Responsive Documents: CREW: FEC: Regarding Vern Buchanan: 1-13-15

8/10/2019 Responsive Documents: CREW: FEC: Regarding Vern Buchanan: 1-13-15

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2

Section 437g(a)(12)(A) requiresallpersons tokeepconfidential any investigation being

conducted by the exceptwith the writtenconsentof the person who is the

subject of the investigation. You areadvised that,in MUR6054,no such writtenconsent

hasbeenfiledregarding either provision. Inall instances in which access to ourfilesis

granted to federalagenciesor authorities, the confidentiality provisions of2

437g(a)(4)(B)(i) and437g(a)(12)shall remain ineffect. Accordingly, we ask that the

Department of Justice(and theFederalBureauof Investigation) establishandmaintain

necessary and appropriate safeguards to protect the confidentiality offilesfor which

access is grantedandthe information derived therefrom, make no public use ofthesefiles

or information withoutpriorapproval of the Office ofGeneralCounsel,notifyus of any

legally enforceable demand for thefilesor informationbeforecomplying with such a

demand,andnot grant any other demand or request for thefilesor information absent

priornoticeto, and alackof objection by, the Office ofGeneralCounsel.

Ifyou have anyquestionsorneedany additional information,pleasecontact me at

(202)694-1588.

Sincerely,

MarkAllen

AssistantGeneralCounsel

Enclosures

Six CDs

Listof Subpoenas and Responses

FEC FOIA 2014-10-R_002

Per CRM

(b)(6), (7)(C)


3/57

-T

CONFIDENTIAL MAT ERIA L

SubpoenaTo

HyundaiofNorthJacksonville(8/19/09)

Sam (8/19/09)

VernBuchananforCongress

6054SUBPOENASAND RESPONSES

Response

ResponsetoInterrogatories(10/02/09)

Documentsproduced(10/26/09and 11/13/09)

VernonG .Buchanan

John Tosch(04/16/10)

Rosa(02/17/10)

Joseph

JosephGruters(6/11/10&6/15/10)

Venice NissanDodge

Subpoena(08/19/09)

Follow-upLetter(10/8/09)

DonaldCaldwell(08/19/09)

JasonMartin(8/19/09&02/17/10)

WilliamMullins(8/19/09&02/17/10)

MarvinWhite(8/19/09&


Docs001-0356 [06/18/10&08/25/10(unredacted)]

Docs357-0482 [06/24/10&08/25/10(unredacted)]

Docs0483-1100 (08/25/10)

(10/15/10)

ResponsetoSubpoenaforDocuments


SilverAff&

for

Brief

Docs00001-000061)

Docs000062-000153 (05/12/10)

PrivilegeLog updated

ResponsetoSubpoenaforDocuments

Docs10/21/09

Deposition subpoenaonly

None(documentsproduced throughVBFC)

Doc SubpoenaResp.(09/21/09)

Supp.DocSubpoenaResp.(10/15/09), (03/17/10)

Doc SubpoenaResp.(09/21/09)

Doc SubpoenaResp.(9/21/09) (03/01/10)

Doc SubpoenaResp. (bankrecords) &03/09/10)

Doc SubpoenaResp.(9/21/09) (03/01/10) ,

Doc SubpoenaResp. (bank records)(03/03/10)

Doc SubpoenaResp.(9/21/09) (03/01/10)

Doc SubpoenaResp.(bank records)(03/03/10 &

03/08/10)

FEC FOIA 2014-10-R_003


4/57

CONFIDENTIAL MATERIAL

JackPrater(8/19/09 02/17/10)

Steve

ShelbyCurtsinger(2/17/10)

BradCombs (08/19/09)

DavidLong (12/01/09)

Brodsky (12/01/09)

DennisSlater(12/01/09)

ChristinaHires (12/01/09)

TimothyMobley (07/02/10)

(07/02/10)

Howell (07/02/10)

RepublicanPartyofF L

ExpressFreightofF L

M-TampaFinancing(07/02/10)

Doc SubpoenaResp.(9-21-09) (03/01/10)

Doc SubpoenaResp. (bankrecords)(03/03/10)

Deposition subpoena

No documentsproduced

Doc SubpoenaResp.


No documentsproduced; interviewedratherthan

deposed



Pre-RTBResponse

Resp.to Interrogatories& Doc. Requests

Responses toInterrogatories&DocumentRequests

(08/31/10)

Response toSubpoenafor Documents

Response toSubpoenafor Documents

Responses toInterrogatories&DocumentRequests(09/03/10)

Responses toInterrogatories& DocumentRequests

(09/03/10)

FEC FOIA 2014-10-R_004


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WASHINGTON, D. C20463

FEDERAL ELECTION COMMISSION

FEB

HAND DELIVERY

PublicIntegrity Section

U.S. Department of Justice

YorkAvenue, 12thFloor

Washington, 20005

Re: document from closedMUR 6054(Buchanan)

Dear

We received your formal written request datedFebruary fbr"acopy of the

letter from counsel showing no records exist in response toFEC' s subpoena toKevin

of your request is attached. response, we you

copiesofan emaildated December from DaleR. Sisco,Mr. Brodsky's counsel,

and a responsive emailfromFECattorneyMichaelA.

sentthe same day. Theattachment toMr. Columbo's email isablankDesignation ofCounselform,whichwe

also provide. These documents areBates stamped"MUR Documents

000001-000003."

AssociateGeneralCounselfor Enforcement

Attachments:

Formalrequest for document

MUR Documents 000001-000003

FEC FOIA 2014-10-R_005

Per CRM

(b)(6), (7)(C)

Per CRM

(b)(6), (7)(C)


6/57FEC FOIA 2014-10-R_006

Per CRM

(b)(5), (6), (7)(C)


7/57

To "DaleR,Sisco"

bcc

Subject Re:BrodskySubpoenafor Deposition- MUR

Dale,

Thankyou. appreciate thequickarrangementsyouhave The afternoon ofthe 16th willworkforus

welt. You indicatedduringour callthatyou were available after lunchon the

itisconvenient for you andyour we will

yourofficeat 2 p.m.

Mr.Brodsky'sparticipation intheinformaltelephone interviewandsubsequentsubmission of a swornaffidavitbasedon theinterviewcan substitute for theformaldepositioninWashington,D.C . We agreethat the deposition is postponedtopermitMr.Brodskytosubmitthe affidavit instead. Once theaffidavit issubmitted(confirmingthat he has no documents and the relevantinformationhe providesduringtheinterview}, willcan sendyou gwrittenreleasefromthesubpoena.

inthe meantime,pleasehaveMr. Brodskyfillout and sign the attached "Designation ofCounsel"form,whichgives us permissiontoworkwithyouashis attorney.

Regards,

MichaelAttorney- EnforcementDivisionOffice ofthe General CounselFederalElectionCommission

Email:

BrodskySubpoenaforDeposition- 6054

Michael

12/02/200904:51 PM

"Dale R. Sisco"

R.

To

04:19 PM cc

Subject

Thiscorrespondence

confirmourtelephoneconversationearlierthis afternoon. Ihavebeen

retainedtorepresentKevinBrodskywithregardtothe subpoena in thereferenced

matter. Mr.Brodskydocsnothaveany responsivetothesubpoenaanddoesnotliave

accesstoanyresponsive documents. Mr.Brodskynolongerhas any interestin the

companies.

MUR 000001

FEC FOIA 2014-10-R_007


8/57

Further to ourdiscussion,1have

thatMr.Brodsky I can beavailablefor aconference

callwithyou on theafternoonofDecember Therefore,unlessI hearfromyou to the

contrary, I willadviseMr.Brodskythathe isreleasedfromthesubpoenafordepositionWashington.DConDecember willawaityourconfirmationof timefor our informal

telephoneconversation. I furtherassumeyou will initiatethe call to myofficeat 224-0555.

Thank foryourcooperation thisregard.

Managing Partner

AvenueSuite

electronicmessage,and contents, contains orotherwiseprotected from Thisinformation for the I f addressee,any

distribution

use thismessage prohibited.

message error, notify us Immediately anddestroythe originalmessageand copies.

MUR documents000002

FEC FOIA 2014-10-R_008


9/57

reDERAL COMMISSION

Washington, DC 20463

of Designation ofCounsel

MUR:

Name ofCounsel:

Finn:

Telephone: (

Fax:{ )

Theabovenamedindividualis herebydesignatedas my counsel

is authorized to

receiveanynotifications othercommunications from the Commissionandto act onmy behalfbeforethe Commission.

Date Signature

Name(Print):

Telephone: Homef

Business (

beingsought part anInvestigation conducted by the ElectionCommissionand confidentiality apply.Thissectionprohibits

publicanyInvestigationconducted

theFederal withoutexpresswrittenconsentoftheperson underinvestigation.

MUR documents000003

FEC FOIA 2014-10-R_009


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FEDERAL ELECTION COMMISSIONWASHINGTON, D.C. 20463

FEB

February

HAND DELIVERY

PublicIntegrity Section

U.S. Department of Justice

1400 NewYorkAvenue, 12thFloor

Washington,D.C.20005

Re: Request for document from closedMUR 6054(Buchanan)

Dear

We your formal written request datedFebruary for"acopy of the

letter from counsel showing no records exist in response toFEC's subpoena toKevin

Brodsky."A copy of your request is attached. Inresponse, we areproviding to you

copiesofanemail dated December from DaleR.Sisco,Mr.Brodsky's counsel,

a responsive emailfromFECattorneyMichaelA. Columbosentthe same day. The

attachment toMr. Columbo's email isablanlc Designation ofCounselform, which wealso provide, These documents areBates stamped"MUR 6054-Brodsky Documents

000001-000003."

AssociateGeneralCounsel for Enforcement

Attachments:

Formalrequest for document

MUR Documents000001-000003

FEC FOIA 2014-10-R_010

Per CRM

(b)(6), (7)(C)

Per CRM

(b)(6), (7)(C)


11/57FEC FOIA 2014-10-R_011

Per CRM

(b)(5), (6), (7)(C)


12/57

To "DaleR,

bcc

Subject

SubpoenaforDeposition- MUR

Dale,

Thankyou. appreciatethe quickarrangementsyouhave made.The afternoon ofthe willworkforus aswell. You indicated during call you were available after lunch on the 16th. If Isconvenient foryou and yourclient,wewillcallyour office at 2 p.m.

participationIntheinformaltelephoneinterviewandsubsequentsubmission of a swornaffidavitbasedon theInterviewcan substitute for theformaldeposition inWashington, D.C. Weagreethat the deposition is postponed to permitMr. Brodsky to submit theaffidavit Instead. Oncetheaffidavitsubmitted (confirmingthat he has nodocumentsand memorializing the relevantinformationhe providesduringtheinterview), cansendyou awrittenreleasefromthesubpoena,

the meantime,pleasehaveMr.

Brodsky

outand sign the

attached"Designation of Counsel"

whichgives us permission toworkwithyouas

attorney.

Regards,

MichaelA. umboAttorney- EnforcementDivisionOfficeof the General CounselFederal Election CommissionPhone:(202)694-1341Email:

D0

"Dale Sisco"

"Dale R. Sisco"

To

04:19PM ccSubject BrodskySubpoenaforDeposition- MUR 6054

Thiscorrespondencewillconfirmourtelephoneconversationearlierthisafternoon. Ihavebeen

retainedtorepresentKevinBrodskywithregardto thesubpoenafor

in thereferenced

matter. Mr.Brodskydoesnothave documents responsivetothe subpoenaanddoesnothave

accesstoanyresponsive documents. Mr.Brodskyno longerhas any interestin the "TM"

companies.

MUR6054-Brodskydocuments000001

FEC FOIA 2014-10-R_012


13/57

Furthertoour discussion,1have confirmed thatMr.Brodskyand Ican beavailableforaconferencecallwithyou on the afternoon of December Therefore, unlessIhearfromyou to the

contrary,Iwill adviseMr.Brodsky that he is releasedfromthe subpoena fordepositionin

WashingtonDCon December

Iwill awaityourconfirmation of thetimefor our informaltelephoneconversation. I further assume you will initiate thecallto myofficeat 224-0555.

Thankyouforyourcooperation inthis regard.

9

Partner

1110 Avenue

Florida 33602

URL:wwwsiscolaw.com9

Partner

1110 Avenue

Florida 33602

electronicmessage,and

of

contents,

Information whichIsprivileged, confidential,or otherwiseprotectedfromdisclosure. InformationisIntendedfortheaddresseeonly. Ifyouare not theaddressee,anydisclosure, copy,distributionor useofthecontentsof messageIsprohibited. Ifyouhavereceived electronicmessage error,pleasenotify Immediatelyand destroy theoriginalmessageandallcopies.

MUR6054-Brodskydocuments000002

FEC FOIA 2014-10-R_013


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FEDERALELECTION COMMISSIONStreet,

Washington, DC

Statement of Designation ofCounsel

MUR:

Nameof Counsel;

.

Telephone: (

Fax:(

Theabovenamedindividual isherebydesignatedas mycounseland is authorized to

receiveanynotificationsandother communicationsfrom the Commission and to act on

my behalfbeforethe Commission.

Date Signature

Name(Print):

Address:,

Telephone:Home( _)

Business (

is

sought aspart

aninvestigation being conducted by theFederalElectionCommission andthe confidentiality provisions

U.S.C.

apply.

sectionprohibitsmaking public anyinvestigation conducted by theFederalElectionCommissionwithoutthe expresswrittenconsent thepersonunderinvestigation,

MUR6054-Brodsky documents000003

FEC FOIA 2014-10-R_014


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Cetera

. ..

From:

To:

kazranTuesday,August

4:42 PM

Hello Vern

Thankyou fo r taki ng the time to speak with

today, unfortunately w i l l be ab le to

with you tomorrow, I havemeetings with Bofa and Chr ys le r. I value relationshipwith you and look forward to extending our frie nds hip . At t h i s time c e r t a i n w.ehave

reached the end of our pa rt ne rs hi p, i t i s my greathope to be able to have a amicable,clean and speedy exit strategy.

a personal note,i t i s my hope that t h i s note serves as a for future

dialog with partners.

1 want tomakecertain and be on record that or.form, Ihavehad nointention tohavemy chal leng esbecomeyours, furt hermore ihaveh ad ask forany type ofmoneysimply because Xneed i t . . .Whenyou and Ispoke, My unders tan ding was

that John and I r aw i l l e val uat e our c urr ent sta tus 'andcome up with a s olu tio n that

or help me to res olv e t h i s i s s u e . . At no time

have had any reaso n to be li ev e thishas been the case, I respect and agree with your concerns about the investm ent you had

made in the Ki a stores, the r i g h t and i t s to prov ide you with anyinformatio n that you desire , I can say with cer tai nty Ihavedoneth e ver y best than Ican, including hiring a firm to a s s i s t Ir a at52500per day i n the past thr ee weeks.As.

w i l l probably read the emails that we have sentback and fo rt h, the l e v e l of 'f r u s t r a t i o n and disappointment has acc eler ate d to heig hts unimaginable..

I am a big boy and 1 own t h i s at the l e v e l , butwhenmy h elp, my guidesand my support has been nothing but unfai r,unreasonable

s e l f i s h offers,when I see

that there i s no nor i n t e r e s t in the we ll being of t h i s whenJohns besti s to takeawaythe Ki a st o r e s and ask me to t e l l BofA to write off the debt, I

read untrue, unprofessional and unrelated fromSteve suggesting Idon'tpay myb i l l s , when I hear rumorson s t r e e t he i s discuss ing our pri va te and con fid enti al

when so c a l l ad vice for me i s to f i l e bankruptcyand most o f a l lwhenno onewants to take the timeto l i s t e n to the r e a l bigproblem"Dodge",whenIhave offered to

borrow j u s t enoughmoneyso we can c ove r s a l e s tax and vendors so that I can keepyour'exposureand mine as low as pos si ble , 1even offered to give you c o l l a t e r a l on everyt hingthat I own inc lud ing the land

the dealership yet

cant seem tomakeany progre ss.... Iguess that's l i f e .

I have a great deal of confusion because constantlyremindsme he has t o speak withyoo, ye t he has notmadeyou aware of our d iscus sions ... I have great deal of respect foryou, I am honored tohavehad a par tne rsh ip with bu t t h i s one timeI i f youcan see thingsthrough my v i s i o n . . . .

haveworked sinceA p r i l of 04, whenHyundaihad l o s t 500k, by April..since then Ihavedonenothing but work to pay you...-

a 850kcap lo an fromJenkins days whichno one e ve r told me, I pa id you almost be fo re Ibegan t:.o pay150k permonthand f i n a l l y pay

m i l l i o n Cor 51%, which I s t i l l pay for..

I was awarded t h i sDodgedealershi p but because of my agreement with you, I had to

you 51% of i t , -you and Ibothshookhands and agreed you wouldcomeup wit h the capitaland I w i l l run the three I paid you 300kpl us 15k permonth,

cap loan from Chrysler,

bank

not tomention I had to take a l l the r i s k and doa l l thework. Al l along I

thought the companyhad 1.400ki n c a p i t a l , wheni n facti twas not the ca se. .. Our agreement Chrysl er was v iol ate dwhenwe committed to having825k in to recei ve825k I John copies of bank statements to v e r i f y wei n j e c t e d t h i s cash toshowChrysle r, then took right out our company

was and leveraged to high from day most of myyou was broken

I asked I r a and gave him pe rm iss io n, I chal leng ed him. to go through our books and verify,

1

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90% of the netp r o f i t s fo r theen'tirecompanyhasgoneto pay you... Icantbegin todescribe to the level ofpain I went through to understand my optionswere to A. give back

th e Kias t o r e s , 8.continue withDodge,C. f i l e bankrupt cy and f i n a l l yask BofA to writedebt on Kia

I c e r t a i nsomeonefrom bank of America w i l l communicatewith you the ir e disappointment from Johns recommendations

I haverepeatedly requested fo r us toaddress thei s s u e Dodge,according to ouragreement I notonly paid on themoneyI neverreceived,but theoption to purchase i svoid due to defaultwhich w i l l makeyou and I both partners withyou at A l lalongI havemadevery c l e a r my intend i s to get yourname of theleaseand pay for

bank.. I havemadeJohn aware so longas we f u l f i l l ourcommitmentand thestore I w i l l be ablet o have yourname off...

unfortunately thathas not been an option, infarct johnwas kindenoughto send me anemail on the

to remind me that unlessthe payments 'are madecurrent he would nolonger discuss helping my s a t i a t i o n , whenhe i sveryaware of our financial condition,what he d id not r e a l i z e i sthat I did madeth e payments, I went to my bank to geta personal loan tomake c e r t a i n your payments weremade,I have alwaysgone theextra milefor our partnership, I am theonly one i n our group that has donated over 80k to campaign

onlyone who has been

as I have been.

Yesterday wecameup with aplan to notonlyget yournameoffDodgebutalsoget you back2 ki as t o r e s , while giving me back themoneyI paid you i nDodge.3.5 m i l l i o n to

take

m i ll i onexposure, pay back 1.8 m i l l i o n fromdodgeand get 2 kiastoresbackdoes not evencomeclose to a f a i r deal fo r me, but I agreed to do i tsimplybecause thisi s how muchI need to complete t h i s project. under stand todayt h i s option i s no longeragood

I than k you coach, Iregret verymuchto see ourpartnershipend and deteriadi nsuchmatter, Sam

2

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EXHIBIT

From:John Tosch

Sent; Wednesday, August 27,2008 PM

To : Mike

Forwardfrom Josh - SamKazran'spartner (and I think

See below

From:Josh [mailto:[email protected]

Sent; Wednesday, August 27,20083:23 PM

To :

Sent to you inerror - please disregard

Unfortunately due to most recentevents willnot attend the partners meeting.is very disheartening for me to see my entire life savings go down thedrainwhile Sam's attempt at reaching out

to you and for an amicable resolution is delayed until as you have put it "the cookie crumbles". Itis veryfrustrating for me especially when look back at the amount of money that t have had to payMr.Buchanan for

justthe Hyundai store, where

am a minority owner. We have not only paidhugesums of money toBuchananfor the Hyundai dealership but whenMr.Buchanan asked Sam for contribution to his political campaignthis dealership supported Mr.Buchanan's political campaign to a tune $80K,something that wasopposedto.Butwhat is mostegregiousto me is all of the past history and how Mr.Buchanantoutshimself a s "helpingothers get into business", now the very person whom he has repeatedly referred to as his returnoninvestment and"partner"would stand idlybywhile he is in need of help inpartdue to a broken agreementandobligation fromMr.Buchanan on the Dodge store. The well being of theHyundaistore has been impactedbecause Hyundaihad toInjectfunds into Dodge due to lack ofinitialworking capital. When the lawfirmof DougLyons contacted us aboutinquiringinformation about the donations we given to Buchanan campaign, Samadamantly discouraged any further communicationswiihthem.

Myfrustrationgoesto thedeepestlevel not only withMr.Buchanan but with Sam as well. don't know aboutSambut willnot stand while my future is infront of me.

Best Regards,

"Leadership is atightrope; ethics are your balance pole"

John:

TOSCH DEPO000001

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DianeMitchell

Sent:-To:

Subject:

Attachments:

Monday,September

6:38 PM

for. ...to review

EXHIBIT

scan0001[1] scan0002[1] (2).jpg;scan0004|1]

KB) KB) (583KB) (748th i s t h i s 1st set of

checks, gives for whenhe doesn't evenh esit ates for a second me and my wif e over 20k.. Maybe he can

taking part

.80k+ as

month

payment

wife doesn't cry

out of

of loosing ourhome.

thank

for gi vi ng me per missi on to se t as ide mymoral character...1. 1.3million of loan on Hyundai that was never d isc los ed nor mentioned i n agreement2. purposly decei ving i n j e c t i n g cash and taki ng i tright back to qua li fy for aJoan, "fraud"

money c a p i t a l contributionwhen that' s a direct lender violation 4.

m i l l i o n i n gwinette in outstanding b i l l s plus i.6 mi lli on in leasepayments S. aof c a p i t a l r equired by Vern as per our agreement and manufacture requirement 6.

a t o t a l of i ndamages caused by lack of c a p i t a l i n companies that Verncontributed 7. major reason f or loss of 423 employees and t h e i r f a m i l i e sbecause Imade a bad de ci si on s and bel ieve d Vern at hisword

8. I am s ur e the other 5 pa rt ne rs can add on to t h i s l i s t . . . .

dis sol ve our partnership .... Vernwants to take Kia store s i tw i l l be

what's not o pt ion al i s gwinette.... based on rayagreement the best way to resolve chis i sto go back to what we i sowed 10k pe rmonth as a partner, a l l other moneyneedsto be paid to that i sdonewe both ca n work together and dis so lv e the

company as par tne rs other option i s wait u n t i l tomorrow to find out i f

Se nt : Mon, 8 Sep 2008

Subject: check copies

have,.

Thank

Looking for

rev iew s on the new TV season? Get ultimata quids

to f a i l TV.

I

DEPO000028

FEC FOIA 2014-10-R_018

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FEC - (b)(6), (7)(C)FEC - (b)(6), (7)(C)


19/57

From:Sent:Wednesday, 2008 6:44 PMTo: kazran RogerCc: [email protected]; [email protected]

RE :Draft TermSheet

On e though, Wehaven otdiscussed payment method for Kia at theavenues,when !spokewi.thJohn he said it willbe veryflexible, obviously we will nothaveany interest, wewould haveto havea7yr payback with no prepayment penalty,!would suggestwehavea bonusfor early

it isimperative tohave low, low payment s the 1styear..

thanksSam

From:

To :

Cc: jpost@smithh uIsey.co m; [email protected]; [email protected]:Wed, 1 Oct 2008 6:33Subject: RE:DraftTermSheet

Ok, believe Jimwill be out, He has beenworkingaround the clock so he needs a break.. Justa .other is a billfor him and also

prosserwho is the at torney in he worked onalterative for bankruptcy and reorganization.. will havethem contact hereare somechangesthat need to be made

overseeof Ira Sliver should be for Kia buy/sell, although haveno objection to himseeinggwinnette, want to make certain the committed amountdoesnot chaiige, as you know havethe termination of franchise, as a resuft

had to pay over 100k inrebateaudit',sales tax and many -more bills, most ofwhich had to be paid through and otherstores, overallbills are well over

million.Agreement was J from all with respectto Dodge and handle

TOSCH DEPO000048

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FEC - (b)(6), (7)(C)

FEC - (b)(6), (7)(C)


20/57

Hendrixlease, others are myresponsibility

3. loan should be less than 800K, need to get the exact balance, keep inmind paid

of this note, the rest went to auto central services

4. Collateralfor Hendrixleaseand bank has to be limited to Hyundai and itsassets, will not beable to ask any partners nor pledge the 22acressince we are selling itto DOT, this also has to besecond behind BofA any new lenderobviously. would have noissuewith collateral incase ofdefault so longas its for the balance IoweVern excessobviouslywill not go to him

5. Itwould be responsibilityto obtain financing property and approvalfrom manufacture,should he failt o do that, wouldnot be responsible, willhowev er give him any cooperation heneeds.

6. We need a clean APA for Kia at theavenues, wouldsuggestwe remove that from the andhave aseparateagreement, will not need Kia approv al since l am already a dealer

7.Vern had mentioned hewoufdw ant to reimburse th e storesa bill that he and spoke of, the

'amount is $83 500 , He has copies of 52k, ifhe likes can get the rest or he can veritythrough hisrecord, Thi s wa s at his request,

8. outstanding balance for Jim post and Richardprosser,both ofwhichworked on Kia andReorganization options

9. The only thing was not to get byBofA is the used cars Atlantic,other is a total of 1.3million, i have researched themfullyand other is a maximum of if allwere to be liquidated atauctiontom orrow, theaverage recon was over $800 per units and they are all retailpieces, I can goover themwith oneVern chooses

ThankyouSam kazran

Roger To: kazran ; Roger Gannam Cc:

Michael Lindell Michelle; LisaMontesion

john@b uchananautogroup .comSent: 1 Oct 2008 5:51

RE :Draft TermSheet

Subject to counsel's agreement, mark through and you say th e terms are different, and I'llpresen t it to my clients. I'll need tohearfromyour counsel before can advise my clients thatthe revised terms are binding.

(Sentwirelessly>

Roger K. GannamLindell& Farson, P.A.12276 San JoseBoulevard, Suite 126Jacksonville, Florida 32223-8630(904) 880-4000

2

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(904) [email protected]

From: Sam KazranSent: Wednesday, October0 1,2008 5:39 PMTo:"Roger Gannam"Cc:"Jim Post" "Michael Lindell"

"Michelle

"LisaMontesion"

Subject Term Sheet

HelloRoger !just gotoff the Phone withVent, heverified the 22acre landwould not be a.part of this deal sincewe are sellingo f tocity.Second part is oversee of Silver,other is no issue withthat onKiaonAtlantic, however to make certain other is a cle ar understanding that thetotal dollaramount

doesnot get reduced from Gwinnett, as youknowwe have been out of trust to paysalestax, andclosedowngwinnette, Sam

Sent from my iPhone

OnOct 1, 2008, at 5:02 PM, "Roger Gannam"

wrote:

Jim, attached is thedraft termsheet. Myclients have already agreed to the terms, but haveforwarded itto them forfinalok on the form.

'I'm sending to at Same time'forthesakeo fefficiency. am also copyingMr.Kazran

because he called us and asked us to send it directly to him.

forwardyou the signed termsheet as soon as have itfrom my clients.

Regards, Roger

Roger K. Gannam

Lindell & Farson, P.A.

12276 San JoseBoulevard, Suite 126

Jacksonville,Florida 32223-8630

(904) 880-4000

3

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(904)

FAX

rgannam@lindel!farson.com

www.lindellfarson.cofn

This email contains PRIVILEGEDAND CONFIDENTIAL information intended only use of theaddressee(s)named above. If you are not the intended recipient of this email , or an authorizedemployee or

for delivering

to the intended recipient, you are herebynotified thatany

or copying of this email is strictly prohibited. If youhave received this

error, pleasenotifyus by reply email and deletethis emailfrom your Thank you for your

\

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Lindell P.A.Attorneysand Counselors at Law

12276San Jose

Spite 126Jacksonville,F L32223-8630

Fax: (904)8804013

J . Michael LindellBoard

R.Howard Walton

October

Roger K. Gannam

A. in

Vi a to:

Sam Kazran

JamesH.Post, Esquire

CONF IDE NT IAL S E T T L E M E N T

COMMUNICATION

Smith &

225 WaterStreet, Suite

Jacksonville, 32202

RE: R E V I S E DBinding Settlement Term Sheet

DearMr . Kazran:

The purpose of this is to confirm terms upon which our clients have agreed io

resolve existing claims among them with

andcurrentbusiness relationships.

The core terms agreed upon are as follows:

Within 48 hours of the of this agreement, i099 Management

Co., LLC, aFlorida limited liability company into escrow with ihe law

of Lindell &Farson,P.A. the total sum of $2.9 million (ihe"EscrowAmount") lo be applied as

provided below.

2. this million paid by at closing for the purchase of

theassetsofPremierAutomotive on Atlantic, Premier Automotive

the Avenues, L L C ("Premier Avenues") and Premier Properties on Atlantic, L L C("Premier

Properties") including, bur not limited to, all rights ofthosecompanies to conduct business as a

Kiadealership at the addresses of

Atlantic

and1.0845Phillips Highway,

Florida and specifically including all real parts inventory, fixed assets and all new,

previously undelivered, 2008 K ia automobiles (with 5.000 miles thereon), free and

clear and encumbrances whatsoever.

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Sam Kazran

October

Page 2 of5

3. conditions to the closing upon purchase of the foregoing assets are:

(a) Approvalby theKia manufacturer;

(b) Approval by the first mortgage with respect to the existing

mortgage on the 9401 AtlanticBlvd. realestate; and

(c) Cleartitle to assets being conveyed (with the exception of the existing

first mortgage on thereal estate.)

4. Out of theEscrowAmount, $1.6 million be applied, under the oversight of

Ira Silver, C PA, to retiring the obligations of Premier Dodge and LLC, including

withoutlimitationall obligations for floor plan sales out oftrustand outstanding federal and state

lax liabilities related to thePremierDodge operation, which out oftrustand tax liabilitieswill be

satisfied before any otherPremierDodge liabilities. You. SamKazran.agree to boldBuchanan,

andany other businesses or entities affiliated with harmless for all.damages. as well

as costs, associated with all obligations aris ing out o f the Premier Dodge dealerships

(hereinafterthe"PremierDodge Liabilities").

5. The balance of the Escrow Amount in sum of $200,000 is earmarked as a

reserve account to be applied to any remaining obligations to the lessor of the automobile

dealership facility located in Duiuth, Georgia and currently occupied by the Premier Dodge

Dealership. Uponfullsatisfaction of that obligation, you, SamKazran,willbe entitled lo receive

any balance remaining on hand in that reserve account. Should satisfaction of the obligation to

the- lessor require an amount greater than deposited into this reserve account, Kazran agrees toBuchanan, and any other businesses or entities affiliated with them, harmless for all

damages, as asdefensecosts, associated withfinalresolution of obligation (hereinafter

the LeaseLiability").

6. Provided

timely advances theEscrowAmount byparagraph1

above, and otherwise tenders

performance hereunder, within 48' of the complete

execution of this agreement you,SamKazran,will cause all against G.

Buchanan ("Buchanan"), 1099 and any of their affiliated businesses entities t'o be immediately

dismissed with prejudice and within that same time framewill furnish a copy of the notices of

dismissalthat have been forwarded to the respective courts for filing.

7. Withrespect to the existing working capital loan incurredin connection with the

operation of the Premier Dodge Dealership in Georgia payable to

& Bank in the

approximate principal sum of $800,000 under which Buchanan and one or more of his relatedentities may be obligated, you, SamKazran,agree that this obligation will be kept current with

the lender and that youwill holdBuchananand all of his related businesses and entities harmless

for damages as asdefense costs withthat loan (the"Gap

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Sam Kazran

James

Post,Esquire

October

Page3of5

ft. Withinninety(90) daysofthe full execution of thisagreement,you, Sam Kazran.repurchase from 1099 theassetsof the Kia dealership located at Phillips Highway,

Jacksonville, Florida

the total sum, at

of $1 million, payable by promissory notebearing interest at therate 6%, witha term of42 months, interest-only payments for thefirst 12 months, principle and interest payments due for remaining 30 months calculatedbasedupon a5-yearamortization, and balloon payment due for all remainingprincipal and interestafter

months (the Kia Note"). willretain apurchasemoney securitythe dealershipassets.The conditions to theclosingof will

(a) Approvalby the Kiamanufacturer; and

(b) Clear title to allassetswhich shall specifically include the new parts

inventory,allnewears(subject tofloorplan) and allfixedassets.

9. With respectto the required approvals by the Kia manufacturer contemplated by

paragraphs3 and 8 above, partiesagreethat theywill and in good faith,take all

steps necessary, within their control, to satisfy the requirements of the Kia manufacturer for

approval.

10. Provided you. Sam Kazran,fully perform hereunder, the promissory note datedDecember 2006 in the original principal sum of $700,000 under which you, yourGwinnett,LLC and LC listed as makers,will be deemed fullypaid and satisfied.

order to secure your obligations under the Lease Liability, the

Premier DodgeLiabilities,the Cap Loan

and the Avenues Kia

as defined above,you, and any of your related oraffiliated businesseswill grant no than a second priority,enforceable security interest in the following described collateral no later than the firstdisbursement ofescrow funds as contemplated above:

(a) Al lassetsused, or to be in connectionwith businessofHyundaiofNorthJacksonville both at its current location and at its anticipated newlocation inthevicinityof interstate BrowardRoad, and Dunn Avenue.

(b) Al l real estateowned by you, Sam LLC, JacksonvilleAuto Mail, LLC,Aram Askarifar, and any other person, at thelocationofHyundaio fNorth excluding the adjacent 22acres(tax parcel no. referred toduringour negotiations; and

(c) All rights you, Sam Kazran, or any of your partners or affiliates

tooperateas aHyundaidealer in theNorthJacksonvillearea.

. . (d) counsel,mutuallyagreeableto the parties,willprovide anopinion

that the security interest described is enforceable

to its terms.

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Sam Kazran

c/oJamesH.Post,EsquireOctoberPage4o f5

2. Furtherconditions the disbursement of the EscrowAmountare asfollows:

(a) executiono f theAffidavit attached hereto asExhibit

(b) provision to Buchanan and of written verification fromBankofAmericathat, as a result ofthe parties executingthesesettlementterms, provided EscrowAmountis disbursed in accordanceherewith,Bank of will allow HyundaiofNorthJacksonville tocontinue its operations and loan additionalworking capita) for theoperationof

The parties contemplate that

agreements among themimplementingtheseterms. Thoseagreementswill include areleaseof claims by Kazran andhis affiliated interests against Buchanan and hisaffiliated interests by reason of anyknown orunknown set of facts arising before thisdate except for the obligationsassumed under thissettlement. Likewise,assuming performance,.by_ Buchanan hisaffiliated interestswill releaseKazran and hisaffiliated interests from all claims other thanthosecontemplated bythisagreement,

' The parties agree (I) that the terms this settlement will be kept strictlyconfidential except where its disclosure isnecessaryin order tosecureapprovalsfrom personswhose is essential to accomplishment of the transactions described herein (2) not todisparage one another and to report to any inquiry that "all disputes have been

salisfactorily resolved;" and (3) not to

litigationagainst one another, exceptto enforce the termsof thissettlement.

Pleaseindicate your to the.se.core terms by signing in the spacesprovided

below.

Sincerely,

RogerK.

[Signatures appearon thefollowing

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Sam KazranJames Post,EsquireOctober

Page5of5

SAM KAZRAN

Individuallyand onbehalfofPremier Avenues,Atlantic,

Properties,Gwinnett,LLC, L.C.and otherbusinessesandentitiescontrolledby

MANAGEMENT CO, L.L.C.

By :John

President

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Affidavit ofSam Kazran Sam Khazrwan

SamKazran,under penalty ofperjury,statethat to thebestofmyknowledge:

I have been the person in charge of the operations o f the automobile dealerships knownas Premier Dodge ("Premier Dodge")which is owned by Gwinnett, LL C, a Floridalimited liability company and Hyundai ofNorth Jacksonville ("Hyundai") owned by

} LLC, a Florida liability during all periods relevant to thesetforthbelow.

VernonG. Buchanan ("Buchanan"),directlyorindirectlythrough Co.L.L.C., a limited liability company, had an economic ownership each

dealership, although Buchanan's economic arrangements, andcontinuityo fownership, ineach dealership changed over theyearsofmy

Due in part to the economic circumstances that existed in theautomobileindustry, eachofthesedealerships experienced afinancialdownturn, and certain amounts that I, therespective dealership, owed Buchanan or entities controlled by him were delinquent inpayment, and the relationship between Buchanan and me deterioratedbecauseof suchdelinquencies,commencingprimarilyinearly 2008.

During the course oftenseand somewhat hostile negotiations between my lawyers andme, and representatives for Buchanan,

advised a representative ofBuchanan that one ormore of the dealerships ofwhich I was in operational had reimbursed certainindividuals whohad contributed to Buchanan for Congress campaign.

Before September, 2008 neither

nor to my knowledge, any other person who had ever

advised Buchanan or any of his representatives had any infonnation that one or both of"the dealerships referred to in 1 above reimbursed certain individuals for contributions

to the Vernon G. Buchanan for Congress campaign.

Since my relationshipwith Buchanan first commenced, attended various meetings ofother general managers or "partners" of Buchanan who were involved in otherdealerships inwhichBuchanan, or companiescontrolled byhim,had a direct or indirectownership interest. At no time was there any statement or anyformof encouragement to

rfiake a campaign contribution based upon a threat of jobdiscrimination, financialreprisal, or other detriment forfailure to make acontribution disseminated orsuggested by Buchanan, a Buchanan representative or anyone under his or their

direction. Furthermore, there never was a discussion, statement or other actionwhichwouldhaveimplied that a person who made acontributionto the G. Buchanan

for Congress campaign would be reimbursed bysomeone orwould receive a specialbenefit.

Noone has advised me that Buchanan or any representative knew any intention,plan or arrangement by anyone to make a reimbursement, directly or to aperson inexchange formakingacontribution the Buchanan for Congress campaign.

EXHIBITA

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fc-

g

8. consent fo Buchanan filing this Affidavit with FederalElection Commission andusinginformationcontained herein in connectionwithcampaign for

matters.

Sam Kazran

STATEOF

COUNTYOF

The foregoing instrument was acknowledged before me this ,day of October,

by Sam Kazran. He is personally known to me or has produced -as

(SEAL)

Notary ofCommission Number:

A

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From:Sent:

To:

Subject:

Attachments:

kazranSunday, October

4:33 PM

Re: (nosubject)

public

EXHIBIT

public* .

I have donemy best to s t i c k with facts, I understa ndt h i s may not be thebest thingforVern at time, Ihope you do not take t h i s readingmany a r t i c l e s onlinewhich has untruestatements, s p e c i a l l y che ones that r e f l e c t on my Character damagingto both and raybusiness .

I hope t h i s does not change Verns position with respect to hi so f f e r to s e t t l e t h i smatter. Movingforward, topreventmorep u b l i c i t y , I would also ask fo r my nameandcompany tostayout of Verns campaign issues.I don't believe i t s productive.

Unless you have any w i l l be sendingt h i s statement to Mrs. Jenningss andthe reporters who have been contactingme, I look forward to t a l k i n g to you soon Samkazran

OriginalFrom: Sam KazranTo: JohnSent: Sun, 5 Oct200810:47 PMSubject: (no subject)

Hello John

I was on the Internettoday and saw mynamementioned i nconnection with the complaintf i l e d by Vern. I also read that had signed a sworn statement i n which you s a i d ,Mrs.

Jenningsh as motiva ted me to f i l e alawsuit, i talso s a i d I t o l d you

am meeting Mrs.jenning to t a l k about Vern.Wouldyouplease v e r i f y i ft h i s i scorrect? I s i tpossiblefor

me to see t he statement you have signed? I rememberhaving a discussionabout themultiple individuals who have but that was The attorneyDoug Lyons and

from e t h i c s not r e c a l l anything rayunderstanding that theywould l i k eto speak to me regarding t h i smatter, do you have anyidea what do they want to t a l k about? I would r e a l l y prefer to stayout of any p o l i t i c a l

media. I am sure theyare going to useanything I say against Vern and I don't want to getinvolved.

Please c a l l me on t h i smatter i f you want me sayanything whenVern calledme l a s t week, he said i ft h i s reporterwho'sbeen c a l l i n g me, c a l l s back again j u s tle t

knowthere was misunderstanding.I w i l l do be fo re I s t a r tray day.

I think i t s best I f I ormaybeeven both of us to orwrite to Jenningss andapologize, I can t e l l herthat Vern and

have agood r e l a t i o n s h i p and that we simply havedispute, t h i s may stopthem from chasingmedownto find out what were my motives, and

why did Ibringup hernamewhen she has never spoken to me before.

a d i f f e r e n t note I c a l l e d Vern to himknowI wouldn't be able to

se e him at 9. I have a meeting with at 10am, We need tomake changes we discussedsoI can Save these stored, I f I t h i s donebeforemy meeting, they w i l l notworkor give us another a reminder on che changes we talked about..

1. I f bo fa has a problem with secondposition we need to have a d i f f e r e n t plan that'sgoodfor Vern financing fo r theA t l a n t i c store i s Verns r e s p o n s i b i l i t y and i tshould

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not be acondition of agreement lawsuitsdrop a f t e r bofa receives of

courseI w i l l havewritten confo rmatio n from r e l e a s i n g l i a b i l i t i e s andc l e a r t i t l e )that i f Vern doesn'tgetfinancing forA t l a n t i c property dealcan beo f i

I s t i l l havetodropthes u i t , 1 am surehe wasmisunderstandi ng.It o l d him aslong :.domy partthen Vernhas to

h i s

4.Jim andRichard pr osser w i l l beworkinginrestructuringtheremaining debtand weto paythem,i f youwant1 ca nt a l k toVern about that, theb i l l sof a r i s35k,theysayi t wouldbearound75k total...

5. Vernand Iw i l l thel a s t part withoutattorneys, IthinkIhavea suggestion

that w i l lmake him out acheckfor a l l theamount,Ihave about70k

trackeddown therest are' c r e d i t cards, i fhewantst ov e r i f y , Ihavet oc a l l campaign

to ask herford e t a i l s , i f you canhavesomeonedothat Iwould appreciate i t .

I have everythingpreparedto move f a s t , infact i t s best tohaveMike wire Sotsto

Bofa d i r e c t onTuesday.

I t s a t o t a lof 1.5m i l l fo r 3 stored, We alsohavea t o t a l of 1.1 s a l e stax or

which 840ki s forKIA andgwinnett..

mindIhavea guy for for .500k. afirm o f f e r ,he i s a

goodoperatorand has 150kcash. Verncan do ands e l l him thestore, i f thedeal

doesn'tgo down I w i l l s t i l l buy

(just a suggestion).

Sam

Sent frommy

2

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PUBLICANNOUNCEMENT

Thisstatement being submittedinorder toclarifycertainstatementsand allegationsthat

SamKazran,have been encouraged, involvedor engaged or heldany discussionswith Mr.Buchanan's politicalrivalMrs. infact there has been anaffidavitprovidedby John Tosch, President of Buchanan Enterprises that Ihave had

withMrs.Jennings andsomehow thelaw which broughtagainstMr.Buchanan was perpetrated

encouraged by the-Jennings campaign.

would liketostatefor therecord,t disputetheseallegations andstatements. Nor

any one associated withme and myorganization,have ever had any"discussion,

any meetings'withthe

campaign

respect toMr.Buchanan;no onefromJennings campaign has ever to contact us or has had

any knowledge of the pendinglaw againstMr.Buchanan.

For the record, J have a

legal dispute against Mr. Buchanan. accordance tothe termsofour contract,fromwhich instantlawsu it has arisen, the venue for any .legal actionis set inSarasotaCounty.Thelawsuit and its claims are a matterofpublicrecordand they involveallegationoffraud,lenderlawviolationand misrepresentations.ForMr.Buchanan, hisassociatesor campaign tosuggestthat am somehowmotivatedbyMrs.Jennings inorder todamagehis campaign isutterlyabsurd to say the least.

SometimeinAugust,Mr.Buchanan and I held a meeting at hisoffice inSarasota,withcounsel for bothsidespresent, Inorder to amicably resolve our disputes. theconclusionofthis day we reached what appeared to be amutuallyacceptable

However,withina couple of

this meeting,Mr.Buchananfileda barrage of surprise taw suits inJacksonville,FLagainst personally as ascorporate entities that bothMr.Buchanan and1 own. These suits wereonlyserved inJacksonvilleto preempt our inSarasota.Since thefillingoftheselawsuitsin

Jacksonville,the presidingJudgehas made arulingin ourfavor;hisrulingis a matterofpublicrecord. Bothmylegalcounsel and continued our discussion

Mr.Buchananto reach a settlement.Itis noteworthythatinfactMr.Buchananstronglynot tofilea lawsuitinSarasotatoavoidmorepublicityand went as far asofferingme

towardshiringa legal counselInJacksonville,FL 1agreed tobring suitagainsthimInDuvalCountyInstead ofSarasotaCounty.

1am setting the record straightsimplybecausedespite Mr.Buchanan's advice to me invarious discussions we have had, bothtelephonicallyandinperson,priortofillingourlawsuitinSarasota, inwhichhe askedforassuranceto have a professional disputewithoutany

or discussion regarding campaigncontributions,apointinwhich agreed to.However,by his recent actions and hisassociatesmisinformedclaimsofcollusionwith campaign, he has chosen to drag meintohispoliticalcampaign. have beendiligently workingtowards a resolution of our disputes, however,1wasflabbergasted when, to everyone's surprise;includingmylegalteam, he alongwithbislegalteam amended an already agreed upon settlement even counter signed byMr.Buchananwithaswornaffidavitfromme pertaining to campaigncontributions.Mr.

Buchanan has made thesigningofthis

by me the centralstipulationto anytwillbe consultingwithmylegalcounciltoidentifywhether or not we cansharethose publicly without violatinganyconfidentiality agreements.

AsforMr. affidavit, Itdoesnot picture. have had manydiscussions inthepastregardingindividualswho are interested intalkingto me. during

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ofthosediscussions I tofdMr. Jhavealwaysavoided and.Instructedmyteam tobadpublicityforMr.Buchanan, alsotold himmovingforward Ifanyone wants

totalkto mefwilt theyhave to say, mybeliefMr. has eithermisunderstoodordoesnot have a clearrecollectionof discussions.

Onceagainto make absolute clear at no time have f'been contacted by Jennings nor havehad any encouragementfromher campaigninanyway,formorfashion. Furthermore,

clarifyanymisinformation my legalcounsel inSarasota,Mr.StevenHuttonwas referred tome by a colleagueinJacksonville. Huttonhas at notimespoken to mewithrespect toMr.Buchanan's campaign andinfactHehas advised me not to getinvolvedany discussions ofthismatter and hasfocused solely themeritof mycaseagainstMr.Buchanan..

havingtocreateany negative forMr.Buehanan nor do Ihave anypoliticalagendas, iwish Mr.Buchanan inhis campaign and tofocusingon thefactssurroundingmycase.Myhopesare thatMr.Buchanandoes

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10-18-10

GoodafternoonMark

As may already know, I've byF ECregarding campaign

contributions made toMr. Buchananfor congress. TheF E C a determination

that11-2001LLCviolated the rules set forth byFederalelection commission.strongly disagree withsomeof the allegations made,nonethelessthey Have made asettlementproposal as an alternative to formal complaint filed against LLCfederal court.F EChas offered tosettleand consider this matter closed based on aconsent agreement which includes a fine of 136K.

I've disclosed toFECthat providedMr. Buchananaccepts responsibility for any

fine imposed byFEC,and agree to pay back to the moneys inconnection

Contributions to

would notopposeasettlementresolution. Moreover,

would

do mybesttonegotiatedown the penalties set forth byFE C. Inaddition, thesettlementproposal as thecurrentmanaging member of the corporation. Based on mydiscussionswithFEC,this is the only method to avoid legal action. .

am process ofmaking to propose consent agreement. Prior

making anyfinaldecision, must understandMr.Buchanan's position this matter. My

proposal the following:

.A.Mr.Buchanan-would funds toVBFC to LLC.B. Mr. Buchananpays any penalty imposed byFEC .

C. Mr. BuchananwillcauseVernBuchananfor Congress to disgorge the contributions

received to the USTreasury.

is my preference to avoid any litigation with FEC.Particularlyasthesematterswillrequire costly legal representation. As such, Iwould request thatMr. Buchanan

aqree to resolve and satisfy FEC'sdemands in an amicable way.Moreover,

request thatMr.Buchanan returnthe funds to the corporation as promised. Please be

informed Mr. Buchananhas made specific representations with respect to the

returnof funds paid toVBFC.The company must satisfy its tax,payroll,utilities

and various other obligations. Mr.Buchanangaveme his word thatthesefunds wouldbe paidbackon more than one occasion.

Most recent was in Sept 2008, (the day we met at hisofficewithMr.Hutton andMr Lindel) MrBuchananwords were"we need togivethis money back anddeleteitfrom contribution Inthat same meeting, Mr.Buchananmade representations

that he would agree to a 50k payment to be used in connectionwithlegal representationprovided

agree to retain counsel inJacksonville.Based onMr.Buchanan's

representation,Mr. Lindelreferred me toSmithHusley and BeasleyinJacksonville.To

this date Mr. Buchanan has not fulfilled his commitment.

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Mr.

refusal to

matterswillleave me no choice but toinitiate legal action on an immediate basis. I've attached the complaint thatwillbe filed

againstMr.Buchananin theeventresolution is not made.F E Chas indicated thatdeadline for resolution is October 27th. As such, absent of an immediate answer

will

file a complaint againstMr. Buchananin 48 hours.

am hopefulMr. Buchanan not commingle theforegoingwith theongoingsettlementdiscussions taken placein few months. These issues are unrelated andshould be viewed in that matter.Mr.Buchanan'sdecision to these issueslast time resultedinmajorcastastrophe, destruction of the entire company and

additionalcomplaints filed with court.

would ask thattheseissues remain separate and notbecomea condition of one orthe maintained a professional attitude and have actedingoodfaith inresolving my legal disputewithMr.Buchanan.

have

the entire company as a resultofMr.Buchanan'sactions, both in terms ofremovalofmoneysfrom company and filing

appoint receiver (whichgaverise toboa'sdeclaring a default), andMr.Buchanan'sbreachof contractinOctober Inthe past,Mr.Buchananhas changedhis position insettling our dispute as a result of my refusal to sign certain affidavits. Asmentioned before, Mr.Tosch made the affidavit a condition of the agreement after anagreement was reached. wouldhopeto avoid this route again.

As mentioned toMr.SlaterlastFriday,terms ofsettlementdiscussions are outlinedindividuallyand viewed ina simplistic manner to avoid any delays or complications.

Termsset forth are as follows:

a. ASTOGWINNETTE: would agree to release Mr.Buchananof any and all

Liabilitiesincludingongoing

return,Mr:Buchanan

pay backMoneys collected based on payments made toMr.Buchananin connectionWithOption to purchase agreement as relates to Gwinnett foregoallInterest, punitivedamagesand attorneyfeesin ofactualpayments made.The total amount is 886k. willalso releaseMr.Buchananfrom breach of 2.9Million is worth remindingallthat bothMr.BuchananandMr.Toschhave acknowledged payments made and haye agreed to the dollar amount.

b. ASTO KIA DERALERSHIP: The dealership can be purchased for the same

amount ascurrentoffer of 525k.Currently am discussing the buy/sell of theKIA

dealership with a highly interestedindividual.InordertoengageinexclusiveDiscussions,1would require a non refundabledepositof 50k alongwitha signedAPA otherwise we can continue talks on non exclusive terms.

c. ASTO HY DERALERSHIP:The dealership can be purchased for the sameamount ascurrentoffer of mills, that includes the property free andclearof all

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liens as well as franchise.rights.Currently am exploringoptionswith multipleinterested individuals to enhance the offer on the table. Inordertoengagein

exclusive discussions, would require nonrefundabledepositof 50k alongwith an Otherwise we continue discussions based non exclusive terms.

Ona differentnote,thismorning.Ihad a discussionwiththeMr.Arne

Vansprumdirector ofACAPatFloridaBarregarding the complaintfiled.I'vebeenaskedto send additional documents to fully startaninvestigation. have held offinhopesofresolution.

Asmentioned before, Ihave no desire, nor enjoy taking thisstep. I'maware of theconsequencesof sanctions imposed by thebar. Particularlymatters involving conflict inthis magnitude including direct involvementbeforesuit commenced.

assure you this

matter

resultinan investigation byGrievanceCommittee;

would kindly renew myprevious offer that includedwithdrawingmy complaintwiththe understanding that youalong with firm withdrawfrom,andrefrainfrom anydirectorindirectinvolvementinfurther representation ofMr.Buchananin this matter

have remained hopeful my disputewithMr.Buchananwould be resolved by now.Unfortunately that has notbeenthe Deadline toreturnadditional documentsrequested isThursday.Accordingly, must receive a written confirmationbeforethen.Again apologizeforthisaction; everything in my power to avoid this routewithout any success. remainwilling,flexible and optimistic youwould honor

request.Thankyou

Sam

Contact

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IN CIRCUITCOURT

IN AND FOR SARASOTA COUNTY, FLORIDACIVILDIVISION

SAM KAZRAN, AND LLC

andGWINNETT,LLC, aFlorida

Limitedliability Company,

Plaintiffs,

V.

VERNON G.BUCHANANandVERNBUCHANANFOR CONGRESS,AFloridalimitedLiabilityCompany,

Defendants.

COMPLAINT

COME NOW, the Plaintiffs, by and through their counsel andsuesthe Defendants,

Buchanan and Buchanan for Congress. This case arises out of the Defendants improper

removal of fundsbelongingtoentitiesownedor controlled byMr.Buchanan, who usedthese

funds for illegal contributions made to "BUCHANAN FOR CONGRESS".In support of the

foregoing,the plaintiffstate:

Thisisanactionat andequity fordamagesinexcessof

2. 11-2001 LL C d/b/a Hyundai ofNorthJacksonville,LL C aFloridaLimited

LiabilityCompany authorized totransactbusiness in thestateofFlorida.

3. Gwinnett LLC

PremierDodge("DODGE")is aFlorida limited liability company

license to do business in Georgia. .

4. Mr.Buchananisanindividual who resides,inSarasota County,stateofFlorida.

FEC FOIA 2014-10-R_038


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5. Buchananfor Congress("VBFC") VernonG.Buchanan's

principalcampaigncommittee.

6. Jurisdiction in this cpunty is proper as the actions that gave rise to this complaint

occurred in Sarasota CountyFlorida.

7. During the relevanttimeperiod, SamKazranowned49% of HNJand operated HNJ.

G.Buchananowned51%ofHNJthrough 1099 Management-Company, LLC.

8. At alltimerelevant hereto, SamKazranowned49% ofDODGE and operated DODGE.

VernonG.Buchananowns5.1%ofDODGEthrough

Management CompanyLLC.

9. In 2005, Representative ("Buchanan")began his campaign for the 2006

electionto Florida's13

thCongressional District.

During.that.timeMr.Buchanan instructedKazranto arrange forHNJemployeesto

contribute-to VBFC.andfortheircontributions to be reimbursed with company funds. In

2005,HNJreimbursed theemployeesfor their contributions toVBFCinexcessof

In2006,Mr.Buchanan instructedKazranto arrange

HNJ and DODGEemployees,

his relativesandbusiness partnersandtheirspousesto contribute toVBFCandfor their

contributions to be reimbursed with Company funds. HNJ and DODGEreimbursed

various individuals over$50,000.

In BuchananinstructedKazrantoarrangeforemployeesto contribute to

VBFCand fortheircontributions to be reimbursed with company funds. Companies

reimbursed

in contributions in2007;all dated

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During2005-2007,HNJand GwinnettLLCmadevarious contributions toVBFC

exceeding These contributions were reimbursed to various for

contributions toVBFC.

14. Atalltimematerial,Kazranwasfollowinginstructions ofMr.Buchanantofindswaysto

toVBFC.Mr.Buchananwould routinelycallKazranto ensure that

contributions would bemadeintimely manner.

Mr.Buchananmaderepresentations thatthecorporation would receivethesemoneys

back. BeingthatMr.Buchananwasa Sr.Partnerandmanaging member ofthecompany;

Kazrancomplied withMr.Buchanan's request.

Onone incident,Mr.Buchananreturnedacheck to VBFCissuedfrom

LLC.Mr.Buchananrequestedthat the check be issued throughanindividualthatisnot

affiliated tothecorp.Mr.Buchanan'sreason was" wouldlookalotbetterifthese .

contributions camefromindividuals,itneedstolookas there is a of support for me".

Mr.Buchananmadethis representationonmore thanoneoccasionsatthepresentsof

severalpartners. -

DuringaninvestigationsinitiatedbyFederalElectionCommission,Kazranlearnedfor

thefirsttimethatsuch contributions were illegal.KazranthencooperatedwithFECin

conducting theirinvestigation.

]9. Theresults ofFEC'sinvestigations among other thingswere:

HNJviolated2 441 a(a) bymaking contributions to Buchananfor

Congress thatexceededthe contribution limits.

RespondentHNJviolated2U.S.C. 441f by making contributions toVern

Buchananfor Congress inthenamesofotherpersons.

FEC FOIA 2014-10-R_040


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c. Inaddition,FECfoundthatHNJ is to pay acivilpenalty to theFederalElection

Commissioninthe amount ofOne HundredThirty-SixThousand Dollars

pursuant to2U.S.C. 437g(a)(5)(A).

20.HNJ, DODGEand Kazranhave made demandson Mr. Buchanantopay backthe

contributionsmadetoVBFC, and topay the penalties imposedby FEC.Mr.Buchanan

has refused to satisfytheseobligations.

21.

1(Intentional Interferencewitha Business Relationship)

23.. Plaintiffsre sand incorporatesbyreferenceParagraphs1through are

incorporated by referenceas iffully herein.

LLC, LL C and KazransueMr. BuchananforIntentionalInterference

withabusiness relationship.

Defendant at all times knew that plaintiffs were in needthosefunds for their business

operations

26. Defendanthas not returned'thosefundsaspromised.

27.Plaintiffhasbeendamaged asaresultof Defendant's actions.

WHEREFORE, Plaintiffs demands judgment against Mr. Buchanan and Buchanan for

congress, for damages, including reasonable attorney's fees and costs and such other

damages and/or

relief as this HonorableCourtdeemsproper and just. Plaintiff

demandsajury trialon all issuesso

28. COUNTI I - Conversion

FEC FOIA 2014-10-R_041


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29. Plaintiffs reallegeand incorporates by reference Paragraphs 1 through 27 as if fully

restated herein.

30. Plaintiffs sueMr.Buchananfor conversion.

31. Plaintiff demanded return of its operating funds Plaintiffs in need of those funds to

satisfy sales tax, healthcareandpayrollobligations.

32.Theplaintiffs have requestedthesefunds,butMr.Buchananhasrefused to do so.

33.Plaintiffhasbeen damaged asaresult of Defendant's actions.

WHEREFORE,Plaintiffsdemandsjudgment againstMr.Buchananfor damages, including

reasonable attorney's fees andcosts and such other damages and/or equitable relief as this

HonorableCourtdeemsproperandjust. Plaintiffdemandsa jury trialonallissues so triable.

34.35. offiduciaryobligations)

36. Plaintiffsre andincorporatebyreferenceParagraphs1 through 33 as if fully restated

herein.

37. Plaintiffs SueMr.Buchananfor violations offiduciaryobligations as managing member

of the corporation.

Mr.Buchananhas anethicalandmoralduty to preserve the wellbeing of corporations.

39. Defendants are fully aware that plaintiffs are in need of these funds to. satisfy their

business obligations.

40. arefullyawarethat Plaintiffs have receivednoticesfromFEC.

41. Defendants have refused to satisfy penalties imposed byFECasaresult of instructing

2001 LLC,Gwinnettand Kazrantoengageinillegally campaign contributions.

42.Plaintiffhasbeen damaged asaresult of Defendant's actions.

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WHEREFORE,Plaintiffdemandsjudgment againstMr.Buchanan,for damages,

includingreasonable attorney'sfeesandcostsand such otherdamagesand/or equitable

reliefas thisHonorableCourtdeemsproperandjust. Plaintiffdemandsajurytrial on all

triable.

DatedinSarasota Countythis Wednesday ofOctober

FEC FOIA 2014-10-R_043


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Page1

Mark

From: Lee Levenson [[email protected]]Sent:

September

4:08 PMTo: MarkOrnsteinSubject: RE Vernon Buchanan Settlement

Yes- the parties actually signed a confidential settlementagreementinwhichthe "clientshave agreedto

resolveexistingclaims with toallpastand currentbusiness Essentially, Mr.

Buchananagreedto pay Kazran $2.9million.Litigationwouldbe anunintelligentway to resolvethis. is our

furtheropinionfromdiscussing this matterwith Mr.Kazran the partieswouldbe far better offnegotiating

an immediate settlement ofthis particular matter andworkingtogether withregard to successfully resolvingthe

variouslitigationsswirlingaround them.

The RomanoLawGroup, PA

www.RomanoLawGrottp.com

1005 Lake Avenue

Tei.561533.670O

From:MarkOrnstein [mailto:[email protected]

Sent:Thursday,September PM

To:Lee LevensonSubject:RE:VernonBuchanan Settlement

Thanks Lee. Is this oneofthe matters that iscurrentlyinlitigation?

From:LeeLevenson

Sent:Thursday,September PM

To: MarkOrnstein

RE:VernonBuchanan Settlement

Michelle,

WerepresentMr.Kazraninthe matterofthe "BindingSettlementTermSheet"dated 10-1-2008.Pleaselet us

know you'dliketo resolve theissuesbetween theseparties. Thankyou,Lee

Lee Levenson

Lee Levenson


wivw.RomanoLawGroup.com

10/26/2011

FEC FOIA 2014-10-R_044


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2

Avenue

From:MarkOrnstein [mailto:[email protected]]

Sent:Thursday, September

PM

To:Lee Levenson

Subject:RE: VernonBuchanan Settlement

Mr.Levenson,

isMichelleMcKinnierespondingfrom Mark computer.

Mr.Ornsteinwould clarificationof the matters inwhichyouhave been retained torepresentMr.Kazran.

Wehave several matterscurrentlypending between Congressman Buchanan andMr.Kazranand confused

as to your representation.

Thankyou.

From:Lee Levenson

Sent:Thursday, September15, PM

To: MafkOrnstein

Cc: Sam Kazran

VernonBuchanan Settlement

DearMr.Ornstein,

Youare advised that we have been retained torepresentSamKazranwithregard to the enforcementofthesettlement agreement dated betweenMr .Buchanan,Mr.Kazranand the Premier Companies. Our

investigation us to believe that we mustinitiatediscoveryandlitigationproceduresimmediately.

However,i t is ourpolicytoallowfor abriefwindowofopportunityto negotiate anextra-judicialresolutionof

anylitigationmatter.Pleaseadvise us as to your client'sposition.Regards, Lee

Lee Levenson

The RomanoLawGroup,PA

www.RomanoLawGroup.com

1005 Lake AvenueTel.561.533.6700

FEC FOIA 2014-10-R_045


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Page1

MarkOrnstein

From: Lee Levenson [[email protected]]

Sent: Tuesday, September

AMTo: McKinnie

Cc: MarkOrnstein;MichaelA. BarbaraLouv

Subject: RE: Buchanan/Kazran

DearMark,

for your letter dated September

We areinformedthat Congressman Buchanan, John Tosh,

Mike and all participatedinthe conference callwithSam Kazranwhereinthe terms of

the subject agreement were negotiated.Additionally,Jim Post,SteveHutton,and Sam took partin the

negotiations ofthe termso fsubject agreement. Mr. KazranstatesemphaticallythatMr. Buchananhimself

outlinedthe terms ofthe subject agreement. Uponinformationand belief, Congressman Buchanan stated:

"Sam,Ido this and we have a deal andyou

drop thechargesinSarasotaCounty".Thesenegotiations and

agreementswerememorializedinthe whichweforwarded you. Mr. Kazran maintains the final

draftwasactuallysignedbythe parties.You are correct that several iterations existed at one point or another.

However,onlyonefinalembodimentofthe agreement onewhichwesentyou) was executed by the

parties.It isbinding.

Apparently, shortlyafter the conference

Mr. Kazran received acallfrom Mr. Buchanan to congratulate him

of resolvingthe disputes between the parties andinviting him to join Mr. Buchanan for dinner. Mr. Kazranwas

surprised when, uponhis arrival,Mr. Buchanan'slawyertriedto foistuponhim the subjectaffidavit whichwas

drafted byMr. Buchanan, his staff, or his attorney. Theaffidavitis self-serving forthe congressman and seif-

forMr. Kazran.itwas ascapegoatdocument.To the amazement ofMr. Kazran's lawyers, the

proposedaffidavitwas actually submitted by the Congressman or his agents/attorneys to them aswell.Itis

puzzling the congressman tiedexecution of theaffidavit, whichbearsno connectionwiththe disputes

whichgave rise

subject settlement agreement, to his goodfaithfulfillmentofhis obligationsunder thesettlement agreement. Up untilthat evening there had been no communications regarding anaffidavit.

Although,we have itinformationandbeliefthatMr.John Toshforcefullyordered, "Sam, you have 5min. to sign

thisaffidavit or deal isoff," Sam did notsignsameon advice ofhis counsel.

Theforgoingallegations have been confessed toby the Congressman. Hisstatementsare apparently

memorializedinmultiple left on Mr. Kazran'scellphone. Some salientsamplesare that Mr.

Buchanan:

made references regardingMr. Kazran's"liabilities",

expressed lackofconcern that the foregoingwouldhurt his electionchancessince he was "up

points",

the congressman specificallytiedresolution oftheseunderlyingbusinessdisputes to certain unrelated

factswhichthe congressman specifically did not want to "become the subject of discussions",

Mr. Kazran also alleges thatMr.Buchanan offeredMr. Kazran $50,000 tofireSteveHuttonin favor ofhiringan

attorneyinJacksonville as opposed toSarasotaCounty where yourclientwas engaged incampaigning for aseat

forUS Congress.

Mark,Mr. Kazran needed the subject settlementproceedstosavehisbusinesses.BecauseMr.Kazran refused to

signthe affidavit,the Congressman did notfulfill hisobligationsand Mr. Kazran has his businesses.While

FEC FOIA 2014-10-R_046


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Mr.Buchanan mayhavedifferentviews,Mr.Kazran is of the believe that he has done allhe can toseek

alternative resolutionsMr.Kazran believes tolitigation,includingflexibilityinterms and conditionsof

settlement discussions of has no choice at this juncture but totryto recover hislossesbyanymeansavailable

atlaw.

Atthistime,you are likelyaware that11-2001LLC,and Mr.Kazraninvolvedin a brought by Federal

ElectionCommissioninthe NorthernDistrictofFlorida.Thatsuit involvesvariousviolationsand penaltiesin

excessof$70,000.00. Wewillbe appearing inthatcase.Atthis junctureMr.Kazran mustcrossclaim the

Congressman intothatcasebecausehe alleges thatMr.Buchanan isactuallythe proper partyintheaction.Mr.

Kazran further must move to compelMr.Buchanan to pay $105,000.00 of paymentsinwhichMr.Buchanan had

allegedlypreviouslyoffered to reimburse11-

Kazran.

Youare correctthat the $2.9millioncontract contemplated the separationo ftheKiadealerships andfinalstock

transfer and that this is nowimpossible. However,Mr.Kazran'spositionisthat said separation and stock

transferswouldhave beenpossible but forMr.Buchanan's actions and inactions against the interests ofMr.

Kazran and the partnershipbusinesses.

The purposeofthis letter isconciliatory.Itisinallparties'bestinterests to achieve an amicableresolutionto

thismatter. Wewouldpropose to negotiate a compromise. We understand thatyouhad recently offered to

arbitratethismatter. However, this is probablyunnecessary.Wecan easily resolve this matterprivatelyor

throughmediation. Towardthese endswe'dofferto come over there for a settlement conference or

Pleaseconveytheseoffers to yourclientand us know how he'dliketo resolvethesematters-.

Finally, wouldpointout thatgiventhe number ofadversarieswhichour respective clients arecurrently facing,

they'deachbe betteroffwithanother

as opposed to opponent. We welcome any questions or

concernsyoumay have. Therefore,pleasefeelfree to

KindRegards, Lee

Lake Avenue

561.533.5700

From:Michelle McKinnie[maiito:[email protected]]

Sent:Friday,September

PMTo:LeeLevenson

Cc:MarkOrnstein;MichaelA. BarbaraLouv

Subject: Buchanan/Kazran

Levenson,

Attachedpleasefindcorrespondence from MikeSemanie regarding the above referenced matter.

Lee Levenson


10/26/2011

FEC FOIA 2014-10-R_047


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Thank you.

Michelle McKinnie,FRP

Litigation Paralegal

Killgore, Stamp, Ornstein&Squires, P.A.

2 South Orange Avenue, 5th Floor

Orlando,Florida 32801

www.kpsos.com

407/425-1020

407/839-3635 (fax)

CONFIDENTIALITYSTATEMENT:Thismessage Intended only for the use of the Individualor entity towhichIt Isaddressedand may contain information that Isprivileged,

confidentialand exemptfromdisclosure under applicablelaw.Ifthereaderof messageis not the Intended recipient or employee oragentresponsible fordeliveringthe

messageto the intended recipientYOUARE HEREBY NOTIFIEDthat any dissemination,distributionor-copylng of this communication is strialyprohibited.Ifyouare not the

intended recipientofthismessage, pleasenotifysenderand destroy any printed version anddelete communication may contain nonpublicInformation about

Individualsandbusinessessubject to the

of the Act Youmay notdirectlyor reuseor such Information for anypurpose

other than to provide theservicesforwhich youare receiving theinformation.

IRS Notice:Pursuanttorecendyenaaed

Treasury Department Regulations, we are now required to advise thatunlessotherwise expressly indicated, any

federal t ax adviceexpressedabovewas nor intended by thesender this to be

and beusedby any taxpayer for thepurposeofavoiding

penalties that may be Imposed underVS.taxlaw. Ifany personusesor refers to any such tax adviceIn marketing or recommending a or otherInvestment pla n or

any taxpayer, then the adviceshould be considered tohave beenwrittento support thepromotionor marketing by a person other than the

sender transaction or matter, and such taxpayer shouldseekadvicebasedon the taxpayer's particular

an tax advisor.

FEC FOIA 2014-10-R_048


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1. Page1

MarkOrnstein

From: Lee Levenson[[email protected]]Sent: Wednesday, September

AMTo: MichelleM.McKinnieCc: MarkOrnstein;MichaelA.SemanieSubject: RE Buchanan/Kazran

DearMichelle, Michael:

We arewillingto settle matters betweenthesepartners to furtherlitigationbetween the

partners orinvolving the FEC).Wepropose that the congressman honor theoriginalsettlementagreement:

However, we are open to counter-proposals. advise. Thankyou,Lee

Lee Levenson

A

The RomanoLawGroup,PA

Lake Avenue

561.533.6700

From:MichelleM.McKinnie

Sent:Wednesday, September AMTo:LeeLevenson

CcMarkOrnstein;MichaelA.SemanieSubject: Buchanan/Kazran

Mr.Levenson,

Mr.Ornstein hassuggesteda meeting regarding the above referenced matter t o get everyoneinvolvedonthe

page. He iscurrentlyavailableMonday,October 10 th , the late afternoonofThursday, October or

October 14 t h . Pleaselet meknowifanyofthese dateswork for you.

Thankyou.

MichelleM.McKinnie,FRP

litigation ParalegalPearlman, Stamp, Ornstein&Squires, P.A.

2South OrangeAvenue,5th Floor

Orlando,Florida 32801

www.kpsos.com

407/425-1020

407/839-3635 (fax)

FEC FOIA 2014-10-R_049


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Page2

CONFIDENTIALITYSTATEMENT: messageIs Intended only for the use oFthe individualor to which it isaddressedand may contain information that is privileged,

from employee he

messageto the Intended recipient,YOU AREHEREBYNOTIFIEDthat any dissemination, distribution or copying of this communication is strictlyprohibited.If you are not the

recipient of thismessage, pleasenotifysenderand destroy any printed version anddeletethisemail. Thiscommunication may contain nonpublic information about

andbusinessessubject t o the restrictions of the Act. You may not directly or indirealyreuseor re-disclose such Information anypurpose

other than to provide theservicesfor whichyou arereceivingtheinformation.

IRSCircular Notice: to recentlyenacted Treasury Department Regulations, we are now required toadviseyou that,unlessotherwise expressly indicated, any

thesender

penaltiesthat may bo imposedunderUS. tax Ifany personusesor refers to any such tax advice in marketing o r recommending a or other

marketing person other the

sender firm ofthattransaction or matter , and such taxpayer shouldseekadvicebasedon thetaxpayer'sparticularcircumstancesfroman Independent lax advisor.

FEC FOIA 2014-10-R_050


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Page1of1

MarkOrnstein

From: Sam

Sent: Tuesday,

5:20

To: MarkOrnstein

Cc: [email protected]

Subject:secondDCA

GoodafternoonMark

Attachedwasmailedtoyourofficeon Ihavetheinitial briefdoneandjustwaitingtohear CE C FBIastowhetherIcanfilemybrief. AssumingI the ok,briefwillbemailedto youroffice.

Ona differentnote,backinJulyIaskedyour

youprefer e-mailorregularmail.Don'tbelieveIgotananswerback.Please let me knowifemailisok.Haveagood

andaskedSam KazranContact

This containsPRIVILEGEDANDCONHDBNTIAI. intended only for of named yon

not the

intended recipient of this email,or anauthorizedemployeeoragentresponsiblefordeliveringitto intended you

any

copying ofthisemailisstrictly prohibited. you have receivedthisemailinerror,pleasenotify

by reply anddeletethis

email

your

foryour cooperation.

10/26/2011

FEC FOIA 2014-10-R_051

FEC - (b)(6), (7)(C)

FEC - (b)(6), (7)(C)

FEC - (b)(6), (7)(C)


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V

Datedthis 21st

day of October,

.32225

C E R T I F I C A T E

SERVICE

IHEREB Y CERTIFYthatIserveda.copyofthe following on

MarkL .Ornstein,Esquire,Killgore, Pearlman, Stamp, Ornstein&Squires

Box 1913Orlando,FL32802 USmailon day ofOctober

2

FEC FOIA 2014-10-R_052

FEC - (b)(6), (7)(C)

FEC - (b)(6), (7)(C)


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October

The of

Appeals, SecondDistrict

RE:

1099 Management Co. NO:2011-4238

The

Court

The undersigned respectfullyseekan extension oftimeorstayoftheseproceeding to file

his initial brief based on unforeseen circumstances that have transpired in recent days.

Specifically,on October received a confidential letter from theCongressofUnited

States,Office o f Congressional Ethics committee requesting certain information and documents

regarding their investigation of Appellees managing member Congressman Vernon G.

Buchanan.

In addition, on October 13, the undersigned metwith specialagentVanessa

Federal Bureau of Investigation(FBI)regarding aseparateFederal Grand JurySubpoena

calling for production of various documents in connection with the agency's criminal

investigationagainst Appellees managing member Congressman G.Buchanan.

Boththeofficeo f Congressional Ethics Committee and the Federal BureauofInvestigation

haveinstructed the undersigned to refrain fromdisclosing any information to anyindividualor

entity regarding their investigations. This Honorable court should know that many of the

information requested representfactualaverments and records inwhichAppellant relies on topresenthiscaseto this Honorable court. Thus, Appellant isunsurewhether filing hisbriefcould

impede the investigation being conducted. For thisreason,Appellantrespectfullyrequests

extension/stay topermitthe undersigned toseekthe advice of counsel.

Itshould be noted that the undersigned contacted the Clerksoffice andspoketoMr.James

Dirkholdtoseekdirection inforwardingthe above-mentioned notices for this Honorable Courts

review.To protect the content o fthesedocuments,Mr.Dirkholdsuggestedthat the undersigned

refrain from forwardingthe subject documents priorto seeking courts approval.

Respectfully Submitted

Jacksonville

32225

FEC FOIA 2014-10-R_053

FEC - (b)(6), (7)(C)

FEC - (b)(6), (7)(C)


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FEDERAL ELECTION COM MISSION

Washington, D.C. 20463

CONFIDENTIAL MATERIAL

July 1,2011

BY ELECTRONIC M IL

Esq.

er CRM (b)(6), (7)(C)

Election Crimes Branch

Public Integrity Section

U.S, Department of Justice

1400 New York Avenue, 12

t h Floor

Washington, D.C. 20005

RE: Matter Under Review 6054

Dar

er CRM (b)(6), (7)(C)

In response to your requests yesterday and today for materials from the Federal

Election Com mission's investigation into the reimbursement of political contributions at

automobile dealerships owned by V ernon G, B uchanan, please find enclosed G eneral

Counsel's Reports (10), General C ounsel's Briefs (3) and R eply Briefs (2),

We will follow up with additional materials including deposition transcripts and

documents obtained during the investigation.

In view of the ong oing investigation in MU R 6054 (relating to General Counsel's

Report 3) and the ongoing conciliation negotiations (relating to General Counsel's

Repo rt 10), we note that there are federal statutes applicable to these materials. Title 2

of the U.S. Code Section 437g(a)(4)(B)(i) prohibits making public any information

derived in connection with a conciliation attempt (other than the final executed

conciliation agreement) without the written consent of the person who is conciliating with

the Com mission. Title 2 S ection 437g(a)(12)(A) requires all persons to keep confidential

any investigation being conducted by the Comm ission, except with the written consent of

the person who is the subject of the investigation. You are advised that, in MUR 6054,

no such written consent has been filed regarding either provision. In all instances in

which access to our files is granted to federal agencies or authorities, the confidentiality

provisions of 2 U.S.C. 437g(a)(4)(B)(i) and 437g(a)(12) shall remain in effect.

Accordingly, we ask that the D epartment of Justice (and the Federal Bureau of

Investigation) establish and maintain necessary and appropriate safeguards to protect the

FEC FOIA 2014-11-R_001


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age ME

sq.

Per CRM (b)(6), (7)(C)

confidentiality of files for which access is granted and the information derived therefrom,

make no public use of these fil

Responsive Documents: CREW: FEC: Regarding Vern Buchanan: 1-13-15

Documents

Transcript of Responsive Documents: CREW: FEC: Regarding Vern Buchanan: 1-13-15