FOIA Request - CREW: Regarding the Department of Justice Investigation of Christine O'Donnell:...

8/6/2019 FOIA Request - CREW: Regarding the Department of Justice Investigation of Christine O'Donnell: Exhibits

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Copyright 2010 Associated PressAll Rights Reserved

The Associated Press

December 30,2010 Thursday 02:08AM GMT

HEADLINE: Feds probe Christine O'Donnell's campaign spending

BYLINE: By BEN EVANS and MATTHEW BARAKAT, Associated Press

DATELINE: BALTIMORE

BODY:

Page 7

Federal authorities have launched a criminal investigation to determine whether failed U.S. Senate candidate Christine O'Donnell broke the law by using campaign money to pay personal expenses, according to a person familiar withthe investigation.

O'Donnell, the Delaware Republican and tea party favorite who scored a surprise primary victory this year only tolose badly in the November general election, denied the charges and suggested they were being driven by her politicalopponents on the right and left, including Vice President Joe Biden.

The person spoke to The Associated Press on condition of anonymity to protect the identity of a client who hasbeen questioned as part of the probe. The case, which has been assigned to two federal prosecutors and two FBI agentsin Delaware, has not been brought before a grand jury.

O'Donnell, who set a state record by raising more than $7.3 million in a tea party-fueled campaign this year, hasbeen dogged by questions about her personal and campaign finances.

At least two former campaign workers have alleged that O'Donnell routinely used political contributions to paypersonal expenses including her rent as she ran for the Senate three consecutive times, start ing in 2006. She acknowledged in a newspaper interview in March that she paid part of her rent with campaign money, arguing that her housedoubled as a campaign headquarters.

The U.S. Attorney's office in Delaware has confirmed it is reviewing a complaint about O'Donnell's campaignspending made this year by a nonpartisan watchdog group, Citizens for Responsibility and Ethics in Washington. Butofficials in the office and the FBI declined to say whether a criminal investigation was under way.

O'Donnell's campaign issued a statement Wednesday denying that she misspent campaign money and saying it hasheard nothing from authorities.

"I f anything does materialize from this rumor, we will continue to fully cooperate as we have made every attemptto ensure we are in compliance with all rules and regulations," the statement said.

O'Donnell called the allegations politically motivated and singled out Biden, who represented Delaware in the Senate for decades.



Page 8Feds probe Christine O'Donnell's campaign spending The Associated Press December 30,2010 Thursday 02:08AM

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"Given that the king of the Delaware political establishment jus t so happens to be the vice president of the mostliberal presidential administration in U.S. history, it is no surprise that misuse and abuse of the FBI would not be of f thetable," she said in the statement.

CREW alleged in a complaint last September that O'Donnell improperly used more than $20,000 in campaign

funds to pay her rent and other personal expenses. The group also asked Delaware's federal prosecutor to investigate.Federal law prohibits candidates from spending campaign money for personal benefit. FEC rules state that this pro

hibition applies to the use of campaign money for a candidate's mortgage or rent "even if part of the residence is beingused by the campaign," although O'Donnell's campaign maintained that it was told otherwise by someone at the agency.

O'Donnell drew national attent ion in September when she upset U.S. Rep. Mike Castle for the GOP Senate nomination. She was handily defeated in November by Democrat Chris Coons following a campaign that focused largely onpast controversial statements, including that she'd "dabbled into witchcraft" when she was young.

One former O'Donnell staffer, Kristin Murray, recorded an automated phone call for the Delaware Republican Party just before the primary, accusing O'Donnell of "living on campaign donations using them for rent and personal expenses, while leaving her workers unpaid and piling up thousands in debt."

Another former aide, David Keegan, said he became concerned about O'Donnell's 2008 campaign finances as she

fell behind on bills and had no apparent sourceof

income besides political contributions. He submitted an affidavit toCREW alleging that she used campaign money to cover meals, gas, a bowling outing, and rent to a landlord, BrentVasher.

Vasher, a nephew of Keegan's and a one-time boyfriend of O'Donnell, declined comment when asked by The AP ifhe had been contacted by authorities. Vasher bought O'Donnell's house in 2008 after she was served with a foreclosurenotice, then charged her rent to stay there, according to CREW's complaint.

In a message sent last week to The AP, Keegan said he had not been questioned as part of a criminal investigation,and that he considers himse lf only a "catalyst" in a case in which several people must be questioned to scrutinizeO'Donnell's accounting practices and alleged misuse of campaign funds.

After losing two treasurers in 2009, O'Donnell named herself campaign treasurer until this past summer. Anothershort-term treasurer took over in August and resigned less than two months later, at which point campaign managerMatt Moran added the treasurer's role to his responsibilities.

Murray, the former aide who recorded the automated message, also said she had not been contacted about the investigation.

Democrat Charles Oberly III, the U.S. attorney for Delaware, and his predecessor, David Weiss, did not immediately return messages Wednesday seeking comment. Oberly was sworn in Tuesday as Weiss' successor.

Kim Reeves, a spokeswoman for the office, reiterated Wednesday that the office was reviewing the CREW complaint. She would not confirm the existence of a criminal probe.

Rich Wolf, a spokesman for the Baltimore office of the FBI, said he could neither confirm nor deny that any investigation was taking place.

O'Donnell, who announced just after Election Day that she had signed a book deal, hasn't held a full-time job inyears and has struggled to explain how she makes a living.

She reported in July that she earned only $5,800 in income for the previous 18 months through freelance public relations work. She said she lived mostly on a savings account that she reported in an amended Senate disclosure report asbeing worth between $1,000 and $15,000.

Her financial past includes a tax lien from the IRS, a lawsuit from the university she attended over unpaid bills anda foreclosure action that she avoided by selling her house to Vasher jus t before a sheriff s auction. Her campaign maintained the tax lien was the result of an IRS mistake and computer error.

Her campaign reported spending some $6.1 million in the 2010 campaign. Moran said earlier this month that campaign attorney Cleta Mitchell advised reserving several hundred thousand dollars for legal fees to defend against thecampaign spending allegations.



Page 9Feds probe Christine O'Donnell's campaign spending The Associated Press December 30,2010 Thursday 02:08AM

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"We've been warned by multiple high-ranking Democrat insiders that the Delaware Democrat and Republican political establishment is jointly planning to pull out all the stops to ensure I would never again upset the apple cart,"O'Donnell said in her statement Wednesday. "Specifically they told me the plan was to crush me with investigations,lawsuits and false accusations so that my political reputation would become so toxic no one would ever get behind me."

Barakat reported from McLean, Va. Associated Press writers Ben Nuckols in Baltimore and Randall Chase in Dover, Del., contributed to this story.

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Re: Christine O'Donnell

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ln or about September 21HO, this office received a rdcmu from Citizens forR e ~ o n s i b i l i t yaud Ethlcs in WJJ!ihington{"CREW'} alkging certain criminal l."nrnpruanfinance viulationscommi(ied by Ms. O'DonnelL As ycu a.r-c aware, this ()fflCo has lx::en

reviewing I J 1 ~ ; s eallegations, "'hkh principally invnlve the claim lliat Ms. O'DonnellH l e ~ a l l yconverted crurtpai gn fimds tu her pcrs•;nal use and .rnade c.OrT¢1lfHJlldJngthlsestatements <lnforms fited wltl.1 ihc Fe.dcralElection Conllllisslon.

r v.nte to inform you that this oftic.e l ~ dose<! its review and d o e ~not intend topur.me cti ntinal ci:JJ,rgesat this •une. It i& my uooe.r:standingthat the CREW C ( ~ m p h u n tWill>Ali\<1filed wllh !he FEC, <Uld we lmen(iiO refer this m . a t t ~ r!.o that a g ~ ; n c y .

If )•ou huve an y questions., pkase C { ~ n ! . a c t/I.J;$iStuntUnite>d States Attorney Keith l \ tRo.stJ\, the Chief of our CrrminaliJJvisiun.

Very truly yours,

Clw-L. l ' v ' ~. a b ~0 - J A R L F ~ SM. OBE.!UY,irf ~ - - .11nitcdStates Attorney

Letter Outlining CREW Violations

7/19/201110



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Copyright 2011 The News JournalAll Rights Reserved

The News Journal (Wilmington, Delaware)

July 17,2011 Sunday

HEADLINE: O'Donnell backers take aim at groupBYLINE: By, CHAD LIVENGOOD

BODY:

The News Journal

Page 1

Christine O'Donnell is fighting back against critics who have accused her of living of f donations from her failedU.S. Senate campaigns.

Federal prosecutors have closed an investigation into allegations O'Donnell used campaign funds in 2009 to make$1,500 in rent payments to a former boyfriend who bought her Wilmington home.

U.S. Attorney Charles Oberly sent O'Donnell's attorney a letter Friday saying he was closing his investigation and"does not intend to pursue criminal charges at this time."

Oberly said his office would refer the matter to the Federal Elections Commission, which already has been investigating a similar complaint lodged by Citizens for Responsibility and Ethics in Washington (CREW).

In May, the FEC's general counsel said there was "reason to believe" O'Donnell's campaign illegally coordinatedwith a California tea party group in the primary, but the commission deadlocked on a 3-3 vote along party lines and thatinvestigation was ended.

With two of three federal investigations against her now closed, O'Donnell is preparing to swing back at her accus-ers.

"We're going on the offensive, and it's time to bring CREW to justice for their slimy tactics," said attorney RichAbbott, a Republican from Hockessin.

Abbott said he was not at liberty to discuss O'Donnell's next move against CREW, but that it would be announced

soon.On Thursday, Abbott initiated an offensive that he said has been months in the making by asking Oberly's office to

investigate CREW for filing a criminal complaint that he claims contains "false statements."

Separately, a friend of O'Donnell's is seeking to have CREW executive director Melanie Sloan, an attorney whogrew up in Wilmington, disbarred in the state of Virginia.

"We were beginning the offensive regardless of this dismissal by the U.S. Attorney's Office," Abbott said Saturday.



Page 2O'Donnell backers take aim at group The News Journal (Wilmington, Delaware) July 17, 2011 Sunday

Matt Moran, campaign manager for O'Donnell, alluded to what may come next. "Sloan, like the George Soros-financed CREW, is a shameless fool who may possibly lose her legal license and face criminal charges in the nearfuture," Moran said in a statement.

CREW filed its complaints with the FEC and U.S. Attorney's Office last September after O'Donnell upset Rep.Mike Castle, R-Del., in the Republican Senate primary. O'Donnell went on to lose the race to Democrat Chris Coons inNovember.

CREW's complaint contained a signed affidavit from former O'Donnell campaign worker David C. Keegan claiming O'Donnell made two payments of $750 each in 2009 to her former boyfriend, Brent Vasher, who bought her homeon Lincoln Street in 2008 to prevent it from being auctioned of f at a sheriffs sale.

"I later became aware that in 2009, Ms. O'Donnell used her campaign funds for other personal expenses, includinggas, meals and even an outing to a bowling alley," Keegan wrote in sworn affidavit that was not dated.

Abbott requested that Oberly prosecute Keegan for allegedly making false statements under penalty of perjury.

Sloan said the Washington-based watchdog group's allegations were based on Keegan's sworn affidavit andO'Donnell's campaign finance reports that show a $750 payment to Vasher for "expense reimbursement" in March 2009and another $750 the following month for "reimbursement for services." O'Donnell has maintained the checks were to

reimburse Vasher for expenses he incurred working on her failed 2008 Senate campaign against Joe Biden, not for rent.Keegan stood by his story Saturday that Vasher --his nephew-- told him the payments were for O'Donnell's unpaid

rent. "No, I don't back away from that because that's what Brent told me," Keegan said.

Contact Chad Livengood at 324-2832 or [email protected]

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Copyright 2010 The News JournalAll Rights Reserved

The News Journal (Wilmington, Delaware)

December 12, 2010 Sunday

SECTION: NEWS

LENGTH: 2943 words

HEADLINE: O'Donnell parlaying politics into paychecks

BYLINE: By, JEFF MONTGOMERY and NICOLE GAUDIANO

BODY:

The News Journal

Christine O'Donnell finally has a job.

Page 1

Calling it "Christine PAC" for now, the former low-budget religious activist has banked enough leftover cash fromher record $7.3 million campaign to finance her national ambitions as boss of her own political action committee, if shechooses.

Even after furious campaign spending through the election, the three-time failure as a Republican Senate candidatealready has cut last-minute, five-figure payouts to her sister and other campaign staffers, many after the election.

O'Donnell, who lost by a nearly 17 percent margin to Democrat Chris Coons on Nov. 2, was nearly debt-free andhad $924,745.43 remaining when post-election financial reporting deadlines rolled around late last month.

Her improving fortunes also include a book deal.

News shows are calling for interviews, and she already has pocketed cash as a hired speaker. Last week, she delivered the keynote speech to about 250 tea party members at a Pearl Harbor anniversary commemoration held in a Chinese banquet hall in Virginia. A host at that event- - which featured a huge O'Donnell campaign banner and Americanflags placed around the disco ball-equipped dance floor-- introduced O'Donnell as "an international star" whose namerecognition was comparable to Oprah's.

I t was a dramatic improvement from her recent history of lean times and marginal employment that netted only

$5,800of

income during the 18-month period summarizedin

her last official financial disclosurein

July. Those hardtimes, at one point, included a federal tax lien ofmore than $11,700.

"Here's a person who has been consistently unsuccessful politically who has made it pay of f very well fmancially,"said former Superior Court Judge William S. Lee, a Republican whose 2008 gubernatorial campaign coincided withO'Donnell's losing race against then-Sen. Joe Biden.

"She has found a degree of financial independence as a result ofrunning this campaign," Lee said, "and withholding enough funds in an apparently legal way so that, basically, she won the political lottery."

O'Donnell may have to spend some of the leftovers defending an investigation by the Federal Election Commissionand federal prosecutors in Delaware into allegations of the improper use of some contributions. Many believe, however,



Page 2O'Donnell parlaying politics into paychecks The News Journal (Wilmington, Delaware) December 12, 2010 Sunday

that the book and the political action committee she said she will soon form will enable O'Donnell to extend her political influence as a national conservative spokeswoman.

Federal Election Commission spokeswoman Judith Ingram said on Saturday that O'Donnell does have options if

she chooses to shut down her own campaign committee and create a multicandidate committee.

"Basically, she can take the committee and roll it over into a PAC, if that is the way she wants to go," Ingram said."She can do it."

O'Donnell described her new organization in recent comments to The News Journal as "the new kind" of PAC. Shewas unclear about the type of organization and referred specific questions to her attorney, who would not comment.

O'Donnell said the group will allow her to be politically involved without running for office, an ex-candidate trailrecently blazed by Republican Sarah Palin after she and running mate John McCain lost the 2008 presidential election.

"So I can endorse candidates. I can do independent expenditures in certain races. I can speak out on issues and lobby against the death tax and so many things that other activist organizations have the handcuffs on because of the IRS,"she said after delivering her speech in Virginia.

Wayne Steger, an associate professor of political science at DePaul University in Chicago, said that the O'Donnellcampaign's surplus raises questions.

"What's surprising is that they didn't spend it all. More often, when a candidate is behind, they spend money likecrazy," Steger said. "That tells us that they didn't know what they're doing, or they anticipated the defeat and sought tonot fully invest in the race. Either way, one is calculated, and one is an error."

"What usually happens around the country is a candidate wants to still be involved in politics, and they've got thismoney, and they can try to play a visible role as kingmaker," he said.

Outside support led surge

O'Donnell's wide-ranging political options, some critics say, were made possible by her campaign's unprecedentedsuccess in tapping special-interest and single-issue voters through the Internet and new media. That effort produced asurge ofunitemized donations from outside Delaware. Tidal waves of cash followed praise of O'Donnell and attacks onher opponent by conservative talk-show hosts Rush Limbaugh, Sean Hannity and others.

In all, more than $4.8 million of the nearly $7.16 million in donations that O'Donnell listed from individuals werereported as unitemized amounts of $200 or less, according to federal campaign-finance reports.

Among the itemized donations, only about 4 percent originated inside Delaware through mid-October.

Delawareans accounted for about 42 percent of contributions to Coons for the same period.

Much of O'Donnell's money went back out as payments to fundraisers and consultants in other states, as well as tofavorite staffers, in some cases refugees from unsuccessful conservative campaigns in other states or national activistswith the religious right and conservative groups.

O'Donnell pointed out that she was not the only one spending heavily in Delaware.

Coons, whom she outspent by a 2-1 ratio, "had a lot of independent expenditures playing in that race," she said.

Coons had $4,959.19 spent in his favor and $44,307.50 spent against him from independent avenues, whileO'Donnell had nearly $204,900 spent in her favor and $699,611.87 against her.

Although O'Donnell trailed Coons badly through muchof

the general election, her fundraising soared after hercampaign's primary upset of Republican Party favorite Mike Castle.

By mid-October, the organization was comfortable enough to ramp up payments to a stable of salaried staffers thatalready included sister Jennie, a Californian, and Carole O'Donnell, the candidate's mother, who lives in New Jersey.There were others with close ties to the candidate's philosophy and political views, including some closely associatedwith special-interest groups in other states.

Payments raise questions



Page 3O'Donnell parlaying politics into paychecks The News Journal (Wilmington, Delaware) December 12,2010 Sunday

A big change in the O'Donnell campaign finance books came right after the pre-election deadline for public disclosure of campaign spending.

In the weeks that followed, O'Donnell started reporting checks written to paid workers as "political strategy consulting" disbursements, instead of salary. The change in some cases was followed by big, one-time jumps in paymentsof up to $20,700 in a single week.

Jennie O'Donnell was one of the larger beneficiaries of that change. Her weekly $1,000 pay was relabeled fromwage to political strategy consulting. That payment jumped to $15,000 on Nov. 4, two days after voters rejected theRepublican candidate, with total payments to Jennie O'Donnell reported at $26,000 between Sept. 8 and Nov. 4.

Carole O'Donnell was paid $3,000 for "fmancial consulting" in July and $500 for bookkeeping earlier in the year.

The Federal Election Commission has issued a general caution in the past about family hirings for campaign staffs,ruling that payments in excess of market rates can be considered improper personal use of campaign funds.

The campaign also issued a $20,000 "political strategy consulting" payment to David Hust, a staffer and Christianmusic artist from Texas who lived in one of O'Donnell's campaign-funded apartments at Greenville Place. Hust receivedmore than $28,700 from the campaign overall.

"Faith-based outreach coordinator" Ronald Robertson, a Johnstown, Pa., conservative Christian activist, received

$4,000 in salary and fees, then another $4,200 for political consulting. The Rev. Jason McGuire, a top campaign aideand fonner director of New Yorkers for Constitutional Freedoms, received just $500 under the same category, but healso was paid $2,000 for "social networking and evangelical outreach" on top of$18,500 in salary payments.

Andresen BJorn, executive director of the American Principles Project and active nationally in opposing same-sexmarriage initiatives, received a $12,000 consulting payment four days before the vote.

The largest single consulting payment to a campaign staffer who had previously received a salary was a $20,700check written on Oct. 22 to campaign spokesman and t reasurer Matthew Moran.

Michael Cornfield, an author and professor at George Washington University, said O'Donnell's surge in spendingapparently was made possible by the unprecedented numbers of small, unitemized donations from around the country.

He predicts more similar efforts in the future as voters realize they can become a "PAC of one" by giving to candidates and groups around the country.

"I think that's not only legitimate, it's a good thing," Cornfield said. "I don't see anything wrong with people givingmoney into a Senate race. What is important is the check we have on all of this -- that it be disclosed."

The rapid shift to small, faceless donations, Cornfield said, makes it harder to understand and verify a candidate'ssource of support and possible political ties, a weakness that he said has to be addressed by an alert news media.

"Maybe what we need to do is make sure that we devote, as a country, enough resources to doing as quick an interpretation as the data allow us," Cornfield said.

Local topics overshadowed

Through mid-October, nearly 95 percent of itemized donations to O'Donnell came from residents outside Delaware,with contributions reported from every state.

Texas, California, Florida and Pennsylvania residents all donated more than those in Delaware.

Castle, whose primary loss to O'Donnell vaulted her into national attention, said last week that campaign-financelaws need to help voters determine the origins of a candidate's support and money.

Castle also said that O'Donnell's campaign and others like it around the country have helped out-of-state and national interests overshadow local concerns.

"The whole business of campaigns based on volunteerism and person-to-person contact is becoming less significant," Castle said.

"In the case of Christine, you see a lot of consultants coming in from outside of Delaware, being brought in to staffthe election," Castle said. "There's a real professionalism to this. The Tea Party Express people have political backgrounds. They have backgrounds in how to raise money."




Campaign-finance reports show plenty of money going to consultants with backgrounds in raising money.

Throughout the course of her campaign, O'Donnell directed more than $1.94 million to a single promotion andproduction company: Alexandria, Va.,-based Smart Media Group. Another $300,000 went to Newsmax Media in PalmBeach, Fla., some $325,000 to a Fort Washington, Pa., company called Campaign Grid and $240,000 to Hollywood,Calif., media company Strategic Perception, which produced O'Donnell's infamous "I'm not a witch" ad.

A fundraising, media, financial and consulting company in Springfield, Va., called The Rainmakers was paid about$220,000. There were smaller outlays as well, including nearly $12,000 for private detective services and $8,900 forexecutive protection.

"When she got the national notoriety, the people around the country who are for the issues that she represents senttheir money in, the grass roots of the nation," said Gretchen Ellixson, longtime chair of the 11th Representative DistrictRepublican Committee and an O'Donnell supporter. "That's not a bad thing. What happened here is, Mike Castle didn'tsupport the people's vote after the primary. He held his supporters hostage, and she lost."

PAC will differ from Palin's

During the speech in Virginia last week, O'Donnell made it clear she was planning to provide for her political ideas.

O'Donnell is likely to form a "super PAC," an independent expenditures committee resulting from two recent Su-preme Court decisions, said Meredith McGehee of the Campaign Legal Center.

A super PAC could accept unlimited amounts of money from unlimited sources and make unlimited expendituresas long as the PAC does not coordinate with or make direct contributions to candidates.

O'Donnell could take a salary as long as she provides bona fide services, which could be as limited as television interviews.

"It's very, very loose," McGehee said.

Moran said O'Donnell "most likely" will not take a salary, but that he would know more next week when the PACpaperwork is likely to be filed.

Former Alaska Gov. Sarah Palin launched "Sarah PAC" after her failed vice presidential bid. While comparisonsoften are drawn between Palin and O'Donnell, O'Donnell said her PAC will be different.

"The focus of my PAC is not necessarily on getting behind individual candidates but, right now, more so issues,"

she said.O'Donnell said she and Palin exchanged "some Happy Thanksgiving texts," but beyond that, Palin is not advising

her or sending st aff her way.

O'Donnell said her goals include writing a book, due out next summer, that will give a behind-the-scenes look ather campaign and inspire people to not give up in their fight against the "establishment," she said.

"This isn't about Republican versus Democrat. This really is about us against them."

St. Martin's Press purchased the rights for an undisclosed amount.

Jon Moseley, a Virginia lawyer and O'Donnell's 2008 Senate primary campaign manager, said O'Donnell has beenreading papal encyclicals analyzing the morality of socialism and other economic models because she wants to includethem in the book.

"Republican insiders" and "those who have misrepresented her record," Moseley said, should wony about thebook's release.

Reforming the Delaware Republican Party is another goal, O'Donnell said.

"Right now, in order for anyone in Delaware to be successful who's not part of the establishment, we have tochange the Republican leadership there," she said. "They were losing elections long before I stepped onto the scene."

Some see O'Donnell's campaign as a sign of things to come.




"With absolutely no money at all, she's run several campaigns," Lee said. "Then to suddenly have $7 million is areal phenomenon and speaks about the fact that there are national forces at play. They look for places, like Delaware,where they can spend their money most efficiently."

Lee said O'Donnell's loss does not rule out another targeting of the state in the future.

George Washington University's Cornfield dismissed O'Donnell as "a candidate whose main political talent wasbeing able to get attention, which is sort of a second-tier qualification for the job."

But political fundraising innovations are moving at the speed of light.

"Instead of people staging dinners and asking for checks, you're going to have people coming up with iPhoneplans," Cornfield said, "so they can ask people to input information and not only get money but donor and contact in-formation, so they can go back and ask for more."

That could accelerate the growth of small, untraceable donations.

Groups file FEC complaints

For now, O'Donnell is basking in the glow of defeat.

Her speech in Virginia last week was a favor to Moseley, a Virginia attorney who asked her to fill in after VirginiaAttorney General Ken Cuccinelli canceled. She received a "token offering" for her speech, although one of the sponsors, Greenmail America, covered her travel expenses, according to organizers.

Wearing a glittery black suit and seemingly still in campaign mode, O'Donnell thanked the Virginia tea partiers forvolunteering in her Senate campaign, addressing them as "fellow revolutionaries."

"We changed the political system for good, and you had a direct part in that," she told them.

"Christine is a fascinating person who exemplifies the values of the tea party movement of limited government anda return to constitutional values and fiscal restraint," said the group's executive organizer, Ron Wilcox.

Joe Gaiser, another organizer, asked when was "the last time you had a conservative draw any kind of fight inDelaware? The idea that we can have a battle in Delaware is a win for me."

Asked by reporters whether she would run a fourth campaign for Senate, she said, "Who knows?" and, "I'm notthinking about it."

By year's end, the campaign will be left with about $500,000 "and that's pretty much what our lawyer told us tokeep in reserve" to fight legal challenges, Moran said.

Federal prosecutors in Delaware are reviewing a complaint by the nonpartisan watchdog group Citizens for Re-sponsibility and Ethics in Washington, alleging O'Donnell used campaign contributions for personal living expenses.CREW and the Delaware Republican Party, which initially opposed O'Donnell's candidacy, also filed complaintsagainst O'Donnell with the Federal Election Commission.

Those questions joi n others that have shadowed the campaign, including a lawsuit filed by her alma mater, Fairleigh Dickinson University, in Rutherford, N.J., over $4,823 in unpaid expenses, which led to a judgment that O'Donnell said was satisfied in 2003. In a separate incident, O'Donnell narrowly avoided losing her Wilmington home to asheriffs sale after falling behind on a mortgage. The sale was averted when her boyfriend, who also was her 2008 campaign's legal counsel, purchased the property for $135,000.

"I am very confident that we've always been aboveboard and ethical with our campaign funds," O'Donnell said."We've made every attempt to be responsible with the dollars that have been donated to our campaign."

Contact Jeff Montgomery at 678-4277 or [email protected]

LOAD-DATE: December 13,2010



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ristine O'Donnell's Official Biography for Christine PAC I Christi .. http://www. christinepac. com/about -c

Home About Christine Mission Christine Counters Multimedia News Contact Donate

1

About Christine

As a woman of principled determination, with agoverning philosophy centered on the core values ofthe gr eat American tradition and a wide experience in

taking on the liberal establishment, ChristineO'Donnell was a candidate for U.S. Senate from theFirst State.

Christine has served as a marketing and mediaconsultant to various clients, including: Icon Pictures'

The Passion of The Christ, Natalia Tsarkova, theVatican's first female portrait painter, and non-profitorganizations such as the World Education andDevelopment Fund, a charity that providesscholarships to children in poor communitiesthroughout Latin America.

Like

After attending Fairleigh Dickinson University in Madison, NJ, Christine was awardeda 2002 Abraham Lincoln Graduate Fellowship in Constitutional Government from theClaremont Institute in Claremont, CA. She resides in Wilmington, DE.

Christine O'Donnell is a nationally recognized political commentator and marketingconsultant. She has appeared on national news outlets such as the Fox NewsChannel, CNN, C-SPAN, MSNBC and ABC, including major ratings hits like 'TheO'Reilly Factor," "Sean Hannity Show," "The Glenn Beck Show," "Hardball with ChrisMatthews" and "Entertainment Tonight." Christine has also been a radio talk show

guest-hoston

WGMDin

Rehoboth Beach and WDELin

Wilmington.As part of a delegation of journalists , Christine toured the middle-eastern country ofJordan as a guest of the Royal Jordanian government. Having witnessed firsthand theoppression in the Middle East, Christine describes this journey as truly a life changingexperience and says it deepened her commit ment to the women's movement.

An effective communicator, Christine is known for her skill in winning over even thosewho disagree with her most. Liberal Bill Maher stated, "I don't know how many timesyou've been here but it's always a good show when you're on." Even Democraticstrategist James Carville was forced to admit of Christine O'Donnell "Now, this is onehip woman," on CNN's "Crossfire."

During her 20-year career, Christine hasserved as a social advocate in

Washington, D.C., participating in regularWhite House and Capitol Hill strategymeetings and leading delegations to theUnited Nations to lobby on behalf ofpro-family global policies. She'ssuccessfully debated Cabinet members,lawmakers and international leaders.

In the early 1990's Christine worked forthe Republican National Committee

(under then Chairman Haley Barbour) helping to develop the marketing strategycredited with having had a key role in the historic '94 Republican Congressionalsweep.

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Targeted News Service

September 10, 2010 Friday 2:36AM EST

HEADLINE: Delaware GOP: O'Donnell Campaign Charged with Illegal Conduct

BYLINE: Targeted News Service

DATELINE: WILMINGTON, Del.

BODY:

The Delaware Republican Party issued the following news release:

Page 1

The Republican Party of Delaware filed a complaint today with the Federal Election Commission (FEC) to investigate potentially illegal coordination between the Christine O'Donnell campaign for Senate and the Tea Party ExpressPolitical Action Committee (PAC), a national group based in Sacramento, Calif.

The filing shows that the O'Donnell campaign is knowingly accepting illegal campaign contributions from the TeaParty Express PAC. I t points to two alarming instances of this activity:

* O'Donnell has knowingly accepted excessive contributions from the Tea Party Express that were directly solicitedon behalf of the O'Donnell campaign.

* O'Donnell has accepted illegal excessive contributions from the Tea Party Express by engaging in a statewidecoordinated communications effort in support of her campaign. This means that every advertisement that is being run bythe Tea Party Express in support of Ms. O'Donnell is a violation of Federal law.

The filing goes on to show that the illegal scheme means that Ms. O'Donnell and the Tea Party Express PAC haveplaced contributors who have donated in response to solicitations from the PAC in jeopardy of exceeding their ownpersonal contribution limits under Federal law.

Last week, the Tea Party Express began running political advertisements on behalf of the O'Donnell campaign andpledging to dump a $250, 000 "moneybomb" in their attempt to influence Delawareans in the upcoming primary election on Tuesday. As Talking Points Memo reported yesterday, the group has been sending out "many fundraising ap

peals for O'Donnell's candidacy," and has revealed that they "aren't taking in donations from strictly Delaware voters.""Christine O'Donnell needs to immediately call upon her third party supporters to cease and desist this illegal be

havior," Delaware GOP Chairman Tom Ross said. "This type of behavior has no place in our political process, andO'Donnell should denounce these illegal ads. Donors deserve to know whether they made an illegal donation so theycan demand a refund and get their money back."

Below is a copy of the official complaint submitted to the FEC:

FEC Complaint(http:/ r20.rs6.net/tn.jsp?llr=t9nhj 8dab&et= 11 03672673574&s=354&e=OO 1 0Xc4gwiNrTVr6a5cPLdyo WlthJK5-awttr



Page 2Delaware GOP: O'Donnell Campaign Charged with Illegal Conduct Targeted News Service September 10, 2010 Friday

2:36AM EST

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Copyright 2010 Associated PressAll Rights Reserved

Associated Press Online

September 3, 2010 Friday 2:00AM GMT

HEADLINE: Wary of tea party, GOP attacks Senate candidate

BYLINE: By PHILIP ELLIOTT, Associated Press Writer

DATELINE: WASHINGTON

BODY:

Page 1

Delaware Republicans call Senate hopeful Christine O'Donnell a liar who "could not be elected dog catcher" in afierce attack that underscores GOP fears of the tea pmiy-backed candidate knocking of f top recruit Rep. Mike Castleand winning the nomination.

Stunned by tea partier Joe Miller's upset of Alaska Sen. Lisa Murkowski, Republicans are taking no chances in

Delaware, which holds its primary Sept. 14. The party sees Castle, the state's lone congressman since 1993, as the bestcandidate for the seat long held by Vice President Joe Biden.

Republicans circulated audio of a testy, 22-minute interview that O'Donnell had with radio station WGMD onThursday. Party officials also have said she inflated her resume and made flat-out untrue statements while being doggedby questions about tax liens and foreclosures. Castle says she has misrepresented his record.

"She's not a viable candidate for any office in the state of Delaware," state party chairman Tom Ross, who is backing Castle, said in a telephone interview. "She could not be elected dog catcher."

Castle's campaign began running radio ads on Thursday and prepared negative television ads against O'Donnell.The radio ads cite a News Journal of Wilmington, Del., report on O'Donnell's finances and declares her "a financialnightmare."

"According to the News Journal, O'Donnell has become a professional candidate, living off contributions from her

two failed campaigns," the announcer says. "While leaving a trailof

unpaid bills to vendors and staff, O'Donnell insteadused those donations for her own personal expenses and rent .. . While you work hard to pay your bills and taxes, Christine O'Donnelllives by different rules."

The ad also cites O'Donnell's slow repayment of student loans and that she "got caught when she refused to paythousands in taxes she owed the IRS and defaulted on her mmigage."

The planned television commercials would air in the week leading up to the primary. The campaign also has created a website, Rea!Christine.com, a clearinghouse of negative O'Donnell stories.

"Unfortunately, the truth always seems to be an issue," said Ross. "Her version of reality doesn't jibe with any of

the facts."



CREW! citizens for responsibilityand ethics in washington

David C. WeissUnited States AttorneyU.S. Attorney's Officefor the District of Delaware

P.O. Box 2046Wilmington, DE 19899

BY FAX: (302) 573-6220

Dear Mr. Weiss:

September 20, 2010

Citizens for Responsibility and Ethics in Washington ("CREW") respectfully requeststhat the Delaware United States Attorney's Office immediately commence an investigation intoRepublican senatorial candidate Christine O'Donnell for converting campaign funds to personaluse, for making false statements on forms filed with the federal Election Commission ("PEC"),and for tax evasion.

Friends of Christine O'Donnell is a "political committee" within the meaning of theFederal Election Campaign Act ("FECA"), 2 U.S.C. § 432(e)(l), and the principal campaigncommittee authorized by Ms. O'D01mell under 2 U.S.C. § 432(e)(l) to supp01i her candidacy forelection to the United States Senate. Friends of Christine 0 'D01mell is registered with the FECand is subject to the reporting requirements and the campaign finance limitations and

prohibitions of the FECA, 2 U.S.C. §§ 431-35.

Friends of Christine O'Donnell maintained a business checking account at WachoviaBank. According to Ms. O'Donnell's former campaign finance consultant, David Keegan, Ms.O'Donnell had signature authority on the account and also had a debit card to withdraw cashfrom the account. In a signed affidavit, Mr. Keegan attests that Ms. O'Donnell used campaignfunds to pay rent she owed to her landlord, Brent Vasher, on two occasions in 2009. In addition,Ms. O'Donnell used campaign funds to pay for personal expenses, including gas, meals and evena bowling outing. As the forms Ms. O'Donnell filed with the FEC clearly indicate, however, Ms.O'Donnell claimed the payments to Mr. Vasher were "reimbursement expenses" and claimed thegas, meals and bowling outings were "travel" expenses.

As you know, federal law prohibits federal candidates from using campaign funds forpersonal use. By wrongfully converting to her personal use over twenty thousand dollars incontributions to the authorized political committee Friends of Christine O'Donnell in both 2009and 2010, Ms. O'Donnell violated 2 U.S.C. § 439a(b) and§ 437g(d)(l)(A)(ii), which prohibitknowingly and willfully failing to report expenditures aggregating more than $2,000 in a calendaryear.

1400 Eye Street, N.W., Suite 450, Washington, D.C. 20005 l 202.408.5565 phone I 202.588.5020 fax I wvvw.citizensforethics.o



Honorable David C. WeissSeptember 20, 2010Page Two

In order to conceal the fact she had embezzled funds from Friends of Christine O'Donnellto pay for her rent in March and April 2009 an d to pay for meals, gas, an d even a bowling outing,Ms. 0 'Donnell reported those expenses on the campaign's Year- End FEC Report as "expensereimbursements," and "travel" expenses. Ms. O'Donnell personally signed theY car-End Rcpmithe campaign submit ted to the FEC. Therefore, by deliberating misrepresenting the true nature ofthe campaign's expenditures on the reports submitted to the FEC, Ms. O'Do1mell knowingly andwillfully made materially false, fictitious, and fraudulent statements and representations to theFEC in violation of 18 U.S.C. § 1001.

Finally, given that Ms. O'Donnell used Friends o f Clu·istinc O'Donnell campaign fundsfor her personal benefit, she likely committed tax evasion by failing to include those funds asincome on her 2009 U.S. Individual Tax Return, Form 1040 in violation of26 U.S.C. § 7201.

Given these apparent criminal violations, it is critical for the Depa rtment of Justice tobegin an immediate inquiry into Ms. O'D01mell's conduct. A candidate cannot treat hercampaign account like a personal piggy bank -- even when she has no o ther visible means ofsupp01i. The govemment has an obligation to protect citizens seeking to be engaged in ourpolitical process from those who would prey upon them for their own financial benefit. Ms.O'Donnell's blatant misappropriation of campaign funds undennines the integrity o f ourelectoral system and it is incumbent upon the Department of Justice to deal with such crimesquickly an d severely.

A copy o f the complaint CREW has filed with the FEC will be sent to you via overnight

delivery, but is also available on our website, WVYw.citizensforethics.org. Thank you for yourprompt attention to this matter. / / / -

/l /

cc: Jack SmithChief, Public Integrity SectionDepartment of Justice

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FOIA Request - CREW: Regarding the Department of Justice Investigation of Christine O'Donnell:...

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