. The report sets forth in detail the observations giving rise to these credibilityassessments.

vi. Some Contributors Contributed After Jenny Hou Resigned as Campaign Treasurer13 of the 85 contributors interviewed, or attempted to be interviewed, by Thacher Associates,contributed to the campaign after Jenny Hou resigned as campaign treasurer following her arrest onFebruary 28, 2012. These contributors include all five contributors we attempted to interview who wereemployed by, or linked to employees of, Jennan Comprehensive Medical and seven of the eightemployees ofthe Ng Fook Funeral Group (some of whom also contributed before February 2012).

vii. Some Contributors Had Connections to Events and/or Individuals That Were Part of theTrial of Jenny Hou and Oliver PanThacher Associates, at the direction of the CFB, specifically focused on contributions other than thosethat would be at issue at the trial of Jenny Hou and Oliver Pan. In spite of this, unanticipatedconnections were found between some contributors we interviewed or attempted to interview and



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events and/or individuals that were part of the trial of Hou and Pan. The connections were withemployees of Farwell International, a seafood company with a Brooklyn, NY address.Eleven Farwell employees each made $800 contributions and at least five of these contributions weremade in connection with a May 9, 2011 fundraising event or were otherwise linked to individualsidentified in connection with the trial as possible straw donors. During the trial, two business ownerstestified that they had reimbursed employees and others in connection with the May 9,2011 event andthat in April 2011 they had had dinner together and discussed obtaining contributions for this event.According to the criminal complaint against Hou, law enforcement agents spoke with an intermediarywho said that s/he reimbursed between 10 and 20 straw donors in connection with this event and theyspoke with multiple straw donors who donated at this event. In addition to direct connections betweenFarwell and the May 9, 2011 event, it appears that the President of Farwell attended the April 2011dinner at which those present discussed obtain ing contributions fo r the May 9 event.

viii. Further Investigation is l ikely to Reveal Additional Potential Violations of CampaignFinance Laws

Thacher Associates' work revealed red flags that suggest that additional research and interviews couldidentify additional potential violations of campaign finance law. For example, TA identified a possibleaddress fo r a Farwell employee that is almost identical to a false business address that The New YorkTimes had identified fo r a company that had 10 employees contribute and, which testimony at the Houand Pan trial subsequently demonstrated, included straw donations.Database research that TA had conducted connected a Farwell employee to inFlushing. In a November 9, 2011 story regarding the Liu campaign, the Times reported on contributionsby 10 Kang Kang employees and noted that "all of the workers list the company's business address as

in Flushing, but that address does not exist." (A copy of this story is attached asExhibit 1.) During the Hou and Pan trial, . {the owner of Kang Kang, testified that he hadreimbursed employees of his construction company for contributions to the Liu campaign.We subsequently learned that the campaign had reported .as the home address fortwo other contributors and that their contributions were very similar to the reported contributions bythe 10 Kang Kang employees. These similarities with known straw donations suggests that further workregarding these two contributions, and other contributions that we identified that were linked bycommon employer or common address to these two, could reveal additional potential violations ofcampaign finance laws.



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II. Interview SummariesUsing the in format ion provided by the CFB and the selection criteria set forth above, Thacher Associatesselected 85 contributors to interview; we also interviewed two former employees of McCormick &O'Brien regarding contributions made by the firm's employees. Nearly all of the attempts to interviewoccurred during unannounced visits to contributors' homes. Visits were made weekday evenings afterstandard work hours but prior to 9:00 pm; in order to take maximum advantage of this narrow windowof time, a car and driver were used and interviews were grouped by geography. Some of the interviewattempts were made during the day on a weekend and a few interviews occurred by telephone. Onmany occasions, when a family member or neighbor said that a contributor would be home at a latertime, fo llow-up visits were made.

The interviews were conducted by three employees of Thacher Associates with over 60 years ofcombined relevant experience. This includes extensive experience conducting interviews asprosecutors, attorneys and investigators in the public and private sectors, including conductinginterviews with interpreters, and conducting many prior interviews for the CFB. In addition, theseemployees have conducted many prior investigations fo r the CFB, some of which have involvedreviewing contribution data and researching contributors to identify suspicious contributions andperforming related fieldwork.The majority of the contributors interviewed spoke Chinese and spoke very little, if any, English.Therefore, the Thacher Associates employees were accompanied by experienced, professionalinterpreters fluent in multiple Chinese dialects from a firm that Thacher Associates has worked with forover ten years. The CFB provided a letter in simplified Chinese and traditional Chinese, as well as inEnglish, that Thacher Associates could show to contributors or others. The letter states that the CFBauthorized Thacher Associates to assist with the CFB's audits of political campaigns and that, inconnection with these audits, Thacher Associates was authorized to conduct interviews, requestdocumentation and undertake any other actions necessary to assist with the CFB's audits. Copies of thethree versions of this letter are attached as Exhibit 2.Out of the 85 attempted interviews, Thacher Associates spoke with 22 contributors. In addition, wespoke with 19 family members of contributors, some of whom were able to provide informationregarding the contributions.With regards to the remaining 44, we either spoke with neighbors, current residents or no one at all.

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Below is a chart ofthe results of our attempts to interview contributors.2

Group Contributor Family Other3 NoOne TOTALMember

Great Wall Supermarket 4 2 3 3 12McCormick & O'Brien4 2 1 3Yang Shing Trading 3 3 4 2 12Farwell International 1 2 2 5Jennan Comprehensive Medical 2 3 5Flytiger Plumbing & Heating 3 1 4

3 2 4 92 2

China Grand Buffet 3 1 3 4 11Ng Fook Funeral Group 1 4 3 8Hua Yang Development 5 1 6

4 1 5Stone Computer 1 1 1 3TOTAL 22 19 24 20 85

The report is a summary of the interviews conducted by Thacher Associates. This report is not intendedto be a comprehensive account of the interviews. Rather, the summaries are merely brief descriptionsof some of the information that was learned during the meetings.

Please note that the date of contributions referred to in the report is the date that the campaignreported receiving the contribution. This date may not necessarily match the date. that the contributordrafted a check or the date on a contribut ion card.

2 Attempts to interview each contributor were only assigned to one of the four categories in the chart. Although infour instances a family member was spoken to before a contributor was interviewed during a subsequent visit orphone call, these were counted under "Contributor," and not also under "Family Member." In three instances, aninterview of a family member was counted more than once; for example, an interview of a contributor whoworked at Great Wall Supermarket and who provided information regarding a contribution by his brother, whoalso worked at Great Wall and who the contributor said lived with him but was not home, was counted under both"Contribu tor" and "Family Member."3 "Other" refers to either a neighbor, current resident, or other individuals that were spoken to regarding thewhereabouts of the contributor's location.4 Totals for this group do not include interviews with two former employees who were not contributors.

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II

Great Wall SupermarketA. Great Wall Supermarket Summary

i. General InformationThe website for Great Wall Supermarket, also referred to as GW Supermarket, identifies eight locations,two of which are on Northern Boulevard in Flushing, Queens; the others are in Georgia, Massachusetts,Maryland, and Virginia.

ii. Information Provided to the CFBInformation the Liu campaign provided to the CFB identified Great Wall Supermarket as the employer of15 contributors, each of whom made one contribution. These 15 contributors ' reported positions atGreat Wall Supermarket ranged from cashier and sales to manager and general manager. Theintermediary for 14 of these contributions was , who was identified as theowner of Great Wall Supermarket; the one contribution for which she was not listed as the intermediarywas by who has been identified as her husband and who has the same(Long Island), NY address asThe other 14 contributors have New York City addresses and records the CFB provided from the Liucampaign indicate that they were seeking matching funds fo r all. Each of the 15 contributions was fo r$800, all were made by check, and all were reportedly received by the campaign between July 7, 2011and July 11, 2011. A list of fundraising events that the Liu campaign provided to the CFB included a"Guest Appearance for on July 8, 2011, at Mellie's, 2nd FI, 137-87 NorthernBlvd., Flushing, NY 11354.

iii. Contributor Was Reimbursed By Her EmployerTA attempted to interview 10 of the 15 Great Wall employees and we were able to locate and interviewfour of them. One of these contributors told us that her boss reimbursed her fo r her contribution.None of them mentioned having gone to a fundraising event.The first contributor, I a former cashier, initially denied having made a contribution.However, after we showed her a copy of her check she admitted that she had made the contribution.She said that she had done so only because her boss, husband, asked her to and told her beforeshe made it that he would reimburse her, which he did do. When was asked about "John Liu," shestated that she did not know the name.The three other Great Wall employees we interviewed all stated that they were not reimbursed. Twostated that either - or her husband had asked them to contribute and had suggested the amount of$800 and one of those two said that had asked everyone at work to contribute. The otheremployee said that no one had asked him to contribute and that he had come up with the amount of$800 on his own. He also said he was not aware of anyone else at work contributing and could notexplain why others at work would have contributed on the same date he did. We note that, unlike the

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Great Wall Supermarketother employees, this employee had advance notice that we wished to speak with him about hiscontribution; before we were able to reach him, we spoke with his wife and told her we wished to speakwith her husband about his contribution.

iv. Contributions to Other CandidatesThe three employees who stated that they were not reimbursed all said they had contributed to othercampaigns. With regards to the other contributions: (i) one said she likes to contribute to Chinesepoliticians and cited _; as an example; (ii) one said he had contributed before when his bosshad asked but he could not recall the names of any other candidates to whom he had contributed; and(iii) the third said he had contributed to a candidate named but he could not recall thecandidate's first name.TA reviewed contribution information on the websites of the CFB, the New York State Board of Elections("BOE") and the Federal Elections Commission ("FEC"). We found that one employee and the apparentspouse of another employee made contributions to the same candidate, on the exact dateI that also made a contribution to IIWe did not find records that indicated the thirdemployee made any contributions.

v.In addition to serving as the intermediary fo r contributions by 14 Great Wall employees, I wasalso the intermediary for contr ibutions made by 11 additional individuals. These individuals all madeone contribution, each of which was fo r $800 and was reportedly received by the campaign betweenJuly 8 and July 12, 2011. We did not interview these contributors. However, we note that three ofthesecontributors were reported as having the same"retired."

'as Pan and were identified as

We were also informed by a contributor, " that one of these additional 11 contributors,, reimbursed him for his contribution. This reimbursement is discussed further in the section on

Yang Shing Trading below. We note this here to highlight that has a connection to twocontributors who admitted to Thacher Associates that they were reimbursed.

vi . Interview SummariesSee below.



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Great Wall Supermarket1.

Contributor:Employment: Cashier, Great Wall Supermarket

~ - - - - - - - - - - - - - - - - - - - - - - ~ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -Address:

Contribution: $800, check; 7/10/11Intermediary:Interview Date/Time: 5/9/13; 6:10PM

Summaryr - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~,was interviewed, in Chinese, in front of her residence.

Initially, she said that she had not made a political contribution and that because she is only a greencard holder she could not contribute. When shown a check in her name for $800, she confirmed that itwas her check and that she had signed it.She said that she had worked at Great Wall Supermarket as a cashier for about one year, from 2010 to2011, and that her boss had asked her to contr ibute. Her boss, whom she only knew as(she thought that was the spelling) told her before she contributed that he would reimburse her and hedid do so. She belieyed that GW had one or two branches and said that she did not know if her bosswas the boss of all branches. The store she worked at was on Northern Boulevard but she could notrecall the street number.She recalled that her boss' wife, who visited the store once in a while, had the last namecould not recall her first name and did not know the name

but she

She made the contribution because he was her boss and he asked her to. She did not know if he askedother employees to contribute. She added that if he had asked other employees to contribute, hewould not tell her he had done so and if other employees had been asked to contribute, they would nottell her if they had contributed.She gave him the check at the supermarket and said she could not recall if she had filled out acontribution card; she said that if she had-done so, she could only have done so on her own if it was inChinese and that if it was in English she would have needed help. She confirmed that the signature onthe check was hers but said she was not sure about the rest of the writing on the check and noted thatit had been a long time ago. (TA did not receive a copy of a contribut ion card.)When we asked her about "John Liu," she said she did not know the name.She said she has lived at this address for three years and has never lived at



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Great Wall SupermarketShe was concerned about getting in trouble or her former boss finding out that she had told us that hehad reimbursed her for the contribution, but she provided her phone number and agreed that we couldcall her i f we had additional questions. She noted that she speaks Mandarin and does not speakEnglish.

[Note: TA subsequently conducted searches of contribution information on the CFB, NYS BOE and FECweb sites and did not find any other contributions made by.



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Contributor:Employment: Cashier, Great Wall SupermarketAddress:Contribution: ~ 8 0 0 , c h e c k ; 7 / 9 / 1 1Intermediary:Interview Date/Time:" 5/9/13; 7:25PM

Summaryi was interviewed, in Chinese, in front of her residence.

At the start of the interview, she asked if this was about the $800. She explained that she had beenquestioned about this about a year earlier by one person and a translator. She didn't know who theyworked for but thought they also worked for the City of NY (we had told her we were assisting the NYCCFB).

She said she used to work as a cashier at GW Supermarket and that her boss, . had asked herto contribute and had suggested the amount of $800. She insisted she was not reimbursed for hercont ribution . Her boss asked everyone at work to contribute, to do their part, but she said she didn'tknow if other employees did contribute. She later said that her boss had asked her in private tocontribute and that she had given the check to her boss at the GW Supermarket at 144 NorthernBoulevard; she said that her boss has many supermarkets.When we asked about John Liu, she said she knew who he was but she could not identify the office hewas running for, although she said that she had known at the time of the contribution. She added thatshe thought he was running fo r the United States Government and said that she knows there are aPresident, Senators and Congressman but she didn't know which position he was running for.She said she likes to contribute to Chinese politicians and cited as another politician towhom she has cont ributed. Her husband, whose name she gave as arrived duringthe interview. Although his name is also on the check, she said that he did not contribute to John Liu.[Note: TA subsequently conducted searches of contribution information on the CFB, NYS BOE and FECweb sites and found tw o other contributions by aSeptember 22, 2010 for '

\o f Flushing -a $1,000 contribution onand a $250 contribution in September 2012

fo r _ The 2010 cont ribut ion to was on the same date ascontributions by ,land he wife of (#3 below); the amount was the same as .wife while gave $3,800, which, according to the NYS BOE web site, was the maximum allowableindividual contribution for primary elections for the New York State Assembly in 2010. We did not findany cont ribut ions by her husband. While we did find one contribution in the same name as herhusband's, the reported address was in Woodside, Queens, rather than in Flushing; that was a $100

July 15, 2013CONFIDENTIAL Page 17


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Great Wall Supermarketcontribution to John Liu in January 2013.)When we asked if she had told her husband what the interview was about, she thought we wondered ifshe had told him about the $800 and she laughed and said that she had told him about the $800because it was no t $8. When we then asked why she had contributed so much, she said it was her firstcontribution and her boss, who was very nice to the employees, had suggested that amount. Sheadded that sometimes the business would have a party and John Liu would come and speak, although itwas not a party fo r Liu.She said that she completed a contribution card and signed it in English. She said that she can read alittle bit in English and can write simple things in English, such as her name and address, and that foritems on the card that she didn't understand, she asked fo r assistance from the head cashier, whomshe only knew as I '(TA did not receive a copy of a contribution card).



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Contributor:Employment: Manager, Great Wall Supermarket

~ - - - - - - - - - - - - - - - - - - - - - - - + - - - - - - - - ~ .Address:Contribution: ';$800, check; 7/8/11Intermediary:Interview Date/Time: 5/11/13; 11:00AM

SummaryThis address appeared to be a relatively new, well-maintained two-family home. When we arrived,

was in the driveway sitting in an Infiniti NY plate , with the enginerunning. [According to NYS DMV records, this license plate I!> lU I a Infiniti registered to at

He said he did not speak any English and he was interviewed in Chinese. He said that he is a managerat GW Supermarket. He said he contributed $800 because his boss, asked him if he waswilling to contribute $800. His boss said that if he was willing to, he could contribute more. Hecontributed because he is a manager and stock shareholder and thought it would be good for thecommunity. He insisted that he was not reimbursed for his contribution and said that he hascontributed before when his boss, who has good relationships with politicians, has asked forcontributions. He could not recall the names of any other candidates to whom he has contributed.He confirmed the signature on the check was his but said that his wife had filled out the rest of thecheck because he cannot write in English. He added that the check was filled out at home.His wife, who spoke a little English, came out as we were talking and confirmed that she had writtenthe check other than the signature and said she did not contribute to the Liu campaign.

[Note: TA subsequently conducted searches of contribution information on the CFB, NYS BOE and FECweb sites and did not find any other contributions made by We did find one contributionby a who would appear to be his wife; we did not obtain his wife's name but is theother name or, check to Liu and the contributor eported the same address on as

The one contribution !lade was a $1,000 contribution on September 22, 2010 to: - the same date as contributions by (#2 above) and

it was the same amount as Nhile gave $3,800, which, according to the NYS BOE web site,was the maximum allowable individual contribution for primary elections for the New York StateAssembly in 2010. 1His wife said they had to leave to go to work but before they did ,said that , (# 4 below)was his brother, also contributed, was also a manager at GW Supermarket, was working at that time,and lived with them.



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4.Contributor:Employment:Address:Contribution:Intermediary:Interview Date/Time:

See notes under

/

Great Wall Supermarket

Manager, Great Wall Supermarket): $800. check; 7/9/11

5/11/13; 11:00AMSummary

,#3 above.



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Contributor:Employment: Manager, Great Wall SupermarketAddress:Contribution: , $800, check; 7/10/11Intermediary: JInterview Date/Time: 5/9/13; 8:40PM

SummaryThis apartment is in one of a group of four apartment buildings, all of which appeared to be in disrepair.

At Apartment , a woman stated, in Chinese, that she was wife and that he was workingat GW Supermarket where he is a manager. At first she said that he could not make a politicalcontribution because he is only a green card holder but then she said that she didn't know if he wouldmake a contribution and that he would not tell her if he did. She said his company has events fornatural disasters and such but she did no t know about political events.We showed her the contribution check and she confirmed that the signature on it was her husband'sbut said that she did not know about the check. She suggested that we call her husband and talk withhim, provided his phone number, and said that he doesn't speak English. She took a photograph of thecheck and of the letter from the CFB authorizing TA to assist with the CFB's audits.Interview Date/Time: 6/21/13; 4:10PM

Summarywas reached at phone at the number provided by his wife and interviewed, in Chinese.

After he was told the purpose of the call, he said that he had written a check fo r John Liu at home, thatno one had asked him to contribute, that he had not been reimbursed and that he had thought of thecontribution amount of $800 on his own. He could not recall if he had mailed the check and noted thatit was a long time ago.At first he could not recall if he had completed a contribution card and then said that he thought hemight have and that he might have gotten one at a library on Main Street where John Liu had had anevent. (TA did no t receive a contribution card.) He said he worked at Great Wall at the time and stillworks there. He did not know if anyone else at work contributed and said he did not think it wasappropriate to ask others if they had done so. He could not explain why others at Great Wall wouldhave made contributions to Liu on the same date. His boss's last name is

When asked if he had contributerl to other campaigns, he said that he had contributed to a City Councilmember with the last name when asked if it was he said he did not know. He saidhe supported her because of her ethnicity and that it was like "Jews supporting Jews and Italianssupporting Italians./I [Note: TA subsequently conducted searches of contribution information on theCFB, NYS BOE and FEC web sites and did not find any other contributions made by

CONFIDENTIALJuly IS, 2013Page 21


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6.Contributor:Employment: Manager, Great Wall SupermarketAddress:Contribution: ;$800, check; 7/10/11Intermediary:Interview Date/Time: 5/11/13; 10:40AM

SummaryThis address is a large apartment building and would appear to contain modestly-priced apartments.

1At Apartment _,! an elderly woman stated, in Chinese, that she was wife and that hewas working at Great Wall Supermarket. She said that she did not know anything about contributionsand was unwilling to talk with us.

7. .Contributor:Employment: Sales, Great Wall SupermarketAddress: -Contribution: \; $800, check; 7/11/11Intermediary:Interview Date/Time: 5/11/13; 10:10AM

SummaryThis large, modest apartment building had buzzers but no names out front. We did not get an answerwhen we rang the buzzer. An elderly Chinese-speaking male who was coming out of the building saidthat ;was working "in the basement" at a GW Supermarket down the street.' We observed a! .GW Supermarket a couple of blocks away on Northern Boulevard.

CONFIDENTIAlJuly 15, 2013Page 22


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8.Contributor: -Employment: Manager, Great Wall SupermarketAddress:Contribution: ! : $800, check; 7/9/11Intermediary:Interview Date/Time: 5/11/13; 11:10AM

SummaryThis address is a well kept two-family home. There were no names in front of the house, we got noanswer when we rang the buzzers and no neighbors were observed.

9.Contributor:Employment: Manager, Great Wall SupermarketAddress: .- - .Contribution: $800, check; 7/9/11Intermediary:Interview Date/Time: 5/11/13; l1:lOAM

SummaryThis is the same address as #8 above. No one answered the door at this two-family home.

10.Contributor:Employment: Cashier, Great Wall Supermarket

-,Address:-_._-. ,-

Contribution: $800, check; 7/10/11Intermediary:Interview Date/Time: 5/11/13; 1O:20AM

SummaryThis address is a large apartment building that appeared to be well-maintained. The name next to thebuzzer fo r Apartment - was - - - - -We got no answer when we rang that buzzer. When weaccidentally rang the buzzer fo r Apartment , we asked the male who answered in English i f he knewwas

I and he said that he did not know the name; the name by the buzzer for Apartment,- -



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11.Contributor: :Employment: Office Clerk, United Fruit & ProduceAddress:Contribution: ; $800, check; 7/11/11Intermediary: None .. "Interview Date/Time: 5/8/13; 7:55PM

SummaryThis address is a three-fami ly home. No one was home on the second floor but we spoke with thelandlord, an Asian male who lives on the first floor and spoke English. He told us that he did not knowthe name' but said that a lot of people get mail at the second floor.Interview Date/Time: 5/10/13; 5:45PM (Second Attempt)

SummaryNo one answered when we rang the buzzer for the second floor.Interview Date/Time: 5/10/13; 6:05PM (Third Attempt)

Summary-"

We went to this location, a two-family home, because database research by TA had identified it as apotential address fo rWe got no answer at either unit, no names were visible out front and no neighbors were around.



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Contributor:Employment: Manager, United Fruit & ProduceAddress:Contribution: ; $800, credit card; 7/11/11Intermediary: NoneInterview Date/Time: 5/11/13; 11:25AM

SummaryNo one answered at this well-maintained two-family brick home. There were no names on the houseand no neighbors were around.Parked in the driveway was a large Mercedes Benz SUV with NY plate I[Accordingto NYSDMV records, this license plate is fo r a Mercedes Benz registered to

.. A search of contribution information on the CFB web site did notfind any contributions by to the Liu campaign.]



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McCormick & O'Brien, LLP

B. McCormick & O'Brien, LLP Summaryi. Information Provided to the CFB

Information the Liu campaign provided to the CFB identified contributions by five employees ofMcCormick & O'Brien, LLP ("M&O"), a Manhattan-based law firm. Each of these employees wasreported to have made one contribution fo r $800 and paid by credit card, although three of the credit

." .card charges were subsequently cancelled. The contributions that were cancelled were byand . . attorneys, and I office administrator. The other two contributions were by

, and I Records that the campaign provided to the CFB include a copy ofa one-page fax from \ at M&O to , 1\ I requesting receipts for contributions bythe five individuals identified above and fo r I and .1 (likely the spouses of

and' I)' Seto was the intermediary fo r all seven of these contributionsand all but the McCormicks' contributions were reportedly received by the campaign on April 15, 2011.

ii. Contributors Were To Be Reimbursed By Their EmployerWe interviewedstated that

. . and a former paralegal at the firm.(iold her to tell employees at the firm that they had to contribute and

that they would be reimbursed. __ and said that they were not reimbursed for theircontributions but gave conflicting reasons for why they contributed and why they cancelled theircontributions.According to , a former bookkeeper at the firm, one of the partners,told her to tell the other employees that they had to contribute to the Liu campaign.stated that \ told her to tell the employees to contribute from their personal accounts andthen the firm would reimburse them. 'stated that \ "was demanding that theother staff do it ... put money in to John Liu's account, you had to make the contribution whether youwanted to or not ... that's what he said he was going to do ... whether they wanted to or not, they had todo" it. \ was on vacation and called her and told her that "they had to do that and they had todo it right away."At that time, there were approximately seven or eight lawyers at the firm, including and

.1,. When . --! sked tbem to cOl'ltr:ibute, "they were worded about losing their jobs ll ifthey didn't. When she asked them to contribute she told them that they would be reimbursed becausethat was what \had told her to tell them.

i, stated that some employees did contribute to the Liu campaign but several requested thatthe Liu campaign return their contributions.



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McCormick&O'Brien, LLP

and save conf lict ing stories. -) aid he believed that a client of the firm's wasaffiliated with Liu and, because they wanted to help the client out, employees of the firm contributed.His recollection was that the money was not going directly to Liu and that a paralegal in the office hadfound out that there was a problem with "the bundler," so he withdrew his cont ribution. saidthat she had contributed because she supported the candidate and that she had cancelled hercontribution because, on her own, she had read something in the newspaper "that something fishy wasgoing on" with the campaign. She said that after she found this out she told " her sister, tocancel her contribution. She said that, with the exception of her sister, she was not aware of others atthe firm having contributed to the campaign and said it was a coincidence that others at the firm haddone so at the same time she had. Nei ther . nor.i Iknew the name I

IWe also spoke with a former paralegal at M&O. She said that at the time of thecontributions she researched John Liu and found articles regarding Jenny Hou having been investigatedin connection with campaign donations. She had further concerns after she did some researchregarding the Liu campaign, including concerns about the address and phone number on the credit cardreceipts. She said that she and shared the info rmation she had found withthat he said "I don't want to hear it." She then shared her concerns with I and and

and they all cancelled their contributions. She said that .. later asked if she still had theinformation she had found; she didn't think she had it but she later found it and in January 2012 shesent him an email with the article. In her email, a copy of which is attached as Exhibit 3, she describedher research and what she had found. She closed the email with, "About mid-month in May 2011, therewas renewed media coverage on campaign funds fraud fo r John Liu.who contributed of the issues with fraud."

iii. Interview SummariesSee below.

CONFIDENTIAL

and I informed the employees

July lS , 2013Page 27


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McCormick & O'Brien, llP

1.Contributor:Employment : Attorney, McCormick &O'BrienContribution: ; $800, credit card; 4/15/11 (chargeback to credit card on

6/1/11)Intermediary:Interview Date/Time: 6/7/13; 3:15PM

Summarywas interviewed by phone at McCormick & O'Brien. After explaining the purpose of the

call, he was asked about his contribution to the John Liu campaign. He stated at the start that thecontribution was not completed. He said that he believed that a client was affiliated with Liu and theywanted to help the client out so they contributed. The client was not his but the client of anotherlawyer in the firm, although he could not recall which lawyer. His recollection was that the money wasnot going directly to Liu and that a paralegal in the office had found out that there was a problem withlithe bundler," so he withdrew his contribution. He said he could not recall any details about this.When he was asked about the name he said he was not familiar with that name and thathe could not recall the bundler's name.He noted that he is often asked fo r contributions and that sometimes he does contribute.[Note: TA subsequently conducted searches of contribution information on the CFB, NYS BOE and FECweb sites and found only two other contributions by a with an address or employmentmatch: a $500 contribution for lin August 2012 and a $100 contribution toI, in May 2012.]When asked about , and " he stated that they are sisters, one is an attorney, and thatboth had worked fo r the firm but neither currently does. He did not know what firm the attorney iscurrently with but suggested that that information could be found online.He said that he could be called if we had any u ! t h ~ r Questions.



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2.Contributor:Employment: Attorney, McCormick & O'BrienContribution: ; $800, credit card; 4/15/11 (chargeback to credit card on

6/10/11)Intermediary:Interview Date/Time: 6/11/13; 2:45PM

Summarywas interviewed by phone. After explaining the purpose of the call, she was asked about

her contribution to the John Liu campaign. She said that she had made the contribution using herAmerican Express card and then had "cancelled" it; she said the contribution was fo r $800 or less.When asked why she had contributed, she said that she had done so fo r the "usual reasons," andexplained that she supported the candidate. She later said that she never went to a campaign event orhad any contact with the campaign.When asked why she had cancelled her contribution, she said she had read something in thenewspaper "that something fishy was going on." She said she found this out on her own and that it wasright at the start when "things" started to come out about the campaign. She couldn't recall detailsabout what she had found and later said that she thought it was probably about the start of "the case."She said that "we faxed" the contribution forms and when asked why she had said "we," she said thatshe had given the form to a secretary at work to fax; she could not recall the name of the secretary.She could not recall how she decided on the amount of $800 to contribute and did not recall that thatamount had been typed on her contribu tion form. Her recollection was that she had completed thecontribution form by hand.

is her sister and worked at McCormick & O'Brien as the office administrator. i alsocontributed to the Liu campaign and she reviewed her contribution form before it was faxed.withdrew her contribution for the same reasons that she I did because she told to do so.She was not aware of an intermediary having been irwolvee with-her contribution-ane die no t know thename She asked us i f was a client of the firm's and we said that we did notknow.She worked at McCormick & O'Brien for a little less than tw o years. She handled the immigrationpractice and her clients were mostly her own. Her sister, who is a few years younger than her, workedat the firm fo r about one year or one year and a few months (TA database research found that wasborn in and in



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She acknowledged that she has not made other political contributions and said "I think I'm done withit," and later said that it had "left a bad taste in my mouth." [Note: TA subsequently conductedsearches of contribution information on the CFB, NYS BOE and FEC web sites and did not find any other

c o n t r i b ~ t i o n s by orShe did not discuss her contribution with anyone and said that, besides her sister, the only person shetold why she withdrew her contribution was a female attorney that she shared an office with. She didnot believe that this attorney contributed to Liu and did not want to provide her name; she asked if shehad to provide the name and was told that she did not have to.When asked i f anyone ever told her that they would reimburse her fo r her contribution, she said thatno one had. She said she was not aware of others at McCormick & O'Brien having contributed andwhen told that others had and on the same date that she had, she said that, as far as she knew, it was acoincidence that they had done so on the same date. She was not aware of anyone else at the firmcancelling their contribution.When told that $800 was a lot of money, she said that she did not think it was that much.At this point in the interview, a phone could be heard ringing in the background and she said that shehad to go but that she could be called back if we had further questions.

3.Contributor:Employment:Address:Contribution:

Intermediary:Interview Date/Time:

-

See #2 above.

!i,

Office Administrator, McCormick &O'BrienNone

; $800 cred it card; 4/15/11 (chargeback to credi t card on6/10/11)

6/11/13; 2:45PM- - Summary



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4.Contributor:Employment: Accountant, McCormick & O'BrienContribution: NoneIntermediary: NoneInterview Date/Time: 6/12/13; 8:30AM

Summary~ - . ~ - - - - - - - ~ - - - - - - - - - - ' - - - - - - - - - - - - - - - - - - - - - - - - - - - l!was interviewed by phone. She was told that TA was assisting the CFB with an auditof the John Liu campaign and that, among the steps we were taking, we were reviewing contributionsby employees of McCormick & O'Brien. She said that she had worked at the firm as a bookkeeper, twodays a week, for about one year and that she had left the firm about 13 or 14 months ago. She wasasked about a document that the CFB had received from the campaign. This document is a fax coversheet in which she asked the Liu campaign for receipts fo r contributions (the cover page is dated May 4,2011, and asks fo r receipts fo r the following:

She said that one of the partners at the firm, whom she subsequently identified ashad asked her to ask other members of the staff if they would be willing to contribute to the Liucampaign. She asked fo r receipts "because I didn't trust anything that was going on." She added thattwo people who had contributed pulled out because "I told them that it didn't look legit."She said that employees had to contribute from their personal accounts and then the company wasgoing to reimburse them. "was demanding that the other staff do it ... put money in to JohnLiu's account, you had to make the contribution whether you wanted to or not ... that's what he said hewas going to do ... whether they wanted to or not, they had to do" it. \was on vacation andcalled her and told her that "they had to do that and they had to do it right away."There were approximately 7 or 8 lawyers at the firm and when she asked them to contribute "theywere worried about Ibsing their jobs" if they didn 't. When she asked them to contribute she told themthat they would be reimbursed because that was what, , had told her to tell them. Her initialrecollection was that was the only one who contributed and she did not know if he gotreimbursed. She then recalled th9t ~ ~ ~ . had conJributec! ami then "she pullecl out." _She thoughtthat had contributed $800 on her American Express card. She also recalled that

, a lawyer who did wills and trusts, talked to his wife who told him not to contribute but that hedid, though he later cancelled it.Regarding request for contributions, she said that "me anddid our own investigation of John Liu" and they told "i t was a fraud and he didn't want tohear it." She thought that I, who she believed had changed her first name from .. would



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McCormick & O'Brien, ll P

remember more than she did. She noted that was there full-time and she was only there twodays a week, so she was not aware of all conversations.at the law firm of where she used to work.

left the firm and she got a job

She recalled that 's sister and a receptionist at McCormick & O'Brien, had alsocontributed but she thought that, like she also "pul led out." She didn't ask Ito contribute anddid not know who did; just asked her to ask the lawyers and he did not ask her tocontribute.The fax cover sheet was addressed to and the Friends of John Liu. She does not knowhad no contact with and did not think was a client of the firm. She recalled talking with awoman from the Friends of John Liu, who she thought was the treasurer. She could not remember hername and when asked if it was Jenny Hou, she said that that was the name of the woman she spokewith. She did not mention anything to Hou about the reimbursement of contributions and said that shedid not think that ___Iknew Hou.

In discussing, " she brought up that if TA attempted to talk with him that he would not talkand that he would not be honest if he did. She said there would have been emails from , inaddition to phone calls, about these contributions and that "they were definitely going to be refunded."She provided\'s cell phone number, suggested calling her around 6:00 or 7:00 in the evening,since she works during the day, and said that we could tell that we had spoken with her.



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5.Contributor: ..Employment: Paralegal, McCormick & O'BrienContribution: NoneIntermediary: NoneInterview Date/Time: 6/12/13; 9:30AM

Summarycalled Thacher Associates and was interviewed by phone. She said that - .

had called and given her TA's name and contact information. She provided the followinginformation.

She worked at McCormick & O'Brien (M&O) from 6/28/10 until 8/9/12. She was hired as the ChiefLitigation Paralegal but also served other roles: general IT help; litigation tech support specialist; andshe did securities anrl background checks on clients and others. She has a Master's degree inICriminology/Law from )niversity in Louisiana and completed post-Master's studies atthe University of ,/here sne studied forensics.Regarding contributions by lawyers at M&O to the John Liu campaign, she said that ' gave hercontribution forms and she scanned them and typed in information on the form: on one form she onlytyped in a contribution amount of $800 and on other forms she typed in the contribution amount andthe contributor's name and other information. She later said that she took $800 of f one of the formsbecause one of the attorneys at the firm wanted to give less; she thought there might be an emailregarding this. She believed that gave the contribution forms to

After she saw the contribution forms, she Googled John Liu and found articles linking Jenny Hou, Liu'sfinance manager, to a Chinese businessmen's association in Chinatown that had given a collectivedonation to the ',campaign and that Hou was under investigation. She went to land

J"wondered if it was on me up and Up" because the finance manager was under investigation.went to 'and came back and said that he didn't want to hear about it.She continued to look into the contributions. She asked . -,if she had run the American Express cardinformation that emp!oye_es had used to make fon!ributions ang __ ~ s a i d she bag. brolJgbtberthe American Express receipts and she checked on the address and phone number on it and found bothsuspicious. She found that the address was fo r an apartment building on Mott Street (an address onMott Street was on the contribution form; the American Express receipt had an address of'), which she thought couldn't be right fo r a campaign office. Shecalled the phone number on the receipt, which she thought should be fo r the campaign office, and itwas answered "hello," rather than a greeting for a campaign office. She told the woman who answeredthat she was trying to reach the Liu campaign office because she wanted to confirm that some



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McCormick & O'Brien, ll P

contributions had been received and she wanted receipts other than an American Express receipt. Thewoman told her that they did not give receipts and she told the woman that was impossible and askedfo r the woman's office number, as it sounded like she was on a cell phone. The woman told her thatsomeone would call her bu t the woman did not ask fo r her name and phone number. She then calledthe li u campaign office and asked to speak with Jenny Hou. When she was told that Hou did not takephone calls, she asked fo r receipts and she was told they did not give receipts. The unknown male shewas speaking with said they would give her a call and, although he did not ask fo r her contactinformation, she gave it to him.

After this she told' " that she should give the attorneys the information she had found and whichshe had pulled together. She and .. went to office and presented him with the articleand information she had found and he said "I don't want to hear it." told them he hadn'tasked them to do that and that he just wanted them to do what they were told.

She and then called the other attorneys down to their office and told them what they had found.The attorneys wondered if "it" was legitimate and she said she didn't think that it was and she gavethem the reasons why, including the information she had found on Jenny Hou, the address beingresidential and the way the phone was answered.She provided the following information on attorneys and spouses at M&O who may have contributed: - he and his wife, who works at Conde Nast, both contributed. had to

convince his wife, who she believes also has the last name , to contribute. (A search of theCFB online database did not identify any contributions to li u by a female with the last name of

and information the campaign provided to the CFB shows no other contributors with thesame residential address as

- he was in North Carolina when this came up and he sent an email to cancel hiscontribution; his wife did not want to contribute and she did not know if she did (CFB records showthat a with the same residential address as " also contr ibuted).

- she believed he and his wife both contributed (CFB records show that a .;, with the same residential address as , also contr ibuted).

She spoke withcontributions.

and and ,about what she had found and they all voided their

She said that one time \ told her that he had been called by a newspaper reporter regardingJohn liu. When I old her this, he asked if she had the information she had done regarding thearticles and, at that time, she didn't think she did. A couple of months later she realized she did havethe information and she sent I an email about it, but he said that it was too late. She said that



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did not recall the reporter's name. (During this interview she located and forwarded the emailshe had sent to ' and his response, which are attached as Exhibit 3. In that January 19, 2012email to ; she went over some of the research she had done to confirm that the contributionsby the firm's employees were legitimately applied to the Liu campaign and some of her findings,including information on the campaign manager and residential addresses fo r campaign offices.

, responded on the same date with simply "Thanks.")She said she believed that if \ s contacted by TA that he would call her.She still does contract work for M&O and said that she is the only one they trust to do backgroundresearch.She did not directly hear 'tell lawyers at the firm to contribute and she said that "he dealtwith ~ e g a r d i n g that." She did think that there was an email in which instructedto ask the attorneys fo r contributions and she said she would check to see if she had it. She also saidshe had heard that at a partners' meeting 'had told the lawyers to give to the Liu campaign;she thought that \ had told her about this. There were some convers


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told they could leave a message fo r and later they were told that was not there.

When asked about Jenny Hou, she said that she had no contact with h

EC2013 Liu Thacher Report Final FOIL Distribution

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